Privacy Policy

Effective Date: March 8, 2026 · Last Updated: March 8, 2026

This Privacy Policy ("Policy") governs the collection, use, storage, processing, disclosure, and transfer of all information obtained by Action Units ("Company," "we," "us," or "our") through the website located at app.actionunits.com, all related subdomains, mobile applications, APIs, email communications, and any other services provided by Action Units (collectively, the "Platform"). By accessing or using the Platform, you ("User," "you," or "your") irrevocably consent to the practices described in this Policy. If you do not agree with this Policy in its entirety, you must immediately cease all use of the Platform.

1. Information We Collect

We collect the broadest categories of information permitted by applicable law, including but not limited to:

• Personal Information: Name, email address, phone number, mailing address, date of birth, government-issued identification numbers, and any other identifying information you provide.
• Account Information: Username, password (stored in encrypted form), account preferences, notification settings, timezone, state/country of residence, and profile configurations.
• Financial Information: Bankroll data, unit sizes, bet amounts, profit/loss records, subscription and payment information, billing addresses, and transaction history.
• Betting Activity Data: All bets placed, picks viewed, capper subscriptions, follow/unfollow activity, confidence levels, odds data, grading results, ladder challenge participation, and all analytical data derived therefrom.
• Device and Technical Information: IP address, browser type and version, operating system, device identifiers, screen resolution, referring URLs, access times, pages viewed, click patterns, session duration, and all server log data.
• Cookies, Tracking Technologies, and Analytics: We use cookies, web beacons, pixel tags, local storage, session identifiers, and similar technologies to collect behavioral data, track usage patterns, and enable Platform functionality.
• Communications: All communications sent to or through the Platform, including emails, support requests, feedback, and any other correspondence.
• Third-Party Data: Information received from third-party services, advertising networks, analytics providers, data brokers, social media platforms, and any other external sources.
• Derived and Inferred Data: We may create, generate, infer, or derive additional data points from the information collected, including user profiles, behavioral patterns, risk assessments, performance scores, and predictive analytics.

2. How We Use Your Information

We reserve the right to use all collected information for any lawful purpose, including but not limited to:

• Operating, maintaining, and improving the Platform and all associated services.
• Personalizing your experience, including content recommendations, targeted notifications, and customized features.
• Marketing, advertising, and promotional purposes, including direct marketing via email, SMS, push notifications, and other channels.
• Analyzing usage patterns, generating aggregated statistics, and conducting research and development.
• Enforcing our Terms of Service and other agreements.
• Complying with legal obligations, responding to lawful requests, and protecting our legal rights.
• Detecting, preventing, and addressing fraud, security issues, and technical problems.
• Creating and distributing aggregated, anonymized, or de-identified data sets for any purpose, including commercial sale or licensing to third parties.
• Any other purpose disclosed at the time of collection or with your consent.

3. Sharing and Disclosure of Information

We may share, disclose, transfer, license, or sell your information to third parties without restriction, to the fullest extent permitted by law, including but not limited to:

• Service Providers and Partners: Third-party vendors, contractors, consultants, and business partners who assist in Platform operations, payment processing, analytics, data hosting, email delivery, and customer support.
• Advertising and Marketing Partners: Advertising networks, data brokers, marketing agencies, and affiliated businesses for targeted advertising, retargeting, and promotional campaigns.
• Affiliates and Subsidiaries: Any current or future parent company, subsidiary, affiliate, or related entity under common control.
• Business Transfers: In connection with any merger, acquisition, reorganization, asset sale, financing, or similar transaction, your information may be transferred as a business asset without notice or consent.
• Legal and Regulatory: To comply with applicable law, regulation, legal process, or governmental request; to enforce our agreements; to protect the rights, property, or safety of Action Units, our users, or the public.
• Aggregated and De-Identified Data: We may share aggregated, anonymized, or de-identified data with any third party for any purpose without restriction.
• With Your Consent: For any other purpose with your explicit or implied consent.

4. Data Retention

We retain all collected information indefinitely, or for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. You acknowledge that certain data, once shared with third parties, may be retained by those parties independently and beyond our control. We are under no obligation to delete or return any data unless specifically required by applicable law.

5. Data Security

While we implement commercially reasonable administrative, technical, and physical security measures to protect your information, no method of transmission over the Internet or electronic storage is completely secure. You acknowledge and agree that:

• We cannot and do not guarantee the absolute security of your information.
• Any transmission of information is at your own risk.
• We shall not be held liable for any unauthorized access, data breaches, hacking incidents, cyberattacks, data theft, or any other security incidents, whether caused by our negligence or otherwise.
• You are solely responsible for maintaining the confidentiality of your account credentials.
• In the event of a security breach, our sole obligation shall be to provide notice as required by applicable law, and we shall have no further liability whatsoever.

6. Limitation of Liability for Data Incidents

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ACTION UNITS, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AFFILIATES, AND LICENSORS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING FROM OR RELATED TO ANY DATA BREACH, UNAUTHORIZED ACCESS, DATA LOSS, HACKING INCIDENT, OR ANY OTHER SECURITY EVENT, REGARDLESS OF THE CAUSE, INCLUDING BUT NOT LIMITED TO NEGLIGENCE, AND REGARDLESS OF WHETHER ACTION UNITS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to access, correct, or request deletion of your data. To exercise any such rights, contact us at the address below. We will respond to verifiable requests within the timeframe required by applicable law. We reserve the right to deny requests that are unreasonable, repetitive, or technically impracticable, or that would jeopardize the privacy of others.

You may opt out of promotional communications by following the unsubscribe instructions in our emails or adjusting your notification preferences in your account settings. However, you may not opt out of transactional or service-related communications.

8. Children's Privacy

The Platform is not directed to individuals under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take steps to delete such information.

9. International Data Transfers

Your information may be transferred to, stored in, and processed in any country where we or our service providers maintain facilities. By using the Platform, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection laws.

10. Changes to This Policy

We reserve the right to modify, amend, or replace this Policy at any time, in our sole discretion, without prior notice. Changes become effective immediately upon posting to the Platform. Your continued use of the Platform following any changes constitutes your acceptance of the revised Policy. It is your responsibility to review this Policy periodically.

11. Contact Us

If you have questions about this Privacy Policy, contact us at:

Action Units
Email: support@actionunits.com
Website: app.actionunits.com