Privacy Policy

This Privacy Policy describes how Challenge LLC (“Challenge,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you use the Challenge platform (“Platform”). This policy applies to all users including players and developers.

By using the Platform, you consent to the practices described in this Privacy Policy. Please also review our Terms of Service.

1. Information We Collect

Account Information

When you create an account, we collect:

• Full name, email address, and username
• Date of birth
• Country and state of residence

Financial Information

When you make deposits or withdrawals, we collect:

• Payment card details (processed and stored by our payment processor, Stripe — we do not store full card numbers)
• Bank account information for ACH transfers (collected via Plaid)
• Transaction history and account balances

Identity Verification Data

To comply with regulatory requirements, we collect:

• Government-issued photo ID (processed by our verification partner, Veriff — we do not store identity documents on our servers)
• Verification results and status

Gameplay Data

• Match results, scores, and performance statistics
• Game-specific data submitted through developer games
• Match history and competition records

Device & Technical Data

• IP address
• Device fingerprint (a hash derived from your device characteristics, used for fraud prevention)

Geolocation Data

• IP-based approximate location to help enforce state eligibility requirements
• Self-reported state of residence

2. How We Use Your Information

We use your information for the following purposes:

• Platform operations — Provide, maintain, and improve the Platform
• Payment processing — Process deposits, withdrawals, and prize payouts
• Identity verification — Verify your age, identity, and eligibility
• Geographic compliance — Enforce state-based restrictions on skill gaming
• Fraud prevention — Detect and prevent cheating, multi-accounting, collusion, and other prohibited conduct
• Tax compliance — Comply with IRS reporting requirements as applicable
• Communications — Send account updates, security alerts, transaction confirmations, and required legal notices
• Matchmaking — Pair players of similar skill levels
• Analytics — Understand how the Platform is used and improve the user experience
• Legal compliance — Comply with applicable laws, regulations, and legal processes

3. How We Share Your Information

We may share your information with the following categories of third parties:

• Payment processors — Stripe (payment processing) and Plaid (bank account linking) receive financial data necessary to process transactions
• Identity verification — Veriff receives identity documents and biometric data to verify your identity
• Analytics providers — We use analytics services to understand Platform usage (data is aggregated and anonymized where possible)
• Law enforcement — We may disclose information when required by law, subpoena, court order, or other legal process, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others
• Business transfers — In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity

We do NOT sell your personal information. We have not sold personal information in the preceding 12 months and have no plans to do so.

4. Data Retention

We retain your information according to the following schedule:

• Account data — Retained while your account is active, plus 5 years after account closure (anti-money-laundering compliance)
• Financial records — 7 years (tax and regulatory requirements)
• Gameplay data — Retained for the life of the Platform to maintain game integrity and historical records
• Identity verification data — Retained per our verification partner's policies and applicable regulatory requirements
• Device and technical data — 2 years

When data is no longer needed for the purposes described above, we securely delete or anonymize it.

5. Your Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

• Right to Know / Access — Request a copy of the personal information we hold about you
• Right to Delete — Request deletion of your personal information, subject to legal retention requirements
• Right to Correct — Request correction of inaccurate personal information
• Right to Opt-Out of Sale — We do not sell your personal information, but you may submit a request to confirm this
• Right to Non-Discrimination — We will not discriminate against you for exercising your privacy rights

To exercise any of these rights, please email us at privacy@withchallenge.com. We will respond to verified requests within 45 days. We may need to verify your identity before processing your request.

6. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights:

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete your personal information
• The right to opt-out of the sale or sharing of your personal information
• The right to correct inaccurate personal information
• The right to limit the use and disclosure of sensitive personal information
• The right to non-discrimination for exercising your rights

Do Not Sell My Personal Information: We do not sell your personal information as defined by the CCPA/CPRA.

This Privacy Policy also serves to provide the required disclosures under Virginia's Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and Utah Consumer Privacy Act (UCPA). Residents of these states have similar rights as described in Section 5.

7. Children's Privacy (COPPA)

The Platform is not directed to persons under the age of 18. We do not knowingly collect personal information from anyone under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete that information.

If you believe a child under 13 has provided us with personal information, please contact us at privacy@withchallenge.com.

8. Security Measures

We implement industry-standard security measures to protect your personal information:

• Encryption in transit — All data transmitted between your device and our servers is encrypted using TLS (Transport Layer Security)
• Encryption at rest — Sensitive data is encrypted when stored
• Access controls — Access to personal information is restricted to authorized personnel on a need-to-know basis
• Secure payment processing — Payment card data is handled by PCI-DSS compliant processors (Stripe) — we never store full card numbers
• Regular security reviews — We conduct periodic reviews of our security practices

While we take reasonable measures to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

9. Cookies & Tracking Technologies

We use the following types of cookies and similar technologies:

• Essential cookies — Required for authentication, session management, and Platform functionality. These cannot be disabled.
• Analytics cookies — Help us understand how the Platform is used. You can opt out of analytics cookies through your browser settings.

We do not use advertising or tracking cookies. We do not engage in cross-site behavioral tracking.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will notify you via email or by posting a notice on the Platform. The “Last updated” date at the top of this page indicates when the policy was last revised.

Your continued use of the Platform after changes are posted constitutes your acceptance of the updated Privacy Policy.

11. Contact Information

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

• Privacy inquiries: privacy@withchallenge.com
• General support: support@withchallenge.com
• Company: Challenge LLC