Legal

App Privacy Policy

Version August 30, 2026

Last updated August 30, 2026

INTRODUCTION AND GENERAL BACKGROUND

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") with information about Headlights’ 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

Definition. 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.

Collection of Personal Data – General Provisions. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Information when you use the App, and the provision of it is solely based on your free will. However, without collection of Personal Information it may not be possible to operate the App and its related services.

Category of Personal Information	How we collect Personal Data	Purposes	Example of use of Personal Information	EEA legal basis (for EEA Users only)
Email address	Such Personal Information is provided voluntarily by you through the App	Joining the beta community (‘Join Recapp Beta’)	• To register and manage your participation in the beta community, such as group discussions, questionnaires, etc. • To provide you with beta-community features, benefits, opportunities, and other services you request • To communicate with you regarding the beta community and your participation	We process your email address as necessary for the performance of our contract with you (i.e., Terms of Use). You may unsubscribe from the beta community at any time via the unsubscribe link included in each email.
• Email address (optional) • Any comments, feedback, suggestions, or other information you choose to add in the feedback form		Managing the received feedback	• To receive, review, and evaluate your Feedback • To respond to your Feedback and communicate with you by email • To request additional information or clarification where necessary • To provide support or address issues raised in your Feedback; and • To improve, develop, maintain the App, our products, services, and user experience.	Our legitimate interests in communicating with our users, understanding their feedback, responding to inquiries, improving and developing the App and our services, and identifying and resolving issues. Where your Feedback constitutes a request to take steps before entering into a contract (Terms of Use), we may process the relevant information where necessary to take steps at your request prior to entering into a contract with you.
Information automatically collected or generated from the App, including information extracted by the App from the mobile device, includes: • Usage Data, meaning information about your interactions with the App, such as content accessed, clicks, frequency of access, and time spent on the App. • Device Information (for iOS only), meaning information about your mobile device, including model, operating system, settings used and unique device identifiers. • Advertising identifiers (for iOS only), such as Google Advertising ID/AAID, and IDFA.	Such data is automatically collected or generated from the App. We use log files and SDK as tracking technologies to store and retrieve this information on a User’s system and mobile device, and to 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 provide access to and use of the App and its related services	Necessary for the performance of a contract to which the User is a party (i.e., the Terms of Use)
		Delivering and display advertisements through the Google Mobile Ads SDKs	• to provide personalized or non-personalized ads, depending on your settings and consent.	User’s consent
		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	Legitimate interest in improving User’s experience
		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 services errors, and, in cases of abuse, track and mitigate the abuse.	Legitimate interest in supporting and enhancing the security of our App and User’s experience
		Defending rights	• 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.	Legitimate interest in defending our rights and interests
		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.	Legal obligations to which we are subject

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your Personal Information with certain third parties, as follows:

1. With our Group Entities. Your Personal Information will be shared with: (a) the U.S. entity of the group, and (b) the Israeli entity of the group; both for research and development purposes.

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 providers, content and data enrichment providers, and insurers. We only provide such service providers and business partners with Personal Information so that 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 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 and Google Play). 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.

INTERNATIONAL DATA TRANSFERS

We may host, store, process, maintain or transfer the Personal Information to various sites worldwide, outside your jurisdiction.

EEA Transfers. When we transfer Personal Information from within the European Economic Area ("EEA") to countries or international organizations that are based outside the EEA, the transfer takes place on the basis of an adequacy decision by the European Commission, or in the absence of an adequacy decision, other legally permitted safeguards under the General Data Protection Regulation (GDPR), such as standard contractual clauses.

Israeli Transfers. When we transfer Personal Information from the State of Israel to a third country outside Israel, the transfer takes place on the basis of a country declared as offering an equivalent level of protection by the Israeli Privacy Protection Authority; but you should be aware that in some cases we may transfer Personal Information to countries in which the level of data protection may be lower than in Israel and by using our App you agree to such transfer.

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 of our intention to do so.

HOW DO WE KEEP YOUR PERSONAL INFORMATION 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; and harm to the integrity of Personal Information. Personal Information is stored anonymously (with no username, email, or identifier of the User), and all external services (SaaS) require authentication and authorization and are stored in data centers 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 YOUR PERSONAL INFORMATION?

General Provisions. Please note that under certain circumstances and depending on your jurisdiction, you are entitled to specific rights regarding your Personal Information (subject to some exceptions). In most cases, you can exercise such rights free of charge. When you ask us to exercise any of your rights under this Privacy Policy and the applicable privacy and data protection 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 personal data that you request to access. We may redact from the Personal Information we will make available to you any Personal Information related to others. Please note that you can deliver your request by contacting us at fans@recapp.co

Data Rights for Israeli Users. If you are based in Israel, you are entitled to the following rights:

review and access your Personal Information that we process
update, amendment, and deletion of Personal Information which is incomplete, incorrect, outdated or unclear.

EEA Users. If you are based in the EEA and subject to the GDPR, you are entitled to the following rights:

Right of Access. You have the right to access your Personal Information in order to obtain clear, transparent and understandable information on how we process your Personal Information and on your rights, as well as a copy of your Personal Information.
Right to Rectification. You have the right to rectify your Personal Information in case your Personal Information is obsolete, inaccurate or incomplete.
Right to Object. You have the right to object to the processing of your Personal Information when the processing is based on Headlights’s legitimate interest. We will no longer process your Personal Information unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g., legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims.
Right to Restriction. In certain circumstances under GDPR, you have the right to restrict the processing of some of your Personal Information during a limited period of time.
Right to Withdraw your Consent. You have the right to withdraw your consent to the processing of Personal Information when the processing is based on consent.
Right to Data Portability. In certain circumstances under GDPR, you have the right to request data portability, meaning that you can receive the Personal Information originally provided by you in a structured and commonly used format or that you can request the transfer of the Personal Information you provided to another data controller.
Right to Erasure. In certain circumstances under GDPR, you have the right to erase your Personal Information (also known as the right to be forgotten).
Automated Processing. If applicable, you have the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning you or similarly significantly affects you and if automated processing is used.
Lodge a Complaint. You have the right to lodge a complaint with your national data protection authority. If you have a complaint about how we use your Personal Information, we will always prefer you to contact us first. If you are unsure which data protection authority to contact, please contact us at fans@recapp.co

California Resident User. If the 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.

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.

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

THIRD-PARTY SERVICES

Our App uses the Google Mobile Ads SDK to serve ads.
Google and its partners may collect and use data (such as device identifiers, cookies, and usage data) to provide personalized and non-personalized ads.
For more information on how Google uses data, please visit: Google Privacy & Terms.

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’S DETAILS

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

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.	Yes	Installation ID (or Anonymous ID), IP address, and advertising identifiers (Google Advertising ID/AAID, IDFA)
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
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes	Information on a consumer’s interaction with our App (e.g., through cookies) and advertisement.
G. Geolocation data.	Physical location, approximate location derived from IP address or movements.	Yes	IP address and approximate location
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Sensitive personal information.	Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.	No

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 law request, such as 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 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

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.