Privacy Policy

Thank you for choosing to be part of our community at Grindit LLC ("Company," "Fundly Games," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices regarding your personal information, please contact us at support@fundly.games.

This Privacy Policy describes how we collect, process, store, share, and protect your personal data when you:

• Visit or register on our website at https://fundly.games/ (the "Website" or "Platform");
• Purchase an Evaluation Package via our authorized merchant facility, Whop Inc. ("WHOP");
• Participate in our simulation evaluation challenges, data research activities, or contractor partner program; or
• Engage with us in other related ways, including customer support, sales, or marketing.

Please read this Privacy Policy carefully. If you do not agree with any terms contained in this notice, please discontinue the use of our Platform and Services immediately.

1. What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect personal information that you voluntarily provide to us when registering, participating in evaluation challenges, completing identity verification, or submitting B2B invoices.

We collect personal information depending on the context of your interactions with us, the choices you make, and the features you use. This includes:

• Basic Identity & Contact Data: Full name, email address, telephone number, mailing/residential address, account login credentials, and contact preferences.
• Identity Verification & KYC Data (Whop Verification): To qualify for Phase 3 (Partner Phase) or request contractor performance fee payouts, you must complete identity verification conducted via WHOP's identity verification service. This includes government-issued ID documents (passport, national ID card, driver's license), facial biometric selfie data (processed with your explicit consent under GDPR Article 9), date of birth, nationality, and proof of address documents (utility bills or bank statements).
• B2B Invoicing & Tax Information: For Users operating as B2B Independent Contractors in Phase 3, we collect Tax Identification Numbers (TIN/VAT/EIN/IČO), registered business entity names, and banking/payout wallet addresses (e.g., Rise, Wise, bank wire, or cryptocurrency wallet addresses).
• Payment Data: All payment transactions for Evaluation Packages are processed by our primary authorized merchant, Whop Inc. ("WHOP"). We do not store full credit card details or payment security codes directly on our servers. All billing and card data are handled directly by WHOP under their privacy practices.

Information Automatically Collected

In Short: Technical data — such as IP address, browser type, device characteristics, and simulation performance logs — is collected automatically when you navigate our Platform.

• Log and Simulation Performance Data: IP addresses, browser types, operating system settings, device characteristics, access timestamps, referral URLs, error reports, and full historical logs of simulated prediction entries, odds selections, and performance parameters.
• Geolocation Data: Precise or imprecise location data derived from your IP address, strictly used to verify geographic eligibility, enforce anti-syndicate rules, and comply with international sanctions laws.

2. How Do We Use Your Information?

In Short: We process your personal information for purposes based on contractual fulfillment, legal compliance, fraud monitoring, B2B contractor payouts, and legitimate business interests.

We use the information we collect to:

• Facilitate Account Creation and Execution of Contract: To set up your Virtual Account, manage your participation in evaluation challenges (Phase 1, Phase 2, Phase 3), and provide access to our simulation software.
• Execute Identity Verification (KYC/AML): To verify your identity via WHOP's identity verification service, prevent underage access (under 18), detect fraudulent activity, enforce anti-syndicate/challenge-passing policies, and comply with anti-money laundering (AML) protocols prior to contractor onboarding.
• Process B2B Contractor Performance Rewards: To review B2B invoices, calculate performance fee splits (80/20), and disburse contractor payouts via authorized payout infrastructure (Rise, Wise, Crypto).
• Platform Security & Fraud Monitoring: To monitor for latency exploitation, system glitches, automated bots, multi-account group hedging, or illegal activities.
• Enforce Terms & Policies: To enforce our Terms and Conditions, Disclaimers, Non-Disparagement clauses, and Refund Policies.
• Support & Communication: To respond to support tickets, issue critical policy updates, and deliver administrative account notifications.

3. What Legal Bases Do We Rely On to Process Your Data?

We process your personal information under the following legal frameworks (including GDPR / UK GDPR and applicable UAE Laws):

• Performance of a Contract: Processing is necessary to deliver the simulation services you purchased and to fulfill our obligations under our Terms and Conditions or Independent Contractor Agreements.
• Legal Obligation: Processing is required to comply with financial reporting, anti-money laundering (AML), sanctions screening, and tax record-keeping requirements.
• Legitimate Business Interests: Processing is necessary to secure our Platform against technical exploiters, protect our corporate reputation, prevent fraud, and optimize our analytical simulation algorithms.
• Consent: Where you have granted explicit consent for specific processing activities (e.g., marketing communications, biometric ID processing via WHOP's identity verification service, or public testimonials).

4. Will Your Information Be Shared With Anyone?

In Short: We only share information with authorized third-party data processors, merchant facilities, identity verification services, and payout providers essential to running our operations.

We share data strictly on a need-to-know basis with the following third-party providers:

• Payment Gateway, Merchant of Record & Identity Verification: Whop Inc. (https://whop.com/) for processing challenge fees, managing subscriptions, handling customer billing data, and for automated photo ID verification, facial biometric matching, and AML sanctions checks (KYC).
• Contractor Payout & Banking Infrastructures: Providers such as Rise Works, Wise, or designated cryptocurrency networks for settling approved B2B contractor invoices.
• Cloud Infrastructure & Hosting: Encrypted cloud hosting providers, database management tools, and performance monitoring software.
• Legal and Regulatory Authorities: Government bodies, courts, or law enforcement agencies when legally compelled to comply with statutory requests or defend against legal claims.

5. International Data Transfers

In Short: We may store or process your data outside your country of residence, including in the United Arab Emirates (UAE) and the United States.

Our operational company, Grindit LLC, is registered in the United Arab Emirates (Sharjah Media City). Third-party vendors (such as Whop Inc.) may process data in the United States and European Economic Area (EEA).

When transferring data internationally outside the UK or EEA, we ensure appropriate safeguards are implemented, including Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) / UK Addendum, to maintain data security under UK GDPR and EU GDPR standards.

6. How Long Do We Keep Your Information?

In Short: We retain your information for as long as necessary to fulfill the operational, tax, and legal requirements outlined in this policy.

• Active Accounts: Personal data associated with active user accounts is retained for the duration of your registration.
• Inactive Accounts & Legal Record-Keeping: Following account termination or challenge completion, data required for tax, B2B invoicing history, fraud monitoring, legal defense, and AML compliance will be retained for up to six (6) years, after which it will be permanently deleted or securely anonymized.

7. How Do We Keep Your Information Safe?

In Short: We employ technical and organizational security measures to protect your personal information.

We have implemented encrypted database storage, strict access control restrictions, SSL/TLS data transmission protocols, and multi-factor authentication (MFA) procedures to safeguard your data. However, no internet transmission is 100% secure. You are responsible for keeping your login credentials and dashboard access confidential.

8. Do We Collect Information From Minors?

In Short: No. We strictly prohibit access and do not knowingly collect personal data from individuals under 18 years of age.

Fundly Games is restricted solely to individuals who are at least 18 years old (or the legal age of majority in your jurisdiction). If we discover that personal data from a minor under age 18 has been collected, we will immediately disable the Virtual Account, cancel any pending evaluation or payout eligibility, and permanently delete the data from our databases. If you suspect a minor is using our services, contact us at support@fundly.games.

9. What Are Your Privacy Rights? (EEA, UK, and Global Users)

Depending on your geographical jurisdiction (including the European Economic Area and the United Kingdom), you hold specific statutory rights regarding your personal information:

• Right of Access & Rectification: You may request copies of the personal information we hold about you or request corrections to inaccurate data.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal data, subject to our statutory legal, tax, and fraud-monitoring retention obligations.
• Right to Restrict or Object to Processing: You may object to data processing carried out under our legitimate business interests or request processing restrictions.
• Right to Data Portability: You may request an electronic copy of the personal data you provided to us in a structured format.
• Withdrawal of Consent: You have the right to withdraw marketing or optional processing consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: You have the statutory right to lodge a complaint with a data protection supervisory authority in your EU/EEA member state or the UK Information Commissioner's Office (ICO) if you believe our processing violates applicable data protection laws.

To exercise any of these rights, please submit a written request to support@fundly.games. We will respond to verified requests within thirty (30) days.

10. Do-Not-Track (DNT) Features & Cookie Policy

Most modern web browsers include a Do-Not-Track ("DNT") setting. Because there is no uniform industry standard for recognizing DNT signals, our Website does not currently respond to automated DNT browser signals.

For detailed information regarding how we utilize essential cookies, performance tracking, and analytical session files, please consult our dedicated Cookie Policy hosted on https://fundly.games/.

11. Specific Privacy Rights for California Residents (CCPA/CPRA)

If you reside in California, California Civil Code Section 1798.83 (the "Shine the Light" law) and the California Consumer Privacy Act (CCPA/CPRA) grant you specific rights:

• Right to Know and Delete: You have the right to request disclosures regarding the categories of personal data collected, shared, or disclosed, and to request erasure of your data.
• No Sale of Personal Information: Grindit LLC does not sell user personal data to third parties for monetary or valuable consideration.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA privacy rights.

To submit a California privacy request, email us at support@fundly.games with the subject line "California Privacy Request."

12. Updates to This Privacy Notice

We may revise this Privacy Policy periodically to reflect operational changes, technical integrations, or legal requirements. Updated versions will be indicated by a revised "Last Updated" date at the top of this document and become effective immediately upon posting to https://fundly.games/. We encourage you to review this page regularly.

13. How Can You Contact Us About This Notice?

If you have questions, comments, or data rights requests regarding this Privacy Policy or our privacy practices, you can contact us directly at:

Grindit LLC
Sharjah Media City, Sharjah
United Arab Emirates
Company Registration No: 2541536
Email Support: support@fundly.games
Website: https://fundly.games/