Privacy Policy

Effective date: June 1, 2025. This is a pre-launch draft. Final policy will be reviewed by counsel prior to public launch. Nothing herein constitutes legal advice.

Newthos LLC (“we,” “us,” or “our”) operates Spurts (“the Service”). This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices you have. By using the Service, you agree to the practices described here.

1. Information We Collect

Information you provide directly:

• Account registration data: email address, username, and password.
• Optional profile information: display name, avatar, bio, city, state, birth month and day, Twitter/X handle, Reddit handle, and theme preference.
• Your date of birth, used to verify that you are 18 or older. We store your date of birth and the time you confirmed your age.
• Identity-verification status. Where identity verification is required (for example, to become a Team Owner or to receive a prize), it is performed by a third-party verification provider. Any government-issued ID or partial Social Security number you submit is handled by that provider — we store only the result (verified, pending, or failed), not your ID images or SSN.
• Answers you submit on daily Sheets.
• Trash talk posts and other content you create on the Service.
• Payment information submitted during membership purchase or Team Owner buy-in (processed by our payment processor — we do not store full card numbers).
• Communications you send to us.

Information generated by your use of the Service:

• Spurt and Sheet history, results, and points data.
• Challenge records: who you challenged, outcomes, wager amounts.
• Leaderboard standing and season-specific stats.
• Poll votes and editorial reactions (emoji).
• Log data: IP address, browser type, device information, pages visited, timestamps.
• Session and authentication cookies managed through Supabase.

2. How We Use Your Information

We use the information we collect to:

• Create and manage your account and authenticate your sessions.
• Record, grade, and display picks, results, and standings.
• Process and settle challenges and point wagers.
• Process membership payments and manage subscription status.
• Display your public profile and stats to other players.
• Send transactional communications (account confirmation, password reset, etc.).
• Monitor for fraud, abuse, and violations of our Terms of Service and Fair & Competitive Play Policy.
• Improve the Service, fix bugs, and analyze usage patterns.
• Comply with applicable legal obligations.

3. What Other Players Can See

The following information is visible to other users of the Service by default:

• Your username, display name, and avatar.
• Your leaderboard rank, total points, and season standings.
• Your Spurts record (correct, incorrect, accuracy) and per-game-mode stats.
• Your challenge history (win/loss, wager amounts, Top Dog history).
• Your Free Agent status and, once Teams are live, your team membership and roster.
• Your public bio, city, state, and social handles (if provided).
• Trash talk posts you submit to the leaderboard board.

Your email address, password, payment information, and internal account identifiers are never visible to other users. Offer sheets you send or receive — including their terms — are visible only to you and the other party (the Team Owner and the Free Agent), not to the public.

4. Service Providers and Data Sharing

We do not sell your personal information. We share information only with the following categories of third-party service providers who assist us in operating the Service, and only to the extent necessary for those purposes:

• Database and authentication (Supabase): Your account data, picks, results, and all in-game records are stored in a Supabase-managed database. Supabase is a US-based infrastructure provider subject to data processing agreements.
• Payment processing (Square): Membership payments are handled by Square Inc. Square collects and processes payment card information directly and is subject to its own privacy policy and PCI-DSS compliance standards. We receive confirmation of payment status but do not store full card numbers.
• Hosting and infrastructure: The Service runs on cloud hosting infrastructure. Server logs and technical data may be processed by those providers.

We may also disclose information if required by law, court order, or government request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. Cookies and Tracking

We use cookies and similar technologies primarily to maintain your authenticated session. Session cookies are required for the Service to function; they are not optional if you choose to create an account. We do not use third-party advertising cookies. We may use basic analytics to understand usage patterns, but we do not sell or share analytics data that identifies individual users.

6. Data Retention

We retain your account data for as long as your account is active. Pick history, results, and leaderboard records are retained indefinitely as part of the game's historical record. If you delete your account, we will remove your personal identifiers (email, name, bio, social handles) within a reasonable period, but anonymized or aggregated game records may be retained.

We may retain certain records longer if required by law or to resolve disputes.

7. Your Choices and Rights

Profile updates: You can update your display name, avatar, bio, and optional profile fields at any time through your Profile settings.

Account deletion: You may request deletion of your account by contacting us. We will remove your personal information subject to the retention limitations described above.

California residents (CCPA): If you are a California resident, you have the right to know what personal information we have collected about you, request deletion of your personal information, and opt out of the sale of your personal information (we do not sell personal information). To exercise these rights, contact us using the information below.

Other jurisdictions: If applicable law in your jurisdiction grants you additional privacy rights (such as GDPR rights of access, correction, portability, or erasure), you may contact us to exercise those rights.

8. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If we learn that we have collected information from a minor, we will delete that information promptly. If you believe a minor has registered, please contact us immediately.

9. Security

We implement reasonable technical and organizational measures to protect your information from unauthorized access, alteration, disclosure, or destruction. However, no internet transmission or storage system is completely secure. We cannot guarantee the absolute security of your information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date above. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy. If we make material changes that affect how we handle data you have already provided, we will make reasonable efforts to notify you.

11. Communications Consent

This section is the Spurts Communications Consent Policy. When you create an account, or when prompted as an existing user, we ask you to consent to our processing of your data as described in this Privacy Policy and to our communicating with you. Your consent — including the date, time, and source (URL, IP address, and device/browser) of that consent — is recorded for compliance purposes.

What you consent to:

• Service & transactional messages (required while your account is active): account confirmation, password resets, security and login alerts, challenge and Top Dog notifications, payment and membership receipts, and important changes to our policies or the Service.
• Product & community updates: news about new seasons, features, leaderboard events, and occasional promotional messages about Spurts.
• Channels: we may reach you by email, in-app notification, and — only if you choose to provide a phone number — SMS text message. Message and data rates may apply to SMS; message frequency varies.

Your control: You can opt out of non-essential product and promotional communications at any time using the unsubscribe link in an email, by replying STOP to an SMS, or by contacting us. Service and transactional messages are necessary to operate your account and cannot be opted out of while your account remains active. Withdrawing consent to essential processing or communications may require closing your account.

We do not sell your contact information, and we do not share it with third parties for their own marketing. See Section 4 for the limited service providers who process data on our behalf.

12. Contact

Questions about this Privacy Policy or your personal data? Contact Newthos LLC at privacy@spurts.app or through the contact information provided on our website.