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).
• Communications: information you provide when you contact us for support or otherwise correspond with us.

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.

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. 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 Section 4:

• 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.
• Inferences: limited preferences derived from your activity (for example, that you are an engaged player).

We do not collect government identifiers, biometric data, precise geolocation, or other “sensitive personal information” for the purpose of inferring characteristics, and we do not knowingly collect such data.

4. 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.

5. Legal Bases for Processing (EEA/UK)

If you are in the European Economic Area or the United Kingdom, we rely on these legal bases:

• 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.

6. Text Messaging (SMS) Program

We operate text-messaging programs through our SMS provider, Twilio. The messages we send fall into the following categories:

• Account verification: one-time passcodes used to verify your phone number and log in.
• Subscriber notifications: a message each Friday when the new weekly puzzle goes live, and account or billing notices such as renewals and failed-payment alerts.
• Marketing (with your express consent): free game invites, subscription offers, new-release announcements, and merchandise.

Consent. You opt in to receive messages by providing your mobile number and agreeing to receive texts—during account setup (for notifications) or through our marketing sign-up form (for marketing messages). The free demo is openly playable without opting in, and consent to receive marketing messages is not a condition of any purchase or of using the Service. Message frequency varies. Message and data rates may apply.

Opt out. You can opt out of any text program at any time by replying STOP to a message from that program. Reply HELP for help. Carriers are not liable for delayed or undelivered messages.

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.

7. 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), and Vercel (application hosting).
• 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, and we do not share it for cross-context behavioral advertising or share mobile opt-in data for third-party marketing.

8. Cookies and Tracking Technologies

We use cookies and similar technologies that are necessary to keep you signed in, remember your session, secure the Service, and understand how the Service is used. Some are strictly necessary; others help us measure and improve performance. You can control cookies through your browser settings, though disabling essential cookies may prevent parts of the Service from working.

9. Data Retention

We retain your information for as long as your account is active or as needed to provide the Service, and afterward only as long as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. We determine retention periods based on the type of information, the purpose for which it was collected, and applicable legal requirements. When information is no longer required, we delete or anonymize it.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect your information, including encryption in transit and access controls. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your phone number and account access secure.

11. Your Privacy Rights and Choices

Choices available to everyone

• Access and update: review and update certain account information from your account page, or by contacting us.
• Marketing opt-out: reply STOP to texts, or use the unsubscribe link in emails.
• Account deletion: email support@findfredo.com to request deletion of your account and associated personal information.

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 or share your personal information as those terms are defined under California law, and we do not use or disclose sensitive personal information for purposes that require a right to limit. California’s “Shine the Light” law does not apply because we do not share personal information with third parties for their 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 or use it for targeted advertising. If we decline a request, you may appeal by replying to our decision or emailing support@findfredo.com with the subject line “Privacy Appeal.”

EEA/UK residents (GDPR)

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.

12. Children’s Privacy

The Service is not directed to children under 13, and a paid subscription requires you to be at least 18. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us at support@findfredo.com and we will delete it.

13. 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.

14. International Data Transfers

We operate in the United States, and your information will be processed and stored there and in other countries where our service providers operate. These countries may have different data-protection laws than your jurisdiction. Where required, we use appropriate safeguards for international transfers. By using the Service, you consent to these transfers.

15. Do Not Track

Some browsers offer a “Do Not Track” signal. Because there is no common industry standard for responding to these signals, our Service does not currently respond to them.

16. 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.

17. Contact Us

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