Effective April 30, 2020
o Information We Collect About You and How We Collect
o Information You Provide to Us.
o Information We Collect through Automatic Data Collection Technologies
o Information Collected by Google Analytics.
o How We Use and Protect Your Information
o Disclosure of Your Information
o Choices about How We Use and Disclose Your Information
o Accessing and Correcting Your Information
o Your California Privacy Rights
o Data Security
o Provisions Applicable to European Union (EU) Residents
o Contacting the Company
This policy applies to information, including information relating to you in identified or identifiable form (your "personal information") we collect:
o On the Services;
o In e-mail, text and other electronic messages between you and the Services;
o Through mobile and desktop applications you download through the Services, which provide dedicated non-browser-based interaction between you and the Services; and
o When you interact with our advertising, mobile applications or desktop applications through third-party websites and services, if such applications or advertising include links to this policy.
It does not apply to information collected by:
o Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
o Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Services.
Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this policy.
The Services are not intended for children under 13 years of age (or such legally required higher age of children being lawfully able to provide consent). No one under age 13 (or such legally required higher age) may provide any information to, through or on the Services. We do not knowingly collect personal information from children. If you are under 13 (or such legally required higher age), do not use or provide any information on the Services, register for the Services, make any purchases through the Services, use any of the interactive or public comment features of the Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 (or such legally required higher age) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please email email@example.com.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT
We may collect several types of information from and about users of the Services, including personal information:
o Such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline;
o That is about you but individually does not identify you (e.g. marketing preferences, personal preferences like favorite Patriots player); and/or
o About your internet connection, the equipment you use to access the Services and usage details, such as operating system version and type and device carrier;
o About your demographics, such as gender and date of birth or age;
o About your geolocation;
o About your communications preferences;
o About your search queries;
o Regarding comments and other information posted on our interactive online forums;
o Regarding correspondence and other information that you send to us; and
o Additional information as otherwise described to you at the point of collection or pursuant to your consent.
We may collect this personal information:
o Directly from you when you provide it to us;
o Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons, and other unique identifiers, including mobile device identification numbers, your browser type, sites you visited before and after visiting the Services, pages you view and links you click on within the Services and standard server log information; and
o From third parties, including our marketing or business partners.
INFORMATION YOU PROVIDE TO US
The information we collect on or through the Services may include:
o Information that you provide by filling in forms. This includes information provided at the time of registering or subscribing to use the Services and posting material or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Services;
o Records and copies of your correspondence (including e-mail addresses), if you contact us;
o Your responses to surveys that we might ask you to complete for research purposes;
o Details of transactions you carry out through the Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Services; and
o Your search queries on the Services.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Services, or transmitted to other users of the Services (collectively, "User Contributions"). You should be aware that any information you post or share within your User Contributions may be read, collected, and used by others who access them. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. To request removal of your User Contributions, such as information posted on public areas of the Services, contact us at firstname.lastname@example.org. In some cases we may be unable to remove your personal information in which case we will let you know if we are unable to do so and why.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
o Details of your visits to the Services, including traffic data, referring/exit pages, clickstream data, location data, logs, and other communication data and the resources that you access and use on the Services;
o Information about the type of device you use, operating system version, and device identifier (UDID) when you download and use our Services through mobile applications.
o Information about how often you use an application, the events that occur within the application, aggregated usage and performance data, and where an application was downloaded from; and
o Information about your computer and internet connection, including your IP address, Internet Service Provider (ISP), operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and does not typically include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver a better and more personalized service, including by enabling us to:
o Estimate our audience size and usage patterns;
o Store information about your preferences, allowing us to customize the Services according to your individual interests;
o Speed up your searches; and
o Recognize you when you return to the Services.
We and our partners (e.g., marketing sponsors), affiliates, or analytics or service providers (e.g., online customer support provider) use technologies such as cookies, beacons, tags and scripts to analyze trends, administer the Services, track users' movements around the Services and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. The technologies we use for this automatic data collection may include:
o Local Shared Objects. Certain features of the Services may use local shared objects, such as Flash cookies, and Local Storage, such as HTML5, to collect and store information about your preferences and navigation to, from and on the Services. Third parties with whom we partner to provide certain features on the Services or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information or click here.
o Web Beacons. The Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have used the Services or opened an e-mail and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
o Social Media Features and Widgets. The Services may include Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on the Services. These Features may collect your Internet protocol address, which content you are visiting and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these Features and any information you submit to these Features are governed by the privacy statement of the company providing it.
INFORMATION COLLECTED BY GOOGLE ANALYTICS
We may use Google Analytics to understand how you make use of our content and determine how we can ensure that the Services function properly. Google Analytics cookies follow your progress through the Services, collecting anonymous data on where you have come from, what content you visit and the time spent using the Services. This data is stored by Google in order to create reports. These cookies do not store your personal data.
o The information generated by the cookie about your use of the Services, including your IP address, may be transmitted to and stored by Google on servers in the United States or any other country in which Google maintains facilities. Google may use this information for the purpose of evaluating your use of the Services, compiling reports on Services activity for us and providing other services relating to Internet activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google may combine information (including IP addresses) obtained through its Google Analytics Premium and DoubleClick Bid Manager products to provide these services. By using the Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
o For information about how you can opt out of Google Analytics and other services that place cookies or collect data, see Choices About How We Use and Disclose Your Information.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information or click here.
LINKS TO OTHER WEB SITES
HOW WE USE AND PROTECT YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
o To present the Services and their content to you;
o To provide you with information about products, contests, sweepstakes, events or services that you request from us, including marketing communications and promotional offers;
o To publish stories, comments, photos and other information posted in our interactive online features;
o To provide you with notices about your account/subscription, including expiration and renewal notices;
o To help you locate a place you may be searching for in your area. We may share your geo-location data with third parties in order for you to receive promotional information for activities, products, or services near you. If you do not wish to share your information in this manner please opt-out by submitting a Data Privacy Request Form.
o . To send you push notifications from time-to-time in order to update you about any events or promotions that we may be running;
o To notify you about changes to the Services or any products or services we offer or provide though them;
o To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
o To allow you to participate in interactive features on the Services;
o In any other way we may describe when you provide the information;
o To fulfill any other purpose for which you provide it; and
o For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. You may also submit a Data Privacy Request Form. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may use mobile analytics software to allow us to better understand the functionality of our mobile software applications on your phone or device. The software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the application.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users without restriction.
o To our parent organizations, subsidiaries and affiliates, and with all members of the NFL Family, including, without limitation, NFL Properties LLC, NFL International LLC, NFL Enterprises LLC, NFL Ventures, L.P. and NFL Ventures, Inc.;
o To contractors, service providers, advisers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, including sending e-mails and notifications, analyzing data, providing marketing, event, and order assistance, and/or providing customer service and support;
o To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of New England Patriots LLC's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding in which personal information held by New England Patriots LLC about users of the Services is among the assets transferred;
o To third parties to market their products or services to you if you have consented to or not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. If you do not want us to share your personal information with these third parties, please submit a Data Privacy Request Form. For more information, see Choices About How We Use and Disclose Your Information;
o To fulfill the purpose for which you provide it;
o To third parties, government or regulatory authorities in the context of disputes, litigation or investigations;
o For any other purpose disclosed by us when you provide the information; and
o For any other purpose with your consent.
We may also disclose your personal information:
o To comply with any court order, subpoena, law or legal process, including responding to any government or regulatory request.
o If we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of New England Patriots LLC, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
o Cookies and Flash Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
o Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you may opt-out by clicking here (or if located in the European Union click here). Please note that you will continue to receive generic ads. You may adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by submitting a Data Privacy Request Form. For this opt-out to function, you must have your browser set to accept browser cookies.
o Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your information. You may also opt-out by adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by submitting a Data Privacy Request Form.
o Promotional Offers from*the Company*. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by submitting a Data Privacy Request Form. If we have sent you a promotional e-mail, you may unsubscribe from future promotional e-mails by following the unsubscribe instructions included in such e-mail or by submitting a Data Privacy Request Form. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
o Newsletter. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can submitting a Data Privacy Request Form.
o Location Based Services. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at email@example.com.
o Push Notifications. If you no longer wish to receive push notifications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as the operating system and user identification information.
o Surveys and Sweepstakes. We may provide you the opportunity to participate in contests, surveys, or sweepstakes on our site. If you participate, we will request certain information from you. Participation in these events is completely voluntary and you therefore have a choice whether or not to disclose this information.
We recommend that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings. In addition, although we do not utilize targeted advertising and do not control third parties collection or use of your info, you can opt out of receiving targeted advertisements generally from members of the Network Advertising Initiative ("NAI") by visiting their website.
ACCESSING, DELETING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by visiting your account profile page. To request access to or delete any personal information that you have provided to us, submit to us a Data Privacy Request Form. We cannot delete your personal information except by also deleting your user account. You may also send us an e-mail at firstname.lastname@example.org to correct any personal information that you have provided to us. We may not accommodate a request to access, delete, or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will respond to your request within a reasonable timeframe.
YOUR CALIFORNIA PRIVACY RIGHTS
California residents have additional privacy rights under the California Consumer Privacy Act, which are described in our California Consumer Privacy Act Notice.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services, such as message boards. The information you share in public areas may be viewed by any user of the Services.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.
PROVISIONS APPLICABLE TO EUROPEAN UNION (EU) RESIDENTS
The provisions below up to the section entitled "Third-Party Ad Serving and Audience and Tracking Measurement Services" relate to residents of the European Union. Under applicable data privacy laws, the Company is a data controller and a processor with respect to your personal information.
Some of the personal information you provided to us may include health information or other sensitive or special categories of personal information (defined under applicable data privacy laws.) We do not process sensitive or special categories of data without your express consent or otherwise as permitted by the data privacy laws. We protect your personal information through appropriate technical and organizational security measures in compliance with applicable law. Although we make good faith efforts to store the information we collect in a secure operating environment that is not available to the public, we cannot guarantee complete security. Further, while we work to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.
Under applicable data privacy laws, our lawful processing grounds are contractual and legal necessity and our legitimate interests in operating and improving the Website. In particular, we process your personal information on the basis of our legitimate business interest pursued by the Company and its affiliates to manage any technical issues or support requests that may arise, to comply with our reasonable business-related obligations and requirements and to comply with our legal and contractual requirements. Furthermore, our legitimate interests or those of a third party include our requirements to use your personal information in litigation or for our legal purposes involving the Company and /or its affiliates and may also include the need to transfer your personal information to countries without adequate data protection laws compared to those in your country of residence (including the United States where the Company is located). In this event, we will take reasonable steps to protect your personal information as required by the data privacy laws.
Retention of Your Personal Information
We retain your personal information relating to the use of our Website for the duration of our business relationship and for seven years after our last communication for legal, regulatory, audit and tax requirements. Further, your personal information may be stored within the legal limitation period during which claims against the Company or its affiliates may be asserted. After this period has expired, your personal information relating to your use of the Website will be deleted. Any personal information which you have provided to us for marketing purposes will be kept until you notify us that you no longer wish to receive this information or seven years after you last contacted us.
You have certain rights regarding your personal information, as described below, which are subject to applicable data privacy laws:
• you have the right to access your data;
• you have the right to withdraw your consent at any time for personal information that is processed on consent (the withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal);
• you may object to processing of your personal information, including for any direct marketing or profiling purposes;
• you have the right to request any correction of your personal data or that we delete your personal information;
• you have the right to request that we restrict the processing of your personal information (this may, however, compromise our ability to provide you with our goods and/or services); and
• you also have the right to request the transfer your personal information to another service provider, where required under applicable data protection laws, and following your written request to us, we will provide you with your relevant personal information in a machine-readable format to transfer to another service provider.
To exercise these rights, please contact us at: email@example.com.
If you wish to raise a concern about how we have handled your personal information, you can contact us (details above) and we will investigate the matter and respond to you promptly. You can also raise your concerns with any competent data privacy authority in your country of residence.
THIRD-PARTY AD SERVING AND AUDIENCE AND TRAFFIC MEASUREMENT SERVICES
We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users' online activities over time and across different websites. To manage your preferences you may opt out here http://preferences-mgr.truste.com/. The Services may feature Nielsen proprietary measurement software, which will allow users to contribute to market research, such as Nielsen TV Ratings. Nielsen believes that you should have a choice about whether to contribute to our research and insights. To opt out of Nielsen measurement, you need only to activate the "Limit Ad Tracking" (for iOS devices) or "Opt out of Ads Personalization" (for Android devices) option in your devices settings. For web, please visit: http://www.nielsen.com/digitalprivacy to learn more about the Nielsen digital measurement products and your choices in regard to them.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
CONTACTING THE COMPANY
New England Patriots LLC
One Patriot Place
Foxboro, Massachusetts 02035, USA