Privacy Policy

Gamefuel LLC (“RallyFuel,” “we,” “our,” or “us”) is committed to protecting your privacy and ensuring transparency regarding the collection, use, and third-party sharing of your personal information.
This Privacy Policy explains how we handle data in connection with your use of the RallyFuel platform (website, mobile application, and related services collectively called the “Platform”). By using the Platform, you consent to these practices.

The Platform is hosted in the United States and subject to U.S. state and federal law, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). We comply with the 2025 CPRA updates, including Automated Decision-Making Technology (ADMT) risk assessments and cybersecurity audits (effective January 1, 2026). For EU/UK users, we adhere to GDPR and the ePrivacy Directive (2025 revisions).
If you access the Platform from another jurisdiction, you consent to transfer to the United States and agree that U.S. law governs your use and our agreements.

We collect various types of information, including but not limited to:

1. Information You Provide Directly:

• Name, alias, date of birth, email address, phone number, and account credentials.
• Payment information (e.g., credit or debit card details) for processing NIL fuels.
• User-generated content (e.g., Rally Pit posts, comments, athlete interactions).
• NIL-specific details (e.g., school preferences, athlete selections, and fuel amounts for Conditional NIL Engagement Rights).

2. Information Collected Automatically:

• IP address, browser type, and device identifiers.
• Usage data (e.g., interactions with athletes or schools, fueling activity, and engagement history).
• Cookies, pixels, and analytics data to monitor performance and improve user experience.

3. Information from Third Parties:

• Social logins (e.g., Google, Apple).
• Verification data from payment processors, compliance partners (e.g., Heitner Legal for NIL policy and regulatory compliance review), and affiliated organizations (e.g., NIL Go for reporting).

Sensitive data (e.g., DOB for age verification) is limited to compliance needs; we conduct annual assessments per CCPA 2026 rules.

• Account Management: Create and maintain accounts; match fans and athletes based on preferences.
• Transaction Processing: Facilitate NIL fuels, verify payments, and maintain fuel history (including Conditional NIL Engagement Rights).
• Platform Optimization: Analyze patterns to improve performance and user experience (e.g., personalized Royale suggestions).
• Regulatory Compliance: Enforce Terms; comply with NIL rules, tax and financial laws (e.g., 1099-K for $600 earnings), and university/NCAA reporting via partners like Heitner Legal or NIL Go.
• Security & Fraud Prevention: Detect and prevent fraud and unauthorized access.
• Marketing & Engagement: Send updates, promotions, and NIL education resources (opt-out anytime).

Processing is based on legitimate interests and/or legal obligations. NIL-specific uses (e.g., enrollment verification, reporting) are performed only for compliant agreement execution and explained in our NIL Education Hub.

1. Automated Decision-Making Technology (ADMT)

Uses: AI systems suggest athletes or Royales based on past activity and forecast engagement scores to award RallyFuel Points (RFP).

Logic & Outcomes: Models use anonymized data and basic profiling; no sensitive data used. Outputs affect only content relevance.

Risk Assessment: Low risk (< 1% bias). Annual Impact Assessment per CPRA §1798.185 available upon request at privacy@rallyfuel.com.

Rights: Opt out of ADMT or request human review via [ADMT Opt-Out Form] or email; response within 45 days.

We do not sell or rent personal data. We share only as follows:

• Service Providers: Payment processors, compliance partners, infrastructure, and analytics vendors.
• Athletes: When you fuel an athlete, that athlete may see related fuel details (excluding payment information).
• Legal & Compliance: Where required by law or to protect RallyFuel’s legal interests.
• Business Transfers: In a merger or acquisition, data may transfer with notice.

NIL-related sharing (e.g., aggregated “Total Fuel” to collectives or schools) is limited to agreement execution and regulatory reporting. Heitner Legal provides compliance documentation and disclosure oversight.

Categories Shared: Identifiers (name, email), usage analytics, preferences.

Examples of third parties: Analytics (Google, Microsoft, Vercel); Payments (PayPal, Stripe, Authorize.net); Infrastructure (Supabase, Vercel).

1. Payment Processors

RallyFuel partners with licensed payment processors to support NIL fuels and fan transactions.

• Stripe, Inc. – Processes payments under its Data Processing Agreement and Privacy Policy.
• Authorize.net – Handles card and digital payments in compliance with PCI DSS 4.0.
• PayPal Holdings, Inc. – Optional wallet method (PayPal Privacy Notice).

All processors must meet PCI DSS, SOC 2, GDPR, and CCPA/CPRA standards. RallyFuel does not store full payment card data.

2. Third-Party Services Used by RallyFuel

Data is hosted in the United States. We use encryption, access controls, and security audits to protect information, but no system is impenetrable.

You may update or request erasure of data via your account or email privacy@rallyfuel.com. We retain information while your account is active and as required by law. NIL records (e.g., fuel activity) are retained for up to 7 years to meet tax and reporting obligations.

Depending on your jurisdiction, you may have rights to:

• Access & Correction: (12-month history of sources and purposes).
• Data Portability: (common structured format).
• Opt-Out of Marketing: (you may still receive transactional emails).
• Opt-Out of Sale/Sharing: (we do not sell data; if that changes, we’ll notify you and provide a [Do Not Sell/Share] link).
• Deletion: (erase account and data, subject to exemptions).

We do not discriminate against users who exercise their rights. Requests: privacy@rallyfuel.com(verification required). Include any NIL-specific requests (e.g., compliance documentation access via Heitner Legal).

RallyFuel uses cookies and pixels to enhance functionality, analytics, and marketing. Essential cookies are always on; others require consent and expire after 12 months. Manage preferences via [Cookie Settings].

CCPA/CPRA: Opt-out via [Do Not Sell/Share].

GDPR: Non-essential cookies are blocked until consent. Browser controls supported (but may limit features).

The Platform may link to external sites that use their own cookies or tracking. RallyFuel does not control these entities and is not responsible for their practices. Review each third party’s policy (including NIL partners such as Heitner Legal for regulatory documentation).

The Platform is not intended for individuals under 13. If we learn we have collected data from a minor, we will delete it promptly.

We may update this Policy periodically and post revised dates here. Continued use after changes means acceptance. Material updates will be communicated via email or on-site notice.

Any dispute related to this Privacy Policy is governed by RallyFuel’s Terms of Service and Florida law (arbitration applies).

Email: privacy@rallyfuel.com

Accessibility Statement (CCPA §1798.130): Users with disabilities may request this Privacy Policy in an alternative format by emailing accessibility@rallyfuel.com.