Privacy Policy

Last Updated: 2025-10-26

1. Introduction

Anterl, Inc. ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and safeguard your information when you use our sports betting analytics platform and services ("Services").

This Privacy Policy applies globally and complies with:

• EU General Data Protection Regulation (GDPR)
• US privacy laws (CCPA, COPPA, state-specific regulations)
• APAC privacy legislation (PDPA, Privacy Act, APPI)
• Other applicable international privacy laws

Contact Information:

• Data Controller: Anterl, Inc., a Delaware corporation, 1111B S Governors Ave STE 40992, Dover, DE 19904, United States
• Privacy Contact: Use our contact form at anterly.com/contact-us (select "Privacy Rights")
• Data Protection Inquiries: Use contact form with "Data Protection" category

2. Information We Collect

2.1 Information You Provide Directly

Account Information (via Clerk):

• Name and email address
• Authentication credentials
• Profile preferences
• Communication preferences

Payment Information (via Stripe):

• Billing address
• Payment method details (processed by Stripe, not stored by us)
• Transaction history

User Communications:

• Contact form submissions including name, email, inquiry category, message content, and optional attachments
• Support inquiries and correspondence (via forms, email, or other channels)
• Feedback and survey responses
• User-generated content (if applicable)
• Communications through third-party platforms (such as Telegram for premium features)
• Customer support interactions across various channels
• File attachments and screenshots submitted for support purposes

2.2 Information Collected Automatically

Technical Data:

• IP address and geolocation data
• Device information (type, operating system, browser)
• Usage patterns and interaction data
• Session duration and frequency of visits
• Security verification data from Cloudflare Turnstile (challenge tokens and verification status)
• Form submission metadata (timestamp, user agent, page URL)

Analytics Data (via PostHog):

• Page views and navigation patterns
• Feature usage statistics
• Performance metrics
• User behavior insights (anonymized)

Cookie and Tracking Data:

• Essential cookies for basic service functionality and fraud prevention
• Preference (functional) cookies for user experience
• Analytics cookies for performance measurement
• Bot protection and anti-spam verification tokens

2.3 Information from Third Parties

Authentication Providers:

• Social media profile information (if you choose social login)
• Public profile data as permitted by your social media settings

Service Providers:

• Fraud prevention data
• Security monitoring information
• Payment verification data
• Bot protection verification from Cloudflare Turnstile

3. How We Use Your Information

3.1 Primary Purposes

Service Provision:

• Account creation and management
• Authentication and security
• Processing payments and subscriptions
• Providing customer support and processing contact form inquiries
• Delivering requested services and features
• Bot protection and spam prevention

Legal Basis (GDPR): Performance of contract, legitimate interests

Service Improvement:

• Analyzing usage patterns to enhance user experience
• Developing new features and functionality
• Conducting research and analytics
• Optimizing platform performance

Legal Basis (GDPR): Legitimate interests, consent where required

3.2 Communications

Service Communications:

• Account notifications and updates
• Security alerts and important notices
• Service announcements and changes
• Customer support responses via multiple channels
• Mobile app notifications (when available)
• Third-party platform notifications (such as Telegram alerts for premium users)

Legal Basis (GDPR): Performance of contract, legal obligation

Marketing Communications (with consent):

• Product updates and new feature announcements
• Educational content about sports betting analytics
• Special offers and promotions
• Newsletter and blog updates
• Personalized recommendations for registered users
• Custom alerts and notifications based on user preferences

Legal Basis (GDPR): Consent (you can withdraw anytime)

3.3 Legal and Security Purposes

Compliance and Safety:

• Complying with legal obligations
• Preventing fraud and abuse
• Enforcing our Terms of Service
• Protecting user safety and platform integrity
• Age verification and responsible gambling measures
• Geographic compliance and access restrictions
• User behavior analysis for registered users (security purposes)
• Bot detection and spam prevention through security verification systems

Legal Basis (GDPR): Legal obligation, legitimate interests

4. Data Sharing and Disclosure

4.1 Service Providers

We share information with trusted third-party service providers who assist in delivering our Services:

Authentication and Identity:

• Clerk: Account management and authentication
• Purpose: User registration, login, account security
• Data Shared: Name, email, authentication tokens

Payment Processing:

• Stripe: Payment and billing services
• Purpose: Processing subscriptions and payments
• Data Shared: Billing information, payment details

Analytics and Performance:

• PostHog (EU-hosted): Website analytics and user insights
• Purpose: Service improvement and performance monitoring
• Data Shared: Usage data, behavioral analytics (anonymized)

Security and Bot Protection:

• Cloudflare Turnstile: Anti-bot and spam protection
• Purpose: Protecting contact forms and preventing automated abuse
• Data Shared: Challenge verification tokens, IP addresses, browser fingerprints

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Respond to legal process (subpoenas, court orders)
• Comply with regulatory requirements
• Protect our rights and interests
• Prevent fraud or illegal activities
• Ensure user safety

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their commercial purposes.

5. International Data Transfers

5.1 Cross-Border Processing

Your data may be processed in countries outside your residence, including:

• EU/EEA: PostHog analytics (EU-hosted)
• United States: Clerk authentication, Stripe payments
• Other jurisdictions: As required for service delivery

5.2 Transfer Safeguards

For EU Users:

• Standard Contractual Clauses (SCCs) for transfers outside EU/EEA
• Adequacy decisions where applicable
• Additional safeguards as required by GDPR
• Cloudflare Turnstile operates under Cloudflare's DPA and EU data processing commitments

For All Users:

• Contractual data protection requirements
• Security and privacy commitments from service providers
• Regular compliance monitoring

6. Data Retention

6.1 Retention Periods

Account Data: Retained while your account is active and for legitimate business purposes after closure

Payment Data: Retained as required for billing, tax, and legal compliance (typically 7 years)

Analytics Data: Retained for 24 months for service improvement purposes

Communications: Retained as needed for customer support and legal compliance

Contact Form Data: Retained for 2 years after inquiry resolution to ensure quality customer service and comply with legal obligations

Security Verification Data: Turnstile tokens are not stored; only verification success/failure status is logged temporarily for security monitoring

6.2 Data Deletion

Automatic Deletion:

• Session data expires automatically
• Temporary files are regularly purged
• Analytics data is anonymized over time

User-Requested Deletion:

• You may request account deletion at any time
• We will delete your data subject to legal retention requirements
• Some data may be retained in anonymized form for analytics

7. Your Privacy Rights

7.1 Universal Rights

Access: Request a copy of your personal data Correction: Update or correct inaccurate information Deletion: Request deletion of your personal data Portability: Receive your data in a machine-readable format Objection: Object to processing based on legitimate interests Restriction: Limit how we process your data

7.2 Regional-Specific Rights

EU/EEA Users (GDPR):

• Right to withdraw consent
• Right to lodge a complaint with supervisory authorities
• Right to object to automated decision-making

California Users (CCPA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale (not applicable as we don't sell data)
• Right to non-discrimination

Other Jurisdictions:

• Rights as provided under applicable local privacy laws

7.3 Exercising Your Rights

To exercise your privacy rights:

• Use our contact form at anterly.com/contact-us (select "Privacy Rights" category)
• Use your account settings to update preferences
• For formal data protection requests, use contact form with "Data Protection" category

Response Time: We will respond within the timeframes required by applicable law (typically 30 days for GDPR, 45 days for CCPA).

8. Data Security

8.1 Security Measures

Technical Safeguards:

• Encryption in transit and at rest
• Secure authentication and access controls
• Regular security monitoring and updates
• Vulnerability assessments and penetration testing
• Bot protection and CAPTCHA systems to prevent automated abuse
• Rate limiting and anti-spam measures on contact forms

Organizational Safeguards:

• Employee training on data protection
• Access controls and need-to-know basis
• Data processing agreements with service providers
• Incident response procedures

8.2 Security Limitations

While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security against all potential threats.

Your Responsibilities:

• Keep your account credentials secure
• Report suspected security incidents
• Use strong passwords and enable two-factor authentication

9. Children's Privacy

9.1 Age Restrictions

Our Services are not intended for individuals under 18 years old (or 21 in certain jurisdictions). We do not knowingly collect personal information from children.

9.2 COPPA Compliance (US)

If we discover we have collected information from a child under 13, we will:

• Delete the information immediately
• Notify parents/guardians if identifiable
• Implement additional safeguards to prevent future collection

9.3 EU

We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.

9.4 Parental Rights

Parents/guardians may contact us to:

• Review their child's information
• Request deletion of their child's data
• Refuse further collection of their child's information

10. Cookies and Tracking

10.1 Cookie Types

Essential Cookies: Required for service functionality Analytics Cookies: Help us understand how you use our Services Preference Cookies: Remember your settings and preferences Security Cookies: Protect against fraud and abuse

10.2 Cookie Management

Your Choices:

• Manage cookie preferences through our cookie banner
• Adjust browser settings to block or delete cookies
• Opt-out of analytics tracking

Note: Disabling essential cookies may impact service functionality. Security verification systems like Turnstile are essential for platform protection and cannot be disabled.

10.3 Do Not Track

We honor Global Privacy Control (GPC) signals and similar user preference indicators where technically feasible.

11. Marketing and Communications

11.1 Marketing Preferences

Opt-In Basis: We only send marketing communications with your explicit consent

Types of Communications:

• Product updates and announcements
• Educational content about sports betting analytics
• Special offers and promotions
• Company news and blog updates

11.2 Unsubscribe Options

You can opt-out at any time:

• Click unsubscribe links in emails
• Update preferences in your account settings
• Use our contact form at anterly.com/contact-us (select "Privacy Rights")

Note: You cannot opt-out of essential service communications.

12. Data Breach Notification

12.1 Our Commitments

In the event of a data breach, we will:

• Contain and investigate the incident
• Notify relevant authorities as required by law
• Inform affected users without undue delay
• Provide clear information about the breach and our response

12.2 User Responsibilities

If you suspect a security incident:

• Change your account passwords immediately
• Contact us at anterly.com/contact-us selecting Security Issue topic
• Monitor your accounts for suspicious activity

13. Third-Party Services

13.1 External Links

Our Services may contain links to external websites and services. This Privacy Policy does not apply to third-party sites. We encourage you to review their privacy policies.

13.2 Cloudflare Turnstile Integration

Purpose: We use Cloudflare Turnstile for bot protection and spam prevention on our contact forms.

Data Processing: Turnstile processes browser information and challenge responses to verify human users without compromising privacy.

Privacy Protection: Turnstile is designed as a privacy-preserving alternative to traditional CAPTCHAs, minimizing data collection while maintaining security.

Cloudflare's Privacy Policy: For details on how Cloudflare processes data, please review Cloudflare's Privacy Policy at https://www.cloudflare.com/privacypolicy/

13.3 Social Media Integration

If you use social media features:

• Your interactions may be governed by the social media platform's privacy policy
• Information may be shared with your social network
• We may receive limited profile information as permitted by your settings

14. Privacy Policy Updates

14.1 Changes and Notifications

We may update this Privacy Policy to:

• Reflect changes in our Services
• Comply with new legal requirements
• Improve clarity and transparency

We will notify you of material changes:

• Email notification to registered users
• Prominent notice on our platform
• Updated "Last Modified" date

14.2 Continued Use

Your continued use of our Services after policy updates constitutes acceptance of the revised Privacy Policy.

15. Regional Privacy Information

15.1 European Union

Supervisory Authority: You may lodge complaints with your local data protection authority Legal Basis: We process data based on contract performance, legitimate interests, legal obligations, and consent

15.2 United States

State-Specific Rights: Additional rights may apply under state privacy laws (California, Virginia, Colorado, etc.) COPPA Compliance: Special protections for children under 13 Sector-Specific Laws: Compliance with applicable federal and state regulations

15.3 Asia-Pacific

Local Compliance: We comply with PDPA (Singapore, Thailand), Privacy Act (Australia), APPI (Japan), and other regional laws Data Localization: Where required, data is processed within local jurisdictions Cross-Border Transfers: Conducted with appropriate safeguards Service Availability: Our services may be restricted in certain APAC jurisdictions based on local laws and regulations

16. Contact Information

16.1 Privacy Inquiries

General Privacy Questions:

• Contact Form: anterly.com/contact-us (select "Privacy Rights")
• Response Time: Within 30 business days

Data Protection:

• Contact Form: anterly.com/contact-us (select "Data Protection")
• Response Time: Within 30 business days

Company Address: Anterl, Inc. 1111B S Governors Ave STE 40992 Dover, DE 19904 United States

16.2 Regulatory Contacts

EU Supervisory Authorities: [Links to relevant data protection authorities] US State Agencies: [Links to relevant consumer protection agencies] APAC Regulators: [Links to relevant privacy commissioners]

By using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein, subject to your rights under applicable law.