Open4Fun Privacy Policy

This Privacy Policy explains how Open4Fun LLC (“Open4Fun,” “we,” “us,” or “our”) collects, uses, discloses, and protects Personal Data when you use our website located at www.open4fun.com and related services.

This document includes information for:

• California consumers
• Brazilian users
• Users subject to other applicable privacy laws

1. Owner and Data Controller

Open4Fun LLC 38 Schindler Way Fairfield, NJ 07004

Email: bevan@open4fun.com

2. Types of Data Collected

We may collect the following types of Personal Data:

• Email address
• Usage Data
• Cookies and similar tracking technologies
• Other information you voluntarily provide through forms or communications

Personal Data may be collected:

• Directly from you
• Automatically when you use the website
• Through third parties and service providers

Unless otherwise stated, all data requested by us is necessary to provide our services. If you do not provide required data, we may not be able to offer certain features or services.

You are responsible for any third-party Personal Data you provide or share through the website and confirm that you have the necessary permission to do so.

3. Mode and Place of Processing the Data

Methods of processing

We take reasonable technical and organizational measures to protect Personal Data from unauthorized access, disclosure, alteration, or destruction. Data is processed using computers, IT-enabled tools, and appropriate administrative procedures.

Access to Personal Data may be limited to:

• Authorized employees and contractors
• Administrative, sales, marketing, legal, and IT personnel
• Third-party service providers such as hosting providers, email providers, communications vendors, and technical support partners

Legal basis of processing

We may process Personal Data if one or more of the following apply:

• You have given consent
• Processing is necessary to perform a contract or take steps before entering into a contract
• Processing is necessary to comply with a legal obligation
• Processing is necessary to protect our legitimate interests or those of a third party
• Processing is necessary to carry out a task in the public interest, where applicable

Place of processing

Data is processed at our operating offices and other locations where our service providers are located. Depending on your location, your data may be transferred to and processed in countries other than your own. Where required, we will take steps to protect such transfers in accordance with applicable law.

Retention time

We retain Personal Data only as long as necessary for the purposes for which it was collected, including:

• To fulfill a contract
• To comply with legal obligations
• To support legitimate business interests
• Until consent is withdrawn, where processing is based on consent

When retention is no longer required, Personal Data will be deleted or anonymized as appropriate.

4. Purposes of Processing

We collect and use Personal Data to:

• Provide and operate our services
• Respond to inquiries and requests
• Improve and analyze website performance
• Carry out A/B testing and feature testing
• Display content from external platforms
• Provide hosting and platform-related services
• Comply with legal obligations
• Protect our rights, users, and third parties
• Detect fraud, abuse, or malicious activity

5. Detailed Information on Processing of Personal Data

Personal Data may be processed for the following purposes and through the following services:

• Content performance and feature testing (A/B testing)
• Displaying content from external platforms
• Platform services and hosting
• Analytics, security, and operational support
• Communication and customer service

6. User Rights

Depending on your location and applicable law, you may have the right to:

• Withdraw consent
• Object to processing
• Access your Personal Data
• Correct inaccurate or incomplete data
• Restrict processing
• Request deletion
• Receive your data in a portable format
• Lodge a complaint with a supervisory authority

Right to object

Where processing is based on legitimate interests or public interest grounds, you may object by providing a reason related to your particular situation. You may object to direct marketing at any time without justification.

How to exercise your rights

You may submit requests using the contact information in this policy. We will respond as soon as reasonably possible and within the time required by applicable law.

7. Additional Information About Data Collection and Processing

Legal action

We may use Personal Data for legal purposes, including in connection with claims, disputes, investigations, or legal proceedings.

System logs and maintenance

We and our service providers may collect system logs and technical data such as IP address for maintenance, security, and operational purposes.

Information not contained in this policy

If you need more information about our privacy practices, you may contact us using the information listed above.

Do Not Track

Our website does not currently respond to “Do Not Track” requests. Third-party services may handle such requests differently.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may notify users by posting the updated policy on this page and, where appropriate, through the website or by other available contact methods.

If required by law, we will obtain renewed consent for changes affecting processing based on consent.

California Privacy Notice

This section applies only to California residents and supplements the rest of this Privacy Policy.

Categories of personal information collected

In the past 12 months, we may have collected the following categories of personal information:

• Identifiers
• Internet or electronic activity information

We do not collect additional categories without notice.

Sources of information

We may collect personal information:

• Directly from you
• Automatically when you use the website
• From service providers or third parties that assist us

Use and disclosure

We may disclose personal information to service providers or third parties for business purposes under written agreements requiring confidentiality and limited use.

Sale or sharing of personal information

We do not intend to sell personal information in exchange for money. However, some data practices involving cookies, analytics, or advertising tools may be considered a “sale” or “sharing” under certain privacy laws depending on how those tools operate.

If applicable, you may have the right to opt out of such sale or sharing.

California rights

California residents may have the right to:

• Know what personal information we collect, use, disclose, or share
• Request deletion
• Request correction
• Opt out of sale or sharing
• Limit use of sensitive personal information, if applicable
• Receive non-discriminatory treatment for exercising privacy rights

How to exercise your rights

To submit a request, contact us using the details in this policy. We may need to verify your identity before processing the request.

We will respond within the timeframe required by California law.

Brazil Privacy Notice

This section applies to users residing in Brazil and supplements the rest of this Privacy Policy.

Legal bases for processing

We may process Personal Data under the legal bases permitted by the LGPD, including:

• Consent
• Compliance with legal or regulatory obligations
• Execution of contracts or preliminary procedures
• Exercise of rights in judicial, administrative, or arbitration proceedings
• Legitimate interests
• Protection of life or physical safety
• Protection of health, where applicable
• Credit protection, where applicable

Brazilian rights

Brazilian users may have the right to:

• Confirm whether we process their data
• Access their data
• Correct incomplete, inaccurate, or outdated data
• Request anonymization, blocking, or deletion of unnecessary or noncompliant data
• Request information about data sharing
• Revoke consent
• File a complaint with the ANPD
• Request review of automated decisions, where applicable

How to file a request

You may exercise your rights by contacting us using the contact details provided in this policy. We will respond within a reasonable time and in accordance with applicable law.

International transfers

Where personal data is transferred outside Brazil, we will do so only where permitted by law and with appropriate safeguards, where required.