Tierlock Privacy Policy

Last Updated: May 5, 2026

Tierlock LLC, a Wyoming limited liability company (“Tierlock,” “we,” “us,” or “our”), respects your privacy and is committed to providing a clear explanation of how we collect, use, disclose, retain, and otherwise process Personal Information in connection with our website, applications, account features, verification functionality, wallet-related features, payment-related features, operator-facing onboarding and settlement-support functionality, and related services (collectively, the “Service”).

This Privacy Policy applies when you visit, access, or use the Service, create an account, complete verification, link a payment method, use wallet functionality, access AGO-connected functionality, interact with Tierlock on behalf of an AGO, communicate with us, or otherwise interact with Tierlock in connection with the Service.

This Privacy Policy is incorporated into and forms part of the Tierlock Member Terms of Service and the Tierlock Operator Terms of Service, as applicable (each, a “Governing Agreement” and collectively, the “Governing Agreements”). The Governing Agreements control with respect to contractual matters such as disclaimers, limitations of liability, dispute resolution, arbitration, governing law, and related remedies. This Privacy Policy controls with respect to the categories of Personal Information we collect, the sources of that information, how we use and disclose it, our retention practices, and the privacy choices and rights described below.

1. SCOPE, AUDIENCE, AND DEFINITIONS

1.1 Scope and Audience.

This Privacy Policy applies to individuals who interact with the Service as visitors, members, prospective members, AGO representatives, AGO administrators and personnel, business contacts, support contacts, or other individuals who interact with Tierlock in connection with the Service. The categories of Personal Information we collect, and the ways in which we use and disclose that information, may vary depending on whether you interact with Tierlock as a visitor, member, AGO representative, or support contact. If you use the Service on behalf of a business or other entity, “you” includes you and that entity to the extent applicable.

1.2 Third-Party Services and Exclusions.

This Privacy Policy does not govern the privacy practices of AGOs, Payment Processors, Verification Providers, analytics providers, blockchain networks, or other third parties operating under their own terms and privacy notices. It also does not govern third-party sites, applications, or services that may be linked through or integrated with the Service. This Privacy Policy does, however, govern Tierlock’s own processing of Personal Information about individuals, including Operator Personnel, who interact with Tierlock’s Service.

1.3 Definitions.

For purposes of this Privacy Policy: “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. “AGO” means a third-party operator or platform that offers games, sweepstakes, promotions, entries, prizes, digital goods, services, or other offerings that may be accessed through or in connection with the Service, and includes any operator that accesses the Service under the Tierlock Operator Terms of Service. “Operator Personnel” means individuals who interact with Tierlock on behalf of an AGO, including AGO representatives, onboarding contacts, administrators, business contacts, and similar individuals. “Payment Processor” means a third-party processor, network, bank, gateway, wallet provider, or similar provider used in connection with payment-related or payout-related functionality. “Verification Provider” means a third-party identity, age, location, sanctions, fraud, or compliance vendor used in connection with the Service. “Wallet” means the limited-purpose account feature made available by Tierlock for receipt, display, holding, transfer, or other handling of USDC or other supported digital-asset functionality as expressly permitted by Tierlock.

2. BUSINESS CONTEXT AND TIERLOCK’S ROLE

2.1 What Tierlock Does.

Tierlock provides account functionality, verification-related functionality, access authorization, wallet-related functionality, payment-related support, and related services in connection with third-party AGOs and AGO offerings. Tierlock also provides operator-facing onboarding, system access, transaction support, settlement support, website-posting support, documentation handling, and related services for AGOs.

2.2 Tierlock Is Not the AGO.

Tierlock is not the AGO and does not own or operate AGO offerings. AGO offerings are provided by the applicable AGO under that AGO’s own rules, terms, and privacy practices. Tierlock is also not a Payment Processor. Although Tierlock acts as merchant of record in the payment processing chain, the processing of payment transactions is performed by independent third-party Payment Processors under their own terms and privacy policies. Appendix A to the Governing Agreements describes Tierlock’s role in the payment chain and its separate, limited-purpose Wallet role in further detail.

2.3 Privacy Role.

In connection with the Service, Tierlock generally acts as the business or controller for the Personal Information described in this Privacy Policy, except where another entity acts under its own legal authority or privacy terms.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

3.1 Identifiers and Contact Information.

We may collect your name, email address, phone number, username, mailing address if provided, account identifiers, and similar identifiers. For Operator Personnel, we may also collect business email, business phone, job title, employer or entity name, and business mailing address.

3.2 Account and Authentication Information.

We may collect account credentials, authentication information, account settings, preferences, and information you provide when registering for or maintaining an account. For Operator Personnel, this may include operator-account credentials, administrator-access information, and operator onboarding records.

3.3 Verification and Compliance Information.

We may collect date of birth, age-verification information, identity-verification information, government-issued identification information if required, location-verification information, device or risk signals, sanctions-screening information, fraud-screening information, and verification results. In connection with AGO onboarding and ongoing AGO compliance, we may also collect entity-verification information, beneficial-ownership information, and authorized-signer information relating to natural persons associated with an AGO.

3.4 Payment and Financial Information.

We may receive limited payment-related information such as payment method type, card brand, expiration month or year, billing address, partial payment card information such as the last four digits, payment token references, transaction status, payout status, and reversal status. Full payment credentials are generally collected and processed directly by Payment Processors, not by Tierlock.

3.5 Transaction, AGO, and Service Activity Information.

We may collect information about your use of AGO-connected functionality, transaction initiation and authorization events, clearance status, wallet events, payout events, Payment Reversals, and related service activity.

3.6 Wallet and Digital Asset Information.

We may collect wallet identifiers, wallet status, wallet activity, payout-related records, and digital-asset transaction information associated with wallet features we make available.

3.7 Blockchain or On-Chain Data.

If you use wallet or digital-asset functionality, some transaction-related information may be recorded on public or distributed ledgers. This may include wallet addresses, transaction hashes, amounts, timestamps, and related metadata.

3.8 Communications.

We may collect emails, support requests, chat messages, notices, service communications, security alerts, and other communications between you and Tierlock or between Tierlock and third parties relating to your use of the Service.

3.9 Device, Usage, and Technical Information.

We may collect IP address, browser type, operating system, device identifiers, app or browser activity, timestamps, log data, diagnostic information, crash or performance data, and similar technical or usage information.

3.10 Cookies and Similar Technologies Data.

We and our service providers may collect information through cookies, pixels, local storage, SDKs, session technologies, and similar tools, including information about your device, browsing activity, session activity, and interactions with the Service. See Section 8 for additional detail.

3.11 Sensitive Personal Information.

Depending on the features you use and the verification methods used, we or our Verification Providers may collect or process information that may be considered sensitive under applicable law, such as government-issued identification information, precise location or location-verification data, payment account credentials handled through secure workflows, or selfie-based or biometric verification information. We collect and use sensitive Personal Information only as reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted by applicable law. Where we or our Verification Providers collect or process biometric identifiers or biometric information subject to applicable biometric privacy law, we will maintain a written policy governing retention schedules and destruction guidelines for such information as required by law. Where required by applicable law, we obtain prior written consent before collecting or processing biometric identifiers or biometric information.

3.12 AGO Settlement and Compliance Records.

In connection with AGO participation in the Service, we may collect AGO settlement records, reserve and holdback records, Payment Reversal allocations, representment documentation, payout and suspension status, operator-side pricing, discount, and transaction-support records, website-posting confirmations, transaction-support documentation, prize and fulfilment records submitted to Tierlock, and compliance-review materials.

4. SOURCES OF PERSONAL INFORMATION

4.1 Directly From You.

We collect Personal Information you provide when you create an account, complete verification, link a payment method, use wallet functionality, communicate with us, request support, or otherwise interact with the Service. We also collect Personal Information directly from Operator Personnel during AGO onboarding, transaction support, dispute support, and related interactions. At the time we collect certain Personal Information directly from you, we may provide a separate Notice at Collection as required by applicable law.

4.2 Automatically Through the Service.

We collect certain information automatically through cookies, device identifiers, log files, analytics tools, local storage, SDKs, and similar technologies when you use the Service.

4.3 From AGOs.

We may receive information from AGOs in connection with AGO access, transactions, payouts, wallet credits, settlement support, dispute handling, fraud review, representment cooperation, compliance review, website-posting workflows, or other AGO-related functionality.

4.4 From Payment Processors.

We may receive limited payment-related information from payment processors, including confirmation and status information, payment method type, billing information, and reversal or payout information.

4.5 From Verification Providers and Compliance Partners.

We may receive verification results, fraud scores, sanctions screening information, device or identity risk information, and similar compliance-related information from third-party verification and compliance providers. We may also receive entity-verification, beneficial-ownership, and business-compliance information from know-your-business and similar business-compliance vendors.

4.6 From Service Providers and Vendors.

We may receive information from hosting providers, communications vendors, analytics providers, support tools, cloud providers, and other service providers that help us operate the Service.

4.7 From Public or Other Third-Party Sources.

Where permitted by law and reasonably necessary for compliance, fraud prevention, verification, or business operations, we may receive information from public records, publicly available sources, or other third-party sources.

5. HOW WE USE PERSONAL INFORMATION

5.1 To Provide and Operate the Service.

We use Personal Information to create and manage accounts, authenticate users, provide wallet-related features, support AGO-connected functionality, facilitate member-authorized transactions, administer payouts and reversals, onboard and administer AGO participation, support TEU-related and AMOE-related functionality, evaluate and support AGO compliance, administer required website postings and disclosures, and operate the Service.

5.2 To Verify Identity, Age, Location, and Eligibility.

We use Personal Information to verify identity, age, jurisdiction, eligibility, and compliance status, including through third-party verification providers.

5.3 To Process and Support Transactions.

We use Personal Information to facilitate member-authorized payment flows, transaction support, wallet crediting, payout handling, Payment Reversal handling, fraud prevention, settlement administration, operator-side settlement support, reserves, holdbacks, representment, and related account activity.

5.4 To Communicate With You.

We use Personal Information to send service-related communications, account notifications, verification messages, security alerts, support responses, wallet notices, payout or reversal notices, and, where permitted, marketing communications.

5.5 To Maintain Security and Prevent Fraud.

We use Personal Information to detect, investigate, prevent, and respond to fraud, unauthorized transactions, Payment Reversals, sanctions risks, misuse of the Service, suspicious account activity, and security incidents.

5.6 To Enforce Our Terms and Protect Rights.

We use Personal Information to enforce the Governing Agreements, protect the rights, property, safety, and security of Tierlock, our users, AGOs, service providers, and others, and establish, exercise, or defend legal claims.

5.7 To Comply With Legal Obligations.

We use Personal Information to comply with applicable law, legal process, regulatory obligations, lawful requests from government authorities, accounting requirements, tax obligations, sanctions requirements, and similar legal duties.

5.8 To Improve the Service.

We use Personal Information to understand usage patterns, troubleshoot problems, improve performance, develop features, improve fraud and risk systems, and otherwise improve the Service.

5.9 To Create and Use De-Identified or Aggregated Information.

We may de-identify, aggregate, or anonymize information and use it for analytics, service improvement, business intelligence, operational insights, security analysis, and other lawful business purposes. Where information has been de-identified or aggregated to a legally sufficient standard, it is no longer treated as Personal Information under this Privacy Policy.

5.10 Data Minimization.

We collect and use Personal Information only to the extent reasonably necessary for the purposes described in this Privacy Policy.

6. HOW WE DISCLOSE PERSONAL INFORMATION

6.1 To Service Providers.

We may disclose Personal Information to vendors and service providers that perform services on our behalf, such as hosting, cloud services, communications delivery, customer support, analytics, fraud prevention, sanctions screening, identity verification, and technical infrastructure providers.

6.2 To Verification Providers and Compliance Partners.

We may disclose Personal Information to identity, age, location, fraud, sanctions, and compliance providers as reasonably necessary to verify users, assess risk, maintain security, and comply with law.

6.3 To Payment Processors and Related Providers.

We may disclose Personal Information to Payment Processors and related service providers in connection with payment processing, wallet-related functionality, payout handling, reversals, fraud prevention, settlement support, and related financial operations.

6.4 To AGOs.

We may disclose Personal Information to AGOs as reasonably necessary to enable AGO-connected functionality, support transactions, credit wallet value, administer payouts or reversals, investigate fraud, handle payment-channel disputes and representment, maintain compliance, or otherwise provide the Service in connection with AGO access. Substantive disputes between members and AGOs regarding AGO offerings, prizes, fulfilment, or AGO-side performance are resolved between the member and the AGO, and any disclosures we make in that context are limited to payment-channel and service-support functions.

6.5 To Professional Advisors.

We may disclose Personal Information to attorneys, auditors, accountants, tax advisors, fraud investigators, insurers, consultants, and similar professional advisors where reasonably necessary for legal, compliance, operational, or risk-management purposes.

6.6 For Legal and Protective Reasons.

We may disclose Personal Information where we determine in good faith that disclosure is necessary or appropriate to comply with law, legal process, court orders, regulatory requirements, law enforcement requests, or to protect the rights, property, safety, and security of Tierlock, our users, or others.

6.7 In Corporate Transactions.

We may disclose Personal Information in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, subject to customary protections where appropriate.

6.8 De-Identified and Aggregated Information.

We may disclose de-identified, anonymized, or aggregated information that is not reasonably capable of being associated with you for analytics, benchmarking, security, business intelligence, research, product improvement, or other lawful business purposes.

6.9 No Sale or Sharing for Advertising.

Tierlock does not sell Personal Information. Tierlock does not share Personal Information with third parties for cross-context behavioral advertising purposes.

7. PAYMENT PROCESSING, WALLET, AND BLOCKCHAIN DISCLOSURES

7.1 Payment Processors.

Payment processing is generally performed by independent third-party Payment Processors. Those processors typically collect, store, process, and transmit payment information under their own terms and privacy policies. We may receive limited payment-related information such as payment confirmation, payment method type, partial payment card information, billing information, transaction status, reversal status, and payout status, but we generally do not receive or store full payment card numbers, CVV codes, or complete bank account credentials.

7.2 Your Relationship With Payment Processors.

Your use of payment features may be subject to the Payment Processor’s terms and privacy policy. We are not responsible for the independent privacy or security practices of Payment Processors.

7.3 Wallet and Digital Asset Features.

If we make wallet or digital-asset functionality available, we may collect and use information needed to create, maintain, secure, support, credit, restrict, or close wallet functionality, including wallet identifiers, transaction-related records, and compliance information.

7.4 Public Blockchain Disclosure.

If you use wallet or digital-asset functionality, some transaction information may be recorded on a public or distributed ledger. Publicly visible blockchain data may include wallet addresses, transaction hashes, amounts, timestamps, and related metadata. Although such information may be pseudonymous, it may still be visible to others and may be linkable or inferentially revealing. Tierlock does not control the public availability, permanence, or downstream use of on-chain records.

7.5 Role Alignment With the Governing Agreements.

We may process Personal Information in connection with Tierlock’s role as contractual merchant of record in the payment processing chain and in connection with Tierlock’s separate, limited-purpose role in receiving and holding Wallet value for members, each as described in the Governing Agreements and Appendix A. Substantive disputes between members and AGOs regarding AGO offerings remain with the applicable AGO.

8. COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES

8.1 Cookies and Similar Technologies.

We and our service providers may use cookies, pixels, local storage, SDKs, session technologies, and similar tools to operate the Service, remember settings, maintain account sessions, analyze usage, improve performance, detect fraud, and support communications and security.

8.2 Types of Technologies We May Use.

These technologies may include strictly necessary technologies, functionality-related technologies, analytics or performance tools, and security-related technologies. If we use non-essential cookies or similar technologies that require notice or choice under applicable law, we will provide those notices or choices through the Service or through available cookie or privacy tools.

8.3 Analytics.

We may use analytics providers to understand how users interact with the Service, improve functionality, measure performance, and troubleshoot issues.

8.4 Your Choices.

You may be able to manage some cookies or similar technologies through your browser settings, device settings, and any preference tools or privacy controls we make available. Blocking some technologies may affect Service functionality.

9. AUTOMATED DECISION-MAKING, PROFILING, AND RISK SYSTEMS

9.1 Automated Systems.

We may use automated tools, algorithms, machine learning systems, scoring tools, or other technical systems to support identity verification, fraud prevention, sanctions screening, account security, transaction review, wallet or payout risk review, service integrity, and product improvement. Automated systems may also be used for operator-side fraud review, settlement-risk review, reserve decisions, and compliance or risk screening relating to AGO participation. Outcomes of such processing may include verification failure, account restriction, transaction decline, payout hold, or suspension of access to features of the Service.

9.2 Relevant Inputs.

These systems may analyze account activity, transaction patterns, device or location signals, reversal history, and other relevant factors.

9.3 No Error-Free Promise.

Automated systems may produce errors or incorrect outcomes. Where applicable law provides rights relating to automated decisions that affect you, you may submit a request using the contact information in Section 18. Such requests receive human review. We will respond within the timeframe in Section 13.4.

10. DATA RETENTION

10.1 Retention Criteria.

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide the Service, comply with legal obligations, enforce the Governing Agreements, resolve disputes, prevent fraud, maintain security, and protect our legitimate business interests.

10.2 Retention by Context.

Retention periods depend on the type of information and the reason we hold it. Account information is retained while your account is active and for a reasonable period thereafter. Verification and compliance information is retained as long as necessary for fraud prevention, legal compliance, and risk management. Transaction, wallet, payout, and reversal records are retained for accounting, dispute, tax, and legal purposes. Support and communications records are retained for support, fraud prevention, dispute handling, and legal compliance. AGO onboarding records, settlement-cycle records, reserve and representment documentation, and AGO participation records are retained for the duration of the AGO relationship and for a reasonable period thereafter, consistent with the term of the applicable Governing Agreement and applicable legal and compliance recordkeeping requirements.

10.3 Deletion and De-Identification.

If you request deletion, we may delete or de-identify certain Personal Information, but we may retain information where permitted or required by law, where necessary to complete transactions, detect fraud, comply with legal obligations, resolve disputes, enforce the Governing Agreements, maintain security, or protect our rights. Public blockchain records may remain permanently available outside Tierlock’s control. De-identified or aggregated data may be retained longer or indefinitely.

11. SECURITY

11.1 Security Measures.

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect Personal Information against unauthorized access, use, alteration, and disclosure. The measures we use vary depending on the nature of the information and the risks involved.

11.2 No Absolute Guarantee.

No method of transmission over the internet or method of storage is completely secure, and we cannot guarantee absolute security.

11.3 Your Responsibilities.

You are responsible for maintaining the security of your account credentials, devices, and access methods and for notifying us promptly if you believe your account or information has been compromised.

11.4 Legally Required Incident Notice.

If we experience a security incident requiring notice under applicable law, we will provide notice as required by applicable law.

12. YOUR PRIVACY CHOICES AND RIGHTS

12.1 General Rights.

Depending on where you live and the nature of your relationship with us, you may have rights regarding your Personal Information, such as the right to request access to, correction of, deletion of, or portability of Personal Information; to limit or restrict certain processing; to opt-out of profiling that produces legal or similarly significant effects concerning you; to limit the use or disclosure of sensitive Personal Information; or to appeal a denial of any such request, where applicable law provides those rights.

12.2 Marketing Communications.

If we send you marketing emails, you may opt out by using the unsubscribe link in the message or by contacting us. Even if you opt out of marketing, we may still send you service-related, transactional, security, legal, and operational communications.

12.3 Sensitive Data Rights.

Where applicable law provides rights or limitations regarding sensitive Personal Information, biometric information, precise location data, or similar data, you may exercise those rights using the contact channels below, subject to legal exceptions and verification requirements.

13. HOW TO EXERCISE RIGHTS

13.1 Request Channels.

If you would like to exercise a privacy right, submit a request using the contact information below.

13.2 Verification.

We may need to verify your identity before processing your request and may deny or limit a request where permitted by law.

13.3 Appeals and Authorized Agents.

Where applicable law provides a right to appeal a denial, we will provide an appeal path consistent with applicable law. If you use an authorized agent to submit a request on your behalf where permitted by law, we may require proof of the agent’s authority and may still require you to verify your identity directly.

13.4 Response Timing.

We will respond to verifiable privacy rights requests within 45 days of receipt of a verified request. Where reasonably necessary, we may extend this period by an additional 45 days and will notify you before the initial period expires.

14. CROSS-BORDER PROCESSING

14.1 Processing Locations.

We and our service providers may process Personal Information in the United States and in other jurisdictions in which we or our service providers operate.

14.2 Cross-Border Notice.

Those jurisdictions may have privacy laws that differ from the laws of your jurisdiction. By using the Service, you understand that your information may be processed in the United States and other relevant jurisdictions, subject to this Privacy Policy and applicable law. Where required by applicable law, we apply appropriate safeguards for transfers of Personal Information to jurisdictions outside your own.

15. CHILDREN’S PRIVACY

15.1 Age-Related Scope.

The Service is intended for individuals 21 years of age or older and is not directed to minors. Use of the Service is subject to the eligibility requirements in the applicable Governing Agreement.

15.2 No Knowing Collection From Ineligible Users.

We do not knowingly collect Personal Information from individuals under 21 or from individuals who are not otherwise eligible to use the Service. If you believe that an ineligible individual has provided Personal Information to us, please contact us so that we can review and address the issue appropriately.

16. THIRD-PARTY LINKS AND SERVICES

16.1 Third-Party Links and Integrations.

The Service may contain links to, integrations with, or features provided by third parties, including AGOs, Payment Processors, Verification Providers, analytics providers, and other service providers.

16.2 Separate Privacy Practices.

We do not control the privacy, security, or data practices of those third parties, and your interactions with them are governed by their own terms and privacy notices.

17. CHANGES TO THIS PRIVACY POLICY

17.1 Updates.

We may update this Privacy Policy from time to time. If we do, we will update the “Last Updated” date above and may provide additional notice where required or appropriate.

17.2 Effect of Continued Use.

Your continued use of the Service after the effective date of an updated Privacy Policy means you acknowledge the revised Policy, subject to applicable law.

18. CONTACT US

18.1 Contact Information.

If you have questions about this Privacy Policy or would like to submit a privacy request, please contact us at:

Tierlock LLC

Attn: Privacy

1712 Pioneer Ave Ste 500

Cheyenne, WY 82001

Email: legal@tierlock.com