Privacy Policy

1. Scope of This Policy

This Policy applies to information we process about visitors, players, subscribers, and people who join our messaging lists. It does not apply to third-party websites, products, or services that we do not own or control. Capitalized terms not defined here have the meaning given in our Terms of Service.

2. Information We Collect

Information you provide to us

• Account and contact information: your mobile phone number, and—if you choose to provide them—your email address and a display name.
• Subscription and payment information: payments are processed by our payment provider, Stripe. We do not collect or store your full payment card number. We receive limited billing details and a customer identifier from Stripe to manage your subscription.
• Marketing sign-ups: if you join our text-message list, we collect your mobile number and a record of your consent (including the time, source, and the language you agreed to).
• Profile photo (optional): you may add a photo to your player pin. Taking one is entirely optional—if you don’t, your pin shows your initials instead—and you can remove it at any time.
• Content you submit: reports you file about another player, star ratings and written reviews, answers you volunteer to an in-app question (such as why you did not subscribe), giveaway entries, and messages you send us through the contact form.
• Communications: information you provide when you contact us for support or otherwise correspond with us.

A note on profile photos: your player pin is not a photograph of you—it is a stylized illustrated character created from one, and no scan or measurement of your face is taken at any stage. See Section 3 for exactly what happens to the photograph, who receives it, and how long anything is kept.

Information collected automatically

• Gameplay data: your guesses, scores, rounds played, and attempt history.
• Device and usage data: IP address, browser and device type, device identifiers, operating system, pages viewed, referring pages, and timestamps, collected through cookies, similar technologies, and our hosting infrastructure.
• Security and abuse-prevention records: we record the IP address a verification code was requested from, so that we can rate-limit and block automated abuse of our sign-up.
• Consent records: when you agree to or decline marketing texts, we record your answer together with the exact wording you were shown, the number it applies to, the time, your IP address, and your browser’s user-agent string. We keep this because the law requires us to be able to prove what you agreed to—see Data Retention.
• Message records: the texts and emails we send you, including their content and delivery status.

Information from third parties

• Delivery and engagement status for messages we send, received from our SMS and email providers, and limited transaction and fraud-prevention data from our payment provider.

A note on location: Find Fredo is a geography guessing game. The in-game “guesses” you make are map coordinates you choose for fun—they are not your physical location. We do not collect your device’s GPS or precise geolocation. We may infer only coarse, city/region-level location from your IP address for security and analytics.

3. Your Photo, Your Player Pin, and Biometric Information

Adding a photo to your player pin is entirely optional. If you never add one, your pin shows your initials and nothing in this section applies to you. You can remove a photo at any time from your account settings.

What happens, step by step

1. Your camera opens in your browser. The live camera feed is never transmitted to us or to anyone else—it exists only on your device.
2. A fixed outline is drawn on screen for you to line yourself up with. Nothing analyses, measures, or locates your face at any point—the guide is a static shape, and the only thing read from the camera image is its average brightness, so that the screen can light you if the room is dark.
3. When you take the picture, that single still image is sent to an image-generation provider—currently Google (Gemini) and/or Black Forest Labs (FLUX)— which returns an illustrated character portrait. Their handling of that image is governed by their own terms and privacy policies.
4. If you save the result, only the finished illustration is stored. We do not store the original photograph at any point.
5. The finished illustration is then measured—on your device—so that every player’s pin is framed the same way. That measurement is taken from the drawing, not from you, and nothing derived from it is transmitted or kept.

Biometric information

We want to be precise rather than reassuring here, because the law in some states treats this carefully and so do we.

• We do not perform facial recognition. Nothing in the Service compares one face to another, matches you against any database, or attempts to identify who you are from an image.
• We do not scan the geometry of your face. No software of ours measures, maps, or locates facial features in your photograph or in the camera image. We removed the on-device face detection that used to position the framing guide, and replaced it with a fixed outline, specifically so that this statement needs no qualification.
• We do not create or store a faceprint, face template, or any other biometric identifier, and we never have.
• The only measurement of a face anywhere in the Service is taken from the illustration the model returns, so that pins are framed consistently. A drawing is not a person, that measurement never leaves your device, and it is discarded immediately.
• Photographs are expressly excluded from the definition of a “biometric identifier” under laws such as the Illinois Biometric Information Privacy Act. To the extent any part of this process were nonetheless treated as biometric, we would use it solely to create the player pin you asked us to create; we do not sell, lease, trade, or otherwise profit from it, and we disclose it to no one except the image-generation provider named above, for that purpose alone. Nothing of the kind is retained beyond the completion of that purpose, and in any event no later than the earliest deadline any applicable law imposes—one year after the purpose expires under Texas law, three years after your last interaction with us under Illinois law.

By choosing to take a photo for your player pin, you consent to the processing described in this section. If you would prefer not to, do not add a photo—the Service works fully without one.

Who can see your pin

Your pin is shown to players you have accepted as friends, and to our staff through our internal admin tools (so that we can act on reports). It is stored at an unguessable web address; anyone you send that address to could view the image, so it is best understood as unlisted rather than private. We do not publish it elsewhere.

4. Categories of Personal Information

Under certain laws (such as the California Consumer Privacy Act), the information above falls into these statutory categories, which we collect for the business purposes described in How We Use Your Information below:

• Identifiers: phone number, email address, display name, IP address, device identifiers, customer ID.
• Commercial information: subscription status, transaction history, products considered or purchased.
• Internet or network activity: usage data, gameplay activity, and interactions with the Service.
• Visual information: your optional profile photo, if you choose to add one.
• Inferences: limited preferences derived from your activity (for example, that you are an engaged player).

We do not collect government identifiers, precise geolocation, or other “sensitive personal information” for the purpose of inferring characteristics, and we do not knowingly collect such data. Although an optional profile photo is an image of you, we do not use it for facial recognition and we do not generate or retain any biometric identifier from it—see Your Photo, Your Player Pin, and Biometric Information.

5. How We Use Your Information

• Provide, operate, maintain, secure, and improve the Service and your account.
• Authenticate your logins and send one-time verification codes.
• Process subscriptions, billing, renewals, and refunds.
• Send weekly puzzle notifications, account and billing notices, and—with your consent—marketing and promotional messages.
• Personalize your experience and develop new features and content.
• Provide customer support and respond to your requests.
• Detect, investigate, prevent, and address fraud, abuse, cheating, security, and technical issues.
• Comply with legal obligations, enforce our Terms, and protect our legal rights.

6. Legal Bases for Processing (EEA/UK)

The Service is offered only in the United States, so these bases will rarely apply. If you are nonetheless in the European Economic Area or the United Kingdom, we rely on the following:

• Performance of a contract — to provide the Service, your account, and your subscription.
• Consent — to send marketing messages and to set non-essential cookies (you may withdraw consent at any time).
• Legitimate interests — to secure and improve the Service, prevent fraud, and communicate with you, where not overridden by your rights.
• Legal obligation — to comply with applicable laws.

7. Text Messaging (SMS) Program

We operate a marketing-only text-messaging program through our SMS provider, Twilio. The only text messages we send are:

• Marketing (with your separate express consent): promotional alerts when each Friday’s new puzzle drops, plus occasional offers, new-release announcements, and merchandise. Sent only to people who tick the separate SMS marketing checkbox.

Account, security, and billing communications (such as login/security codes, renewal reminders, and failed-payment alerts) are sent by email, not text.

Consent. You opt in to receive marketing text messages only by giving an express affirmative answer on a screen dedicated to that question, which shows you the full program disclosure and names the number being enrolled before you answer. Declining is offered equally prominently and leads to exactly the same next screen. You may also opt in through our sign-up form at findfredo.com/join. Consent to receive texts is optional, is never a condition of any purchase or of using the Service, is not bundled with acceptance of our Terms or this Policy, and is not requested at the same time as any other agreement. Message frequency varies. Message and data rates may apply.

Opt out. You can opt out at any time by replying STOP to any message. Reply HELP for help. An opt-out is permanent: we will not text you again on the strength of the consent you revoked, and messages resume only if you give fresh consent (for example by replying START). Carriers are not liable for delayed or undelivered messages.

If you change your number, we treat the consent attached to the old number as revoked, because that number may now belong to someone else. You would need to opt in again on the new number.

No sharing of mobile information for third-party marketing. We do not sell your personal information. No mobile information (including your phone number and your SMS opt-in or consent) will be shared with, sold to, or rented to third parties or affiliates for their own marketing or promotional purposes. We share mobile information only with the service providers that help us operate the messaging program (such as Twilio), and only as necessary to deliver the Service to you.

8. Reports, Blocks, Invites, and Giveaways

Reports and blocks. If you report or block another player, we record who reported or blocked whom, when, and any reason you selected, together with the content complained about. We keep this to review the report, to act on it, and to keep the block in force. A block remains recorded for as long as your account exists, because forgetting it would undo it.

Invites and referrals. When you join through someone’s invite link we record that they invited you, so their rewards can be counted and so the two of you can be connected as friends. This is a link between two accounts; we do not collect your contacts, and we never send messages on your behalf.

Giveaways. If you enter a giveaway we collect your entry and the details the entry form asks for, which may include your name and email address. If you win, we collect what is needed to verify eligibility and deliver the prize, which may include confirmation of your age and country of residence and, for a physical prize, a postal address. Winners may be listed publicly by first name and last initial. We keep winner records as long as needed for the giveaway and for our own tax, audit, and legal purposes.

Product measurement and attribution. We record which steps of the demo and the sign-up flow each visit reaches—for example, that a visit finished round three of a demo, saw the plans screen, and did not subscribe—together with any answer you volunteer about why you did not subscribe. To join those steps into a single journey, we set a first-party cookie containing a random identifier that lasts up to 30 days, along with the demo and advertising campaign you arrived from. That lets us see which advertisements and which demos actually lead to subscriptions, rather than guessing.

The identifier is random and is not your name, number, or email. If you go on to create an account, the journey can be associated with that account. We use this for our own measurement, and—where advertising partners are enabled, as described in Advertising, Analytics, and Your Choices—to report conversions back to the platform an advertisement ran on.

9. How We Share Your Information

We share information with the following categories of recipients:

• Service providers (subprocessors) that process information on our behalf under contract, including: Supabase (database, authentication, storage), Stripe (payments and subscriptions), Twilio (SMS delivery and phone verification), Resend (email delivery), Google Maps Platform (map rendering), jsDelivr (a public content-delivery network that serves the 360° panorama viewer code to your browser, and which therefore receives your IP address when a game loads), an image-generation provider—Google (Gemini) and/or Black Forest Labs (FLUX)—(creating your player pin illustration from the photo you take), and Vercel (application hosting, which processes request logs including IP addresses).
• Advertising and measurement partners. Where we run advertising, we work with advertising platforms—currently Meta (Facebook and Instagram) and TikTok—to measure which advertisements lead to sign-ups. See Advertising, Analytics, and Your Choices, which explains exactly what is shared, why, and how to opt out.
• Professional advisors such as lawyers, accountants, and auditors, where reasonably necessary.
• Legal and safety: when required by law or legal process, or to protect the rights, property, or safety of Find Fredo, our users, or others, and to enforce our Terms.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our assets.
• With your consent or at your direction.

We do not sell your personal information for money. We have never done so and have no plans to.

We do not share your mobile number, or the fact that you opted in to texts, with anyone for their own marketing. That commitment is absolute and is unaffected by anything in the advertising section below.

Some privacy laws define “sharing” or a “sale” broadly enough to include advertising cookies and conversion reporting, even where no money changes hands. Where we have those partners enabled, we treat our advertising measurement as “sharing” for cross-context behavioral advertising and we honor opt-outs accordingly—see Advertising, Analytics, and Your Choices and Your Privacy Rights and Choices. We would rather tell you this plainly than rely on a narrow reading.

10. Cookies and Similar Technologies

We use cookies and browser storage for the purposes below. Except where stated, all are first-party—set by us, readable only by us.

Strictly necessary

• Authentication. Keeps you signed in and refreshes your session. Set by our authentication provider. Without it you cannot stay logged in.
• Sign-up verification. A short-lived, cryptographically signed cookie set after you enter a texted code but before your account exists, proving that the number was verified. It contains your phone number and is discarded as soon as the account is created or the attempt is abandoned.
• Session preference. Records whether you asked us to keep you signed in.
• Invite reference. If you open a friend’s invite link before signing in, we remember which link it was for up to 30 days so the two of you can be connected once you join.

Functional

• Demo history. Records that this browser has completed a free demo, so that we do not send you through the same demo again.
• Local storage on your device. Your most recent demo result, so we can show it back to you, and which one-time messages you have already dismissed. This stays on your device and is not transmitted to us.

Measurement

• Journey identifier. A random identifier lasting up to 30 days, plus the demo and campaign you arrived from, so we can measure which advertisements and demos lead to subscriptions.

Advertising (only while advertising partners are enabled)

• Meta and TikTok advertising tags. Third-party cookies and identifiers set by those platforms. These are the only third-party tracking technologies we use, and they are described in full in the next section.

You can block or delete cookies through your browser settings, and you can use a browser or extension that transmits a Global Privacy Control signal—we honor it, as described below. Blocking strictly necessary cookies will prevent you from signing in.

11. Advertising, Analytics, and Your Choices

What this covers. We advertise Find Fredo on platforms such as Meta (Facebook and Instagram) and TikTok. To know whether those advertisements work, we tell the platform when someone who saw one went on to finish a demo, reach the checkout, begin payment, or subscribe.

How that happens

• In your browser. When enabled, the platform’s advertising tag loads on our pages and receives the page you are on, your IP address, your browser and device information, and the identifiers in its own cookies—which may allow it to recognize you if you also use that platform. It also receives an event at each of the four moments named above.
• From our servers. When someone subscribes, we also report that purchase directly from our servers, because browser-based reporting is frequently blocked. That report contains the amount, the currency, an identifier for the transaction, and—so the platform can match it to the right advertisement—your email address and phone number in irreversibly hashed form (SHA-256). We do not send your email address or phone number to an advertising platform in readable form.

We never send an advertising platform your gameplay, your photo or player pin, your friends list, your reports or blocks, your payment card details, or the content of your messages.

Your choices

• Global Privacy Control. If your browser or an extension sends a GPC signal, we do not load advertising tags for that visit and we do not report conversions from it. This is the simplest and most reliable way to opt out; it takes effect immediately and needs no account.
• Browser controls. Blocking third-party cookies, or using a tracker blocker, prevents the platforms’ tags from working.
• Platform controls. Meta and TikTok each provide ad-preference settings within your account with them, which govern how they use what they receive.
• Ask us. Email support@findfredo.com with the subject “Do Not Sell or Share My Personal Information” and we will exclude you from conversion reporting.

Opting out does not stop you seeing our advertisements—it stops us and the platform measuring what you do afterward. The first-party product measurement described above continues either way, because we need it to operate and improve the Service.

When we are not running paid advertising, no third-party advertising tag loads at all and nothing in this section takes place. We have set it out here so that you know what happens when we do advertise, rather than changing this Policy quietly at that moment.

12. Data Retention

We keep information for as long as your account is active or as needed to provide the Service, and afterward only as long as necessary to meet our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. In practice:

• Account, profile, and gameplay: for the life of your account, then deleted or anonymized when you close it.
• Player pin image: only while it is in use. Replacing or removing your photo deletes the previous file from our storage rather than keeping a copy, and closing your account removes it too.
• The original photograph you took: never stored by us at any point.
• On-device measurement of the generated illustration: discarded as soon as the pin is framed. Never transmitted to us, and nothing is measured from your photograph.
• Billing records: as long as required by tax and accounting law, typically seven years. Stripe retains its own records under its own policy.
• Verification rate-limit records: pruned automatically after 24 hours.
• Friendships, reports, and blocks: for the life of the accounts involved. A block is kept because forgetting it would undo it.
• Giveaway entries and winner records: for the giveaway and afterward as long as needed for tax, audit, and legal purposes.

What survives closing your account, and why

Some records are kept even after an account is closed, because deleting them would destroy evidence we are required to hold or would let a deleted account be used to undo a protection:

• Text-message consent records. Our record of what you agreed to or declined is append-only and is never edited or deleted. Federal telemarketing law allows claims for four years, and this record is the only proof of what you consented to. It is keyed to a phone number and is retained for at least that period. Closing your account does not resume texts—an opt-out is permanent until you give fresh consent.
• Records of messages we sent you, for the same reason and period.
• Marketing list entries collected before you had an account, which are keyed to the email or number you gave rather than to an account.
• Aggregate and de-identified measurement counts, which no longer identify you.
• Records we are required to keep for tax, accounting, fraud-prevention, or legal-claim purposes.

If you want your consent records deleted as well and no legal obligation requires us to keep them, say so in your request and we will tell you honestly what we can and cannot remove.

13. Data Security

We maintain a data-security program with reasonable administrative, technical, and physical safeguards designed to protect your information, as required by the Texas Identity Theft Enforcement and Protection Act, the New York SHIELD Act, and comparable laws in other states. In practice that includes encryption in transit, access controls and row-level authorization on our database, server-side handling of anything sensitive, rate-limiting and abuse controls on sign-up, restricted internal access to player data, and keeping payment card details entirely with our payment processor rather than on our systems.

No method of transmission or storage is completely secure and we cannot guarantee absolute security. If a breach affecting your information occurs, we will notify you and the authorities as and when applicable law requires. You are responsible for keeping your phone number and account access secure.

14. Your Privacy Rights and Choices

Choices available to everyone, wherever you live

• Access and update: review and change your name, contact details, and player pin from your account settings, or ask us.
• Remove your photo: delete your player pin at any time from your account settings, which deletes the stored image.
• Marketing opt-out: reply STOP to any text, or use the unsubscribe link in any marketing email.
• Opt out of advertising measurement: send a Global Privacy Control signal, or email us—see the advertising section above.
• Account deletion: email support@findfredo.com from the address on your account, or contact us from the phone number on it, and we will delete your account and associated personal information subject to the exceptions listed under Data Retention. There is currently no self-service delete button; a person handles the request, and we aim to complete it within 30 days.

California residents (CCPA/CPRA)

If you are a California resident, you have the right to know and access the personal information we collect, use, and disclose; to request correction; to request deletion; to opt out of the “sale” or “sharing” of personal information; to limit the use of sensitive personal information; and to not be discriminated against for exercising your rights. We do not sell personal information for money. While advertising partners are enabled, we treat our conversion measurement as “sharing” for cross-context behavioral advertising and honor opt-outs, including the Global Privacy Control signal, which we treat as a valid request to opt out. We do not use or disclose sensitive personal information for purposes that would require a right to limit. California’s “Shine the Light” law does not apply because we do not disclose personal information to third parties for their own direct marketing. You may use an authorized agent to submit a request; we may require verification of the request and the agent’s authority.

Virginia, Colorado, Connecticut, Utah, and other US state residents

Depending on your state, you may have the right to confirm whether we process your personal data, to access it, to correct it, to delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of personal data, and certain profiling. We do not sell personal data. Where we run advertising, you may opt out of targeted advertising and conversion measurement as described above, including by sending a Global Privacy Control signal. If we decline a request, you may appeal by replying to our decision or emailing support@findfredo.com with the subject line “Privacy Appeal.”

Texas residents (TDPSA)

Under the Texas Data Privacy and Security Act you may confirm whether we process your personal data and access it, correct it, delete it, obtain a portable copy, and opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions producing legal or similarly significant effects. We honor the Global Privacy Control as a universal opt-out mechanism. If we decline a request you may appeal, as described below.

The TDPSA treats biometric data as sensitive data and requires your consent before it is processed. Adding a photo to your player pin is entirely optional and is the act by which you give that consent—see Your Photo, Your Player Pin, and Biometric Information. We do not sell sensitive personal data and we do not sell biometric personal data, so the sale notices the TDPSA would otherwise require do not apply to us. The Texas Capture or Use of Biometric Identifier Act also applies to Texas residents, and is addressed in that same section.

New York residents

New York does not currently have a comprehensive consumer privacy statute. The New York SHIELD Act requires us to maintain reasonable safeguards for New York residents’ private information and to notify you of a breach affecting it. The choices listed above—access, correction, deletion, marketing opt-out, and advertising opt-out—are available to you regardless of where you live, so you do not need a particular state’s law to use them.

EEA/UK residents (GDPR)

The Service is offered only in the United States and is not directed to the EEA or the UK. If you are nonetheless subject to those laws, you have the rights to access, rectify, erase, restrict, and port your personal data, to object to certain processing, and to withdraw consent at any time. You may also lodge a complaint with your local supervisory authority.

How to exercise your rights

Submit requests to support@findfredo.com. We will respond within the time required by applicable law. To protect your information, we may need to verify your identity before acting on a request, and we may decline requests as permitted by law.

15. Children’s Privacy

The Service is not directed to children. You must be at least 13 years old to create an account, and at least 18 to purchase a subscription or enter a giveaway. If you are between 13 and 18, you may use the Service only with the involvement of a parent or guardian.

We do not knowingly collect personal information from children under 13, and we do not knowingly allow anyone under 13 to add a photo to a player pin. We verify age by asking rather than by document check, so if a child gives us an inaccurate age we may not detect it.

Parents and guardians: if you believe a child under 13 has given us personal information, or that a person under 18 has added a photo, contact us at support@findfredo.com and we will delete the account and the image promptly. We will act on such a request without requiring you to prove the child’s identity beyond what is needed to locate the account.

16. Third-Party Links and Services

The Service may contain links to or rely on third-party websites and services that we do not control, such as our mapping, payment, and messaging providers. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their policies.

17. International Data Transfers

The Service is offered only in the United States, and your information is processed and stored there. Some of our service providers operate infrastructure or support teams in other countries, so limited processing may occur outside the United States; where that happens we rely on contractual safeguards with those providers. We do not direct the Service to the European Economic Area or the United Kingdom, and sign-up requires a U.S. mobile number.

18. Do Not Track and Global Privacy Control

We honor the Global Privacy Control (GPC). If your browser or an extension transmits a GPC signal, we do not load advertising tags for that visit and we do not report conversions from it. Under California law we treat GPC as a valid request to opt out of sharing for cross-context behavioral advertising. Because GPC is transmitted by your browser rather than tied to your account, it applies to the browser sending it.

The older “Do Not Track” header has no agreed industry standard and we do not respond to it separately; GPC supersedes it in practice.

19. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above, and for material changes we will provide additional notice as appropriate. Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

20. Contact Us

If you have questions about this Privacy Policy, or to exercise your rights, contact us at support@findfredo.com (Find Fredo LLC).