FitFaction Privacy Policy

Effective Date: March 12, 2026

Entity: FitFaction, LLC ("FitFaction," "we," "us," or "our")

Website/App: https://www.fitfactionllc.net/ (the "Services")

Status note (pre-launch): FitFaction is a single-member LLC that is pre-launch, with no users, no revenue, and no active data collection at this time. This Policy therefore describes FitFaction's intended data practices once the Services become available and may be updated as operations evolve.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you access or use the Services, or otherwise interact with us. This Policy is incorporated into the FitFaction Terms and Conditions.

1) Who We Are and How To Contact Us

Company: FitFaction, LLC

Mailing Address: 5900 Balcones Drive, Ste 100, Austin, TX 78731, USA

Email: info@fitfactionllc.net

For customers: legal notices may also be provided through the instrument specified in the University Agreement or Data Processing Addendum ("DPA").

2) Definitions (Plain-English)

Personal Information / Personal Data: Information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual (e.g., name, email, identifiers, IP address).

Sensitive Personal Information: Certain categories that may carry elevated privacy risks (e.g., precise geolocation, government IDs, financial account credentials, health or biometric data).

Institution: A university or affiliated entity that contracts with FitFaction to enable eligibility-based access for its community.

User Content: Content you post or share through the Services (e.g., profile info, messages, activity listings).

Processing: Any operation performed on personal information (collection, storage, use, disclosure, deletion, etc.).

3) Scope and Audience

This Policy applies to information we process:

Intended Users / Age Gate. The Services are for individuals 18 years of age or older. We do not knowingly collect information from individuals under 18.

4) What We Collect (Categories and Examples)

Because FitFaction is pre-launch, no active collection is occurring. When launched, we anticipate collecting the following categories:

A. Information You Provide Directly

Account and Eligibility: Name, university-issued email address, affiliated institution, eligibility/verification status.

Profile (Optional): Fitness interests or activities, availability windows, profile photo/biography.

Communications: Messages or inquiries you send us; in-app messages to other users (for delivery and moderation safety tooling).

User Content: Activity/event descriptions and other content you intentionally submit.

PLEASE AVOID PROVIDING SENSITIVE PERSONAL INFORMATION (E.G., HEALTH, MEDICAL, BIOMETRIC, PRECISE LOCATION BEYOND WHAT THE APP REQUESTS) UNLESS WE SPECIFICALLY REQUEST IT FOR A FEATURE YOU CHOOSE TO USE. FITFACTION IS NOT A MEDICAL PROVIDER AND DOES NOT REQUEST MEDICAL RECORDS.

B. Information Collected Automatically

Device/Log Data: IP address, device identifiers, browser type, operating system, timestamps, referring/exit pages, error logs.

Usage/Interaction Data: Screens or pages viewed, features used, engagement metrics, diagnostic data.

Cookies and Similar Tech: Cookies, local storage, pixels, and SDKs for authentication, security, and analytics.

C. Information From Institutions (If Applicable)

Eligibility and Admin Data: Domain verification, roster or eligibility confirmation, configuration settings, and administrator contact information to support access control, troubleshooting, and compliance.

5) How and Why We Use Personal Information

NO SALE / NO CROSS-CONTEXT BEHAVIORAL ADVERTISING. FITFACTION DOES NOT SELL PERSONAL INFORMATION AND DOES NOT SHARE PERSONAL INFORMATION FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING. IF OUR PRACTICES CHANGE, WE WILL UPDATE THIS POLICY AND PROVIDE APPLICABLE CHOICES. NO AUTOMATED DECISION-MAKING WITH LEGAL/SIMILAR EFFECTS. WE DO NOT USE AUTOMATED DECISION-MAKING THAT PRODUCES LEGAL OR COMPARABLY SIGNIFICANT EFFECTS ABOUT YOU.

6) Cookies, Analytics and Controls

We use first-party cookies and similar technologies for login persistence, security, and metrics. When analytics are enabled, we may use privacy-protective settings (e.g., truncation of IP addresses where available, aggregated reporting). Your browser may allow you to block cookies or clear them.

Do Not Track (DNT) and Global Privacy Control (GPC). We do not currently respond to DNT signals. Where legally required, we will honor GPC as an opt-out preference signal for relevant jurisdictions and will update this Policy to describe how GPC is recognized.

7) Disclosures of Personal Information (Categories of Recipients)

Other Users: Information you choose to make visible in your profile or User Content may be visible to other eligible users within your institution.

Service Providers / Contractors: Cloud hosting and infrastructure (e.g., Amazon Web Services), logging/monitoring, security, analytics, email delivery, and development contractors who process data only on our behalf under contractual restrictions.

Institutions: Limited data to designated institution administrators for subscription management, compliance with policies, safety investigations, or misuse reports, consistent with the University Agreement/DPA.

Legal/Safety: To competent authorities or third parties where disclosure is necessary to comply with law or legal process; to protect rights, property, or safety of FitFaction, users, or others; or to respond to an emergency.

Corporate Transactions: In connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality and continuity of privacy protections.

We do not disclose personal information to data brokers.

8) Institutional Relationships; FERPA Considerations

FitFaction is not an educational institution and does not independently claim FERPA coverage. However, because access is institution-linked, FitFaction may process limited education-related identifiers (such as university email). For subscribing institutions, FitFaction may agree—under a University Agreement and/or DPA—to act as a "school official with legitimate educational interests" and to implement safeguards consistent with institutional policies. Those agreements will govern FitFaction's processing on behalf of the institution and may address data access, deletion, and retention upon termination.

9) Data Retention and Minimization

We retain personal information only as long as reasonably necessary to:

Provide and improve the Services;

Support security, fraud prevention, and compliance;

Satisfy legal and accounting requirements; and

Enforce or defend legal claims.

When data is no longer needed for the above purposes, we will delete or de-identify it, subject to technical limitations and backup cycles. If an institution requests deletion consistent with a University Agreement/DPA, we will comply as contractually required.

10) Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or destruction. Examples may include role-based access controls, encryption in transit, environment hardening, and audit logging aligned to our hosting provider's capabilities.

IMPORTANT: NO SYSTEM IS COMPLETELY SECURE. YOU ARE RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF YOUR ACCOUNT CREDENTIALS AND FOR ACTIVITIES UNDER YOUR ACCOUNT.

11) Your Privacy Choices and Rights (General)

Depending on your jurisdiction and relationship with FitFaction (e.g., end user vs. institution administrator), you may have the ability to:

Access / Know the personal information we maintain about you;

Correct / Update inaccurate information;

Delete personal information (subject to legal/contractual exceptions);

Opt Out of non-essential communications; and

Appeal a rights request decision (where applicable).

Submit requests to info@fitfactionllc.net. We will verify your identity using information reasonably related to your account or request. If we refuse your request (e.g., due to legal constraints), we will explain why and how to appeal, if applicable. If your account is tied to an institution, we may redirect or coordinate with the institution pursuant to the University Agreement/DPA.

12) U.S. State-Specific Privacy Rights

Texas (TDPSA). Based on current facts (pre-launch; no users; no revenue; small-business status), FitFaction is not currently subject to the Texas Data Privacy and Security Act. If operations change such that TDPSA applies, we will update this Policy and implement compliant mechanisms (including recognition of applicable opt-outs and disclosures).

Other States (e.g., CA, CO, CT, VA, UT). If and when these laws apply, we will provide state-specific notices, honor applicable consumer rights (access, correction, deletion, portability; opt-out of sales/sharing/targeted advertising; limits on sensitive data), and publish required disclosures (e.g., "Notice at Collection" for California). Until such time, we apply the general rights process described above.

WE DO NOT SELL PERSONAL INFORMATION, DO NOT SHARE FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING, AND DO NOT USE SENSITIVE PERSONAL INFORMATION FOR INFERRING CHARACTERISTICS, AS OF THE EFFECTIVE DATE.

13) Children's Privacy

The Services are intended for individuals 18+. We do not knowingly collect personal information from minors. If you believe a minor has provided information to us, please contact info@fitfactionllc.net so we can take appropriate action (e.g., deletion) without unreasonable delay.

14) International Users; Data Location

FitFaction primarily processes data in the United States. If you access the Services from outside the U.S., you understand that your information may be transferred to, stored in, and processed in the U.S., where data protection laws may differ from those in your jurisdiction. Where required, we will implement appropriate safeguards for cross-border transfers.

15) Third-Party Sites, Plug-Ins and Social Features

The Services may include links to third-party websites or integrate third-party components. FitFaction does not control and is not responsible for third-party content or privacy practices. Your use of third-party services is governed by their terms and privacy policies. We recommend reviewing those policies before interacting with them.

16) Communications and Marketing

We may send administrative emails (e.g., service announcements, security alerts). You cannot opt out of administrative communications that are necessary to provide the Services. For non-essential messages, you may opt out via unsubscribe links or by contacting info@fitfactionllc.net.

17) Changes To This Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the Effective Date at the top and provide additional notice as appropriate (e.g., in-product notice or email). Your continued use of the Services after the effective date of the update constitutes acceptance of the revised Policy.

Version history:

v1.0 (Mar 12, 2026) – Comprehensive pre-launch draft.

18) Governing Law

This Privacy Policy is governed by the laws of the State of Texas, without regard to conflict-of-laws principles. Venue and dispute resolution for end users are addressed in the Terms and Conditions.

19) Contact

FitFaction, LLC

5900 Balcones Drive, Ste 100

Austin, TX 78731, USA

Email: info@fitfactionllc.net

© 2026 FitFactionllc.net. All rights reserved.


Appendix A — Summary of Data Handling (At Launch)

Category Examples Purpose Primary Recipients
Account/Eligibility Name; university email; affiliation; eligibility status Account setup; access control FitFaction; institution admins (limited)
Profile (optional) Interests; availability; photo Discoverability; coordination Other eligible users; FitFaction
Communications Support emails; in-app messages Delivery; support; safety moderation FitFaction; limited, policy-driven moderation tooling
Device/Usage IP; device/browser; pages/screens viewed Security; performance; analytics FitFaction; cloud/analytics providers
Institution Data Domain verification; admin contacts Subscription management; compliance FitFaction; institution admins

Note: We do not sell personal information, and we do not share personal information for cross-context behavioral advertising as of the Effective Date.