Lock & Cash Sports – Privacy Policy

Effective Date: July 16, 2025

Last updated: July 16, 2025

Welcome to Lock & Cash Sports, LLC ("Lock & Cash," "we," "our," or "us"). We value your privacy and are committed to safeguarding your Personal Information. This Policy explains how we collect, use, disclose, store, and protect information when you:

  • visit lockandcash.com or any branded sub‑domains (the "Site");
  • purchase or use our Lock & Cash Sports Insight Service subscription offerings (the "Services"); or
  • interact with us via SMS, email, Telegram, social media, or any other channel we control.

This Policy is designed to meet or exceed the requirements of the California Consumer Privacy Act, as amended by the CPRA (collectively, "CCPA"), other similar U.S. state privacy laws (Colorado CPA, Virginia VCDPA, Connecticut CTDPA, Utah UCPA, etc.), and the EU/UK GDPR.

Age Restriction: Our Services are intended for natural persons 21 years of age or older. We do not knowingly collect data from anyone under 21.

1. Personal Information We Collect

CategoryExamplesSourceSensitive?
IdentifiersName, username, postal address, email, phone number, IP address, device IDProvided by you; collected automaticallyNo
Commercial dataSubscription tier, transaction dates, Stripe payment ID (tokenized)StripeNo
Internet / app activityLog files, pages viewed, referral URLs, session duration, in‑app clicksAutomatically via cookies, pixels, Supabase, Vercel analyticsNo
Approx. geolocationCity/State derived from IP or SMS area codeAutomaticallyNo
CommunicationsSMS messages, support emails, Telegram chatsProvided by youPotentially sensitive
Inferences / profile dataBetting‑sport preferences, content engagement metricsDerived internallyNo
Biometric identifiersNone (we do not intentionally collect)N/AN/A

We do not intentionally collect "sensitive personal information" as defined under the CPRA or biometric identifiers. If such data is provided (e.g., a voiceprint in a voicemail) we handle it using the strictest applicable standard.

2. How We Collect Information

  • Directly from you when you create an account, purchase a subscription, request a free pick, or communicate with us.
  • Automatically through cookies, web beacons, and similar tracking technology.
  • From third‑party partners such as Stripe (payments), Twilio (SMS), Telegram, Google Analytics, and social‑media platforms when you interact with our ads or posts.

3. Purposes for Processing & Legal Bases

PurposeLawful Basis (GDPR)
Provide, maintain & secure the ServicesContract; Legitimate Interest
Deliver picks & content via SMS, email, Telegram, or web dashboardContract
Process payments & manage billing recordsContract; Legal Obligation
Send service announcements & transactional messagesContract
Send marketing/promotional offers (with opt‑out)Consent (SMS/email); Legitimate Interest (existing customers, subject to opt‑out)
Analyze usage, improve UX, develop new featuresLegitimate Interest
Enforce our Terms, comply with laws, respond to legal requestsLegal Obligation

4. Disclosure of Personal Information

We never sell Personal Information for money. We may "share" (as that term is defined under certain state laws) limited identifiers for cross‑context behavioural advertising; you can opt out (see § 8).

RecipientReason
Service Providers (Stripe, Supabase, Vercel, Google, Twilio, Telegram)Hosting, payments, analytics, messaging
Professional AdvisorsAccounting, legal, compliance
Law Enforcement / RegulatorsWhen required to comply with law or protect rights
Business TransfereesIn connection with a merger, acquisition, or asset sale (with notice to you)

All vendors are bound by written contracts restricting use of Personal Information to specified purposes and requiring appropriate security.

5. Cookies & Tracking Technologies

We use first‑ and third‑party cookies/pixels for:

  • Essential operations (authentication, load‑balancing)
  • Analytics (e.g., Google Analytics with IP anonymisation)
  • Advertising (retargeting via custom audiences)

You can manage cookies via your browser settings or by clicking Cookie Settings in our footer.

6. SMS, Email & Telegram Communications

By providing your mobile number or email, you consent to receive automated and/or manual marketing and transactional messages. Message and data rates may apply. You may withdraw consent at any time by:

  • SMS: Replying STOP to any marketing text.
  • Email: Clicking the unsubscribe link in the footer.
  • Account settings: Toggling delivery channels off.

Opt‑out will not affect non‑marketing communications essential to your subscription (e.g., password resets, payment receipts).

7. Your Privacy Rights

Depending on where you live, you may have rights to:

  • Access the Personal Information we hold about you.
  • Correct inaccurate data.
  • Delete or request erasure.
  • Portability (receive a copy in machine‑readable format).
  • Opt‑out of (a) targeted advertising, (b) the "sale" or "sharing" of data, and (c) certain profiling.
  • Limit the use/disclosure of sensitive personal information.
  • Appeal our decision if we deny your request.

How to Exercise Your Rights

Email support@lockandcash.com or log in to your account dashboard. We will verify your identity (and authority if acting as an agent) before fulfilling the request. We will not discriminate against you for exercising privacy rights.

8. Do‑Not‑Track & Global Privacy Control

Our Site honours the Global Privacy Control (GPC) signal as a valid request to opt out of data "sales" and targeted advertising under applicable U.S. state laws.

9. International Data Transfers

If you are in the EEA/UK, your data may be transferred to the United States and other countries not deemed to provide "adequate" protection by the European Commission. We rely on:

  • Standard Contractual Clauses (SCCs) and, where required, supplementary measures.
  • Article 49 GDPR derogations for occasional transfers (e.g., because you request SMS delivery).

10. Data Security

We implement reasonable and appropriate technical and organisational safeguards—encryption in transit and at rest, least‑privilege IAM, continuous monitoring, annual penetration tests, and incident‑response playbooks. No method of transmission is 100% secure, but we follow industry best practices (ISO 27001/2; NIST 800‑171 guidance).

11. Data Retention

We retain Personal Information only as long as necessary to:

  • Fulfil the purposes listed above;
  • Comply with legal, tax, and accounting obligations; and
  • Maintain business records and defend legal claims.

Typical retention periods:

  • Account data: 6 years after account closure
  • Payment records: 7 years (IRS rule)
  • Marketing opt‑out lists: Permanently (to honour opt‑out)

12. Children's Privacy

We do not knowingly collect data from anyone under 21. If we learn we have inadvertently received such data, we will delete it promptly. Parents or guardians may contact us at support@lockandcash.com.

13. Changes to This Privacy Policy

We may revise this Policy periodically. Material changes will be announced via Site banner, in‑app notice, or email/SMS. The "Last updated" date at the top indicates when changes take effect; continuing to use the Services after that date constitutes acceptance.

14. Contact Us

support@lockandcash.com

End of Policy