PRIVACY POLICY

Stars Fantasy Sports SubCo, LLC (“StarsDraft”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

This policy (together with our Terms of Website Use (“TOWU”) and any other documents referred to within the same or hereunder) sets out the basis on which any personal data we collect from you, or that you provide to us, will be used, stored and processed   by us, all in accordance with applicable laws. Please read the following carefully to understand our procedures and practices regarding our collection, use and storage of your personal data.

By accessing our website located at StarsDraft.com (“Site”) or, to the extent applicable, downloading any applications (“Apps”) which we make available to you,  in order to use our services (“Services”),  you unconditionally accept and agree to be bound by this privacy policy (“Privacy Policy”) If you do not consent to or wish to be bound by our Privacy Policy, then you are not permitted to use our Services nor should you continue to navigate our Site and/or App.

The Site may contain links to third party websites (“Third Party Sites”) that enable us provide our Services to you. Please be aware that we are not responsible for the privacy practices or policies of these Third Party Sites and this Privacy Policy will not apply to all such sites.   Your access and use of such Third Party Sites is entirely at your own risk and we encourage you to review the privacy policies of these Third Party Sites separately.

INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:

  • Information you give us. You may give us information about you by filling in forms on the Site, registering for an account at the Site, or by corresponding with us by phone, e-mail or otherwise. This includes, but is not limited to, information you provide when you register to use the Site, participate in discussion boards or other social media functions on the Site, place an order on the Site, participate in competitions, promotions, contests or surveys and/or when you report a problem with the Site. The information you give us may include but is not limited to, your name, username, address, email address, phone number, geo-location data, social security number, financial and credit card information, personal description and photograph. From time to time, we may also request that you provide us with copies of personal and official documentation
    (for example your passport, driving license, certificate of residency, bank statements, etc.).
  • Information we collect about you. Each time you visit the Site we may automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, geo-location data, operating system and platform; and
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), search terms entered, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer services.
  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

COOKIES
The Site uses cookies to distinguish you from other users of the Site. This allows us to both provide you with a better experience when you browse the Site and also to improve the Site generally. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

HOW INFORMATION COLLECTED IS USED
We use information held about you in the following ways:

  • Information you give to us. We will use this information:
    • to operate, maintain and provide to you the features and functionality of the Site and our Services, for example, displaying your username, profile photo (if supplied), date of joining and your statistics on our Site or through the use of our Services (if necessary);
    • to carry out our obligations pursuant to any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • to provide you with information about other goods and services we offer that are similar to those that you have already purchased, used or enquired about;
    • to provide you with information about goods or services we feel may interest you;
      or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the Site’s account registration form;
    • to notify you about changes to the Site and/or any of our services and to interact with you generally;
    • to ensure that content from the Site is presented in the most effective manner for you and for your computer; and
    • in connection with any advertising, marketing and/or publicity activity with which you may have agreed to participate (for example, we may publish  and/or disclose your name as a winner or participant in our contests/promotions, together with a link to your profile page on our Site).
  • Information we collect about you. We will use this information:
    • to administer the Site and provide the Services together with our various internal operations, including but not limited to; identification and verification purposes, troubleshooting, data analysis, testing, research and development, statistical and survey purposes, customer profiling, compliance with regulatory or legal requirements;
    • to improve the Site as well as our Services on offer, to ensure that content is presented in the most effective manner for you;
    • to allow you to participate in interactive features of the Site and use of the Services, when you choose to do so;
    • as part of our efforts to keep the Site safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • to make suggestions and recommendations to you and other users of the Site and the nature of our Services or other  goods or services that may interest you or them.
    • to provide the Services to you in accordance with the TOWU
    • for marketing and publicity purposes (e.g. use your name and/or username), unless restricted by applicable law.
  • Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its direct and indirect subsidiaries.

We may share your information with selected third parties including:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, solely in relation to your use of the Services, for instance, verification and/or identification suppliers or  a supplier that acts as a fulfillment service for us in providing you with any goods or services or to confirm or carry out any financial transactions (as applicable) on your behalf so that you can use the Services;
  • advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We do not disclose personally identifiable information about individuals to our advertisers, but we may provide them with anonymized and/or aggregated information about our users. We may also use such anonymized and/or aggregate information to help advertisers reach a particular demographic. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
  • analytics and search engine providers that assist us in the improvement and optimization of the Site.

We may disclose your personal information to third parties:

  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the assets transferred; this includes a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or legal request, such as a subpoena, or in connection with required governmental filings or submissions, or in order to enforce or apply our Terms of Website Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of StarsDraft, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

We take reasonable technical, physical, administrative and managerial procedures, and employ security measures and safeguards to protect information about you that is stored on our servers.

Any financial transactions are processed by third party payment processing suppliers who employ security measures, including encryption protocols and storage procedures, which we believe to be at least as effective as the industry standard.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you believe your password or account has been compromised, you are required to notify us immediately at support@starsdraft.com

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, including on our servers, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use commercially reasonable technical, physical, administrative and managerial procedures, security measures and safeguards to try to prevent unauthorized access to, and to preserve the integrity and security of, your personal information.

If you are accessing the Site from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, storage and disclosure, that differ from United States laws, you acknowledge that you are transferring your personal information to the United States wherein it will be processed and used in accordance with applicable  laws and you consent and agree to such transfers.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at

ACCESS TO INFORMATION
You may request a copy of all information held about you, at any time, by contacting support@starsdraft.com.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request, once a calendar year, information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2015 will receive information regarding 2014 sharing activities). To make such a request, please write us at:

StarsDraft
9111 Jollyville Road, Suite 235
Austin, TX 78759

We only use your personal information for specific purposes. For example, you must be at least 18 years of age, or older than 18 years of age in those jurisdictions, territories, and locations where the minimum age for permissible use of the Site by you is greater than 18 years old. We use such information to verify age.

CHANGES TO OUR PRIVACY POLICY
This Privacy Policy may be revised periodically and this will be reflected by the “Last updated” date below. Please revisit this page to stay aware of any changes. Your continued use of the Site and/or our Services constitutes your agreement to this Privacy Policy and any future revisions.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@starsdraft.com.

This privacy policy was last updated on 3 September 2015.