Privacy Policy

2.1 Information You Provide Directly. When you register, participate in contests, complete verification, or communicate with us, we collect: (a) Registration Data: full legal first and last name, display name, email address, phone number, and date of birth; (b) Profile Data: any optional profile information you choose to provide; (c) Contest Data: all predictions submitted, performance data, timestamps, and contest participation history; (d) Communications: messages, support requests, or feedback you send to us.

2.2 Identity Verification (KYC) and Sensitive Personal Information. As a condition of prize withdrawals, eligibility verification, fraud prevention, or special circumstances determined by us, we or our third-party KYC provider may collect the following categories of sensitive personal information: government-issued photo identification (e.g., driver's license, passport); proof of residential address; Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN); date of birth; financial account or payment information necessary for disbursements; and such other identity, financial, or personal documentation as we determine necessary, including information required by applicable law. We may request any of the above at any time, before or after a contest win, before or after a withdrawal request, or in any special circumstance we deem appropriate. By using the Platform, you consent to the collection and processing of sensitive personal information under the conditions described herein. KYC documents are processed by our verification provider in accordance with applicable law and its own privacy policy.

2.3 Automatically Collected Information. When you access the Platform, we and our service providers may automatically collect: (a) Device and Technical Data: IP address, browser type and version, operating system, device identifiers, and hardware configuration; (b) Usage Data: pages viewed, features used, clickstream data, referring URLs, session duration, and timestamps; (c) Location Data: general geographic location inferred from IP address, used in part to enforce the US-only geographic restriction; (d) Cookie and Tracking Data: as described in our Cookie Policy.

2.4 Third-Party Sources. We may receive information about you from third-party sources, including: (a) authentication providers (Google, Apple) if you register or log in using their services; (b) identity verification and fraud-prevention partners; (c) publicly available sources, to the extent permitted by applicable law.

3.1 We use the personal information we collect for the following purposes: (a) Platform Operations: to create and manage your account, authenticate your identity, process contest entries, score predictions, and operate leaderboards; (b) Prize Administration: to determine contest winners, manage Account Balances, and process withdrawals and payout disbursements; (c) Identity Verification and Reverification: to conduct KYC and ongoing reverification prior to or following prize authorization, and at any time we determine necessary; (d) Safety and Fraud Prevention: to detect, investigate, and prevent fraudulent transactions, unauthorized account access, multi-accounting, bot usage, geographic violations, and other violations of our Terms; (e) Legal Compliance: to comply with applicable federal, state, and local laws and regulations, including tax reporting obligations, anti-money laundering requirements, and responses to valid legal process; (f) Communications: to send you transactional messages (account activity, prize notifications, security alerts, verification requests) and, with your consent, promotional communications about the Platform; (g) Customer Support: to respond to your inquiries, troubleshoot issues, and improve our support processes; (h) Platform Improvement: to analyze usage patterns, conduct research, test new features, and improve the performance and user experience of the Platform; and (i) Advertising: to serve contextually relevant third-party advertisements on the Platform. We do not share personally identifiable information with advertisers.

3.2 Legal Bases. Where applicable law requires a legal basis for processing, we process your data on the following bases: (a) performance of a contract (to provide the Platform services); (b) compliance with legal obligations; (c) our legitimate interests in operating a safe, secure, and high-quality platform; and (d) your consent, where required and provided.

4.1 We Do Not Sell Personal Data. We do not sell, rent, or trade your personal information to any third party for their independent marketing purposes.

4.2 Service Providers. We may share your information with trusted third-party service providers who perform services on our behalf, including: cloud hosting and infrastructure providers, email and communication service providers, identity verification and KYC vendors, payment processing and disbursement partners, analytics and performance monitoring services, fraud detection and security vendors, and customer support platforms. All service providers are contractually obligated to use your data only as directed by us and to maintain appropriate security measures.

4.3 Legal Disclosure. We may disclose your personal information if required to do so by law or in good-faith belief that such action is necessary to: (a) comply with a legal obligation, court order, or governmental request; (b) enforce our Terms of Service or Official Contest Rules; (c) protect the rights, property, or safety of MoonDay Capital LLC, our users, or the public; or (d) detect, prevent, or investigate fraud or other illegal activity.

4.4 Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to a successor entity. We will provide notice via in-Platform posting prior to your information being transferred and becoming subject to a different privacy policy.

4.5 Public Leaderboard. Your display name and contest ranking may be displayed publicly on the Platform leaderboard. Your legal name, email, phone number, SSN, and other personal information will not be disclosed publicly.

5.1 Security Measures. We implement and maintain industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, loss, or destruction. These measures include, as applicable: AES-256 encryption at rest, TLS encryption in transit, password hashing using industry-standard algorithms, access controls and role-based permissions, regular security audits and penetration testing, and anomaly detection and intrusion prevention systems.

5.2 No Absolute Security. Despite our efforts, no security measure is impenetrable. We cannot guarantee that your personal information will never be accessed, disclosed, altered, or destroyed in a breach of our security measures. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us of any suspected unauthorized access.

5.3 Breach Notification. In the event of a data breach that triggers a notification obligation under applicable law, we will notify affected users and relevant regulatory authorities as required by and within the timeframes mandated by applicable law.

6.1 Retention Periods. We retain personal information for as long as your account is active or as necessary to: (a) provide the Platform and related services; (b) administer and resolve contest disputes; (c) comply with applicable legal and regulatory retention obligations (which may require retention for five (5) to seven (7) years for financial and tax records); (d) prevent fraud and enforce our Terms; and (e) maintain audit logs for security and compliance purposes.

6.2 Deletion Requests. You may request deletion of your personal information by contacting us at [email protected]. We will fulfill deletion requests within thirty (30) days, subject to our obligation to retain certain data as required by law, for fraud prevention, or to resolve pending disputes. Deletion of your account will result in permanent loss of your Account Balance history, contest history, and other account data.

6.3 Anonymization. Where we are unable to delete information due to legal or operational requirements, we will anonymize or aggregate the data so that it can no longer be reasonably associated with you as an individual.

7.1 General Rights. Depending on your jurisdiction and applicable law, you may have the following rights with respect to your personal information: (a) Right to Access: to request a copy of the personal information we hold about you; (b) Right to Rectification: to request correction of inaccurate or incomplete personal information; (c) Right to Erasure: to request deletion of your personal information, subject to legal exceptions; (d) Right to Restriction: to request that we restrict the processing of your personal information in certain circumstances; (e) Right to Data Portability: to receive your personal information in a structured, machine-readable format; (f) Right to Object: to object to processing based on our legitimate interests; and (g) Right to Withdraw Consent: where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

7.2 California Residents. If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to opt out of the "sale" or "sharing" of personal information (we do not sell or share personal information), the right to non-discrimination for exercising your privacy rights, and the right to limit use of sensitive personal information. Note that the collection of SSN and government identification for KYC purposes is required for legal compliance and prize disbursement and is not subject to the sensitive personal information limitation right in that context.

7.3 Exercising Rights. To exercise any of the rights described in this Section, please contact us at [email protected]. We will respond to verifiable requests within the timeframes required by applicable law. We may require you to verify your identity before processing your request.