Privacy Policy

1. Introduction; Scope and Acceptance

This Privacy Policy ("Policy") describes how Foresight Collective ("Company", "we", "us" or "our") collects, uses, processes, discloses, and safeguards personal data in connection with your access to and use of the SafeBets platform, including any websites, applications, APIs, and related services (collectively, the "Platform").

This Policy applies to all users globally and is intended to comply with applicable data protection and privacy laws, including:

• United States privacy laws, including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• The General Data Protection Regulation (GDPR) and applicable UK data protection laws
• Other applicable national and international data protection laws and regulations

This Policy is incorporated by reference into, and forms part of, the SafeBets Terms of Service.

By accessing or using the Platform, you:

• Acknowledge that you have read and understood this Policy
• Consent, where required by applicable law, to the collection and processing of your personal data as described herein
• Agree that your continued use of the Platform constitutes acceptance of this Policy

If you do not agree with this Policy, you must immediately discontinue use of the Platform.

2. Data We Collect

We may collect the following categories of personal data:

2.1 Information You Provide

• Name
• Email address
• Account credentials
• Communications and support requests
• User Content submitted to the Platform

2.2 Automatically Collected Data

• IP address
• Device type, browser, and operating system
• Usage data (pages visited, interactions, timestamps)
• Log files and diagnostic data

2.3 Inferred and Derived Data

• Platform activity patterns
• Behavioral and usage analytics
• Aggregated and anonymized insights

2.4 Sensitive Data

We do not intentionally collect sensitive personal data (e.g., race, religion, health data). If such data is inadvertently provided, it will be processed only as necessary and in accordance with applicable law.

3. How We Use Data

We process personal data for the following purposes:

3.1 Platform Operation

• Provide, maintain, and improve the Platform
• Authenticate users and manage accounts
• Enable core functionality

3.2 Security and Compliance

• Detect, prevent, and investigate fraud, abuse, or security incidents
• Enforce our Terms of Service
• Comply with legal and regulatory obligations

3.3 Analytics and Improvement

• Analyze usage patterns and performance
• Improve algorithms, models, and system functionality
• Conduct internal research and development

3.4 Communications

• Respond to inquiries and support requests
• Send service-related notifications

4. Legal Basis for Processing (GDPR)

Where the General Data Protection Regulation ("GDPR") applies, SafeBets processes personal data in accordance with one or more of the following legal bases under Article 6(1) GDPR:

• Performance of a Contract (Article 6(1)(b))
  • Processing is necessary to provide, operate, and maintain the Platform, including account management, authentication, and delivery of core services requested by you
• Legitimate Interests (Article 6(1)(f))
  • Processing is necessary for our legitimate interests, including ensuring the security and integrity of the Platform, preventing fraud and abuse, conducting analytics, improving functionality, and developing new features, provided that such interests are not overridden by your fundamental rights and freedoms
• Compliance with Legal Obligations (Article 6(1)(c))
  • Processing is necessary to comply with applicable laws, regulations, legal processes, and enforceable governmental requests
• Consent (Article 6(1)(a))
  • Where required by law, we rely on your consent for specific processing activities, including the use of non-essential cookies and similar technologies. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal

5. Data Sharing and Disclosure

We may share data with:

5.1 Service Providers

• Cloud infrastructure providers
• Analytics providers
• Security and compliance vendors

All providers are bound by contractual confidentiality and data protection obligations.

5.2 Legal and Regulatory Authorities

Where required to:

• Comply with legal obligations
• Respond to lawful requests
• Protect rights, safety, or security

5.3 Business Transfers

In connection with:

• Mergers
• Acquisitions
• Corporate restructuring

5.3.1 No Sale of Personal Data

SafeBets does not sell or share personal data, including for purposes of cross-context behavioral advertising, as those terms are defined under applicable U.S. privacy laws, including the CCPA/CPRA.

6. Data Retention

SafeBets retains personal data only for as long as is necessary, proportionate, and consistent with the purposes for which it was collected, in accordance with applicable data protection laws.

We retain personal data for the following purposes:

• To fulfill the purposes described in this Privacy Policy, including operation and provision of the Platform
• To comply with applicable legal, regulatory, tax, accounting, and reporting obligations
• To establish, exercise, or defend legal claims, and to enforce our Terms of Service and other agreements

Retention periods are determined based on the nature, sensitivity, and purpose of the data, as well as applicable legal requirements and risk considerations

7. Data Security

SafeBets implements and maintains appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction, in accordance with applicable data protection laws, including Article 32 of the GDPR.

Such measures include, where appropriate:

• Encryption and pseudonymization of data in transit and at rest
• Access controls and authentication mechanisms to restrict access to authorized personnel on a need-to-know basis
• Network, system, and application security controls, including monitoring, logging, and intrusion detection mechanisms
• Operational safeguards, including internal policies, staff training, and incident response procedures

8. Your Rights

8.1 GDPR Rights (EU/UK Users)

Where the General Data Protection Regulation ("GDPR") applies, you have the following rights in relation to your personal data, subject to applicable legal limitations:

• Right of Access (Article 15)
  • You have the right to request confirmation as to whether we process your personal data and, if so, to obtain a copy of such data along with relevant information about how it is processed
• Right to Rectification (Article 16)
  • You have the right to request correction of any inaccurate or incomplete personal data
• Right to Erasure ("Right to be Forgotten") (Article 17)
  • You have the right to request deletion of your personal data where there is no lawful basis for continued processing
• Right to Restriction of Processing (Article 18)
  • You have the right to request that we limit the processing of your personal data under certain circumstances
• Right to Object (Article 21)
  • You have the right to object to processing based on legitimate interests or for direct marketing purposes
• Right to Data Portability (Article 20)
  • You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller
• Right to Withdraw Consent (Article 7(3))
  • Where processing is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing prior to withdrawal

8.2 CCPA/CPRA Rights (California Users)

You have the right to:

• Know what personal data is collected and how it is used
• Request deletion of personal data
• Correct inaccurate data
• Opt out of "sale" or "sharing" (note: we do not sell data)
• Non-discrimination for exercising rights

8.3 Exercising Rights

To exercise your rights, contact: [email protected]

We may require verification of identity before fulfilling requests.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enable core functionality
• Analyze usage and performance
• Enhance user experience

Where required by law, we will obtain your consent before using non-essential cookies.

10. International Data Transfers

Your data may be processed in jurisdictions outside your country of residence, including the United States.

Where required, we implement appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs)
• Equivalent legal protections

11. Children's Privacy

The Platform is not intended for individuals under the age of 18.

We do not knowingly collect personal data from minors.

If we become aware of such data, we will take steps to delete it.

12. Third-Party Links

The Platform may contain links to third-party services.

We are not responsible for the privacy practices of such third parties.

13. Changes to This Policy

We may update this Privacy Policy from time to time.

We will:

• Update the "Last Updated" date
• Notify users where required by law

Continued use constitutes acceptance of updates.

14. Contact

For privacy-related inquiries:

SafeBets

Email: [email protected]

Address: 611 S Dupont Highway, Suite 102, Dover, DE 19901 United States

Data Protection Officer

SafeBets has not appointed a Data Protection Officer (DPO), as it is not required to do so under applicable data protection laws.

For any questions relating to privacy or data protection, you may contact us using the details provided in the Contact section above.