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Privacy and Security Policy

1. Background

This is the official privacy and security policy (“Privacy Policy”) for the Rebel Holdings website located at the URL: http://rebel.fun (referred to herein, together with all Content available through the http://rebel.fun domain name and/or other related domain names which may point or direct a visitor to this website and any related websites or Apps on the Rebel Holdings Platform, as the “Website”). The Website is owned and provided by Rebel Holdings Inc, a Delaware corporation (“Rebel Holdings” or “us” or “we”). This Privacy Policy is also part of, and is subject to, the terms of service (the “Terms of Service”) for the Service of Rebel Holdings therein described, which can also be found at the Website. Capitalized terms used herein and not otherwise defined have the meaning set forth in the Terms of Service. In this Privacy Policy, “you” and “your” mean any visitor to the Website, and any Customer or User of the Service under the Terms of Service.

By using the Website and/or the Service, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by it and the Terms of Service. If you do not agree to this Privacy Policy or Terms of Service, do not use the Website or Service, or provide any information through or at the Website or Service.

This Privacy Policy is intended to apply only to the Personal Information collected by Rebel Holdings as a result of your use of the Website or Service, and does not cover any information collected in any other manner, for any other purpose or by any other website or enterprise. When we refer to “Personal Information” in this Privacy Policy, we mean information such as your name, address, telephone number, blog or other personal website URL, date of birth (but not general age range), e-mail address, credit card and billing information, and banking, account and related financial information used in connection with Payment Processing Services (as defined below), and any other information that would allow someone to identify you or contact you. Personal Information also includes information about your personal preferences, survey responses and your transactions or relationship with the Website or Services, if you have been a Customer or User or you have provided this type of information to us. Providing your Personal Information to us may enable you to use the Service or various functions or features of it, receive offers, participate in community discussions, beta tests, promotions, trial offers, chat rooms, online bulletin boards, to receive text messages and/or emails, to subscribe to newsletters or mailing lists, or to purchase products and services using the Website or Service.

Rebel Holdings reserves the right, without advance notice to you, to revise this Privacy Policy and/or the Terms of Service at any time by posting the revisions and/or the revised Privacy Policy or Terms of Service on the Website and, from time-to-time, may also require you to affirmatively acknowledge and affirm your review and acceptance of updates to the provisions of this Privacy Policy or Terms of Service; provided, however, whether or not we choose to implement such measures will be determined solely by us and you must recognize that once we post such revisions, they shall be effective and binding upon you immediately upon posting. Rebel Holdings therefore encourages you to check this Privacy Policy and our Terms of Service on the Website often for updates. Rebel Holdings may also e-mail you about any changes to this Privacy Policy or the Terms of Service when they have been made. Keeping the Personal Information you share with us on the Website or through the Service secure and ensuring your understanding of how Rebel Holdings collects, uses, discloses and maintains your Personal Information is important to Rebel Holdings. Rebel Holdings endeavors to maintain reasonable physical, electronic and procedural safeguards to protect your Personal Information.

2. General Privacy Information

Rebel Holdings is not intended for use by users under the age of 13, and no one under age 13 is allowed to use the Website or Service, or provide any Personal Information to Rebel Holdings.

You are required to, and agree to, provide true, current, complete and accurate Personal Information to Rebel Holdings when prompted, and Rebel Holdings will reject and delete any entry or submission that Rebel Holdings believes in good faith to be false, fraudulent, or inconsistent with this Privacy Policy.

Your continued use of the Website or Service indicates your acceptance of this Privacy Policy and of the collection, use, disclosure, management and storage of your Personal Information as described herein. Rebel Holdings may, from time to time, transfer or merge any Personal Information collected off-line to online databases or store off-line information in an electronic format. Rebel Holdings may also combine Personal Information Rebel Holdings collects online with information available from other sources, including information received from our Affiliates, licensors, third party providers, or marketing companies. This Privacy Policy covers all such Personal Information and will remain in full force and effect in accordance with the Terms of Service, even if your use of the Website or Service, or your participation in any particular service, function, feature or promotional activity in connection therewith, terminates, expires, ceases, is suspended or deactivated for any reason.

3. Collection and Use of Personal Information

Rebel Holdings collects Personal Information about you when you use the Website or Service and when you input information or provide a review or comment in community discussions, participate in promotions, purchase products or services or otherwise in the course of any other exchanges of information, transactions and activities involving you and the Website or Service. Rebel Holdings may use the information Rebel Holdings obtains from you, including Personal Information, to tailor your experience with the Website and/or Service, to display Content Rebel Holdings thinks may be of interest to you, or to let Rebel Holdings customize what you see when you use the Website and Service according to your preferences.

Rebel Holdings may integrate the Website and Service with third party products and services that you may decide to use, but only at your sole risk. In such cases, Rebel Holdings may share some of your Personal Information with the third parties providers of products or services, which may enable them to market directly to you, provided you opt-in to such use when you provide Personal Information on or through the Website or Service, or, if applicable, do not opt-out from such use. Rebel Holdings does not warranty or guaranty such integrations or third party products and services, and is not responsible for, and shall have no liability, directly or indirectly, arising out of your use of any such integrations or the third party products and services obtained thereby.

It is your responsibility to give Rebel Holdings current, complete, truthful and accurate information and to keep the Personal Information that you provide to Rebel Holdings up to date. Rebel Holdings is not responsible for any problems or liability that may arise if you do not give Rebel Holdings complete, truthful and accurate information or you fail to update the information you give Rebel Holdings.

You are solely responsible for maintaining the strict confidentiality of your login information, and for any charges, costs, expenses, damages, liabilities and losses we incur or may suffer as a result of your failure to do so. You are solely responsible and liable for your activity, behavior, use and conduct on the Website and in connection with the Service and for any use of the Website or Service or any other activity or conduct in connection with the Website or Service by any others who use your User name and password, unless and until you notify Rebel Holdings that your User name and/or password may have been compromised, misappropriated or improperly taken, or used by another party. Bear in mind that when you submit information to Rebel Holdings, it does not guarantee that Rebel Holdings will permit you to use any or all of the functions or features of the Website or Service.


When you register with the Website or Service, you may be required to provide Rebel Holdings with your full legal name and valid e-mail address, and may also be required to provide certain additional Personal Information, including certain credit card and billing information and banking, account and related financial information used in connection with Payment Processing Services if you elect to subscribe to the Service, utilize certain functions and features of the Service or, in certain instances, make a purchase of products or services offered on or through the Website or Service. Rebel Holdings will allow you to change the password associated with your User name, as well as certain other Personal Information you have given Rebel Holdings in order to keep your Personal Information current. Among other things, this kind of information helps Rebel Holdings securely identify you as a Customer or an authorized User of the Website and Service and the functions and features thereof which you have registered or are otherwise authorized to use. As a Customer or registered User of the Website and/or Service, from time to time, Rebel Holdings may also provide you with certain options to opt-in, opt-out or subscribe to e-mail newsletters, SMS text messaging and other periodic information.

By accessing and using the Website or Service, whether as a visitor, Customer or authorized User, you acknowledge, understand and agree that you are giving Rebel Holdings your consent to track your activities, your use of the Website and Service and its various functions and features, and that you agree to this Privacy Policy and our Terms of Service with you.

We collect your phone number specifically for the purpose of communicating with you via SMS text messaging. We do not share or sell your phone number with any third party.


Rebel Holdings may ask you to provide your credit card and billing information and banking, account and related financial information (all of which constitutes Personal Information), in electronic or other formats (including fillable online forms), when subscribing to the Service, purchasing a function or feature thereof, or purchasing any other product or service offered by the Website or Service using a Payment Instrument (as defined below), some of which may involve recurrent periodic charges, such as in the case of the purchase of subscription services, which are typically billed and charged in advance in monthly or annual intervals. Before providing a product or service to you, including, without limitation, the Service, Rebel Holdings is not responsible to verify that the credit card, debit card or other Payment Instrument and any related Personal Information which you have provided is current and valid. All such Payment Instrument information is used for Payment Processing Services only (and it not used for direct marketing purposes) and is shared with third parties only as necessary to effect such Payment Processing Services. All credit card, debit card and other Payment Instrument information is handled over secure, encrypted connections provided it is submitted by you through the normal registration process. Rebel Holdings does not, however, represent or guarantee that unauthorized access will never occur.

For purposes herein, (A) “Payment Processing Services” means (i) all services necessary to authorize, data capture, process, settle and reconcile transactions for your purchase of products and services (“Transactions”) using Payment Instruments, (ii) all services necessary to authorize, data capture and process (and, when permitted by the applicable Payment Brand (defined below), settle and reconcile) Transactions with you using Payment Instruments, (iii) check guarantee and electronic check acceptance services, (iv) other related products and services, including point of sale terminal equipment and other electronic payments at the point of sale; and (v) unless the context requires otherwise, such term includes related Transaction services, chargeback and retrieval processing, point of sale hardware deployment and service, interchange settlement and risk management (including new application approval); (B) “Payment Instrument” means a payment card, an account, or evidence of an account, authorized and established between you and a Payment Brand and accepted by Rebel Holdings as payment for the Service, function or features thereof, or other products or services, and includes, without limitation, credit and debit cards, stored value cards, electronic gift cards, authorized account or access numbers, paper certificates and credit accounts; and (C) “Payment Brand” means Visa, MasterCard and any other association, payment brand, Payment Instrument issuer, debit network or payment methodology or system having proprietary rights to and clearing and oversight responsibilities with respect to any Payment Instrument used to effect payment-related transactions for which any Payment Processing Services are provided by Rebel Holdings in connection with Transactions.

6. promotions and offers

From time to time, Rebel Holdings or its Customers may provide promotions and offers (“Promotions”) through the Website and Service. Registration may be required to participate in such Promotions. The Promotions may have a separate registration or participation process and may require your submission of Personal Information. The Promotions may have an entry page and/or rules that will provide you with the specific requirements for the Promotion involved. You may also have the opportunity to opt-in to or opt-out of special Promotions from the Website or Service.

Rebel Holdings and third party providers of products and services may contact Customers, Users or others that have registered for or participated in various Promotions, transactions or events, or send offers to you for the purchase of products and/or services that may be of interest to you. If you do not want to receive such e-mails, you may use the opt-out mechanism that is contained in the e-mails Rebel Holdings sends you. However, Rebel Holdings may nevertheless continue to contact you via e-mail for administrative or informational purposes, including follow-up messages regarding the Service, your account, requests or inquiries, any functions or features of the Service or other products or services that you have ordered, or other transactions that you have undertaken with the Website or Service.

7. Polls & Surveys

Rebel Holdings may from time to time request that you participate in polls and/or surveys. The information you provide to Rebel Holdings if you participate in such polls or surveys is provided voluntarily by you. If you participate in polls or surveys, you do so with the understanding that Rebel Holdings reserves the right to store the information you provide and to use such information for the general improvement of the Website and Service.

8. Use of Communities

Rebel Holdings may provide community discussions pages and/or similar functions and features on or through the Website or Service (e.g. discussion boards, blogs, product or service reviews). Please remember that any information disclosed in these venues is automatically made public and may appear on other websites or web searches. You should exercise caution when disclosing any Personal Information in such communities, as you do not know who will access and use your Personal Information or for what purposes. Rebel Holdings will be in no way responsible for the accuracy, use, or misuse of any information that you disclose or receive through these venues, if any, and you should assume that any disclosure you do make in these venues will be available publicly, even without your knowledge or authorization. Additionally, to the extent that the Website or Service allows you to send information to others, Rebel Holdings may, but is not obligated to, monitor such messages via electronic software or personnel to check for obscenity, defamation or other types of abusive language, as well as for content that may infringe Rebel Holdings’ rights or the rights of others or otherwise violate the Terms of Service, all of which we may remove at any time. Rebel Holdings will not otherwise access these messages except in certain cases, including but not limited to times when we receive specific complaints related to a particular message or are compelled to do so by law, and except as otherwise provided in the Terms of Service. Also, for administrative purposes, Rebel Holdings may opt to keep a log that will include a record of which Customers and Users sent messages and to which Customers, Users, email addresses or other destination they were sent.

9. Sharing of Aggregate Information with Third Parties

Some of the aggregate data Rebel Holdings collects in connection with the Website or Service may be shared with Rebel Holdings’ licensors, third party providers of products and services, and certain other business partners of Rebel Holdings and/or its Affiliates, but Rebel Holdings does not give any Personal Information to them as part of the relationship except as described in this Privacy Policy or otherwise provided in the Terms of Service, or as we explicitly state at the time we request Personal Information from you. Use of tracking technology by such licensors, third party providers or business partners is subject to their own privacy policies.

10. Disclosure to Third Parties

Rebel Holdings currently does not sell, rent, lease or disclose your Personal Information to unaffiliated entities, except in the limited circumstances referenced herein or in the Terms of Service, and except to Rebel Holdings’ licensors or third party providers of products or services integrated into the Website or Service or as otherwise explicitly stated by us at the time the Personal Information is requested. When Rebel Holdings discloses your Personal Information as herein provided to such licensors and third parties, Rebel Holdings will ask you to opt-in to do so, or provide you an opportunity to opt-out. If you opt-in, or do not opt-out, as the case may be, such licensors’ and third parties’ use of your Personal Information is subject to the licensors’ or third parties’ own privacy policies. Rebel Holdings may also disclose Personal Information to Affiliates for marketing or administrative purposes or to facilitate the delivery of deals for products and services, news, loyalty programs and other initiatives. Other websites that may be accessible through the Website have their own privacy policies, terms of use and data collection. Rebel Holdings is not responsible for the policies or practices of the operators of such other websites.

11. Operational Service Providers

Rebel Holdings retains the right to disclose your Personal Information to Rebel Holdings’ licensors and other third parties for the purpose of administering and maintaining the Website and the Service, and the functions, features and operations thereof. Rebel Holdings will refer to these licensors and third parties as “Operational Service Providers” and Rebel Holdings uses Operational Service Providers to efficiently provide the full range of the Service and its Content and the services, functions and features we bring you, and we request that our Operational Service Providers also protect your privacy and not disclose your Personal Information to third party marketers that are not associated with the Website or Service. Additionally, such Operational Service Providers are not permitted to use your Personal Information for their own marketing or promotional purposes if the disclosure of your Personal Information is made only for the limited purpose of administering and maintaining the Website or Service or the functions, features and operations thereof.

12. Other Non-Affiliated Third Parties

Rebel Holdings will make your Personal Information available to non-affiliated third parties in the following limited circumstances:

A) When Rebel Holdings is compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process);

B) If Rebel Holdings believes your actions violate any law, regulation, our Terms of Service, this Privacy Policy, or any of our other rules, policies, procedures, offerings or any other services, functions or features of the Website or Service, or if you threaten the rights, property or safety of the Website, the Service, Rebel Holdings, its Affiliates, Customers or Users, or any of its or their service providers, suppliers, advertisers, customers, users or any other party;

C) If, in its sole discretion, Rebel Holdings believes such disclosure to be necessary or appropriate to investigate or resolve possible problems or inquiries, to protect Rebel Holdings’ business and assets, to defend Rebel Holdings ’ interests and/or to comply with our legal and regulatory obligations;

D) Or, in the event of a bankruptcy, merger, acquisition, transfer of control, joint venture or other business combination involving Rebel Holdings.

13. Security AND Protection of Personal Information and customer data

Rebel Holdings maintains reasonable standards of security and confidentiality. It is important to note, however, that for most Internet sites, including the Website and the Service, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. Rebel Holdings limits access to the Website and Service by our own employees to those individuals who are authorized for the proper handling of Personal Information, Customer Data and other information transmitted in connection therewith, and any employee found violating our standards of security and confidentiality will be subject to our disciplinary processes. Rebel Holdings also requests that our service providers follow the same policy.

Except as provided in the Terms of Service, or as may be required by law, Rebel Holdings does not pre-screen Customer Data (as defined in the Terms of Service), and does not review, share, distribute, print, or reference any such Customer Data. Customer Data and other individual records of a person using the Website or Service may at times be viewed or accessed by Rebel Holdings , but only for the purpose of resolving a problem, support issue, or suspected violation of the Terms of Service, or as may be required by law.

14. Reviewing, Updating or Deleting Your Personal Information

Generally, you may review, update or delete your Personal Information contained in your profile which may be accessed through your account settings once you have registered with Rebel Holdings through the Website or Service. You also can, and should, correct factual inaccuracies through these same account settings. While Personal Information that is necessary to check eligibility cannot be deleted, it can be modified with sufficient verification of the correct information. Deletion or attempted deletion of certain Personal Information, such as your Customer or User name, may not be permitted and/or may result in suspension or termination of any registration you may have made. To review, update or delete your Personal Information collected by the Website or Service, please go to your profile page, which may be accessed through your account settings via the Website or Service. Each person who registers through the Website or Service will receive an e-mail or text message to allow their registration. Parents (including legal guardians) of minors that become registered through the Website or Service in violation of the Terms of Service who wish to terminate the minor’s registration must send us an e-mail at info@rebel.fun and provide us with the minor’s User ID or alternatively, a parent must provide verifiable identification that they are the parent of the minor. Rebel Holdings will then provide the parent with further details concerning Rebel Holdings’ policy on terminating registrations by minors. Except as herein provided, Rebel Holdings will not allow direct access to a User’s registration and Personal Information by any person without the User’s User name and password.

15. Cookies

When you visit the Website or use the Service, Rebel Holdings may send one or more cookies (a small text file containing a string of alphanumeric characters) to your computer that uniquely identifies your browser. Rebel Holdings uses cookie technology to collect data regarding your visits to the Website and use of the Service. This data is not stored in aggregate form and may be used to identify any particular Customer, User or individual. Rebel Holdings uses cookies and similar tracking technologies in a variety of ways. Rebel Holdings uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some functions or features of the Website or Service may not operate properly if the ability to accept cookies is disabled.

16. Log File Information

When you use the Website or Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.


When you use the Website or Service, we may employ “clear GIFs” (a.k.a. “Web Beacons”) which are used to track the online usage patterns of our Customers and Users anonymously (i.e., in a non-personally-identifiable manner). In addition, we may also use clear GIFs in HTML-based emails sent to our Customers and Users to track which emails are opened by recipients.

Although Rebel Holdings may track the numbers of visitors to inform Rebel Holdings concerning how best to improve and update the Website and Service and enhance the experience for all visitors, Personal Information is not extracted in this process. Rebel Holdings uses tracking information on an aggregated basis to help Rebel Holdings operate the Website and Service, enhance and improve them, and to display advertising and marketing information.

18. Advertisements; Links

The Website and Service may contain advertisements, references and links to other websites, businesses and organizations. Rebel Holdings may also use third parties to display or serve advertising on the Website or Service and web-based newsletters, emails or other communications which you may choose to receive. Often, these third parties (“Advertisers or Ad Servers”) employ cookie and web bug technologies to measure advertising effectiveness. You should be aware that different rules might apply to the collection, use or disclosure of your information by Advertisers or Ad Servers in connection with their advertisements, promotions and other websites you encounter on the Internet. The use of such technology by these Advertisers or Ad Servers is within their control and not in the control of Rebel Holdings. Even if Rebel Holdings has a relationship with such Advertisers or Ad Servers, Rebel Holdings does not control their sites or their policies and practices regarding your Personal Information. This Privacy Policy does not cover any use of Personal Information that an Advertiser or Ad Server may collect from you, and Rebel Holdings encourages you to investigate and ask questions directly of them in this regard.

19. Reservation of Rights

Rebel Holdings reserves the right to deny access, use and registration privileges to any person, including, without limitation, a Customer or User of the Website or Service, if Rebel Holdings believes there is a question about the identity of the person trying to access and use the Website or Service. If the burden or expense of providing access, use or registration to a person is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide such access, use or registration. In such cases, Rebel Holdings will provide to you an explanation of why access cannot be provided and a contact person for further inquiries.


Rebel Holdings always offers you a choice of how we may use information you provide to us, consistent with this Privacy Policy and the Terms of Service. If at any time after registering with us or providing information to us, you wish to change what information you receive from us, or about our sharing of such information with third parties, please send a request via email to info@rebel.fun . We cannot guarantee that we will make changes but will do out best to make considerations around this.

21. Questions

If you have questions about this Privacy Policy or if you do not understand any information about how Rebel Holdings collects, maintains, uses or shares your personally identifiable information, you may email Rebel Holdings at info@rebel.fun.

Rebel Holdings Privacy and Security Policy – Effective Date: April 1, 2021

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