Mogul Privacy Policy

1. Who We Are

Effective date: [insert]

This Privacy Policy explains how ASTN [LLC / Inc.] d/b/a Mogul (“Mogul,” “we,” “us”) collects, uses, shares, and protects personal information when you use the Mogul website, app, and contests, including mogulgame.moviepass.com and mogul.moviepass.com (the “Platform”). [Confirm final contracting entity; the Terms currently say both “ASTN LLC” and “ASTN Inc.”]

This policy is part of the Mogul Terms and Conditions. It covers Free Play and Paid Play. It does not cover the MoviePass movie ticket subscription, which has its own privacy policy, or third-party services such as Plaid, which have theirs.

By using the Platform, you acknowledge this policy. If you don’t agree with it, don’t use Mogul.

2. Information We Collect

What we collect depends on how you play. Free Play needs less than Paid Play, which requires identity, location, and payment checks.

Account and contact (all users). Name, username, email, mobile number, password.
Identity verification (Paid Play, withdrawals, and when needed for review). Legal name, date of birth, residential address, last four digits of SSN or other taxpayer info, government ID image, selfie or other verification evidence.
Financial (Paid Play). Linked bank account details, deposit and withdrawal history, wallet balance, chargebacks, source-of-funds information.
Tax (when winnings meet reporting thresholds). Taxpayer ID, full SSN where required for W-2G or 1099 reporting.
Geolocation (before Paid Play entry and other location-sensitive actions). Precise device location, IP address, signals used to detect VPNs or proxies.
Gameplay (all users). Rosters, contest entries, scores, rankings, winnings, Season participation, promotions and referrals used.
Device and usage (all users). Device type, OS, app version, device identifiers, IP address, log data, pages and features used, crash data.
Communications (when you contact us or opt in). Support messages, survey answers, marketing preferences.
Responsible play (when you set or trigger them). Deposit limits, self-exclusion or cool-off requests, account restrictions.
Insider screening (when requested). Employer, industry affiliation, and other information needed to apply the Insider Participation Policy.

Sensitive personal information

Several items above (SSN, government ID, precise location, financial account details) are sensitive under some state laws. We use them only to verify identity and eligibility, process payments, meet legal and tax obligations, and prevent fraud. We do not use them to infer characteristics about you.

3. How We Collect It

From you, when you sign up, verify your identity, deposit, build rosters, contact support, or answer surveys.
Automatically, through your device, cookies, SDKs, and similar tools while you use the Platform.
From service providers, including identity verification, geolocation, payment, fraud prevention, and bank-linking providers such as Plaid.
From MoviePass, if you join Mogul with or link a MoviePass account. [Confirm whether MoviePass account data is shared with Mogul and on what basis.]
From public sources and social media, when you interact with Mogul on TikTok, X, Instagram, or similar platforms.

4. How We Use It

Run the game: create your account, process entries, score contests, settle results, and pay winnings.
Verify eligibility: confirm your identity, age, and physical location before Paid Play, and enforce the one-account rule and Insider Participation Policy.
Move money: process deposits, withdrawals, refunds, chargebacks, and promotional credits.
Meet legal duties: tax reporting, anti-money-laundering and sanctions checks, regulator requests, and record-keeping.
Protect the Platform: detect fraud, collusion, multi-accounting, VPN use, and other prohibited conduct.
Support responsible play: apply limits, self-exclusion, and cool-off periods you set or that the law requires.
Improve Mogul: analyze usage, fix bugs, and develop features, including the Hype Index.
Communicate with you: send service messages, contest updates, and, where allowed, marketing. You can opt out of marketing at any time.

We may create de-identified or aggregated data (for example, overall roster trends) and use it for any lawful purpose. We will not try to re-identify it.

5. Plaid and Linked Bank Accounts

We use Plaid Inc. to connect your bank account for deposits and withdrawals. When you link an account, Plaid collects information from your bank, which may include login credentials, account and routing numbers, balances, and transaction history.

What Plaid shares with us: [confirm data fields Mogul receives, e.g., account owner name, masked account number, routing number, balance, account verification status]. We do not receive or store your bank login credentials.
How we use it: to verify that the account is yours and matches your verified name, process deposits and withdrawals, investigate failed payments, and prevent fraud.
Plaid’s own use: Plaid handles the data it collects under the Plaid End User Privacy Policy, separately from this policy.
Disconnecting: you can remove Mogul’s access through the Plaid Portal, by contacting Plaid, or [in-app option, if any]. You may not be able to deposit or withdraw until you link another account.

6. How We Share It

We do not sell your personal information. [Confirm, and confirm whether any ad pixels count as “sharing” for cross-context behavioral advertising under California law.]

We share personal information only with:

Service providers that host the Platform, verify identity, check location, process payments, prevent fraud, provide contest data, send email and push messages (e.g., Braze), run analytics, and support customers. They may use it only to serve Mogul. [List or link current vendors.]
Plaid, as described above.
MoviePass and affiliates under common ownership, for operations and, where allowed, to tell you about MoviePass offers. [Confirm.]
Other players, who can see your username, leaderboard rank, and contest results. Your legal name and contact details are not shown.
Regulators, tax authorities, and law enforcement, when required by law, legal process, gaming or tax rules, or to protect people and the Platform.
Integrity partners, such as other contest operators or industry integrity bodies, to investigate fraud, collusion, or insider activity. [Confirm whether applicable.]
A buyer or successor, if Mogul is involved in a merger, sale, or reorganization. We’ll notify you of any such change.
Anyone else, with your consent.

7. Geolocation

Paid Play requires us to confirm you are physically in an approved jurisdiction. Before you enter a Paid Play contest or take other location-sensitive actions, we check your precise location through your device and our geolocation provider [name provider].

We check location at the moment of the action, not continuously in the background. [Confirm with Product.]
If you deny location permission, you can still use Free Play, but you can’t enter Paid Play.
We also look for signs of VPNs, proxies, or location spoofing, which the Terms prohibit.
We keep location check results as compliance records (see Retention and Security).

8. Cookies and Tracking

We use cookies, pixels, SDKs, and similar tools to keep you signed in, secure your account, measure performance, and understand how people find and use Mogul.

Essential: sign-in, security, fraud prevention, geolocation checks. These can’t be turned off.
Analytics: usage and performance measurement. [Name tools.]
Marketing: measuring campaigns and, where allowed, showing Mogul ads on other sites and apps. [Name tools; confirm whether used.]

You can control cookies in your browser and ad tracking in your device settings. We honor Global Privacy Control signals as an opt-out of sale or sharing where required. [Confirm.]

9. Retention and Security

We keep personal information as long as your account is open and as long afterward as we need it for legal, tax, regulatory, fraud-prevention, and dispute purposes. Gaming and financial rules often require us to keep transaction, identity, and location records for several years after an account closes. [Legal to set periods, e.g., X years for transaction and KYC records.]

Closing your account does not immediately delete records we must keep. When we no longer need information, we delete or de-identify it.

We protect information with administrative, technical, and physical safeguards, including encryption in transit and access controls. [Confirm: encryption at rest, SOC 2 or similar.] No system is fully secure. If a breach affects your information, we’ll notify you as the law requires.

10. Your Rights and Choices

Depending on where you live, you may have the right to:

Know and access what personal information we have about you and get a copy.
Correct inaccurate information.
Delete your information, subject to the records we must keep.
Opt out of sale, sharing for targeted ads, and profiling with significant effects.
Limit use of sensitive personal information to permitted purposes.
Appeal a decision we make on your request.

We extend these rights to all U.S. users. [Confirm.] We won’t treat you differently for using them.

How to make a request

Email [support@mogul.moviepass.com] or use [in-app privacy settings]. We’ll verify your identity before responding, usually by matching information already on your account. An authorized agent can submit a request with your written permission. We respond within 45 days and will tell you if we need more time.

Marketing

Unsubscribe from emails using the link in any message, turn off push notifications in your device settings, and reply STOP to texts. You’ll still get service messages about your account, contests, and payments.

11. Age Requirements

Mogul is for adults. You must be at least 18 to create an account, and Paid Play requires the minimum age set by the state you’re physically in [see “Where Can I Play?”]. We don’t knowingly collect information from anyone under 18. If we learn we have, we’ll close the account and delete the information, except what the law requires us to keep.

12. Mogul and MoviePass

Mogul is operated by ASTN [LLC / Inc.] and offered with MoviePass. [Describe the corporate relationship.] Your MoviePass subscription data is covered by the MoviePass Privacy Policy. Mogul data is covered by this policy. [Confirm what, if anything, moves between the two.]

13. Changes to This Policy

We’ll post updates here with a new effective date. If we make a material change, we’ll notify you in the app or by email before it takes effect.

14. Contact Us

ASTN [LLC / Inc.] d/b/a Mogul

160 Varick Street, Fl 3, New York, NY 10013

Email: [support@mogul.moviepass.com]

In-app support: [insert location]