PRIVACY AND DATA SECURITY STATEMENT
Thank you for visiting the online and mobile resources operated by ZogSports Holdings LLC including https://www.zogsports.com and https://zogculture.com (“Site”), and for viewing this privacy and data security statement. Our privacy statement, contained in the pages that follow, serves to give notice about the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it on our customers, visitors, and any other users. We delve into those matters in a fair amount of detail in the pages that follow. We encourage you to read them carefully. In the meantime, we provide a quick overview below.
Summary of how we handle Personal Information
What do we collect?
We collect and retain certain personal information from a variety of different data subjects. Our privacy statement applies mostly to those who visit and use our online and mobile resources, from whom we collect very little information unless it is voluntarily submitted to us. You can read here to learn about the categories of personal information we collect.
Why do we use it?
We use personal information received from visitors and users of our online and mobile resources to communicate directly with them, enable their participation in our leagues and other events, complete transactions, and personalize offers. We provide further detail about our use of personal information here.
When do we share it?
We share personal information when needed to fulfill our legal obligations and when our vendors and business partners need it to perform under the contracts we have with them. We provide further detail about our sharing of personal information here. We do not sell or rent any personal information.
How do we protect it?
We’ve invested in a Security Program that addresses both technical and operational matters. Our program includes incident response and management and vendor oversight components. You can read about those components here and here.
Your Privacy Choices and Rights
While certain features of our online and mobile resources do require that you provide some personal information, you can choose not to use those specific features and still enjoy the remainder of online and mobile resources. Moreover, you can opt out of certain activities. You can learn more about that here.
Contacting Our Privacy Office
If you have any questions about our privacy and data security policies, procedures and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office.
This privacy statement was amended as of September 28, 2023, and is effective as of that date. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.
NAVIGATING THROUGH THIS STATEMENT
You can use the links below to navigate to areas of this statement that apply specifically to you, or which may otherwise be of interest:
SOME IMPORTANT VOCABULARY
Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. Clarity is therefore important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement” and “our statement”, we mean the Privacy and Data Security Statement you are reading now. Wherever we say “Company”, “we”, “us”, or “our”, we mean ZogSports Holdings LLC and its subsidiaries and affiliates. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this statement here.
When we talk about our “online and mobile resources”, we mean all websites, portals or other features we operate to allow you to interact with us and our systems, as well as any mobile apps we’ve created and distributed to let you interact with the content we provide and participate in. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence.
Finally, and perhaps most importantly, when we refer to “personal information”, we mean any information, data or data element, whether in electronic or other form, that, alone or in combination with other elements, can be used to distinguish, trace, or discover your identity. Certain data privacy laws include specific elements or defined terms for what they consider to be personal information (sometimes also referred to as “personal data”). Where such data privacy laws apply, then the term “personal data” includes the specific elements and defined terms required by such laws.
WHEN AND TO WHOM DOES THIS PRIVACY STATEMENT APPLY?
We may collect personal information from the following data subjects:
This statement applies to our processing and sharing of personal information collected from those specific data subjects listed above whenever they visit our website or any other mobile or online resources we may operate.
WHERE DO WE GET YOUR PERSONAL INFORMATION FROM, WHAT CATEGORIES DO WE COLLECT, AND HOW DO WE USE AND SHARE IT?
Categories of Sources - where do we get your personal information?
We may collect and otherwise obtain your personal information in the following ways:
Voluntary Submissions. Here are some of the ways you voluntarily give us your personal information:
If you prefer that we not receive the above-described personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on or use the applicable features available from our online and mobile resources. Such participation and use is strictly your choice. By not participating, you will be unable to take part in our leagues and activities and access our password-protected features, and you may limit your ability to take full advantage of the online and mobile resources, but much of the content in our online and mobile resources will still be available to you and we never discriminate on the basis of how much information you provide.
Automatic Collection. When you visit or use our online and mobile resources, information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as “cookies.” Cookies may allow us to collect your IP address and/or other identifiers and recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions, such as:
If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, may allow us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that provide a proximate estimate of the physical location of devices and we may receive this proximate geolocation data as well.
In addition, when you use our online and mobile resources, we may allow third party service providers to place their own cookies or similar technologies in order to engage in the same types of collection we describe above. For example, we use third party “web analytics” services such as those offered by Google Analytics. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
Do Not Track (DNT) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals, but do recognize those set at a browser level.
External Sources. We may work with companies who make data, including personal information, available so that companies like us can tailor our services to audiences who have the most interest. We also may work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by third parties. These third parties collect information with their own cookies, pixels, and related tracking technology and then provide that information to us. We are not responsible for their data collection practices. For more information, please see the section “When/To Whom Do We Share Your Personal Information.”
We further maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn. We may allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties. We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third-party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor the terms of use appearing on or in any of our online and mobile resources apply to our social media presence or any third-party sites or apps to which we may link. That means even if you take an affinity action on our specific social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility.
If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. In addition, certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of those coalitions. You can follow the links below to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt outs on each browser on each device for which you wish to opt out of interest-based advertising.
Categories of Data – what types of personal information do we collect?
The categories of personal information we have collected from visitors and users of our online and mobile resources in the previous 12 months, and may collect from you, are as follows, some elements of which, may be considered “sensitive information” under applicable law:
How Do We Use the Personal Information We Collect
We and our service providers use the information we collect from and about you for the following business and operational purposes:
Why Do We Share Your Personal Data?
Analytics. We may allow selected service providers or processors to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
Transfer of Assets. If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.
Advertising. In order to support tailored advertisements, offers, or content that you may find interesting when you browse the internet, we may share certain personal information with our trusted third-party partners that support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, data brokers advertising networks or any other activity that may be considered cross-behavioral advertising.
Security and Fraud. We allow third parties to receive personal information from our users to provide us with both security and fraud protection. We do not control these third parties or how the information is used.
Required By Law. We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to, investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of the Company, the Site or others, as we deem appropriate.
Retention of Your Personal Information.
We store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above and in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:
When/With Whom Do We Share Personal Information?
Over the past twelve months, ZogSports may have shared your personal information as listed below:
HOW DO WE PROTECT COLLECTED PERSONAL INFORMATION?
Our Data Security Program
We have adopted, implemented and maintained an enterprise-wide corporate information security and privacy program that includes technical, organizational, administrative, and other security measures designed to protect, as required by applicable law, against reasonably anticipated or actual threats to the security of your personal information (the “Security Program”). Our Security Program was created by reference to widely recognized industry standards such as those published by the International Standards Organization and the National Institute of Standards and Technology. It includes, among many other things, procedures for assessing the need for, and as appropriate, either employing encryption and multi-factor authentication or using equivalent compensating controls. We therefore have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Our Incident Response and Management Plan
Despite the significant investment we’ve made in, and our commitment to, the Security Program including enforcement of our vendor and service provider oversight procedures, we cannot guarantee that your personal information, whether during transmission or while stored on our systems, otherwise in our care, or the care of our vendors and business partners, will be free from either failed or successful attempts at unauthorized access or that loss or accidental destruction will never occur. Except for our duty under applicable law to maintain the Security Program, we necessarily disclaim, to the maximum extent the law allows, any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.
All that said, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. Those procedures include mechanisms to provide, when circumstances and/or our legal obligations warrant, notice to all affected data subjects within the timeframes required by law, as well as to give them such other mitigation and protection services (such as the credit monitoring and ID theft insurance) as may be required by applicable law. We further require, as part of our vendor and business partner oversight procedures, that such parties notify us immediately if they have any reason to believe that an incident adversely affecting personal information we provided to them has occurred.
CHILDREN’S PRIVACY
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.
SUBMITTING INFORMATION FROM OUTSIDE THE UNITED STATES
We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the Website and Services may be stored and processed in the United States or any other country in which we or our vendors maintain facilities. Although we do not actively block or monitor visitors from other countries, the Website is directed only at visitors from the U.S. As such, this Privacy Policy is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). ZogSports will apply the applicable laws of the U.S. including as embodied in this Privacy Policy in place of data protections under your home country's law. That is, you freely and unambiguously acknowledge that this Privacy Policy, not your home country's laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.
EXERCISE YOUR PRIVACY RIGHTS
ZogSports takes privacy seriously. Where applicable, data subjects have certain rights which they can request for ZogSports to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:
In order to exercise any of the rights detailed above, please contact us using the information listed below. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by ZogSports. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting us at the information below.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at the time of collection. Typically, we will indicate the effective/amendment date at the beginning of this statement. Where ZogSports determines that such changes materially affect your privacy rights, we will provide additional notice to you. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new statement.
CONTACTING US
If you have questions about our privacy statement or privacy practices, please contact our Privacy Office:
Last Updated: 9.28.23