App Privacy Policy
Headlights Inc. ("Headlights", "we" or "us") presents this privacy policy, as may be amended from time to time (the "Privacy Policy") in order to provide our users ("User", "you" or "your") information about Headlights’s practices in relation to Personal Information that is collected, used and/or otherwise processed by Headlights, through its mobile application named "Recapp" (the "App") and its related services.
The App and its related services help you follow your favorite teams and leagues, with personalized highlights and stories.
This Privacy Policy supplements our Terms of Use and App Tracking Technology Policy.
Please note that a separate privacy policy applies to our website – available at Privacy policy.
If you have questions or concerns regarding this Privacy Policy, please contact us at fans@Recapp.co
WE STRONGLY URGE YOU TO READ THIS PRIVACY POLICY CAREFULLY BEFORE YOU START TO USE OUR SERVICES.
PERSONAL INFORMATION WE PROCESS AND PURPOSES OF PROCESSING
For the purpose of this Privacy Policy, "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information.
| Category of Personal Information | How we collect Personal Data | Purposes | Example of use of Personal Information |
|---|---|---|---|
|
Information automatically collected or generated from the App, including extracted by the App from the mobile device, includes: • Usage Data, meaning information about your interactions with the App, such as content access, click on, the frequency of access, and time spent on the App. • Device Information, meaning information about your mobile device, including model, operating system, settings used and unique device identifiers. |
Such data is automatically collected or generated from the App. We use log files as tracking technologies to store and retrieve this information on a User’s system and mobile device, and track Users’ online activities. For more information, please read our Tracking Technology Policy. |
Providing access to and use of the App and its related services |
• to automatically identify you when you return to the App • to deliver customized content to you. |
| Improving the App and its related services |
• to monitor and analyze your use of the App • to develop, customize and improve the App • to determine popular services • to create statistics for further development, and analysis |
||
| Supporting and enhancing data security measures of the App and its related services |
• to prevent and mitigate the risks of fraud, error or any illegal or prohibited activity • technical administration and troubleshooting of the App • to diagnose and repair service errors, and, in cases of abuse, track and mitigate the abuse. |
||
| Managing disputes and litigation |
• to manage any dispute or litigation involving you with respect to the App and its related services • to establish, protect, or exercise our legal rights • as required, to enforce the Terms of Use or other contracts • to defend against legal claims or demands. |
||
| Compliance with legal and regulatory obligations |
• to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities • to process your requests to exercise your rights • to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. |
WITH WHOM DO WE SHARE PERSONAL DATA?
We may share your Personal Information with certain third parties, as follows:
1. With our Israeli Entity Your Personal Information will be shared with the U.S. entity of the group for research and development.
2. Service Providers and Contractors, including data hosting services, data security services, fraud detection and prevention services, session or activity analytics services, content transcription and analysis services, performance measurement, content and data enrichment providers, insurers. We only provide such service providers and business partners with Personal Information so they can perform their required functions on our behalf.
3. Governmental, Administrative or Judiciary Authorities. We will disclose or allow government and law enforcement officials access to certain Personal Information, exclusively in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
4. Corporate Transactions. We may share Personal Information in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
5.Lawyers and Interested Parties. We will share Personal Information exclusively in case of the management of possible disputes and other legal matters where appropriate, including with respect to the App and its related services; to establish, protect, or exercise our legal rights; as required to enforce the Terms of Use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights.
6. Virtual Store (Apple Store). To the extent required, we will share certain Personal Information with the virtual store, in order to comply with our contractual obligations pertaining to the use of the virtual store.
HOW LONG DO WE STORE YOUR PERSONAL INFORMATION FOR?
1. We retain Personal Information for as long as a User is using our App and its related services.
2. Other circumstances in which we will retain your Personal Information for longer periods of time include:
where we are required to do so in accordance with legal and regulatory requirements, or
for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or
if we reasonably believe there is a prospect of litigation.
3. Please note that except as required by applicable law, we will not be obligated to retain your Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
1. We endeavor to maintain appropriate technical and organizational measures compliant with industry standards to protect Personal Information in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Personal Data is saved anonymously (no username, email or identifier of the User) and all external services (SaaS) are requiring authentication and authorization and saved in U.S. datacenters alone.
2. However, although we make every effort to protect the Personal Information which you provide to us or we generate, we cannot completely ensure the security of any Personal Information you transmit to us over the internet or guarantee that this Personal Information will not be accessed, disclosed, altered, or destroyed nor do we have any control over the security measures incorporated by the virtual store where the App is hosted.
3. If you have found a vulnerability or would like to report a security incident, you may send an email to fans@Recapp.co
WHAT RIGHTS DO YOU HAVE REGARDING PERSONAL DATA?
General Provisions
1. If our processing of your Personal Information is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Right Act of 2020 ("CCPA"), you are entitled to the following rights:
Right to Know what Personal Information we Have Collected. You have the right to request what Personal Information we have collected, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose(s) for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
Right to Deletion. You have the right to request the deletion of your Personal Information that we collect or maintain, subject to certain exceptions.
Right to Correction. You have the right to request the correction of your inaccurate Personal Information that we maintain about you.
Right to Opt-Out from Selling. You have the right to opt-out of the sale of your Personal Information to third parties. We do not have actual knowledge that we sell Personal Information.
Right to Opt-Out of the Use of Automated Decision Making. In certain circumstances and to the extent applicable, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
Right to Limit the Use or Disclosure of Sensitive Personal Information (SPI). Under certain circumstances, if we use or disclose SPI, you have the right to limit the use or disclosure of SPI.
Right to Data Portability. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.
Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights regarding your Personal Information under the CCPA.
2. Only you may make a request related to your Personal Information. If you are a California resident a request can be made by a person registered with the California Secretary of State that you authorize to act on your behalf, in such event you must provide us with signed documentation that you have authorized an agent to act on your behalf.
3. When you ask us to exercise any of your rights under this Privacy Policy and the applicable laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of your request. We may redact from the Personal Information we will make available to you any Personal Information related to others.
4. You can exercise your above rights by sending us an email to fans@Recapp.co.
CHILDREN
1.The App and its related services are directed towards and designed for use by persons aged 13 and older. We do not solicit or knowingly collect Personal Information from children under the age of 13.
2.If we nevertheless receive Personal Information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 13, we will endeavor to delete such Personal Information from our systems.
3.If you are an individual under the age of 13, you are required not to use our App, and de-install the App from your mobile device.
OPT-OUT OPTIONS
1.Interest-Based Advertising ("IBA"). We do not sell your Personal Information. The App may provide you with advertisements therefore we may “share” your Personal Information with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your Personal Information with third parties for the purpose of cross-contextual interest-based advertising there are many ways to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.
2.For IBA opt-out options on desktop and mobile app, please visit:
Digital Advertising Alliance (US) https://www.aboutads.info/choices/
Network Advertising Initiative https://optout.networkadvertising.org/?c=1
CHANGES TO THIS PRIVACY POLICY
1. This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new privacy policy in our App accompanied with a notice indicating that some changes have been made. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy. The new privacy policy will be effective from the date mentioned at the top page of the new privacy policy.
2.If there are any material changes to the Privacy Policy, we will notify you by prominently posting on the App.
3.Your continued use of the App after we post such notice constitutes your agreement to any such changes.
CONTACT INFORMATION AND DATA CONTROLLER INFORMATION
If you have any questions about this Privacy Policy, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Information, please contact us as follows:
By email: fans@Recapp.co.
By Mail:
Headlights Inc.
800 North State Street, Suite 304, Kent County, Dover, DE 19901
Version: March 26, 2025
ADDITIONAL CALIFORNIA PRIVACY NOTICE
This California Privacy Notice is an integral part of our Privacy Policy, and thus, the information provided herein is in addition and supplementing the information provided through the Privacy Policy.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
1.As detailed in the table below we do not collect nor process Sensitive Personal Information ("SPI").
2.We have collected the following categories of Personal Information within the last twelve (12) months:
| Category | Example | Collected | Comment |
|---|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
⬜ No ☒ Yes |
Installation ID (or Anonymous ID) and IP address |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
☒ No ⬜ Yes |
________ |
| C. Protected classification characteristics under California or federal law. | Age (40+), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, disability, sex, gender identity, sexual orientation, military status, genetic info. |
☒ No ⬜ Yes |
________ |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
☒ No ⬜ Yes |
________ |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or identifier, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
☒ No ⬜ Yes |
________ |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
⬜ No ☒ Yes |
Information on a consumer’s interaction with our App (e.g., through cookies). |
| G. Geolocation data. | Physical location, approximate location derived from IP address or movements. |
⬜ No ☒ Yes |
IP address and approximate location |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. |
☒ No ⬜ Yes |
________ |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. |
☒ No ⬜ Yes |
________ |
| J. Non-public education information | Education records such as grades, transcripts, class lists, student schedules, financial info, or disciplinary records (as defined by FERPA). |
☒ No ⬜ Yes |
________ |
| K. Inferences drawn from other personal information. | Profile reflecting preferences, characteristics, psychological trends, behavior, intelligence, etc. |
☒ No ⬜ Yes |
________ |
| L. Sensitive personal information. | Gov-issued IDs, financial data, biometric, health data, precise geolocation, beliefs, union membership, communication content, sexual orientation. |
☒ No ⬜ Yes |
________ |
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
1.We may disclose your Personal Information to service providers and contractors as described in section 3.1.2 to the Privacy Policy above.
2.In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
| # | Category (corresponding with the table above) | Category of Recipient | Business Purpose |
|---|---|---|---|
| 1 | Category A Category F |
Government Entities / Law Enforcement | Subject to a lawful request, such as from tax and social security authorities. |
| 2 | Data analysis providers | Providing analytic data on the use of our App. | |
| 3 | Various service providers | Improving the services, development, and optimization. | |
| 4 | Affiliated companies (U.S. entity) | Customer and technical support |
SALE OR SHARE OF PERSONAL INFORMATION
1.In the preceding twelve (12) months, we did not “sell” information as most people would commonly understand that term, we did not disclose your Personal Information in direct exchange for money or some other form of payment. However, for retargeting and analytic purposes, when we promote our App and its related services, we use third-party tools that are able to market our App online, measure these marketing efforts, identify individuals that are interested in our App, etc. This is done by placing cookies, pixel or other tracking technology on our website and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.
2.In the preceding twelve (12) months, we did “sell” or “share” the following categories of Personal Information for a business purpose:
| Category (corresponding with the table above) | Category of Recipient | Purpose of Sale or Share |
|---|---|---|
| Category A Category F |
Marketing tools and vendors | Promoting the App and its related services. |
CHILDREN UNDER AGE 16
We do not knowingly collect Personal Information from children under the age of 16.
DIRECT MARKETING REQUESTS
California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an email to fans@Recapp.co
DO NOT TRACK SETTINGS
Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.