THIS IS A WEBSITE PRIVACY DRAFTED UNDER U.S. LAW. THIS POLICY IS NOT INTENDED TO SATISFY ANY ‘FAIR PROCESSING NOTICE’ OBLIGATIONS THAT YOU MAY HAVE UNDER GDPR OR OTHER APPLICABLE NON-US LAW.
EFFECTIVE DATE: 6.15.2020
By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Wave Sports Terms of Service (the “Terms”) are incorporated by reference into this Policy.
The Information We Collect About You
We collect information about you directly from you and from third parties, and automatically through your use of our Site or Services.
Information We Collect Directly From You. The information we collect from you depends on how you use our Services. We collect personal information from you in the following ways:
(1) When you Submit Content: Name, social media handle, phone number, URL for content or video upload, country (keep compliant from GDPR), age box checkoff.
(2) When you Purchase Our Products: Name, address (e.g., billing and shipping), email address, payment card information, and wireless telephone number (optional).
(3) General personal data submission: Name, email, phone number, social handles, portfolio URL
Information We Collect From Other Entities. On occasion we may obtain personal information about you from third parties, which we process to allow us to improve the Services, or market our Services, or our affiliates’ services to you.
Information We Collect Automatically. When you visit our Site, we automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps (e.g., IP address, browser type, operating system, site usage and navigation). To the extent permitted by applicable law, we combine this information with other information we collect about you, including your name, email, address, purchase history. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
- domain name;
- your browser type and operating system;
- web pages you view on the Site; links you click on the Site; your IP address (e.g., clickstream);
- the length of time you visit our Site and or use our Services;
- the referring URL, or the webpage that led you to our Site.
- device name and model; operating system type, name, and version;
- language information;
- activities within the App; and the length of time that you are logged into our App;
- location information;
- With your permission, we will collect location information from your internet devices to market services to you which may be of interest to you. You may turn off this feature through the location settings on your device(s).
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our Services to you and to fulfill your orders.
- To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to personalized help and instructions, and to otherwise personalize your experiences while using the Services.
- To send you email marketing about our products and services.
- To send you news and newsletters.
- To send you email marketing about products and services of our affiliated entities.
- To send you email marketing about products and services of other entities that we think may be of interest to you.
- To assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).
- To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are more (or least) used by users, and we will use this information.
- For our own research and analytics purposes.
- To administer our customer loyalty program.
- To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
- To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
Other purposes would include: (1) Filing reports to our investors and affiliates; and (2) Compliance with applicable laws.
How We Share Your Information
We may share your information, including personal information, as follows:
- Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include payment card processors, data analytics firms, web hosting and storage vendors.
- Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.
- Social Media Platforms (e.g., Facebook, Twitter, TikTok). Your username and profile picture will be visible to all other Wave Sports users, regardless of whether they are your Facebook friends.
- Company Users. Your user name and any information that you post to our Site, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.
- Third Parties. We may disclose personal information about you to our service providers and vendors to assist us with providing or marketing our Services to you.
We also disclose information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
Third-Party Ad Networks
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Submission of User Generated Content
You may submit content as directed on our Site and Services, including your comments, pictures, and any other information that you would like to make available through our Site or Services. Any content which is submitted may be made available to other users of the Site. We have terms and conditions of use which apply to all submissions of user content, and are made available to you at the time of submission. If you do not accept our terms and conditions, we will not accept your submission of content.
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Site, Applications, and Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Application, or through email.
Your California Privacy Rights
Personal Information under the California Consumer Privacy Act (CCPA). We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
California Privacy Rights. If you reside in California, you have the right to:
- request the deletion of your personal information that we collected,
- opt-out of the sale of your personal information (e.g., “Do Not Sell”), and
- request that we disclose information about our collection and use of your personal information over the past 12 months including:
- the specific pieces and categories of personal information we collected,
- what personal information we collect, use, disclose, or sell about you
- the categories of sources of the personal information we collected about you,
- our business purpose for collecting or selling (if any) the personal information,
- for each category of personal information, the categories of third parties to whom the personal information was disclosed or sold, and
- be free from discriminatory adverse treatment for exercising these rights.
In order to protect your privacy and verify your request, we may require additional information from you when you contact us.
Instructions: If you have a privacy related inquiry and you are a California resident, you or your authorized agent can submit your request by emailing us at firstname.lastname@example.org. In general, we will verify your request and your identity when you contact us by asking your for personal information we have on file about your such as your name, address, acct. number or other info so that we may match it to information that we maintain about you. If you have questions or concerns about our privacy practices, you may contact us.
Why We Collect and Use Personal Information: We collect and use personal information for the following commercial or business purposes
Our Use of Personal Information
- Providing Support and Services: Including to provide our products and services, including our websites, applications and online services (collectively, our “Services”); to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes.
- Personalizing Content and Experiences: Including to tailor content we send or display on our websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences.
- Advertising, Marketing and Promotional Purposes: Including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests.
- Securing and Protecting Our Business: Including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
- Defending our Legal Rights: Including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
- Auditing, Reporting, Corporate Governance, and Internal Operations: Including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
- Complying with Legal Obligations: Including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
Sources of personal information: We collect personal information directly from you and your device for the purposes described in the previous section.
Sale Under CCPA: The CCPA defines “sale” of personal information very broadly, including as “sales” disclosure of personal information in exchange for receiving anything of value in quite a few situations that are not commonly understood to be “sales”. We do not sell your personal information with third parties, as that term is defined under the CCPA.
Categories of Personal Information that We Collect, Disclose, and/or Sell
|CCPA Categories of Personal Information
We Collected in the Last 12 Months
|To what categories of 3rd Parties (if any) did we disclose for a business purpose(s) in last 12 months?||To what categories of 3rd parties (if any) did we sell in the last 12 months?|
|Identifiers: Name, unique personal identifier, online identifier, Internet Protocol (IP) address, clickstream data of browsing history, email address, account name.||website/app developers||None|
|Customer Records: Name, telephone number, billing address, home address, email address, credit card or account number information… [ DLA insert any elements of personally identifiable data you keeps as a part of customer records]||Our service providers, vendors, partners and payment card processors to provide you services or fulfill orders.||None.|
How we use categories of personal information we collect about you:
- Identifiers- We use Identifiers to help us provide and enhance the Services. We also use these identifiers to monitor how often you and other users visit our website or specific content located on our Site. We also use and disclose this information to market our services to you. ,
- Customer Records: We use this information to provide you with information, about the services and our products. We use this information for service fulfillment and customer service purposes. We use this information to market our products to you. We use this information for product development and marketing analytics.
California’s “Shine the Light” law
California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) gives California residents the right to request and receive, once annually and free-of-charge, information about how we share your personal information (if any) with third parties for their own direct marketing use. If you are a California resident and would like to make such a request, please email email@example.com. In your request, please include your name and attest to the fact that you are a California resident and provide a current California address. We may ask you for additional information to confirm your identity before responding to this request.
For any questions or concerns about our privacy policies or practices, you can contact us at our toll free number (800)771-6382 or our e-mail box: firstname.lastname@example.org.
Last Updated: [6.15.20, 2020]