Privacy Policy

Effective Date: [Month Day, Year]
Last Updated: [Month Day, Year]

This Privacy Policy describes how 3 Amigos Holdings LLC (“3 Amigos Holdings,” “we,” “us,” or “our”) collects, uses, discloses, stores, processes, and otherwise handles information in connection with our websites, mobile applications, products, software, tools, features, communications, and related services (collectively, the “Services”).

This Privacy Policy applies to all current and future consumer-facing services, apps, websites, and digital products operated, published, owned, licensed, or controlled by 3 Amigos Holdings LLC, including services made available through our website at amigosholdings.com, app stores, and any other online or offline channel that links to or references this Privacy Policy.

By accessing or using any of the Services, you acknowledge that your information will be handled as described in this Privacy Policy, subject to applicable law.

1. Scope

This Privacy Policy applies to information we collect:

• directly from you;
• automatically when you use the Services;
• from devices associated with you;
• from our affiliates, subsidiaries, contractors, service providers, business partners, analytics providers, advertising partners, app stores, device platforms, payment processors, identity providers, and other third parties;
• from publicly available sources; and
• from inferences and derived data generated from the foregoing.

This Privacy Policy does not apply to third-party products, services, websites, or applications that we do not own or control, even if they are linked to or accessible through the Services.

2. Information We Collect

Depending on the Service you use and how you interact with it, we may collect the following categories of information:

A. Identifiers and Contact Information

• name, username, display name, alias, and account identifiers;
• email address, phone number, mailing address, billing address, and shipping address;
• customer service records and related identifiers;
• other similar identifiers.

B. Account and Profile Information

• login credentials, authentication data, account settings, profile information, and preferences;
• age or age range, interests, goals, survey responses, and optional demographic information;
• referral information and invite-related data.

C. Commercial and Transaction Information

• subscription status, purchase history, order information, receipts, refunds, renewals, and promotional redemptions;
• billing details and payment-related data collected by us or on our behalf by payment processors;
• information relating to offers, discounts, rewards, incentives, or affiliate interactions.

D. Device, Technical, and Network Information

• IP address, device identifiers, advertising identifiers, browser type, device model, operating system, carrier, language, time zone, and app version;
• crash logs, diagnostics, performance data, debugging data, and other technical telemetry;
• device event information and system activity.

E. Usage and Activity Information

• pages, screens, content, and features viewed or used;
• taps, clicks, searches, scrolls, session duration, referring URLs, conversion data, and interaction patterns;
• dates, times, frequency of use, and engagement information;
• communications and activity within the Services.

F. Location Information

• approximate location derived from IP address, device settings, or other signals;
• precise geolocation where permitted by your device settings and applicable Service functionality.

G. User Content

• photos, videos, recordings, messages, prompts, feedback, reviews, comments, documents, notes, uploads, and other content you submit or create through the Services;
• metadata associated with such content, including timestamps, technical metadata, and geotags where available.

H. Contacts and Social Information

• contact information or address book data if you choose to connect, upload, sync, or invite others;
• information from linked social media, single sign-on, or other third-party accounts;
• communications between you and us, including support requests and related records.

I. Sensitive and Similar Information

Depending on the nature of a Service, we may collect information you choose to provide or permit us to access that may be considered sensitive under applicable law, such as:

• health, wellness, habit, treatment, or symptom information;
• photos or videos depicting physical characteristics;
• precise location data;
• account credentials;
• financial information;
• communications content; and
• other categories that may be treated as sensitive under applicable law.

J. Inferences and Derived Data

• preferences, interests, behavioral tendencies, customer segment classifications, and predicted engagement;
• scores, rankings, recommendations, measurements, analytics, or insights generated through algorithms, machine learning, statistical methods, or other automated processing.

3. Sources of Information

We may collect information from the following sources:

• directly from you;
• automatically from your browser, app, or device;
• our affiliates and related companies;
• app stores, device platforms, and operating systems;
• payment processors and subscription management providers;
• analytics, attribution, fraud-prevention, and advertising vendors;
• business partners, integrations, and API providers;
• publicly available sources;
• marketing partners, data providers, and other third parties where permitted by law.

4. How We Use Information

We may use information for any lawful business or commercial purpose, including to:

• provide, operate, maintain, support, and improve the Services;
• create, authenticate, administer, and service accounts;
• process transactions, subscriptions, renewals, payments, refunds, and related requests;
• personalize content, recommendations, features, and user experiences;
• communicate with you about the Services, your account, transactions, updates, support issues, promotions, surveys, and administrative matters;
• analyze usage, trends, engagement, and product performance;
• monitor, troubleshoot, test, audit, research, and improve our products and systems;
• develop new products, features, and offerings;
• train, evaluate, improve, and validate algorithms, artificial intelligence systems, machine learning models, and other automated tools;
• detect, prevent, investigate, and respond to fraud, abuse, security incidents, unauthorized access, harmful conduct, or illegal activity;
• enforce our terms, policies, and contractual rights;
• comply with legal obligations and respond to lawful requests;
• protect the rights, property, safety, and security of us, our users, our partners, and others;
• carry out internal business operations;
• support advertising, marketing, attribution, retargeting, audience building, and campaign measurement;
• create aggregated, de-identified, anonymized, or pseudonymized data sets and use them for analytics, commercialization, benchmarking, research, product improvement, and other lawful purposes; and
• otherwise use information with your consent or as disclosed at the time of collection.

5. How We Disclose Information

A. Affiliates and Related Entities

We may share information with our parents, subsidiaries, affiliates, successors, brands, and other entities under common ownership or control for purposes consistent with this Privacy Policy, including account management, analytics, personalization, product development, support, security, and business operations.

B. Service Providers and Contractors

We may share information with vendors, consultants, contractors, and service providers that perform services on our behalf, including cloud hosting, storage, analytics, communications, customer support, fraud prevention, identity verification, content moderation, infrastructure, development, payment processing, email delivery, AI processing, and professional services.

C. Business Partners and Integrations

We may share information with business partners, co-branded partners, referral partners, API providers, and integration partners in connection with features, products, promotions, referrals, linked accounts, and services you request or authorize.

D. Advertising, Analytics, and Marketing Partners

We may disclose identifiers, technical data, usage data, approximate location, commercial information, and inferences to advertising, analytics, attribution, and marketing partners for campaign performance, measurement, audience creation, personalization, retargeting, and related purposes, subject to applicable law.

E. Legal, Regulatory, and Safety Recipients

We may disclose information where we believe it is necessary or appropriate to:

• comply with applicable law, regulation, legal process, or government request;
• enforce our terms, agreements, and policies;
• protect our rights, property, or interests;
• protect the safety, rights, or property of users, third parties, or the public;
• investigate, detect, or prevent fraud, abuse, or security issues.

F. Business Transfers

We may disclose, transfer, or assign information in connection with any actual or contemplated merger, acquisition, sale of assets, financing, reorganization, bankruptcy, receivership, due diligence process, or similar business transaction.

G. With Your Direction or Consent

We may disclose information to third parties when you direct us to do so or otherwise consent.

H. Aggregated or De-Identified Information

We may disclose aggregated, anonymized, de-identified, or otherwise non-personal information for any lawful purpose.

6. Cookies, SDKs, and Similar Technologies

We and our partners may use cookies, pixels, tags, SDKs, APIs, local storage, web beacons, session replay tools, and similar technologies to:

• remember preferences;
• authenticate users;
• operate and secure the Services;
• collect analytics and performance data;
• understand behavior and usage patterns;
• personalize content and features;
• support advertising, attribution, and marketing;
• detect fraud and abuse.

These technologies may collect information across devices, sessions, websites, apps, and services over time, subject to applicable law.

You may be able to control certain technologies through your browser or device settings, app permissions, cookie preferences, or other controls we provide, though disabling some technologies may affect functionality.

7. Cross-Service and Cross-Device Processing

We may combine information collected across multiple Services, websites, apps, devices, identifiers, and channels operated by or on behalf of 3 Amigos Holdings to:

• create unified accounts or profiles;
• personalize experiences;
• improve the Services;
• support analytics and marketing;
• detect fraud and misuse;
• enforce policies;
• administer our business and offerings.

8. Artificial Intelligence and Automated Processing

Certain features may use artificial intelligence, machine learning, computer vision, natural language processing, rules engines, ranking systems, recommendation engines, or other automated processing tools to analyze inputs, generate outputs, personalize experiences, classify content, moderate content, detect patterns, detect fraud, and improve the Services.

By submitting prompts, messages, photos, videos, audio, documents, or other content to AI-enabled features, you acknowledge that such content may be processed by automated systems and by service providers acting on our behalf, subject to applicable law and our agreements with those providers.

Automated outputs may be inaccurate, incomplete, or inappropriate and should be independently reviewed where material.

9. User Content License

To the extent permitted by applicable law and our Terms of Service, you grant us and our service providers a non-exclusive, worldwide, royalty-free right to host, store, reproduce, process, adapt, analyze, transmit, display, and otherwise use content you submit through the Services as reasonably necessary to:

• provide and improve the Services;
• operate and maintain our systems;
• develop new products and features;
• conduct analytics, testing, moderation, and security review;
• train and improve models and automated systems; and
• support our business operations.

10. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide the Services;
• maintain your account;
• complete transactions;
• comply with legal, tax, accounting, regulatory, and reporting obligations;
• resolve disputes;
• enforce our agreements; and
• protect our business interests and the security and integrity of the Services.

Retention periods vary depending on the type of information, the Service involved, legal requirements, operational needs, and whether information has been de-identified or aggregated.

11. Data Security

We use commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information. However, no security system is perfect, and we cannot guarantee absolute security of any information.

You are responsible for maintaining the confidentiality of your account credentials and using the Services in a reasonably secure manner.

12. International Data Transfers

We and our service providers may process and store information in the United States and other jurisdictions where we or our providers operate. Those jurisdictions may have data protection laws that differ from those in your state, province, or country.

Where required by applicable law, we will use appropriate safeguards for cross-border transfers of personal information.

13. Your Rights and Choices

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

• know, access, or obtain a copy of certain personal information;
• request deletion;
• request correction of inaccurate information;
• opt out of certain targeted advertising, profiling, sale, or sharing practices;
• limit certain uses of sensitive personal information;
• withdraw consent where processing is based on consent;
• appeal decisions on privacy requests; and
• not be discriminated against for exercising applicable privacy rights.

We may take reasonable steps to verify your identity before responding to a request. We may deny or limit requests where permitted by law.

To submit a privacy request, contact us at:

14. U.S. State Privacy Disclosures

If you are a resident of a U.S. state with an applicable privacy law, you may have additional rights and disclosures available to you. Subject to applicable law, we may collect, use, disclose, sell, or share the categories of information described in this Privacy Policy for the business and commercial purposes described above.

We may use or disclose sensitive personal information for purposes permitted by law, including to provide requested services, maintain security, prevent fraud, perform internal analytics, improve quality, operate the Services, and for other purposes permitted by applicable law or based on consent where required.

Where applicable law requires specific notices, opt-out mechanisms, consent flows, or limitation rights, we may provide those through the relevant Service, website, or notice at collection.

15. Children’s Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 in violation of applicable law. If you believe a child has provided personal information in violation of applicable law, contact us and we will take appropriate steps.

If a particular Service is intended for a different minimum age, additional notices or terms may apply.

16. Third-Party Services

The Services may contain links to, or integrations with, third-party websites, applications, content, APIs, SDKs, payment systems, social media services, and other tools that we do not control. Their privacy practices are governed by their own terms and policies, not this Privacy Policy.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will become effective when posted unless otherwise stated. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acknowledgment of the revised Privacy Policy to the extent permitted by law.

18. Contact Us