Table of Contents
2. Information We Collect and How We Use It
3. Children and Parents
4. Your Choices
5. Sharing Information
7. Accessing Information
8. Contacting Us
9. Important Notice
10. Your California Privacy Rights
11. Disclosure to Users Outside the US
12. Do Not Track
b. Whenever you use a Property we may collect, process, and combine Information; contact you from time to time; and provide you with other services you have requested. We may, from time to time, also disclose Information to Spire’s vendors and partners.
2. Information We Collect and How We Use It.
a. Spire may collect Information about you from you and other sources. We use and may combine that Information to operate, tailor content, personalize, adjust and improve our Properties, and to send you messages or personalized information about our services, including for marketing and promotional purposes.
b. We may collect the following categories and types of “Personal Information”:
i. Contact Information: your first and last name, mailing address, email address, and phone number;
ii. Other identifying information: IP address, user names, passwords and other security information for authentication and access;
iii. Financial Information: credit card, debit card and bank account information;
iv. Demographic information: gender, age;
v. Geolocation data;
vi. Internet or other electronic activity: your browsing and click history, including information about how you navigate within our Properties and which elements of our Properties you use the most;
vii. Commercial information: products purchased or viewed on our Properties;
viii. Audio and visual information: your videos and photos; and
ix. Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.
c. Information Provided by You. Spire may collect Information from you when you:
ii. Receive Newsletters on Products and Services and/or Receive Marketing Emails. Spire may offer you the ability to receive newsletters or marketing emails periodically by email about the products and services of Spire and its affiliates. You can stop receiving further newsletters or marketing emails by unsubscribing from the link in the footer of each email we send to you.
iii. Participate in Surveys/Feedback Requests. Spire may ask visitors and users to participate in survey activities or to provide feedback about their products or services.
iv. Participate in Sweepstakes and Contests. Spire and its affiliates may collect information from visitor and users in connection with entry into and participation in sweepstakes and contents offered through the Properties. In doing so, Spire and/or its affiliates may offer visitors and user the opportunity to receive newsletter on products and services and/or receive marketing emails as noted above.
d. Information Provided by Other Sources. We may also obtain Information about you from other sources and each of their vendors and partners, social media, our affiliates, vendors, partners, and network advertising companies, and combine that Information with Information we have collected from or about you. We only collect Information from other sources where they have confirmed to us they are legally entitled to share it with us.
3. Children and Parents. Our Properties are intended for users who are 13 years old or older. Spire and its affiliates do not knowingly collect or store any Personal Information from children under 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records. Parents should contact Spire immediately if they have any concerns. Please see the Contacting Us section below for further details.
4. Your Choices. You have choices over the Information provided by you and by other sources, and how that Information is used by Spire and its affiliates.
a. Your Choices About Information Provided by You. If you do not want to provide Spire or its affiliates with Personal Information, then you can choose not to provide it. Please note that if you choose not to provide us with Personal Information, we may not be able to provide you with the relevant product or service that you want. For example, without providing an email address, you will not be able to sign up for Spire newsletters.
b. Your Choices About Information Provided by Third Parties. You may be able to control how third parties collect and share your Information by changing your preferences or opting out of collection directly with those third parties. Before disclosing Information to third parties, we recommend you check their respective privacy policies for further details.
5. Sharing Information.
a. Spire shares Information: (i) with its affiliates; (ii) with vendors and partners engaged by Spire and its affiliates in order to provide you with goods or services you have requested or online advertising selected by us; (iii) if required to do so by applicable law, regulation or legal process; (iv) if necessary to exercise, establish or defend our legal rights; (v) if necessary to protect the vital interests of any person; and (vi) In connection with the sale of our business or assets.
b. Our Affiliates. We may share Personal Information with businesses controlling, controlled by, or under common control of Spire.
c. Vendors. Vendors provide goods and services (for example, billing, consumer services support, consultancy, information technology hardware and software) to Spire and its affiliates in order to support, operate and develop the Properties and to deliver marketing communications on our behalf. We do not share Information with vendors to use for their own direct marketing purposes or any other purpose without your consent, except those outlined above and to execute, deliver and/or improve the services they provide. We only provide our vendors with the information necessary for them to perform these services on our behalf. Each vendor must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. vendors are prohibited from using Personal Information other than as specified by us.
d. Applicable Law, Regulation or Legal Process. We will disclose your Information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you, us, or our affiliates. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
f. Protect Vital Interests. We disclose your Information with third parties where we believe this is necessary to protect the vital interests of any person. For example, we disclose Information relating to an online account if we in good faith believe the user of that account is using it in ways that are harmful to others (e.g., making inappropriate contact with minors).
g. Sale of Our Business or Assets. Separately, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information of Spire and its affiliates, including Information and communications, may be transferred to our successor or assign.
h. Please note that any information, including Personal Information that you reveal in a bulletin board, message board, chat room or other public forum is publicly viewable. When you post Personal Information publicly through the Properties, it may be viewable by other users of these sites and we cannot prevent further use of the Personal Information by third parties.
6. Security. Spire takes a range of security measures designed to protect your Personal Information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information). We also take steps to ensure that the Personal Information collected is protected from misuse and alteration. In addition, we request vendors who process Personal Information on our behalf to themselves take a range of security measures designed to help protect your Personal Information. However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any Personal Information collected, stored or used by us or our vendors cannot therefore be guaranteed, and you transmit your Personal Information through the Properties at your own risk.
7. Accessing Information.
a. If for any reason you are concerned with the way we are using your Personal Information, or would like to correct, view, update or request that we delete such Personal Information, you can send your request to [email protected]. Alternatively, you may write to us at: 19510 Jetton Road, Suite 300, Cornelius, NC 28031. We will be happy to review, update or remove Information as appropriate.
9. Important Notice.
a. For privacy related information applicable to users who are California residents or based outside the United States please see below.
10. Special Note for Users located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”)—Your Rights and Choices.
a. The data controller for the Properties is: Spire Sports & Entertainment, LLC, 19510 Jetton Road, Suite 300, Cornelius, NC 28031.
b. We use the information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:
i. To enable you to register to the Properties;
ii. To send you transaction-related emails or push notifications;
iii. To offer you the features for which you provide information;
iv. To handle any request you may have to our consumer services such as resolving your problem or question, handling your warranty request; manage any complaints or deal with any feedback you may provide us;
v. For statistical analysis of aggregated data to help us segmenting our offering and develop our products and services;
vi. To better understand the way in which the Properties are working, to offer better experience to you when using the Properties, to create statistics in relation to the use of the Properties, and our other services and offerings in general; and
vii. To help us diagnose technical and service problems and administer the Properties.
c. Based on your voluntary consent, which you may withdraw at any time, we also use:
i. Your browsing data to better understand your profile, interests, preferences to enhance your user experience and facilitate your experience and offer you relevant information and promotional materials and interest-based advertising; and
ii. Your Personal Information and we may combine these with third-party data to send you personalized emails and push notifications tailored to you and your interests.
d. In order to comply with our legal obligations, we may also use some of your Personal Information to detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or government or court orders.
e. You may have certain rights under applicable data protection legislation with respect to your Personal Information, such as the right to:
i. Request access to and be provided with information on the processing of your Personal Information;
ii. Request corrections of your Personal Information if such Personal Information proves inaccurate or incomplete;
v. Object to the processing of your Personal Information for direct marketing purposes or to any processing which we would have based on our legitimate interest (e.g., profiling);
vi. Withdraw consent (to the extent we request and you provide your consent to the processing of your Personal Data, you can withdraw your consent at any time; your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal);
vii. Receive Personal Information which you provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider provided it is processed based on your consent or our contract; and
viii. Lodge a complaint with your relevant data protection authority.
g. Regarding the transfer of Personal Information to countries outside the EEA, Switzerland or the UK, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer of personal information to controllers or processors established in third counties as the case may be, when appropriate.
h. The principle that we apply is that your Personal Information will be deleted when they are no longer necessary for the purpose for which they were collected. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
11. Your California Privacy Rights.
a. Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. Note that we do not share our customer’s Personal Information with unaffiliated third parties for their own direct marketing purposes, without their approval.
b. If at any time you wish to opt out of having your Personal Information shared with the third parties as described in the Sharing Information Section for their direct marketing purposes and/or receiving information from the Spire (via e-mail or postal mail) about new products, services, or promotions, please send us an email at [email protected], or write to us at: 19510 Jetton Road, Suite 300, Cornelius, NC 28031. We will be happy to honor your request.
c. California Privacy Rights for Minor Users. Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or delete Information provided by you or publicly posted by you. You may do this by sending us an email asking us to delete certain posted content at [email protected]. In the alternative, you may write to us at 19510 Jetton Road, Suite 300, Cornelius, NC 28031.
d. We will be happy to review, update or remove Information and/or content as appropriate. Residual copies of Information and/or content that have been deleted may remain in our backup systems. We may still retain your Information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your Personal Information will be blocked from use for any other purpose.
e. California Consumer Privacy Rights. If you are a California resident, you may also have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with us.
CCPA Rights Requests
Right to Know
You can request what Personal Information we have collected about you in the preceding 12 months.
You can request the specific pieces of Personal Information we have collected about you.
You can also request the following categories of information:
• The categories of Personal Information we have collected about you.
• The categories of sources from which the Personal Information was collected.
• The business or commercial purpose for collecting or selling the Personal Information.
• The categories of third parties with whom we shared Personal Information.
Right to Deletion
You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:
• Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
• Security: to detect and prevent data security incidents;
• Error Correction: to debug or repair any errors;
• Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
• Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).
We will also maintain a record of your CCPA Rights requests.
Please note that if we delete your Personal Information, some of our services will not work the same. For example, your previous opt out requests will not be saved and saved preferences and information will no longer be available.
Exercising your Rights
To submit a request to know or delete, please send an email to [email protected]. You must use “California Request to Know Information” or “California Right to Know Categories” in the subject line of your email, as appropriate. You must provide us with your first name, last name, email address, and phone number. To verify your identity, we will match that information to the information we have on our systems. To designate an authorized agent to act on your behalf you or your agent must send a signed, written authorization containing your first name, last name, email address, and phone number to 19510 Jetton Road, Suite 300, Cornelius, NC 28031. You must provide us with all of the information set forth above in any such request, including what request you are making.
Do Not Sell My Personal Information
Personal Information that We Sell
We may “sell” (as sell is defined in CCPA) the following categories of Personal Information:
• Contact Information;
• Characteristics of protected classifications under California and federal law;
• Internet/electronic activity;
• Commercial information; and
• Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.
We “sell” your Personal Information to select partners and to digital advertising networks. We do not knowingly sell the Personal Information of minors under the age of 16.
Right to Opt Out of Sale
California residents have the right to opt out of the sale of your Personal Information to third parties, as “sale” is defined under CCPA.
To submit a request to opt out of the sale of your Personal Information, please email us at [email protected]. You must use “California Opt Out from Sale” in the subject line of your email and provide us with your full name and email address. In order to designate an authorized agent to act on your behalf, you or your agent must send a signed, written authorization containing your first name, last name, email address, and phone number to 19510 Jetton Road, Suite 300, Cornelius, NC 28031. You must provide us with all of the information set forth above in any such request.
We participate in digital advertising networks to deliver advertising that is tailored to your interests. The participation in certain ad networks can constitute a “sale” of Personal Information under CCPA. In order to opt out of this activity, please visit optout.aboutads.info and optout.networkadvertising.org.
We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.
We may offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by contacting us at [email protected] or by unsubscribing to our email marketing by vising our website. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.
b. We use Google Analytics on the Properties to analyze how users use the Properties, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.