PRIVACY POLICY

GiftDaddy™ – The Private Gifting Platform

Effective Date: [Month Day, 2026]

This Privacy Policy ("Privacy Policy") describes how GiftDaddy™ – The Private Gifting Platform, operated by Gifty Club, LLC, a Missouri limited liability company ("GiftDaddy," "Company," "we," "our," or "us"), collects, uses, stores, discloses, and protects personal information obtained through the GiftDaddy website, applications, and related services (collectively, the "Platform").

Your privacy is important to us.

GiftDaddy was designed around a simple principle:

Thoughtful gift giving should not require unnecessary disclosure of personal information.

Unlike many online platforms, protecting the identities of both Senders and Recipients is a core feature of our business model—not simply a legal obligation.

By accessing or using the Platform, you acknowledge that you have read and understand this Privacy Policy.

1. OUR PRIVACY COMMITMENT

GiftDaddy believes privacy builds trust.

Whenever reasonably possible, GiftDaddy maintains a separation between information provided by Senders and information provided by Recipients.

Except as necessary to:

  • process payments;
  • fulfill merchandise orders;
  • comply with applicable law;
  • investigate fraud;
  • protect GiftDaddy's legal rights;
  • provide customer support; or
  • operate the Platform,

GiftDaddy does not intentionally disclose:

  • a Sender's billing information to a Recipient; or
  • a Recipient's shipping information to a Sender.

Our privacy practices are intended to support a secure and respectful gifting experience while allowing Users to control what personal information they choose to share with one another outside the Platform.

2. INFORMATION WE COLLECT

Depending on how you use the Platform, GiftDaddy may collect the following categories of information.

A. Account Information

When creating an Account, we may collect:

  • full name;
  • username;
  • email address;
  • password (stored in encrypted form);
  • telephone number;
  • date of birth or age verification;
  • communication preferences;
  • account settings.

B. Sender Billing Information

When purchasing GiftDaddy Points, we may collect:

  • billing name;
  • billing address;
  • email address;
  • payment method;
  • transaction history;
  • fraud-prevention information.

Payment card information is processed through PCI-compliant payment processing providers.

GiftDaddy does not intentionally store complete payment card numbers except where secure payment tokenization is required by our payment processing providers.

C. Recipient Shipping Information

When a Recipient redeems GiftDaddy Points for Merchandise, we may collect:

  • recipient name;
  • shipping address;
  • telephone number (when required by carriers);
  • delivery instructions;
  • shipment history.

D. Transaction Information

We maintain records regarding:

  • Point purchases;
  • Point transfers;
  • merchandise redemption;
  • Order history;
  • refunds;
  • shipping events;
  • customer support interactions.

E. Technical Information

When you access the Platform, certain information may be collected automatically, including:

  • IP address;
  • browser type;
  • browser version;
  • operating system;
  • device identifiers;
  • language preferences;
  • referring URLs;
  • pages viewed;
  • session duration;
  • approximate geographic location derived from IP address;
  • device type.

F. Cookies & Similar Technologies

GiftDaddy may use:

  • cookies;
  • session cookies;
  • persistent cookies;
  • browser storage;
  • analytics technologies;
  • similar tracking technologies.

These technologies help us:

  • remember user preferences;
  • authenticate Users;
  • improve security;
  • analyze Platform usage;
  • detect fraud;
  • improve performance.

3. INFORMATION WE DO NOT KNOWINGLY COLLECT

GiftDaddy does not knowingly collect personal information from individuals under eighteen (18) years of age.

GiftDaddy does not intentionally collect:

  • biometric information;
  • health records;
  • government-issued identification numbers except where legally required;
  • financial account information beyond what is reasonably necessary to process payments;
  • information unrelated to operation of the Platform.

4. HOW WE USE INFORMATION

GiftDaddy uses personal information only for legitimate business purposes.

Those purposes include:

Account Administration

  • creating Accounts;
  • authenticating Users;
  • maintaining account security;
  • providing customer support.

Transaction Processing

  • processing payment transactions;
  • purchasing GiftDaddy Points;
  • transferring GiftDaddy Points;
  • processing Merchandise redemption;
  • fulfilling Orders.

Platform Operations

  • improving functionality;
  • troubleshooting technical issues;
  • maintaining system security;
  • developing new Platform features.

Communications

  • responding to inquiries;
  • sending transaction confirmations;
  • shipping notifications;
  • security alerts;
  • legal notices;
  • customer support communications.

Fraud Prevention

  • detecting suspicious activity;
  • preventing payment fraud;
  • verifying transactions;
  • investigating abuse;
  • protecting Users.

Legal Compliance

  • complying with court orders;
  • responding to lawful governmental requests;
  • enforcing Terms of Use;
  • protecting legal rights.

5. LEGAL BASIS FOR PROCESSING (WHERE APPLICABLE)

Where applicable under law, GiftDaddy processes personal information based upon one or more of the following legal grounds:

  • performance of a contract;
  • compliance with legal obligations;
  • legitimate business interests;
  • User consent;
  • protection of legal claims;
  • fraud prevention.

6. PLATFORM PRIVACY PHILOSOPHY

GiftDaddy was designed to facilitate private gift giving—not social networking.

Accordingly, GiftDaddy does not use personal information collected from Senders or Recipients to:

  • build publicly searchable profiles;
  • create advertising audiences for sale or licensing;
  • facilitate introductions between Users;
  • recommend strangers;
  • operate a dating or matchmaking service;
  • enable unsolicited communications between Users; or
  • disclose one User's personally identifiable information to another except as necessary to complete an authorized transaction or as otherwise required by law.

GiftDaddy collects and uses personal information only as reasonably necessary to:

  • operate the Platform;
  • process transactions;
  • fulfill Orders;
  • provide customer support;
  • prevent fraud;
  • comply with legal obligations;
  • improve our services; and
  • protect our Users.

7. HOW WE SHARE INFORMATION

GiftDaddy does not sell your personal information.

GiftDaddy does not rent your personal information.

GiftDaddy does not license your personal information to advertising networks or unrelated third parties.

GiftDaddy shares personal information only when reasonably necessary to operate the Platform or when required by law.

Information may be disclosed to:

  • payment processing providers;
  • fraud prevention providers;
  • cloud hosting providers;
  • shipping carriers;
  • fulfillment providers;
  • customer support providers;
  • professional advisors;
  • governmental authorities when legally required.

Each recipient receives only the information reasonably necessary to perform its services.

8. PAYMENT PROCESSING

Payment transactions are processed through independent third-party payment processors.

GiftDaddy does not directly process or store complete payment card information except where secure payment tokenization is required.

Payment processors maintain their own privacy practices and security procedures.

GiftDaddy encourages Users to review the privacy policies of payment providers used during checkout.

9. FULFILLMENT PROVIDERS

GiftDaddy works with professional fulfillment providers and suppliers to package and ship Merchandise.

Those providers receive only the information reasonably necessary to:

  • process Orders;
  • package Merchandise;
  • prepare shipments;
  • arrange delivery;
  • address shipping issues.

GiftDaddy contractually expects service providers to maintain commercially reasonable safeguards protecting confidential information.

GiftDaddy does not publicly identify its fulfillment providers as part of its normal business operations.

10. SHIPPING CARRIERS

Shipping carriers may receive information necessary to complete delivery, including:

  • Recipient name;
  • shipping address;
  • telephone number where required;
  • shipment details.

Carrier privacy practices are governed by their respective privacy policies.

11. CUSTOMER SUPPORT

When Users contact Customer Support, GiftDaddy may collect information relating to:

  • support requests;
  • emails;
  • chat communications;
  • telephone conversations;
  • screenshots;
  • photographs submitted with claims;
  • documentation supporting refund requests.

These communications may be retained to improve customer service, resolve disputes, investigate fraud, and comply with legal obligations.

12. COOKIES AND ANALYTICS

GiftDaddy uses cookies and similar technologies to improve Platform functionality.

Cookies may be used to:

  • authenticate Users;
  • maintain login sessions;
  • remember preferences;
  • analyze traffic;
  • improve navigation;
  • prevent fraud;
  • enhance security.

Users may disable cookies through browser settings.

Disabling cookies may affect Platform functionality.

13. MARKETING COMMUNICATIONS

GiftDaddy may send promotional communications only where permitted by law or where Users have elected to receive them.

Marketing communications may include:

  • promotional offers;
  • feature announcements;
  • product updates;
  • newsletters.

Users may unsubscribe from promotional communications at any time.

GiftDaddy will continue sending transactional communications necessary to operate the Platform regardless of marketing preferences.

14. DATA SECURITY

GiftDaddy employs commercially reasonable administrative, technical, and physical safeguards designed to protect personal information.

Security measures may include:

  • encrypted communications (TLS/HTTPS);
  • password encryption;
  • access controls;
  • audit logging;
  • firewalls;
  • fraud monitoring;
  • secure hosting environments;
  • routine software updates;
  • employee access limitations.

Despite these safeguards, no internet transmission or electronic storage method is completely secure.

Accordingly, GiftDaddy cannot guarantee absolute security.

15. ACCOUNT SECURITY

Users remain responsible for protecting their Account credentials.

Users should:

  • use strong passwords;
  • maintain password confidentiality;
  • avoid sharing login credentials;
  • notify GiftDaddy immediately if unauthorized access is suspected.

GiftDaddy may suspend Accounts while investigating suspected security incidents.

16. DATA RETENTION

GiftDaddy retains personal information only for as long as reasonably necessary to:

  • operate the Platform;
  • process transactions;
  • complete Orders;
  • provide customer support;
  • prevent fraud;
  • comply with legal obligations;
  • enforce agreements;
  • protect GiftDaddy's legal rights.

Retention periods vary depending upon:

  • the type of information involved;
  • legal requirements;
  • accounting obligations;
  • tax regulations;
  • fraud prevention needs.

When information is no longer reasonably necessary, GiftDaddy will securely delete, anonymize, or otherwise dispose of the information where appropriate.

17. YOUR PRIVACY RIGHTS

Subject to applicable law, Users may have the right to:

  • access certain personal information;
  • correct inaccurate information;
  • update Account information;
  • request deletion of eligible information;
  • object to certain processing activities;
  • withdraw consent where processing is based upon consent;
  • request a copy of certain personal information.

GiftDaddy may request reasonable identity verification before processing privacy requests.

Certain information may be retained where legally required.

18. CALIFORNIA PRIVACY RIGHTS

Residents of California may possess rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").

Where applicable, GiftDaddy will respond to verified requests concerning:

  • access;
  • correction;
  • deletion;
  • disclosure of collected information;
  • applicable opt-out rights.

GiftDaddy does not knowingly sell personal information as defined by the CCPA.

19. ADDITIONAL U.S. STATE PRIVACY RIGHTS

Residents of certain U.S. states may possess additional privacy rights under applicable law.

Depending upon jurisdiction, Users may have rights to:

  • access personal information;
  • request corrections;
  • request deletion;
  • appeal privacy decisions;
  • opt out of certain targeted advertising activities where applicable.

GiftDaddy will evaluate and respond to applicable requests in accordance with governing law.

20. BUSINESS TRANSFERS

In the event GiftDaddy or Gifty Club, LLC is involved in:

  • a merger;
  • acquisition;
  • financing;
  • corporate restructuring;
  • sale of assets;
  • bankruptcy proceeding;
  • other corporate transaction,

personal information may be transferred as part of that transaction, subject to applicable law.

Any successor organization will remain subject to the commitments contained within this Privacy Policy unless Users are otherwise notified.

21. INTERNATIONAL USERS

GiftDaddy currently operates primarily within the United States and Canada.

Information collected through the Platform may be processed and stored within the United States.

Users accessing the Platform from outside the United States understand that privacy protections may differ from those available within their country of residence.

Should GiftDaddy expand internationally, supplemental privacy notices may be published where required by applicable law.

22. CHILDREN'S PRIVACY

GiftDaddy is intended solely for adults eighteen (18) years of age or older.

GiftDaddy does not knowingly collect personal information from children.

If GiftDaddy becomes aware that personal information belonging to a minor has been collected, GiftDaddy will take reasonable steps to remove that information, subject to applicable legal obligations.

23. CHANGES TO THIS PRIVACY POLICY

GiftDaddy may revise this Privacy Policy periodically.

Updated versions become effective upon posting unless a later effective date is expressly stated.

Users are encouraged to review this Privacy Policy periodically.

Continued use of the Platform following publication of revised policies constitutes acknowledgment of the updated Privacy Policy.

24. CONTACT INFORMATION

Questions regarding this Privacy Policy or GiftDaddy's privacy practices may be directed to:

Privacy Officer
GiftDaddy™ – The Private Gifting Platform
A service of Gifty Club, LLC

9909 Manchester Road, Suite 314
St. Louis, Missouri 63122
United States

Privacy Email: privacy@giftdaddy.com