Boro Marble League

⚠ PLACEHOLDER — This privacy policy must be reviewed by qualified privacy law counsel (including CCPA, CAN-SPAM, and applicable state law specialists) before publication. Data processing descriptions are illustrative only.

1. Overview

[PLACEHOLDER] Boro Marble League LLC (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Boro Marble League Platform.

2. Information We Collect

Information You Provide

[PLACEHOLDER] We collect information you provide directly to us, including:

Account registration information (name, email address, date of birth, state of residence);
Identity verification documents (when required for KYC/age verification);
Payment information (processed by third-party payment processors — we do not store full card numbers);
Communications you send to our support team;
Mail-in AMOE entries including name, address, and email.

Information Collected Automatically

[PLACEHOLDER] When you access the Platform, we automatically collect:

Device information (IP address, browser type, operating system);
Usage data (pages visited, time spent, features used);
Cookies and similar tracking technologies (see Section 5).

Geolocation

[PLACEHOLDER] We may collect approximate location data (derived from IP address) to enforce geographic restrictions. We do not collect precise GPS location without your explicit consent.

3. How We Use Information

[PLACEHOLDER] We use your information to:

Operate and improve the Platform;
Process sweepstakes entries and prize redemptions;
Verify your identity and age;
Enforce our Terms of Service and prevent fraud;
Comply with legal obligations (including AML/KYC requirements);
Send transactional communications and promotional offers (with your consent);
Respond to your inquiries and provide customer support.

[PLACEHOLDER] We do not sell your personal information to third parties. We may share your information with:

Service providers who assist us in operating the Platform (payment processors, identity verification providers, analytics providers);
Legal authorities when required by law, court order, or to protect the safety of our users;
Business transfers in connection with a merger, acquisition, or sale of assets.

5. Cookies & Tracking Technologies

[PLACEHOLDER] We use cookies, web beacons, and similar technologies to enhance your experience and for analytics. [ATTORNEY TO REVIEW COOKIE CONSENT REQUIREMENTS UNDER CCPA AND APPLICABLE STATE LAWS]. You may manage cookie preferences through your browser settings, though disabling certain cookies may affect Platform functionality.

6. Data Retention

[PLACEHOLDER — ATTORNEY TO SET RETENTION PERIODS] We retain your personal information for as long as your account is active or as needed to provide services. We retain transaction records and identity verification data for [X years] as required by applicable AML/KYC regulations. You may request deletion of your account subject to our legal obligations.

7. Security

[PLACEHOLDER] We implement industry-standard security measures to protect your information, including encryption of data in transit (TLS) and at rest. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

8. Your Rights

[PLACEHOLDER] Depending on your state of residence, you may have the right to:

Access the personal information we hold about you;
Request correction of inaccurate information;
Request deletion of your information (subject to legal hold requirements);
Opt out of certain uses of your information;
Data portability.

[PLACEHOLDER] To exercise these rights, contact us at privacy@boromarbleleague.com. We will respond within [X] days as required by applicable law.

9. Children's Privacy

[PLACEHOLDER] The Platform is not directed to individuals under 18 years of age, and we do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

10. California Residents — CCPA / CPRA

[PLACEHOLDER — ATTORNEY TO DRAFT CCPA SECTION] California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). [FULL CCPA DISCLOSURES TO BE DRAFTED BY COUNSEL, including categories of personal information collected, sources, purposes, and third parties with whom information is shared.]

[PLACEHOLDER] California residents may submit a “Do Not Sell or Share My Personal Information” request by [MECHANISM TO BE DETERMINED].

11. Changes to This Policy

[PLACEHOLDER] We may update this Privacy Policy periodically. We will notify you of material changes by posting a revised policy on the Platform with an updated effective date. Your continued use of the Platform following notification constitutes acceptance of the updated policy.

12. Contact

[PLACEHOLDER] For privacy-related inquiries, contact our Privacy Officer at:
privacy@boromarbleleague.com
Boro Marble League LLC
[ADDRESS — ATTORNEY TO CONFIRM]

Privacy Policy