PRIVACY POLICY

1. Introduction

This Privacy Policy explains how Flash Sports & Media Holdings, Inc. ("FLASH SM," "we," "us," or "our") collects, uses, shares, and protects personal information when you use the FLASH SM streaming service, including the website at flashsm.com and our mobile and connected-device applications (the "Service"), and how we use cookies. Your use of the Service is also governed by our Terms & Conditions.

2. Who we are & how to contact us

Flash Sports & Media Holdings, Inc., a Delaware corporation, is responsible for personal information processed through the Service.

3. Information we collect

Information you provide

• Account information: name, email address, password, country/region, and similar details you give when you register.
• Purchase information: records of the Tournament Passes and other pay-per-view purchases you make. Card and payment details are collected and processed by our payment processors — Apple for purchases in our iOS app, Google for purchases in our Android app, and Stripe for purchases on our website (which may include Apple Pay and Google Pay as payment methods). We receive transaction confirmations and limited details (such as the last four digits and billing country), not full card numbers.
• Communications: information you provide when you contact support, respond to surveys, or otherwise communicate with us.

Information collected automatically

• Device and technical data: device type, operating system, app version, browser, language, and identifiers.
• Usage and viewing data: the Content you view, playback events, quality and diagnostics, and how you navigate the Service.
• Approximate location and IP address: used to deliver the Service, secure your account, and enforce the geographic rights that apply to each item of Content.
• Cookies and similar technologies: as described in Section 6.

Information from third parties

We may receive limited information from App Stores and payment processors (for example, confirmation of a purchase or its status) and from service providers that help us operate, secure, and analyze the Service.

4. How we use your information

We use personal information to:

• create and manage your account and authenticate you;
• process your purchases and deliver the Content and access window you bought;
• operate, maintain, secure, and improve the Service, including streaming performance and troubleshooting;
• enforce territorial Content rights and our one-concurrent-stream limit, and detect and prevent fraud and piracy;
• respond to your requests and provide customer support;
• send you service messages and, where permitted, information about events and offers (you can opt out of marketing messages at any time); and
• comply with law and enforce our Terms.

5. How we share your information

We do not sell your personal information, and we do not use it for cross-context behavioral advertising. We share it only as described here:

• Service providers. Companies that help us operate the Service, acting on our instructions — including Amazon Web Services (AWS) for hosting and content delivery, and Google Analytics 4 (provided by Google) for usage analytics. Our streaming platform is operated by FLASH SM, and our email/CRM and customer communications are handled internally.
• App Stores & payment processors. Apple, Google, and Stripe process and confirm the purchases you make, depending on where you buy (Apple or Google in our apps; Stripe on our website).
• Rights holders and authorities. Where necessary to investigate or prevent piracy or fraud, or to comply with law, legal process, or enforceable governmental requests.
• Corporate transactions. In connection with a merger, acquisition, financing, or sale of assets, consistent with this Policy.

We require service providers to protect personal information and to use it only for the services they provide to us. Google Analytics cookies are set only after you accept analytics cookies in the consent banner; see Section 6 for details and opt-out options.

6. Cookies & similar technologies

We and our service providers use cookies and similar technologies (such as SDKs in our apps, local storage, and pixels) to run the Service, remember your preferences, measure performance, and keep the Service secure. We use Google Analytics 4 (provided by Google) to understand how the Service is used. We do not run advertising and do not use advertising or ad-targeting cookies.

Consent banner: when you first visit the Service, a cookie-consent banner lets you accept or reject non-essential cookies. Google Analytics cookies are set only after you accept them, and you can change your choice at any time through the banner or cookie-settings link.

Cookie	Provider	Purpose	Duration
Session / sign-in	FLASH SM (first-party)	Keeps you signed in, secures your session, and remembers your purchases and access	Session
_ga	Google Analytics	Distinguishes individual users for usage analytics	Up to 2 years
_ga_<container-id>	Google Analytics	Maintains analytics session state for your GA4 property	Up to 2 years
_gid	Google Analytics	Distinguishes users (where set by your configuration)	24 hours
_gat	Google Analytics	Limits the rate of analytics requests	1 minute

Managing cookies: you can accept or reject non-essential cookies in the banner; block or delete cookies in your browser settings (blocking strictly necessary cookies may stop parts of the Service from working); and opt out of Google Analytics on any site using Google’s opt-out browser add-on at tools.google.com/dlpage/gaoptout.

7. Your privacy choices & rights

Marketing communications

You can opt out of marketing emails using the unsubscribe link in the message or by contacting info@flashsm.com. We will still send you essential service messages about your account and purchases.

U.S. state privacy rights

Depending on your state of residence (for example, California, Virginia, Colorado, Connecticut, Texas, Oregon, and other states with comprehensive privacy laws), you may have the right to: access the personal information we hold about you; correct inaccurate information; delete your information; obtain a portable copy; and opt out of the "sale" of personal information or of targeted advertising. As noted above, we do not sell personal information and we do not use it for targeted advertising. We will not discriminate against you for exercising these rights. To make a request, email info@flashsm.com; you may use an authorized agent where the law allows.

Categories of information (California notice at collection)

We collect the following categories of personal information: identifiers (such as name, email, IP address); customer records (such as account details); commercial information (such as purchases); internet and usage activity (such as viewing and device data); approximate geolocation; and inferences drawn from the above. We collect these for the purposes described in Section 4.

Canada

If you are in Canada, you may request access to and correction of your personal information, and you may withdraw consent (subject to legal or contractual limits), consistent with applicable Canadian privacy law.

8. Children’s privacy

The Service is intended for adults and is not directed to children under 13. We do not knowingly collect personal information from children under 13. Consistent with the U.S. Children’s Online Privacy Protection Act (COPPA), if we learn that we have collected such information without verifiable parental consent, we will delete it. If you believe a child under 13 has provided us personal information, contact info@flashsm.com.

9. How long we keep information

We keep personal information for as long as needed to provide the Service, maintain your account, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. Purchase and transaction records are generally retained for the period required by law.

10. How we protect information

We use administrative, technical, and organizational measures designed to protect personal information, including encryption in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Where your information is processed

FLASH SM is based in the United States, and the Service is operated from, and your information is processed in, the United States and other countries where our service providers (such as AWS) operate. The Service is intended for users in our supported territories (primarily North America) and is not directed to or offered in the European Economic Area or the United Kingdom.

12. Do Not Track & Global Privacy Control

Some browsers offer "Do Not Track" signals and Global Privacy Control (GPC). Where required by law, we honor recognized opt-out preference signals such as GPC for the choices they cover. Our cookie choices are described in Section 6.

13. Third-party links & services

The Service may link to or rely on third-party sites, App Stores, and services that we do not control. Their privacy practices are governed by their own policies, and we encourage you to review them.

14. Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Policy with a new "Last updated" date and, where required, provide additional notice. Your continued use of the Service after the changes take effect means you accept the updated Policy.

15. Contact us

If you have questions or requests about this Policy or your personal information: