PRIVACY POLICY
Effective
9/15/2022
This
Privacy Policy notice describes how SportsBubble Inc.
(“SportsBubble”) collects, uses, and shares Personal Data that
you submit to us and that we collect about you in connection to your
use of the WatchSports Application and related Services.
The
term “Services” refers to the information provided in the
WatchSports Event Guide and the connect-to-watch services, as well as
other products, features, tools, or services offered by the
WatchSports application and the SportsBubble Platform.
The
term “Platform” refers to, collectively, the WatchSports
application and WatchSports.io website, and other affiliate or
related websites (the “Site”), mobile applications, and other
places through which sports event information and related content may
be accessed, including websites and applications of SportsBubble’s
third-party business partners and other websites where users or
website operators are permitted to embed or have otherwise licensed
Content.
This
Privacy Notice applies to anyone viewing any content on any Platform
or otherwise using the Services, whether you (collectively, “you”)
are a registered user of the Services, or a visitor who has not
registered for the Services.
DATA
WE COLLECT
For
purposes of this Privacy Notice, “Personal Data” means
information relating, linked or reasonably linkable to an
identifiable person. As described further below, we may collect
certain Personal Data from or about you in connection with your use
of the Services, such as your name, home address, phone number, email
address, username and password, pronoun you use, and payment data.
You are not required to provide all Personal Data identified in this
Privacy Notice in order to view Content or use the Services; however,
please note that if you do not provide the Personal Data requested,
we may be unable to provide some or all of the Services to you. We
may collect Personal Data as follows:
Account
Registration and Purchases
We
collect Personal Data such as your name, zip code, pronoun, email
address and password, and payment data, when you create an account
and/or purchase a Service, or when you use or interact with the
Platform and Services.
Cookies
and Tracking Technologies
When
you use the Services, we may collect certain Personal Data using
cookies and other technologies, such as web beacons, device IDs,
geolocation from IP addresses and Apps, HTML5 local storage, Flash
cookies, and IP addresses. We specifically use browser cookies for
different purposes, including cookies that are strictly necessary for
functionality and cookies that are used for personalization,
performance/analytics, and advertising. When you interact with the
Services, we may also automatically collect certain data about your
device, including information about your web browser, IP address, and
time zone, as well as device identifiers or other unique identifiers
such as advertising identifiers. We may collect information about
your activity on the Services including information about the Content
you view, page views, ad data, referral URLs, network state, and
identifiers associated with browser cookies, and carrier information.
Our “Use of Cookies and Similar Technologies” section contains
more information and options to control or opt-out of certain data
collection or uses.
Social
Media Networks
If
you choose to sign up, log into, access, or otherwise connect to the
Services through a social media or other third-party account, we may
collect Personal Data that you have provided to that
Social
Media Network, such as your user ID and/or user name associated with
that Social Media Network, and any information or content you have
permitted the Social Media Network to share with us, as well as
information you have made public in connection with your Social Media
Network account. If you want to control or limit sharing data from
Social Media Networks, you should adjust the privacy settings on your
Social Media Network account.
Communications
With Us
We
collect Personal Data, such as your name, email address, and other
contact information when you communicate with us, including when you
email us, submit information through the Site, such as an inquiry to
become an advertiser, and when you sign up to receive
materials.
Third
Parties and Publicly-Available Sources
We
may obtain certain data about you from third-party sources, such as
business partners through which you may access the Services or data
aggregators, as well as publicly-available sources, in order to help
us provide and improve the Services and for marketing and
advertising. We may combine your Personal Data with data we obtain
from our Services, other users, or third parties to enhance your
experience and improve the Services.
HOW
WE USE DATA WE COLLECT AND PROCESS
We
use Personal Data for a variety of different purposes as set out in
further detail below. In some cases, we may ask for your consent so
that we may process your Personal Data. However, in certain
circumstances, applicable data protection laws allow us to process
Personal Data without needing to obtain explicit consent. Subject to
applicable law, the purposes for which we may use and process
Personal Data, and the legal basis for such processing include:
Legitimate
Interests
To
operate and provide the Services, in addition to performing our
contractual obligations to you, for our “legitimate interests”
for the purposes of applicable law, except where such interests are
overridden by the interests or fundamental rights and freedoms of the
data subject which require protection of personal data. Legitimate
interests may include:
• To provide and improve the
Services, including for technical support;
• To communicate with you
regarding the Services and to address and respond to your requests,
inquiries, and complaints;
• To protect the
confidentiality or security of information;
• To develop, provide, and
improve the Services and Platform, including to better tailor the
features, content, performance, security, and support of our Services
and the Platform;
• For our direct marketing
purposes and to send surveys in connection with the Services;
• For fraud, loss, and other
crime prevention purposes, to assist in the investigation of
suspected illegal or wrongful activity, and to protect and defend our
rights and property, or the rights or safety of third
parties;
• To enforce our Terms of Use,
this Privacy Notice, or agreements with you or with third
parties;
• To comply with laws,
regulators, court orders, or other legal obligations, or pursuant to
legal process; or
• Subject to applicable
contractual or legal restrictions, in connection with a contemplated
reorganization or an actual reorganization of our organization.
Contractual
Obligations
To
perform our contractual obligations to you, including to fulfill your
request for Services, to contact you in relation to any issues with
the Services, where we need to provide your Personal Data to our
service providers in relation to the Services, or to take steps in
response to information or inquiries you may submit prior to entering
into a contract or agreement with us.
Legal
Obligations
To
comply with laws, regulators, court orders, or other legal
obligations, or pursuant to legal process.
To
Protect Data Subjects’ Vital Interests
To
protect the vital interests of you or of another person.
Consent
By
using our Services and accessing our app or site, you consent to the
collection and use of your personally identifiable information and
non-personal information as described in this privacy policy and we
assume we have your express permission and consent to use transfer
your personally identifiable information and non-personal information
as detailed herein. In
some cases where we are not already authorized to process the
Personal Data under applicable law, we may ask for your consent to
process your Personal Data. Again,
if you do not agree with this Privacy Policy or our other Policies
for Services or on this app or site, please do not use Services.
DATA
RETENTION
We
will generally retain your Personal Data for as long as you maintain
an account, for as long as is necessary to provide the Services, or
for such longer period as may be required or permitted by applicable
law. We will also retain your Personal Data as necessary to comply
with our legal obligations, resolve disputes, and enforce our
agreements. Please
note that the personally identifiable information and non-personal
information that we maintain will be deleted or anonymized after we
determine there is no longer any reason to process your information
or otherwise fulfill our contractual obligations to you. Also,
if you request us to delete your information, you should realize that
deleting personal information may affect our ability to deliver
services or may result in deleting your account completely.
ANONYMOUS
DATA
We
may create de-identified or anonymous data from Personal Data by
removing data components (such as your name, email address, or
linkable tracking ID) that makes the data personally identifiable to
you or through obfuscation or through other means. Our use of
de-identified and anonymized data is not subject to this Privacy
Notice.
HOW
WE MAY DISCLOSE DATA
We
may disclose Personal Data as described in this Privacy Notice,
including:
Affiliates
We
may disclose some or all of your Personal Data to our subsidiaries,
joint ventures, and other companies under our common control
(collectively, “Affiliates”), for the purposes described in this
Privacy Notice. Where we share Personal Data with our Affiliates, we
will require our Affiliates to honor this Privacy Notice, the Terms
and Conditions, and other notices and policies we provide to you for
Services.
Service
Providers and Business Partners
We
may disclose Personal Data to business partners, distributors,
service providers, marketing partners and vendors in order to
maintain the Platform and provide, improve and personalize the
Services, including to fulfill a request for our Services. We may
also share Personal Data for other technical and processing
functions, such as sending e-mails on our behalf, fulfilling orders,
technical support, or otherwise operating the Services, for
analytics, and for marketing and advertising purposes.
Advertising
and Marketing
We
may share Personal Data with advertising and marketing partners for
advertising and marketing purposes on behalf of SportsBubble and on
behalf of third parties, such as video content providers, including
with third parties involved in interest-based advertising. These
third parties may use their own cookies or similar technologies to
collect or request information in delivering advertising tailored to
your interests. For more information regarding interest-based
advertising and your choices, see the “Interest-Based Advertising”
section of this Privacy Notice.
Pursuant
to Legal Process
We
may also disclose Personal Data to comply with applicable laws and
regulations, to respond to a subpoena, search warrant, or other
lawful request for information we receive, or as otherwise pursuant
to legal process.
Protection
of Rights and Interests
We
may also use and disclose Personal Data to establish or exercise our
legal rights, to enforce our Terms of Use, this Privacy Notice or
agreements with you or third parties, to assert and defend against
legal claims, or if we believe such disclosure is necessary to
investigate, prevent or take other action regarding actual or
suspected illegal or fraudulent activities or potential threats to
the physical safety or well-being of any person.
Business
Transactions
Subject
to applicable law, we reserve the right to transfer some or all
Personal Data in our possession to a successor organization in the
event of a merger, acquisition, bankruptcy or other sale or transfer
of all or a portion of our assets, including for the purpose of
permitting the due diligence required to decide whether to proceed
with a transaction. If any such transaction occurs, the purchaser
will be entitled to use and disclose the Personal Data collected by
us in the same manner that we are able to, and the purchaser will
assume the rights and obligations regarding Personal Data as
described in this Privacy Notice.
LINKS
TO OTHER SITES
The
Platform may contain links or otherwise provide access to
non-business partner or non-service providers websites, mobile
applications, or Internet locations (collectively “Third-Party
Sites”). Please note that SportsBubble has no control over and is
not responsible for Third-Party Sites, their content, or any goods or
services available through the Third-Party Sites. Our Privacy Notice
does not apply to Third-Party Sites. We encourage you to read the
privacy policies of any Third-Party Site with which you choose to
interact.
USE
OF COOKIES AND SIMILAR TECHNOLOGIES
SportsBubble
uses cookies and similar technologies to improve user experience, for
performance and analytics, and to improve our Content and Services.
We also use cookies and similar technologies for purposes of
marketing and advertising. In those jurisdictions that require it, we
allow the data subject to give explicit permission or to deny the use
of certain categories of cookies. A “cookie” is a small text file
that a web server stores in browser software. A browser sends cookies
to a server when the browser makes a connection to the server (for
example, when requesting a web page from the same domain that created
the cookie). The purpose of cookies is to remember the browser over
time and distinguish one browser instance (or user) from all others.
Some cookies and other technologies may serve to track Personal Data
previously entered by a user. Most browsers allow you to control
cookies, including whether or not to accept them, and how to remove
them. Cookies can remember login information, preferences, and
similar information. Cookies, as well as other tracking technologies,
such as HTML5 local storage, and Local Shared Objects (such as
“Flash” cookies), and similar mechanisms, may record information
such as a unique identifier, information you enter in a form, IP
address, and other categories of data. We may also use web beacons or
“pixels,” and in certain circumstances may collect IP address,
screen resolution and browser software and operating system types,
clickstream patterns, dates and times that our Site is accessed, and
other categories of data. If you want to block the use and saving of
cookies, you should take the necessary steps within your browser’s
settings to block all cookies from SportsBubble and its external
serving vendors, or use the cookie control system, if available upon
first visit. Please note that if you choose to erase or block your
cookies, certain parts of the Services may not function correctly.
For instance, we may not be able to store your preferences or login
information or customize Content and advertising to your viewing
habits. For information on how to disable cookies, refer to your
browser’s documentation.
SOCIAL
NETWORK WIDGETS
Our
Platform may include social network sharing widgets that may provide
information to their associated social networks or third parties
about your interactions with the Services, even if you do not click
on or otherwise interact with the plug-in or widget. Information may
be transmitted from your browser and may include an identifier
assigned by the social network or third party, information about your
browser type, operating system, device type, IP address, and the URL
of the web page where widget appears. If you use social network tools
or visit social networking sites, we encourage you to read their
privacy disclosures, to learn what information they collect, use, and
share.
INTEREST-BASED
ADVERTISING
We
may disclose various types of information for purposes of
interest-based advertising, including for third-party interest-based
advertising. Interest-based advertising is advertising that is
targeted to you based on your web browsing and app usage over time
and across websites or applications. Our advertising practices may
also include the use of Personal Data to create de-identified
audience segments that can be used for targeted marketing and
interest-based advertising on the Site as well as third party
services and platforms, mobile apps, and/or websites. Prior to use,
the segments are de-identified so that they will not identify You
personally. You have the option to restrict the use of information
for interest-based advertising and to opt-out of receiving
interest-based ads. Depending on from where you access the Services,
you may also be asked to consent to our use of cookies, including
advertising cookies. The opt-outs for interest-based advertising
require that strictly necessary cookies are not blocked by the
settings in your web browser. You can opt-out of interest-based
advertising with participating entities for each region at Ad
Choices. This website also provides detailed information about how
interest-based advertising works. Opting out does not mean that you
will no longer receive advertising from us, or when you use the
Internet. It just means that the data collected from our website will
not be used for interest-based advertising and that the advertising
you see displayed on websites will not be customized to your
interests.
DATA
SUBJECT RIGHTS
It
is important that you keep your personally identifiable information
up to date. We may give you notice of certain changes and updates by
sending you a notice, including to the email address you provided us.
It is therefore important you acknowledge and agree that it is your
responsibility to maintain a valid e-mail address as a user, review
this Platform, our Terms of Use and this Privacy Notice periodically
and to be aware of any changes, updates, modifications, additions or
deletions. Your continued use of the Services and this Platform after
such changes will constitute your acknowledgment of the modified
Privacy Notice and agreement to abide and be bound by the modified
Privacy Notice.
For your convenience, we have made a list of some of your privacy rights as well as explained them in greater detail below. Your personal data is yours and you have rights over it, including but not limited to:
• the right to be informed about the collection and use of your personal data;
• the right of access to your personal data and any supplementary information;
• the right to have any errors in your personal data rectified;
• the right to have your personal data erased (“right to be forgotten”);
• the right to block or suppress the processing of your personal data;
• the right to move, copy or transfer your personal data from one IT environment to another;
• the right to withdraw your consent of our processing of your personal and data;
• the right to file a complaint with your local supervisory authority;
• the right to object to processing of your personal data in certain circumstances;
• the right to non-discrimination for the same prices and service as those who have and have not exercised their privacy rights (although, as mentioned above, exercising rights such as the right to be forgotten, may prevent you from using our services and certain aspects of our Site); and,
• rights related to automated decision-making (i.e. where no humans are involved) and profiling (i.e. where certain personal data is processed to evaluate an individual).
In greater detail, some of the above rights include:
Request
Access to, Modification or Rectification, or Deletion
You
have the right to request access to, modification of, or deletion of
your Personal Data we maintain. If you are a registered user or
subscriber, you can also make changes to your Personal Data by
logging into your account and updating your profile.
Request
Restriction of Processing
You
have the right to request that we restrict processing of your
Personal Data in certain circumstances, such as where you believe
that the Personal Data we hold about you is inaccurate or our
processing is unlawful.
Object
to Processing
In
certain circumstances, you may have the right to opt out of data
processing or request that we stop processing your Personal Data,
such as a request to stop sending you direct marketing
communications. To opt-out of direct marketing communications, please
see the instructions in the “Withdrawing Your Consent” section of
this Privacy Notice.
Data
Portability
In
certain circumstances, you may have the right to receive the Personal
Data concerning you that you provided to us or to request that we
transmit your Personal Data to another data controller.
Lodge
a Complaint
You
have the right to lodge a complaint. To exercise your rights, you may
contact us as at privacy@sportsbubble.io. As permitted by law,
certain data elements may not be subject to access, modification,
portability, restriction and/or deletion. Where permissible, we may
charge for this service. We will respond to reasonable requests as
soon as practicable and as required by law. To protect your privacy
and security, we may take steps to verify your identity in order to
respond to your request.
To manage your data, you can contact us via e-mail with any requests
that you may have.
Data subjects in certain jurisdictions including Nevada and California may have certain rights under applicable data protection laws, including the right to request confirmation from us as to whether or not we are processing your Personal Data.
To manage your data, you can contact us via e-mail with any requests that you may have. You can request access to all your personally identifiable information and manage your data, including your withdrawal of consent, by sending an e-mail to us at: privacy@ sportsbubble.io. Where we can provide information access and correction, we will do so for free, except where such requests are unreasonably repetitive, would require a disproportionate effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). We may not accommodate a request to change information if we believe the change would violate a law or cause the information to be incorrect. Please note that you may only make a California resident CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by phone, post or email, you will need to provide us with: enough information to identify you; proof of your identity and address; and, a description of what right you want to exercise and the information to which your request relates. Please know that we are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Also, you should know that any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
WITHDRAWING
YOUR CONSENT
In
most cases, we need to process certain of your Personal Data in order
to fulfill our contractual obligations to you and for our legitimate
interests. Where the basis of processing is legitimate interests, you
have a right to object to the processing of your Personal Data.
Please note that, subject to applicable law, we may continue to
process your Personal Data even where you object if there are
compelling legitimate grounds for processing that override your
interests and rights, or where processing is necessary to establish,
exercise, or defend legal claims. Where consent is the basis of
processing, you may at any time withdraw the consent you provided for
the processing of your Personal Data for the purposes set forth in
this Privacy Notice by contacting us at privacy@sportsbubble.io
provided that we are not required by applicable law or professional
standards to retain such information. If you would like to stop
receiving marketing or promotional messages, notifications, or
updates from us, you may do so by following the unsubscribe
instructions that appear in e-mail communications. Please be advised
that you may not be able to opt-out of receiving certain service or
transactional messages from us, including legal notices and certain
communications related to the provision of the Services. Please note
that if you withdraw your consent or object to processing, or if you
choose not to provide certain Personal Data, we may be unable to
provide you some or all of the Services.
SECURITY
We
implement technical and organizational security measures designed to
secure and protect Personal Data. Please note, however, we cannot
fully eliminate security risks associated with the storage and
transmission of Personal Data.
INFORMATION
FROM CHILDREN UNDER 13 YEARS OF AGE
We
do not knowingly collect or store information from individuals under
the age of 13 years without parental consent. If you become aware
that an individual under 13 years of age has provided us with
Personal Data without parental consent, please contact us at
privacy@sportsbubble.io. If we become aware that an individual under
13 years has provided us with Personal Data without parental consent,
we will take steps to remove the data as permitted by law.
DO-NOT-TRACK
Do-Not-Track
is a public-private initiative that has developed a “flag” or
signal that an Internet user may activate in the user’s browser
software to notify websites that the user does not wish to be
“tracked” by third-parties as defined by the initiative.
Do-Not-Track is not yet standardized and therefore SportsBubble does
not alter its behavior or use practices when we receive a Do Not
Track signal from your browser.
UPDATES
TO THIS PRIVACY NOTICE
We
may update this Privacy Notice from time to time. The most recent
version of the Privacy Notice is reflected by the version date
located at the top of this Privacy Notice. We encourage you to review
this Privacy Notice often to stay informed of how we may process your
information. Your
continued use of the Services and this Platform after such changes
will constitute your acknowledgment of the modified Privacy Notice
and agreement to abide and be bound by the modified Privacy Notice.
CONTACT
US
For
more information about our privacy practices, if you have questions
or if you would like to make a complaint, please contact us by e-mail
at privacy@sportsbubble.io