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PRIVACY POLICY

Last Update Posted: April 8, 2022


1. INTRODUCTION

1.1 FanDuel Inc. and FanDuel SG LLC (“FanDuel, we, us”) recognizes that people
who use FanDuel’s Service (“you” or “users”) value their privacy. This Privacy
Policy details important information regarding the collection, use and
disclosure of User information collected on FanDuel’s fantasy sports website
located at fanduel.com (the "DFS Site"), the DFS Site's related mobile app,
FanDuel’s skill games website located at www.fanduel.com/faceoff (the “Skill
Games Site” and collectively with the DFS Site, the “Sites”), the Skill Games
Site’s related mobile app, and any other features, tools, materials, or other
services (including co-branded or affiliated services) offered from time to time
by FanDuel (the “Services”). FanDuel provides this Privacy Policy to help you
make an informed decision about whether to use or continue using the Service.

1.2 This Privacy Policy should be read in conjunction with our Terms of Use. By
accessing the Services, you are consenting to the information collection and use
practices described in this Privacy Policy.

1.3 Your use of the Services and any information you provide through the
Services remains subject to the terms of this Privacy Policy and our Terms of
Use, as each may be updated from time to time.

1.4 Any questions, comments or complaints that you might have should be emailed
to privacy@fanduel.com or forwarded in writing to:
FanDuel Inc
300 Park Avenue South, 14th Fl.
New York, NY 10010


2. INFORMATION WE COLLECT

By using our Services and by submitting information to us through your use of
our Services then this Privacy Policy will apply. You provide certain personal
information to FanDuel when choosing to participate in the various activities on
the Services such as registering for an account, participating in contests,
posting messages, taking advantage of promotions, responding to surveys or
subscribing to newsletters or other mailing lists. The personal information we
collect from you generally may include:

2.1.1 your name;

2.1.2 email address;

2.1.3 date of birth;

2.1.4 PayPal or credit card billing information;

2.1.5 contacts you choose to submit;

2.1.6 profile photo;

2.1.7 username;

2.1.8 location;

2.1.9 your preferences;

2.1.10 submissions to various competitions and promotions;

2.1.11 responses to surveys;

2.1.12 communications sent to us by you;

2.1.13 your subscriptions to newsletters and services offered by us; and

2.1.14 any other information you submit to FanDuel when choosing to participate
in various activities on the Services.

2.2 In addition to the above, we may need to verify your identity in order for
you to use some aspects of the Services. For purposes of verification, we may
also collect the following personal information from you (for compliance
reasons, provision of this information, when requested, is a mandatory condition
of using our Services):

2.2.1 passport information;

2.2.2 driving license information;

2.2.3 other identification documents;

2.2.4 permanent and temporary address;

2.2.5 tax-related information; and

2.2.6 other information as may be required to verify you in accordance with
applicable laws and regulations.

2.3 When you use our mobile apps, we also may collect mobile device information
like operating system and hardware type, numbers or codes that are unique to
your particular device (such as IDFA or an Android Ad ID), device information,
default device language, the location of your device (at a GPS level), and app
usage information. This data also may be linked to your other information,
including your location data.

2.4 In addition, if you choose to log in, access or otherwise connect to
FanDuel, or contact FanDuel, through a social networking service (such as
Facebook), we may collect your user ID and user name associated with that social
networking service, as well as any information you make public using that social
networking service. We may also collect information you have authorized the
social networking service to share with us (such as your user ID, public profile
information, email address, birthday, friends list, and pages you have "liked").

2.5 Cookies Information: When you visit the FanDuel.com website or the
fanduel.com/faceoff website, we may send one or more cookies - small files - to
your computer or other device, which may enable us or others to uniquely
identify your browser. FanDuel uses both session cookies and persistent cookies.
A persistent cookie remains after you close your browser. Persistent cookies may
be used by your browser on subsequent visits to the Sites. Persistent cookies
can be removed by following your web browser help file directions. Session
cookies are temporary and typically disappear after you close your browser. You
may be able to reset your web browser to refuse all cookies or to indicate when
a cookie is being sent. However, some features of the Site or Service may not
function properly if the ability to accept cookies is disabled.

2.6 Log File Information: When you use our Service, our servers may
automatically record certain information that your device sends whenever you
visit any website and use certain apps. These server logs may include
information such as your web or app request, Internet Protocol ("IP") address,
browser type, browser language, referring/exit pages and URLs, platform type,
number of clicks, domain names, landing pages, pages viewed and the order of
those pages, the amount of time spent on particular pages, the date and time of
your request, and one or more cookies that may uniquely identify your browser.

2.7 Clear GIFs Information: When you use our Services, we may employ technology
such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online
usage patterns of our users. In addition, we may also use clear GIFs in
HTML-based emails sent to our users to track which emails are opened by specific
users.

2.8 FanDuel may also collect information about you from third parties, such as
marketing partners, identity verification services, anti-fraud services and
other service providers.


3. THE WAY FANDUEL USES YOUR PERSONAL INFORMATION

3.1 We use your personal information to operate, maintain, and provide to you
the features and functionality of the Services, including but not limited to the
following:

3.1.1 providing you with our products and services, including our games;

3.1.2 processing and responding to enquiries;

3.1.3 personalizing your use of the Services,

3.1.4 alerting you to new features, special events, products and services, or
certain third-party products or services in which we think you will be
interested;

3.1.5 enforcing the legal terms that govern your use of the Service; and

3.1.6 investigating and protecting the integrity of FanDuel’s contests.

3.2 We may use your information (both personal and non-personal information) to
send you marketing and advertising content, including sending you advertising
through multiple channels, such as direct mail, email, push notifications and
display media. We may send you advertising or content regarding our products and
services, or products and services that we market on behalf of another company,
such as a sports team, a sports venue, or other entity.

3.3 We may use your information to communicate with you about:

3.3.1 our products and services in which you may be interested provided that you
have not requested otherwise;

3.3.2 newsletters and information for which you have signed up; and

3.3.3 non-marketing or administrative purposes (such as notifying you of major
changes to the Service or for customer service purposes).

3.3 We use your information to improve the quality and design of our Service and
to create new features, promotions, functionality, and services such as by
storing, tracking, and analyzing user preferences and trends.

3.4 We also use cookies, clear gifs, log file information, and mobile app
information such as device identifiers for purposes such as (a) remembering
information so that you will not have to re-enter it during your visit or the
next time you visit our Service; (b) providing custom, personalized content and
information; (c) monitoring the effectiveness of our marketing campaigns; (d)
monitoring aggregate metrics such as total number of visitors, pages viewed,
etc.; and (e) tracking your entries, submissions, and status in promotions,
sweepstakes, and contests. You can learn more about how these technologies are
used in the Section below, Third Party Advertising and Analytics.

3.5 We may anonymize, de-identify, or aggregate your information for any
legitimate business purposes, including for reporting and research, or
advertising. Such anonymized and/or aggregated data does not personally identify
you. Sometimes, this information may be used to target more relevant content or
offers to you across different devices – for instance, we may provide you with
offers and content on your mobile device, based on your web-based activity.

3.6 We will retain personal information as long as necessary to fulfill these
purposes unless the law requires us to keep it for a longer period of time. To
provide security and business continuity for the activities described here, we
make backups of certain data, which we may retain for longer than the original
data.


4. WHEN FANDUEL DISCLOSES INFORMATION

4.1 We may disclose the information we collect or receive from you to our
subsidiaries, affiliated companies, agents, or other businesses, or service
providers who process your information on our behalf in order to provide or
operate the Service. For instance, these entities may have access to your
information for purposes including (but not limited to) billing and accounting,
hosting, marketing, promotional and email services, customer and technical
support, and for the purpose of accepting deposits and paying withdrawals and
processing such information on our behalf, and in each case, may use the
information to make improvements to the services they provide to us. Our
agreements with these service providers limit the kinds of information they can
use or process and require them to use reasonable efforts to keep your personal
information secure.

4.2 When you choose to share information with social media services about your
activities on FanDuel by, for example, connecting your social media account to
our Services, then FanDuel may share your personal information and information
about your use of the Services with such social media sites. Please make sure to
read the terms and privacy statements of such sites prior to connecting to our
Services in this way.

4.3 In the event that you win a prize we may use your personal information (such
as your name and photo) in connection with publicity purposes.

4.4 In the event that you win a promotion run by us we may be required to either
publish or make available upon request your name and county in accordance with
applicable legislation.

4.5 We may publish a profile page that includes your username, the date you
became a member, your stats from previous contests and, if you uploaded one,
your profile picture. Where you post personal information about yourself through
our Services to public areas of our Services, you acknowledge and agree that
this personal information will be publicly available.

4.6 When you participate in a contest or skill game, we may publish your
username on a list of the contest or skill game participants, along with a link
to your profile page.

4.7 Where you have provided your consent, we may share your personal information
with selected third parties for their commercial or marketing use in conjunction
with your relationship with FanDuel or as part of a specific program or feature.

4.8 In addition, we may disclose to third parties various types of your
information for targeted online or mobile advertising, as further described in
the Section titled “Third Party Advertising and Analytics.”

4.9 We also may share personal information in other situations with your
consent.

4.10 FanDuel also reserves the right to disclose personal information that
FanDuel believes, in good faith, is appropriate or necessary to enforce our
Terms of Use, take precautions against liability or harm, to investigate and
respond to third-party claims or allegations, to respond to court orders or
official requests, to comply with state and federal regulations, including but
not limited to sharing with appropriate tax authorities, to protect the security
or integrity of our Services, to report violations of FanDuel’s eligibility
rules to third parties, including employers of individuals affiliated with other
daily fantasy sites, and to protect the rights, property, or safety of FanDuel,
our users or others.

4.11 In the event that FanDuel is involved in a merger, acquisition, sale,
bankruptcy, insolvency, reorganization, receivership, assignment for the benefit
of creditors, or the application of laws or equitable principles affecting
creditors' rights generally, or other change of control, there may be a
disclosure of your personal information to another entity related to such event.

4.12 Recipients of the data disclosures described in this Privacy Policy are
located in the United States and elsewhere in the world, including where privacy
laws may not provide as much protection as your country.


5. LEGAL BASES FOR PROCESSING PERSONAL DATA

5.1Some laws require companies to tell you about the legal grounds they rely on
to process your personal information. To the extent those laws apply, we process
your personal information:

5.1.1 Legitimate interests: In many cases, we handle personal data on the ground
that it furthers our legitimate interests’ in commercial activities such as the
following in ways that are not overridden by the interests or fundamental rights
and freedoms of the affected individuals:

(a) Customer service

(b) Marketing

(c) Protecting our players, personnel and property

(d) Analyzing and improving our business

(e) Processing job applications

(f) Managing legal issues

5.1.2 We may also process personal data for the legitimate interests of our
affiliates or business partners, such as to offer special events or contests or
assist with marketing.

5.1.3 Processing for the contract: Some of our processing of personal data is to
meet our contractual obligations with our players.

5.1.4 Consent: Where required by law, and in some other cases, we handle
personal data on the basis of your implied or express consent.

5.1.5 Legal compliance: We need to use and disclose personal data in certain
ways to comply with our legal obligations.


6. YOUR CHOICES

6.1 FanDuel will process your personal information in accordance with this
Privacy Policy, and as part of that FanDuel provides you with certain choices
about how we process your personal information. These choices are set out below.

6.2 You can access and update certain personal information FanDuel holds about
you at any time by logging into your account via the Services. You can update
your marketing preferences and whether or not you would like us to send you
newsletters in your account. You can also unsubscribe to marketing emails and
newsletters by using the 'unsubscribe' feature in the communication.

6.3 We may occasionally send display media to you, in a targeted way, whether
through web or mobile browsers or mobile applications. You may opt out of many
third parties that support and send this type of targeting advertising by going
to www.aboutads.info, and you may learn more about this type of advertising in
the below Section titled “Third Party Advertising and Analytics.” You may opt
out of tracking for mobile advertising through the settings on most smartphones,
and you may learn more about these settings through those mobile device
platforms, i.e., Google (here) and Apple (here). (Please note that these
companies may change either the way these settings operate, the content or the
availability of these pages.)

6.4 We may occasionally send you push notifications to your mobile device. You
can turn off certain push notifications in the account settings of your FanDuel
mobile app. You can also turn off push notifications specific to our Services in
the settings on your iOS device, or through the application manager in your
Android device.

6.5 Subject to some important legal limitations, users in Canada can contact us
as described below to make additional requests, such as to request access to,
correction or deletion of certain personal information we store; to receive a
copy of certain personal information they provided to us in portable form or to
request that we share it with a third party; to request restrictions on the use
of their personal information; to object to our use of their personal
information; or to withdraw consent to use their personal information (which
will not affect the legality of any processing that happened before the request
takes effect).

6.6 For example, Canadian users can contact us to opt out of all processing of
their personal information for direct marketing purposes (in addition to the
unsubscribe option described here).

6.7 Can reach us as described below with any other concerns, requests or
complaints regarding our data collection, data use or data transfer. You also
have a right to file a privacy complaint with the relevant privacy regulator,
but we respectfully invite you to allow us to try to resolve the matter
directly. We will attempt to answer your questions and satisfy your concerns in
a timely and complete manner.


7. ADVERTISING AND ANALYTICS

7.1 We work with a number of companies that assist in marketing our services to
you on third party websites. These companies may collect information about
online activities conducted on a particular computer, browser or device over
time and across third-party websites or online services for the purpose of
delivering advertising that is likely to be of greater interest to you,
including about our Services, on sites and apps of third parties. Also, certain
ads appearing on our Services are delivered by our advertising partners. Our
advertising partners may use cookies and other similar technologies, often in
conjunction with unique (anonymous) cookie identifiers, to collect data about
your activities and interests, including the technologies described above. Some
of these partners may use mobile device identifiers, such as Apple IDFAs and
Google/Android Advertising IDs. Doing this allows the ad companies to recognize
your computer or device each time they send you an online or mobile
advertisement. In this way, the ad companies may compile information about where
you, or others who are using your computer or device, saw their advertisements
and measure your interaction with each ad. This information allows ad companies
to deliver targeted advertisements that may be of increased interest to you,
both on our Services and elsewhere online. Just as these technologies may be
used to target ads on our websites and apps, we, or our advertising partners,
may use these same technologies and data points (e.g., mobile identifiers,
cookie identifiers, location-based data), through our Services or through other
services, to target advertising (for ourselves or other companies) on other
sites or mobile apps. Sometimes, these identifiers may be derived from a hashed
or encrypted version of personal information such as your email address. We may
use this information to measure the performance of our advertising as well, for
instance, to evaluate which ads or content our users prefer, or which are most
effective. In addition, sometimes we or an advertising partner may tailor
advertising to you across different devices.

7.2 To learn more and to opt out of the collection of data on our website by
third parties (including those described above) for interest-based advertising
purposes, please visit www.aboutads.info/choices or www.youronlinechoices.com.
Note that because this opt out method may be cookie-based, you will need to opt
out again if you update or change your browser, or delete your cookies. You can
also control interest-based advertising on apps on your mobile device with the
AppChoices app, available for iOS and Android. Note that opting out will not
affect the quantity of ads you see online but likely will cause the ads to be
less relevant to you.

7.3 We also that we also work with third-party analytics companies to collect
data on our Service through cookies and other automated means. In some cases,
the third parties mentioned in this section may maintain the information they
collect in personally identifiable form. These services allow us to view a
variety of reports about how visitors interact with the Services so we can
improve our website and understand how people find and navigate it.


8. INFORMATION SECURITY

8.1 We are committed to protecting the security of your personal information. We
use a variety of security technologies and procedures to help protect your
personal information from unauthorized access, use, or disclosure.

8.2 Whilst neither we, nor any other organization, can guarantee the security of
information processed online, we do have appropriate security measures in place
to protect your personal information. For example, we store the personal
information you provide on computer systems with limited access that are located
in facilities to which access is limited.

8.3 To further protect your privacy and security, we reserve the right to take
reasonable steps (such as requesting your password) to verify your identity
before granting you profile access or making corrections.

8.4 Additionally, you should ensure your password is kept secret at all times.
You will be responsible for maintaining the secrecy of your password and account
information.


9. STATE-SPECIFIC PRIVACY RIGHTS

9.1 Shine the Light Disclosures. If you reside in California, you may request
certain general information regarding our disclosure of personal information
during the preceding year to third parties for their direct marketing purposes.
To make such a request, please write to us at the following address:

FanDuel Inc
300 Park Avenue South, 14th Fl.
New York, NY 10005.

9.2 California Consumer Privacy Act. If you are a California resident,
California law requires us to provide you with some additional information
regarding how we collect, use, and share your “personal information” (as defined
in the California Consumer Privacy Act (“CCPA”)).

Categories of personal information we collect. Throughout this Privacy Policy,
we discuss in detail the specific pieces of personal information we collect from
and about users. Under the CCPA, we are also required to provide you with the
“categories” of personal information we collect. The categories we may collect
are: identifiers (such as name, address, email address, driver’s license);
commercial information (such as deposit or contest entry data); financial data
(such as payment information); internet or other network or device activity
(such as browsing history or Services usage); geolocation information (e.g.,
your city and state based on IP address); professional or employment related
data (e.g., as part of your profile); audio information (e.g., if you
participate in a customer support call and do not opt out of call recording); in
certain circumstances, information used to manage potential fraud or legal risk
(such as employment status and criminal history); inference data about you; and
other information that identifies or can be reasonably associated with you.

How we use and disclose these categories of personal information. We use and
disclose the categories of personal information we collect from and about you
consistent with the various business purposes we discuss throughout this Policy,
and how you engage with the Services. Please see the relevant section(s) above
for more information.

9.3 Your California Privacy Rights

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to
make certain requests about your personal information. Specifically, the CCPA
allows you to request:

 * Information about the categories of personal information we collect or
   disclose about you; the categories of sources of such information; the
   business or commercial purpose for collecting your personal information; and
   the categories of third parties with whom we share/disclose personal
   information. Such information is also set forth in this Privacy Policy.
 * Provide access to and/or a copy of certain information we hold about you.
 * Delete certain information we have about you.
 * Provide you with information about the financial incentives that we offer to
   you, if any.

The CCPA further provides you with the right to not be discriminated against (as
provided for in applicable law) for exercising your rights.

We will consider all requests and provide our response within the time period
stated by applicable law. Please note, however, that certain information may be
exempt from such requests in some circumstances, which may include if we need to
keep processing your information or to comply with a legal obligation. We will
let you know where this is the case or if certain rights don’t apply in your
country or state of residence. We also will take reasonable steps to verify your
identity before responding to a request, which might include, at a minimum,
depending on the sensitivity of the information you are requesting and the type
of request you are making, verifying your name, email address, and date of
birth. You are also permitted to designate an authorized agent to submit certain
requests on your behalf. In order for an authorized agent to be verified, you
must provide the authorized agent with signed, written permission to make such
request or a power of attorney. We may also follow up with you to verify your
identity before processing the authorized agent’s request.

Additionally, exercising your deletion right may mean that you may no longer be
able to use the Services.

If you would like further information regarding your legal rights under
California law or would like to exercise any of them, please contact us at
800-475-2250 or via our web form here.



9.4 Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information.
California law broadly defines “sale” in a way that includes when we share your
information with third parties, such as sports leagues or teams, to provide you
with offers and promotions that we believe may be of interest to you. It also
may include allowing third parties to receive certain information, such as
cookies IP address and/ or browsing behavior, to deliver targeted advertising on
the Services or other services. Advertising, including targeted advertising,
enables us to provide you certain content for free and allows us to provide you
offers relevant to you.

Depending on what Services you use, we may provide the following categories of
information to third parties for these purposes:

 * For online targeted advertising purposes: demographic and statistical
   information, user-generated content, device information and identifiers,
   connection and usage data, geolocation, and social media information.
 * For sharing with third parties to send you relevant offers and promotions:
   contact and account registration information; demographic and statistical
   information, user-generated content, and geolocation.

If you would like to opt out of our use of your information for such purposes
that are considered a “sale” under California law, you may do so as outlined on
the following page: Do Not Sell My Personal Information. You can also submit a
sale opt-out request by emailing us at support@fanduel.com. Please note that we
do not knowingly sell the personal information of minors under 16 years of age
without legally-required affirmative authorization.




10. CHANGES AND UPDATES

10.1 This Privacy Policy may be revised periodically and this will be reflected
by the "Last update posted" date above. Please revisit this page to stay aware
of any changes. If a revision to this Privacy Policy, in our sole discretion, is
material, we will notify you by contacting you through the email address
associated with your account.

10.2 Contact Information: Please contact FanDuel with any questions or comments
about this Privacy Policy by emailing privacy@fanduel.com.

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