PRIVACY POLICY
Updated as of August 16, 2026.
AS STATED IN OUR TERMS OF USE, ALL OF YOUR ACTIVITY THROUGH THIS SITE INCLUDING THIS PRIVACY POLICY IS SUBJECT TO THE TERMS OF USE - INCLUDING MANDATORY ARBITRATION PROVISIONS IN THE TERMS OF USE WHICH REQUIRE YOU TO ARBITRATE ANY CLAIMS AGAINST AS AN INDIVIDUAL AND NOT AS PART OF A CLASS ACTION.
Your privacy is important to us. To better protect your privacy, TWLV Inc., its officers, directors, employees, contractors and affiliates (collectively, the "Company", “us”, “our” or “we”), has created this Web Sites/Applications Privacy Policy ("Privacy Policy") to explain the online information collection and use practices in connection with its TWLV Platforms, which include rallytabs.com and any associated websites, mobile apps, or web pages available through external sites, third-party platforms or third party providers, such as through a Facebook page, Instagram, Snapchat, or X, in combination with any operations, content, products and services we provide or made available through any of the foregoing (collectively, the "Web Sites/Applications").  Please note, if accessing any one or more of the Web Sites/Applications through external sites, third party platforms or third party providers, you are also bound by the terms and conditions and privacy policy of such external sites or third party platforms or third party providers.
This Privacy Policy explains how we may collect your information, how we may use your information or share it with others, and how you may access and control your information in connection with our marketing communications and activities. The following policies apply to all Web Sites/Applications owned and operated by the Company. We hope this helps you make an informed decision about sharing information with us. In addition, please review the Terms of Use and Legal Notices, which governs your use of the Web Sites/Applications and any content you submit to us.
The terms stated herein are not intended to conflict with the Terms of Use and Legal Notices. In the event any term stated herein conflicts with the Terms of Use and Legal Notices, the Terms of Use and Legal Notices shall govern.
Please note that any video, image, or other content which you post on the Web Sites/Applications becomes published content and is not considered personally identifiable information subject to this Privacy Policy
ACCEPTANCE OF PRIVACY POLICY.
By accessing or using the Web Sites/Applications and/or providing us with your personal information, you consent to the terms of this Privacy Policy and understand that we will collect, maintain, use, and disclose your personal information in accordance with this Privacy Policy and United States law. You hereby waive any claims that may arise under the laws and regulations that apply to you in any other country or jurisdiction.
The Web Sites/Applications are intended only for users who are at least eighteen (18) years old and otherwise meet the eligibility requirements in the Terms of Use and Official Sweepstakes Rules.
If you do not agree to the terms of this Privacy Policy, you may not use the Web Sites/Applications. Please review this Privacy Policy frequently as we reserve the right to change the policy at any time. For more information, please refer to the section entitled "Changes To This Privacy Policy" detailed below. If you believe we have not adhered to this Privacy Policy or if you have any other questions regarding this Privacy Policy, please contact us at info@rallytabs.com
YOUR SECURITY
We strive to keep your personal information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of personal information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access.
Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through our websites/apps, any transmission of personal information is at your own risk. We cannot guarantee that such information will not be intercepted by third parties, and we will not be liable for any breach of the security of your personal information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for unauthorized circumvention of any privacy settings or security measures contained on the web sites/apps.
You are required to keep your account information confidential. Do you share your login and/or password information with other third-parties. If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), you must immediately notify us by contacting us at the contact information listed below. In the event that we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.
COLLECTION AND USE OF INFORMATION
In order to make this Web Sites/Applications as customized as possible to your needs and interests, we will gather certain information from you. We will use this information for a variety of business purposes, including for example, operate, maintain, and provide you with the features and functionality of the service, to comply with applicable legal requirements, and to tailor our services, content and advertising to you. In order to accomplish this, we may ask you to register with the Web Sites/Applications and provide certain personal information prior to allowing you to enter any contests, participate in any promotions, post any comments or otherwise visit and utilize certain areas of the Web Sites/Applications. If you opt to not register then you may not have access to the areas of the Web Sites/Applications which require your personal information.
The following information is collected by the Company, and defined as follows:
Collected Information: The personal information which you provide to us, may include your legal name, age/date of birth, Credit/Debit/Payment information and billing address, verified residential address, email address, state/province of residence, location, user name, taxpayer information such as a Social Security ID and other verification information such as a Passport, driver's license, source of wealth documents such as a bank statement, or other verification documents or those required to be collected by law, among other information, while using the Web Sites/Applications, such as during a registration process, Sweeps Play Prize Redemption process, responding to surveys, uploading multimedia, posting messages or comments, entering contests, subscribing to newsletters or other mailing lists or entering promotions. In addition, the information provided may be in the format of habits or trend data, such as usage history, activity on the Web Sites/Applications, or the like.
Web Beacons: While you are on the Web Sites/Applications, we may use Web Beacons or clear GIFs or similar features. These tools allow us to track the online usage patterns of our customers. Some of this activity is associated with identifiers that can be linked to you individually, including by our advertising and analytics partners, as described in the section entitled "Advertising and Analytics Partners" below. We may also use Web Beacons in HTML-based emails sent to you by the Company or its affiliates in order to determine whether or not the emails have been read.
Cookies Information: We may opt to send one or more cookies to your computer that uniquely identifies your browser while you are on the Web Sites/Applications in order to better customize your experience on the Web Sites/Applications. A "cookie" is a small line of text that is stored with your Web browser for record-keeping purposes and to help us provide better service to you. You can delete cookies from your computer by following the directions found in your web browser help file. If you opt to refuse all cookies on your computer you may not be able to access certain areas of the Web Sites/Applications or take advantage of certain functions available on the Web Sites/Applications.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit "do-not- track" signals to the websites with which the user communicates. As there is currently no industry standard concerning what, if anything, websites should do when they receive such signals, our website currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals. Certain browsers and browser extensions also transmit a Global Privacy Control ("GPC") signal. We do not currently detect or respond automatically to GPC or other browser-transmitted opt-out signals. If you wish to opt out of the advertising-related uses and disclosures described in the section entitled "Advertising and Analytics Partners" above, please use the methods described in that section, including by contacting us at info@rallytabs.com, rather than relying on a browser signal.
Log File Information: Whenever you visit the Web Sites/Applications, our web servers will automatically record certain information from the web server from which you are using, including the IP address, the type of browser which you are utilizing, the pages viewed from the web browser and other usage details available from your server. This information will allow us to assist in the analysis and correction of technical problems and to better protect the equipment of our users and ourselves.
NOTE: The Web Sites/Applications may include links to other websites, such as banner ads and other advertising tools. These websites and other advertisers may place and access their cookies on your computer. Any such actions or use of cookies by any other entity other than the Company, is subject to such third-parties' privacy policies and not the Privacy Policy of the Company. The Web Sites/Applications may also provide links to other websites via banner, pop-up or other forms of ads. If the link directs you to a third-party web site, such websites are not bound by this Policy or any of the other policies of the Company. Accordingly, we are not responsible for the content or actions of such third-party web sites. If you have any questions or concerns regarding any web site you visit, you should review the privacy policy and/or terms and conditions of the web site before utilizing any of the tools or features presented on the web site. Please be aware that the Company may, from time to time, use the personal information (excluding confidential taxpayer information) which it collects on its users to gear advertisements towards its users. If you wish to opt-out of such personal information use for advertisements, please contact info@rallytabs.com
Applications you use or download from our site may contain digital rights management systems ("DRMS") from the Company or third parties. DRMS provides a means of communication between your software and the third parties and allows third parties to embed certain security features into the software. DRMS are often used to prevent the distribution of or access to software in the event of unauthorized use. These DRMS are subject to their own license agreements. By your use of this Web Sites/Applications, you agree that the Company shall not be responsible for any loss or damage of any sort relating to the use of the DRMS or your dealings with such third parties.
The Web Sites/Applications may allow user reviews, chat sites, bulletin boards, or other public functions and anything that you post in any such sites will be considered public information available to other users. Please be sure not to include any personal information in any such postings or your screen name. If you do, it is considered public information. All such posting is governed by our Terms of Use.
ADVERTISING AND ANALYTICS PARTNERS
We work with third-party advertising and analytics providers to understand how the Web Sites/Applications are used and to measure and improve our advertising. These providers currently include Google Analytics, Meta Platforms, Inc. (the operator of Facebook and Instagram), and Vercel Analytics. These providers may act as our service providers, and in some cases may use the information they receive for their own purposes as described in their own privacy policies.
Meta advertising tools. We use the Meta Pixel, a piece of code that runs in your browser, together with Meta's Conversions API, which sends information directly from our servers to Meta. Please note that because the Conversions API operates server-to-server, information may be transmitted to Meta through it even if you block cookies or scripts in your browser. Deleting cookies or using browser privacy settings will limit browser-based collection but will not by itself stop server-side transmission.
Information shared with Meta. Depending on the activity, the information transmitted may include: (i) your email address, telephone number, and the account identifier we assign to you, each of which is converted to a scrambled value (a "hash") before it is sent; and (ii) your IP address, your browser and device user-agent information, and Meta cookie identifiers, which are sent without hashing. Hashing obscures these values in transit, but the purpose of sending them is to allow Meta to match them against information Meta already holds, and Meta may therefore be able to identify you. We also send information about your activity, including pages and products you view, when you begin a checkout, when you complete a purchase and the dollar amount of that purchase, when you complete registration, and when you sign in or open a pack.
Information we do not share with these partners. We do not send our advertising or analytics partners your legal name, residential or billing address, date of birth, Social Security number or other government identification, verification or source-of-wealth documents, payment card or bank account numbers, or your Rally Cash or Rally Points balances.
Purposes. This information is used to measure whether our advertising is effective, to report on conversions, to build audiences of people who have taken particular actions on the Web Sites/Applications, and to deliver and optimize advertising to you and to similar audiences on Meta's platforms and elsewhere.
Your choices. You may limit this activity by: (i) adjusting your ad preferences directly with Meta through the settings available in your Facebook or Instagram account, including Meta's "Off-Facebook Activity" controls; (ii) using browser settings or extensions that block cookies and tracking scripts, subject to the server-side limitation described above; (iii) opting out of Google Analytics using the browser add-on Google makes available; or (iv) contacting us at info@rallytabs.com to request that we cease using your personal information for advertising purposes. Depending on where you live, you may also have rights described in the sections entitled "California Privacy Rights" and "Nevada Data Sale Opt-Out" below. Certain state privacy laws may treat the sharing described in this section as a "sale" or as "sharing" for purposes of targeted or cross-context behavioral advertising, and we will honor opt-out requests submitted to us as described above.
PRODUCT ANALYTICS
We use a third-party product-analytics provider, PostHog, Inc., to understand how people use the Web Sites/Applications, including the RallyTabs iOS application, and to improve those products. PostHog acts as our service provider for this purpose. PostHog's own practices are described in its privacy policy at https://posthog.com/privacy.
Information we send to PostHog. When product analytics is enabled for a given build of the Web Sites/Applications, we may send: (i) an opaque account identifier we assign to you (not your name, email address, or telephone number); (ii) the screens or features you use, and product events such as sign-in, onboarding, purchases, pack opens, collection activity, community interactions, and similar in-app actions; and (iii) technical information about the application, including platform, application version, build number, and whether the build is pointed at our production or non-production environment.
Information we do not send to PostHog. We do not send PostHog your legal name, email address, telephone number, residential or billing address, date of birth, Social Security number or other government identification, verification or source-of-wealth documents, payment card or bank account numbers, Rally Cash or Rally Points balances, precise location, or advertising identifiers such as the Identifier for Advertisers (IDFA). We do not enable PostHog session replay, touch or screenshot capture, or automatic collection of text you type into forms.
Purposes. This information is used to measure product usage, diagnose problems, and improve the Web Sites/Applications. It is not used by us to deliver or optimize third-party advertising.
Your choices. If you wish to request that we cease using your information for product analytics, please contact us at info@rallytabs.com. Depending on where you live, you may also have rights described in the sections entitled "California Privacy Rights" and "Nevada Data Sale Opt-Out" below.
SERVICE PROVIDERS
In addition to the advertising, analytics, and product-analytics providers described above, we share personal information with third-party service providers that perform services on our behalf. These providers are permitted to use your information only to provide those services to us and as described in their own privacy policies. These providers currently include:
Payments — Coinflow. Purchases and prize redemptions are processed by our payment services provider, Coinflow. When you make a purchase or set up a redemption payout, your payment card number, bank account details, Apple Pay, ACH, Venmo, PayPal, or other payment method information is entered into and collected directly by Coinflow through Coinflow-hosted checkout and payout pages presented within the Web Sites/Applications. We provide Coinflow with your email address and the transaction amount, and we receive transaction status and tokenized references to your payment methods; we do not receive or store your full payment card or bank account numbers.
Identity verification — iDenfy. Before certain purchases and prize redemptions, we verify your identity, age, and eligibility using our identity-verification provider, iDenfy. iDenfy collects, directly from you, photographs of your government-issued identification document and a selfie, and performs automated document authentication, liveness detection, and facial comparison, which may involve the processing of biometric information. These images are transmitted directly to iDenfy; we receive the verification result and identity information extracted from your documents. Verification, taxpayer, and related compliance records are retained by us and by our providers for as long as required for legal, regulatory, fraud-prevention, and tax purposes.
Text messaging — Twilio. Sign-in one-time passcodes and other service text messages are delivered by Twilio, which processes your telephone number and the content of those messages.
Email delivery — Resend. Service and transactional emails, such as receipts, prize and redemption notices, and support responses, are delivered by Resend, which processes your email address, name, and the content of those messages.
Push notifications — OneSignal. If you enable push notifications in the mobile application, notifications are delivered by OneSignal, which processes a push notification token, a device/subscription identifier, the account identifier we assign to you, and general device information such as device model, operating system version, language, and time zone. You may disable push notifications at any time in your device settings.
Our service providers may change over time; we will reflect material changes in updates to this Privacy Policy.
MOBILE APPLICATION PERMISSIONS AND IDENTIFIERS
Device location. The RallyTabs mobile application may request permission to access your device's location to confirm that you are in an eligible state before purchases and Sweeps Play. If you grant permission, we collect your device location and derive your country, state/region, and city from it; jurisdiction eligibility is also checked using your IP address. Location permission is not required to sign in, and we do not use your location to show you advertising. You may change location permission at any time in your device settings.
Advertising identifier. The mobile application may request permission under Apple's App Tracking Transparency framework to access your device's advertising identifier (IDFA). If you grant permission, we may use this identifier, together with the advertising partners described above, to measure how people discover RallyTabs and to improve our marketing. We do not display third-party advertisements inside the application. You may withdraw this permission at any time in your device settings, and the application remains fully functional if you decline.
DISTRIBUTION OF YOUR PERSONAL INFORMATION
Unless (i) you choose to allow us to share your personal information, (ii) we have given you prior notice that the information will be shared, and with whom (such as in this Privacy Policy); or (iii) the information is general information, e.g., aggregate information or other information that does not identify you; we will not share your personally identifiable information with third parties other than those parties that are contracted by the Company to provide services for us, have agreed to be bound by our Privacy Policy or have a policy to protect your personal information, and in those instances set forth below.
As noted earlier, it is your decision whether or not to share your personal information with us. If you opt to provide us with your personal information by logging into our site (e.g. creating an account), this action will be considered opting-in to sharing your personal information. At any time, you may opt out of this. Please see below in order to learn more about our Opt Out Plan. Even if you have not opted to provide us with your personal information, we may use third parties to obtain your personal information to provide services or products to you on our behalf, such as taking and processing orders, analyzing usage, etc. The Company shall be free to distribute or use non-personally identifiable information, such as your age, web site usage patterns, education level or household income, from time to time. We will not share that information in a manner that identifies you as an individual with any other entity unless you have provided your previous consent to such disclosure.
Notwithstanding anything else to the contrary, the Company is free to disclose your personal information if it is required to do so by law or if we have a good faith belief that disclosure is necessary to (1) comply with the law or with legal process served on us; (2) protect and defend our rights or property; or (3) act in an emergency to protect someone's safety.
OPT-OUT PLAN
After you create an account on the Web Sites/Applications, or otherwise use the Web Sites/Applications, and "opt in" to providing your personal information, you may at any time unsubscribe from the Web Sites/Applications. In order to "opt out," please email us through the Web Sites/Applications. Please note that there might be a delay between when you submit your email to opt-out and when it is processed. We appreciate your patience during this period. We maintain archives of our web logs, database, and other systems and information for legal purposes, disaster recovery and other purposes. If you request that we delete your information from our active database, please understand that it is possible some of your information may remain archived after we delete the information from its active database, as allowed by applicable law.
PRIVACY OF CHILDREN UNDER 18
The Company does not offer the Web Sites/Applications to, nor knowingly collect or maintain or use the personally identifiable information of children under the age of eighteen (18).  The Web Sites/Applications is not directed to children under the age of eighteen (18).  If you are under the age of eighteen (18), we ask that you do not use or view the Web Sites/Applications or provide any information through the Web Sites/Applications. If the Company learns that it has collected information from someone under the age of eighteen (18), then the Company will take all steps necessary to delete such personal information. If you believe that your child has provided his or her information to us, please send us an email at info@rallytabs.com or a written letter at the address below so that we may delete such information.
INTERNATIONAL USERS
The Web Sites/Applications are hosted in the United States and is intended for and directed to users in the United States. If you are a User accessing the Web Sites/Applications from any country other than the permitted countries, please be advised that your country's laws or regulations governing personal data collection, use, and disclosure, may differ from U.S. laws. If you opt to continue to use the Web Sites/Applications, any such continued use shall be governed by U.S. law, this Privacy Policy and the Web Site's Terms of Use. Furthermore, you hereby consent that during your use you may be transferring your personal information to the United States and you consent to that transfer.
CALIFORNIA PRIVACY RIGHTS.
California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send (i) an email to: info@rallytabs.com with the subject heading "California Privacy Rights," or (ii) a letter to the Company at the mailing address provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
NEVADA DATA SALE OPT-OUT
Residents of Nevada have the right to opt out of the sale of their personal information under Nevada law. If you are a Nevada resident and wish to exercise this right, please contact us at info@rallytabs.com to submit your request.
IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY
If the Company is acquired by or merged with another entity, or in connection with a financing where personal information is needed, the Company shall have the right to transfer or assign the information we have collected from you in connection with such corporate transaction. We will seek to obligate the acquiring entity to use any information transferred in a manner consistent with this Privacy Policy but cannot guarantee that it will be able to impose that requirement or that the acquiring company will comply.
In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used and assume no liability for any such improper distribution or use. You understand and agree that your personal information may be shared and transferred in connection with such transactions.
SEVERABILITY
If any part of this Privacy Policy is held invalid or unenforceable, that portion shall be interpreted in a manner consistent with applicable law to reflect, as nearly as possible, our original intentions, and the remaining portions shall remain in full force and effect.
CHANGES AND UPDATES TO THIS PRIVACY NOTICE
From time to time, the Company may revise this Privacy Policy. If we make what we determine to be a material change to this Privacy Policy, we will update the "Date Last Modified" and will notify you by posting the updated Privacy Policy on the Web Sites/Applications or by otherwise communicating to you. Please visit this section of the Web Sites/Applications often in order to make sure that you are aware of the terms of the most recent version of the Privacy Policy. Your continued use of the Web Sites/Applications constitutes your agreement to this Privacy Policy and any future revisions of the Privacy Policy.
CONTACT INFORMATION
All questions or concerns regarding this Privacy Policy should be forwarded to:
info@rallytabs.com
Or
TWLV Inc.
186 42nd St
PO Box 40396
Pittsburgh, PA 15201