Free$t. Privacy Policy

Effective Date: June 1, 2026   |   Last Updated: June 1, 2026

1. Who We Are

Free$t., Inc. ("Free$t.," "we," "us," or "our") operates the Free$t. mobile application, the Free$t. for Business retailer app, the Free$t. web operations portal, and related services (collectively, the "Service"). This Privacy Policy explains what information we collect, how we use it, when we share it, and the choices you have. By using Free$t., you agree to this Policy.

2. Information We Collect

2.1 Information You Give Us

• Account information: email address, hashed password, display name, and chosen avatar.

• Apple Sign-In data: when you use Sign in with Apple, Apple sends us a stable user identifier and, if you agree, your name and email. We never see or store your Apple ID password.

• Payment-related information: when you opt in to the Free$t. Visa debit card, our banking partner (the "Issuer") collects payment processing data under its own agreement. Free$t. itself does not store full card numbers.

• Support messages: anything you type into the Lela in-app support chat or send to support@freestapp.com.

• Profile content: optional celebration videos and screenshots you choose to share or save.

2.2 Information We Collect Automatically

• Precise location (GPS): collected while the app is open and you have granted location permission. Used to show nearby prizes and to verify you are at a participating store at the moment of claim.

• Bluetooth Low Energy (BLE) proximity: when you enter a participating store, your device may detect Free$t. prize beacons over BLE. This is used only inside Free$t. retail locations to confirm prize claims. We do not use Bluetooth to track you outside Free$t. stores.

• Device information: device model, operating system version, app version, language, time zone, and an anonymous device identifier.

• Usage data: screens viewed, prize claim attempts, error logs, and crash reports.

2.3 Camera and Microphone

Camera access is used in two situations only: (1) optional Game Mode, an augmented-reality mini-game that overlays floating avatars on your camera view; and (2) when you choose to record a celebration video after winning a prize. We do not record video or images without your explicit action.

Microphone access is used solely when you choose to record a celebration video.

3. How We Use Your Information

• Operating the Service: showing nearby prizes, processing claims, paying out winnings.

• Communicating with you: account notifications, win confirmations, customer support replies.

• Preventing fraud and abuse: detecting GPS spoofing, multi-accounting, automated bots, and fake claims.

• Improving the Service: anonymized analytics and crash diagnostics.

• Legal compliance: tax reporting on prize winnings over the IRS reporting threshold, response to lawful legal process.

4. How We Share Information

Free$t. does not sell personal information to third parties.

We share limited information only in the following situations:

• Retailers — when you claim a prize, the participating retailer is notified that a claim occurred at their store. By default they do not see who you are; if you choose to appear on the public Leaderboard, your display name and avatar may be visible.

• Service providers — cloud hosting (Render), authentication (Apple), AI assistant (Anthropic, for Lela support chat responses), our banking partner (for Visa card processing), Expo / EAS (for application builds and over-the-air updates).

• Anthropic specifically: when you message Lela, your message text and recent conversation history are sent to Anthropic's Claude API to generate a response. Anthropic does not train its models on this data per its API Commercial Terms.

• Law enforcement — when required by a valid subpoena, court order, or other lawful legal process.

• Business transfers — if Free$t. is merged, acquired, or sold, your information may be transferred to the new owner under the same protections described in this Policy.

5. Third-Party Services

Free$t. relies on the following third-party services, each with its own privacy practices:

• Anthropic, PBC — AI processing for Lela support chat.

• Render, Inc. — backend hosting and database storage.

• Apple, Inc. — Sign in with Apple and App Store distribution.

• Google LLC — Play Store distribution.

• Expo (650 Industries, Inc.) — application build pipeline.

• Our banking-as-a-service partner — Free$t. Visa debit card issuance and processing.

6. Data Retention

• Account data: retained while your account is active and for 30 days after deletion request.

• Prize win records: retained for 7 years for tax, audit, and sweepstakes compliance, then deleted.

• Lela chat history: retained for 90 days to improve service quality, then deleted.

• Location data: not stored long-term. GPS coordinates are used at the moment of nearby-prize lookup and at the moment of claim verification, then discarded.

• Crash and error logs: retained for 1 year then deleted.

7. Your Rights and Choices

7.1 California Residents (CCPA / CPRA)

If you are a California resident, you have the right to know what categories of personal information we collect, the sources of that information, the purposes of collection, and the third parties with whom we share it. You also have the right to request deletion (subject to lawful retention exceptions), the right to opt out of "sale" or "sharing" of personal information (Free$t. does not sell), and the right not to be discriminated against for exercising these rights.

7.2 European Union / United Kingdom Residents (GDPR / UK GDPR)

If you are in the EU or the UK, you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection. You may also lodge a complaint with your national data protection authority. Our lawful bases for processing are (a) performance of our contract with you, (b) our legitimate interest in operating and improving the Service, and (c) your explicit consent (for camera, microphone, and location access).

7.3 All Users

You can delete your account at any time from Settings → Account → Delete Account in the app. You can also email privacy@freestapp.com to make any rights request. We will respond within 30 days where required by law.

8. Children's Privacy

Free$t. is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe we have collected such information, please email privacy@freestapp.com and we will delete it within 30 days.

A future version of Free$t. may include a separate, COPPA-compliant Kids' Mode with verifiable parental consent. That mode is not currently active.

9. Security

We protect your information using HTTPS in transit, password hashing (bcrypt), JWT-based session tokens, and secure cloud infrastructure. No method of transmission or storage is 100% secure. If we learn of a security incident that materially affects your information, we will notify you as required by applicable law.

10. International Users

Free$t. is operated from the United States. If you use the Service from outside the U.S., your information will be transferred to, stored in, and processed in the U.S., where data-protection laws may differ from those in your country. By using Free$t., you consent to that transfer.

11. Changes to This Policy

We may update this Policy from time to time. The "Last Updated" date at the top will change. Material changes will be notified within the app at least 14 days before they take effect. Your continued use of Free$t. after the effective date means you accept the updated Policy.

12. Contact

Privacy questions or rights requests: info@freestapp.com

General support: support@freestapp.com

Legal: legal@freestapp.com