Privacy Policy

Effective date: [EFFECTIVE DATE] · Last updated: [EFFECTIVE DATE]

This Privacy Policy explains what personal information [COMPANY LLC NAME], doing business as OTB Funded ("we," "us"), collects when you use otbfunded.com and our challenge services, how we use and share it, and the choices you have.

1. Information we collect

Information you give us

Contact and account details: your email address, login details, and any name or username you provide.
Checkout confirmations: the challenge you choose and your confirmation that you are 18+ (21+ where required) and agree to our Terms.
Identity verification (before payouts): legal name, date of birth, address, government-issued ID images, a selfie or liveness check, and related results. This is generally collected by our verification provider (see Section 3).
Payout details: the cryptocurrency wallet address and network you give us for payouts, and any tax information we are required to collect.
Communications: messages you send us, support requests, self-exclusion or cool-off requests, and community (e.g. Discord) usernames if you link them.

Waitlist sign-ups

If you join our launch waitlist, we collect your email address, your favorite sport (optional), which challenge size you clicked (if any), and where on the site you signed up.
We also record the time of sign-up, your approximate country (from your IP address), your browser type, and a one-way scrambled (hashed) version of your IP address, which we use only to block spam and repeated abuse. We do not store your IP address itself.
We use waitlist information only to tell you when challenges open and to send launch news and early-access offers. You can unsubscribe from any email, or ask us to delete your waitlist entry, at any time by emailing [CONTACT EMAIL].
Waitlist data is stored in a database run by our hosting provider ([HOSTING PROVIDER]). We do not sell it.

Information from payments

When you pay, the third-party crypto payment processor shares with us payment details such as an order ID, payment ID, amount, asset, network, payment status, and transaction hash. It may also share the wallet address the payment came from.
We do not receive or store your wallet's private keys or seed phrase, and you should never share them with anyone.

Information collected automatically

Device and log data: IP address, browser and device type, pages visited, and timestamps.
Approximate location: derived from your IP address, used to check whether the Services are available where you are.
Account activity: your picks, odds, balances, rule checks, and challenge status.
Cookies and similar technologies: see Section 5.

2. How we use your information

To provide the Services: process your order, issue your challenge, send your login, run and grade your account, and pay approved payouts.
To verify age, identity, eligibility, and location, and to enforce our Terms, including detecting multi-accounting, collusion, fraud, and abuse.
To honor self-exclusion and cool-off requests under our Responsible Play policy.
To communicate with you about your account, payouts, and changes to our policies, and, where allowed, to send launch news and offers (you can opt out at any time).
To keep the Services secure, fix problems, and improve them.
To publish our public payout ledger and aggregate transparency reports (see Section 4).
To comply with law, respond to lawful requests, and protect our rights.

[LEGAL BASES FOR PROCESSING, IF REQUIRED: to be added by counsel.]

4. Blockchain data and the public payout ledger

Blockchains are public. Crypto payments and payouts are recorded on public blockchains. Wallet addresses, amounts, and transaction hashes are visible to anyone and cannot be changed or deleted by us. Someone who knows your wallet address may be able to link it to other transactions.
Public payout ledger. When we publish a payout, the ledger shows only [LEDGER FIELDS, e.g. date, amount, challenge size, a pseudonymous handle, and/or a transaction reference]. We do not publish your name or email. [OPT-OUT OR PSEUDONYM OPTION, IF OFFERED.]
Transparency reports use aggregate statistics (such as pass rate and average time to payout) that do not identify you.

5. Cookies and similar technologies

We use cookies and similar technologies that are needed for the site and your account to work (for example, to keep you signed in and to secure checkout). [LIST ANY ANALYTICS OR ADVERTISING COOKIES, OR STATE THAT NONE ARE USED.]

Our pages load fonts from a third-party font service, which receives your IP address and browser information when the page loads. [CONSIDER SELF-HOSTING FONTS.] The payment processor's hosted payment page may set its own cookies.

You can block or delete cookies in your browser settings, but parts of the Services may not work without them. [DESCRIBE HOW WE RESPOND TO "DO NOT TRACK" OR GLOBAL PRIVACY CONTROL SIGNALS.]

6. How long we keep information

Information	Retention
Account, order, and pick history	For as long as your account is open, then [RETENTION PERIOD] for records, tax, and dispute purposes
Identity verification records	[KYC RETENTION PERIOD], as required by law or our verification provider
Payment and payout records (including wallet addresses)	[PAYMENT RECORDS RETENTION PERIOD]
Self-exclusion and cool-off records	At least for the length of the exclusion, and [RETENTION PERIOD] after, so we can honor it
Server and security logs	[LOG RETENTION PERIOD]
Marketing email list and waitlist sign-ups	Until you unsubscribe or ask us to delete it, or [WAITLIST RETENTION PERIOD] after launch if you never become a customer

When we no longer need information, we delete or de-identify it. Information already recorded on a public blockchain cannot be deleted.

7. Security

We use reasonable administrative, technical, and physical safeguards, including encryption in transit, restricted access to personal information, and secure storage of credentials. Payment pages are hosted by the processor, and ID documents are handled by our verification provider. No system is perfectly secure, and we cannot guarantee the security of information you send us. If we learn of a breach affecting your information, we will notify you as the law requires.

8. Your rights and choices

Depending on where you live, you may have the right to:

access the personal information we hold about you and get a copy;
correct inaccurate information;
delete your information, subject to legal and record-keeping exceptions;
object to or limit certain uses, and opt out of marketing emails at any time using the unsubscribe link;
appeal a decision we make about your request.

To make a request, email [CONTACT EMAIL] from the email address on your account. We will verify your identity before acting, and we will not discriminate against you for exercising your rights. [JURISDICTION-SPECIFIC DISCLOSURES, IF REQUIRED: to be added by counsel.]

9. Age limits

The Services are not for anyone under 18 (or under 21 where required). We do not knowingly collect information from minors. If we learn that we have, we will close the account and delete the information except where we must keep it by law. If you believe a minor has used the Services, contact us.

10. Where information is processed

We and our providers may process your information in countries other than the one where you live, which may have different data protection laws. Where required, we use appropriate safeguards for these transfers. [TRANSFER MECHANISMS, IF REQUIRED.]

11. Changes to this policy

We may update this policy. We will post the new version here with a new effective date and, for material changes, notify you by email or in your dashboard.

12. Contact

[COMPANY LLC NAME] (doing business as OTB Funded)
[ADDRESS]
Email: [CONTACT EMAIL]

Privacy requests: [CONTACT EMAIL] (subject line: "Privacy Request").