NWSL Media, LLC
Effective Date: February 7, 2020
- Types of Information We Collect
- How We Collect Your Information
- How We Use Your Information
- How We May Share Your Information
- Communication Services and Community Features
- Third-Party Advertising
- All Users: Your Choices and Controls
- California Residents: California Privacy Rights
- Security Practices
- Links to Other Services
- Additional Information
- Children’s Data
- Contact Us
1. Types of Information We Collect
When you interact with us through the Services, we collect the information you provide, usage information, and information about your device. We also collect information about you from other sources like service providers, and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:
(A) Personal Information
- Personal Identifiers, including your first and last name, birthdate, age, gender, username, and social security number.
- Contact Information, including your email address, phone number, and home address.
- Biographical Information, including your level of education and professional background.
- Financial Information, including your credit card number and purchasing history.
(B) Device Identifiable Information
We may collect information that may not reasonably identify you or a household personally, but is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the Services. When you visit our Sites to browse, read, or download information, we automatically collect information about your computer that your browser sends, such as your IP address, browser type and language, access times, pages visited, and referring website addresses. We may use Device Identifiable Information to analyze trends, help administer the Services, track the online movement of users, to learn about and determine how much time visitors spend on each page of the Sites, how visitors navigate throughout the Sites or use other Services, and to gather broad demographic information for aggregate use. We may also collect Device Identifiable Information through “cookies” or “web beacons” as explained below.
In addition, we may collect information about your mobile device such as the type and model, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), applications using our Sites, and identifiers assigned to your device, such as its iOS Identifier for Advertising (“IDFA”), Android Advertising ID (“AAID”), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.
We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (“ISP”) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.
When aggregated or deidentified information, including Device Identifiable Information, is directly associated with Personal Information, such that the aggregated or deidentified information can be reasonably associated with a particular individual User or household, then this aggregated or deidentified information is treated as Personal Information.
(A) Cookies and Web Beacons
To help us serve you better, we may collect Device Identifiable Information from you through technologies such as “cookies” and “web beacons” (which are also called clear GIFs, pixel tags, or pixels) or by tracking internet protocol (“IP”) addresses.
- “Cookies” are small data files that are stored by your web browser when you interact with a website. When you visit a webpage, the cookie sends back Device Identifiable Information.
- “Web beacons” are small graphic images (usually invisible) that can be embedded in content and ads on a webpage that track usage of the Sites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.
For more information on your choices regarding cookies, you can review the FTC’s guide to opting out of online tracking for computers and mobile devices. You can also see the “All Users: Your Choices and Controls” section below for ways to opt-out.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Sites and Services do not currently support Do Not Track requests at this time.
(B) Other Direct Interactions with You
You give us your information in your direct interactions with us. We collect information you provide to us when you register accounts on our Sites and other Services; request newsletters, and other products, services, or information from us; respond to surveys; participate in sweepstakes or contests; or otherwise interact with us. This information includes Personal Identifiers, Contact Information, Biographical Information, Financial Information, and Device Identifiable Information, which you give us from time to time.
Except for IP addresses, we may match Device Identifiable Information with Personal Information that we may have from or about you, which would allow us to identify you. We may use this information to provide you with offers that are available where you are physically located.
(C) Social Media
When using the Services or when using certain third party social networking services (e.g., Facebook, Twitter) (each, a “Social Network”), you may have the option to connect your Service information and activity with your Social Network information and activity. If you authorize such a connection, you permit us to share or publish information about your Service activity with that Social Network and its users, and to access certain of your Social Network information, as disclosed to you at the time you consent to the connection. Information we may share with a Social Network may include technical information about your Service activity, your Service comments, or the videos you watch on the Service. Information we may access about you, with your consent, from a Social Network may include, but is not limited to, your basic Social Network information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Network. If you permit a connection between a Social Network and a Service, we (and that Social Network) may be able to identify you and to associate information received pursuant to the connection with information we already have about you. For more information, please review the privacy disclosures and terms of your Social Network account, which govern how that account information is collected and shared with us.
(D) Other Third Party Sources
NWSL may also receive other information from Service Providers (as defined below) in connection with the operation of our Services, including when you take our surveys through a third-party vendor. We may also receive information from Service Providers through marketing and demographic studies that we use to supplement Personal Information and deidentified information provided directly by you.
3. How We Use Your Information
(A) For the Purpose Collected: If you provide Personal Information for a certain reason, we will use the Personal Information in connection with the reason for which it was provided. For example, we may use this information to:
- Create accounts and process your registration with our Services;
- Process transactions, including purchases and donations;
- Provide technical support and respond to user inquiries; and
- Notify you about updates to our Services or send other communications that are relevant to your use of our Services.
(B) Support from Service Providers: In addition, Personal Information and Device Identifiable Information we collect may be used by us and by third-party service providers, such as hosting providers, data management companies, address list hosting companies, e-mail service providers, analytics companies (e.g., Google Analytics), distribution companies, fulfillment companies, and payment processors (collectively, “Service Providers”) for a variety of purposes, including to:
- contact you about the Sites and/or Services you have requested;
- provide you with Services or information you have requested, or products or services you have ordered or signed up for, such as newsletters;
- confirm or fulfill an order you have made;
- administer your participation in a contest, sweepstakes, promotion, survey, or voting poll; and
- facilitate the operation, maintenance and improvement of the Services, our business operations, and internal record keeping.
Our Service Providers are given the information they need to perform their designated functions in connection with the Services, and we do not authorize them to use or disclose your Personal Information for their own marketing or other purposes.
(C) To provide effective advertising and marketing: We also use the information we collect and receive to provide ads for our Services and certain third-party services, and to send you promotional communications. For example, we may use this information:
- To send you electronic and other marketing messages about the NWSL, the NWSL’s Member Clubs, or third-party business partners of the NWSL that may be tailored to your preferences and interests – for example, content related to your favorite Member Club. (Please see below the “All Users: Your Choices and Controls” section.);
- To measure and evaluate the effectiveness of online advertising campaigns;
- For performing internal analysis and building models to better understand NWSL fans and fan engagement across the NWSL so that we can customize and improve our Services, advertising and communications; and
- To administer your participation in our contests, sweepstakes, fantasy or interactive games, or other promotions.
(D) Identity Verification and Security: We also may obtain information about you from other businesses to verify your identity so we can properly process your requests and prevent fraud. By accessing and using our Services, you agree that we may use your submitted and obtained Personal Information and Device Identifiable Information for such purposes and to maintain the security of the Services.
(E) Product Improvement and Marketing: NWSL may also use your Personal Information, Device Identifiable Information, and other personally non-identifiable information collected through the Sites and Services to help us improve the content and functionality of the Sites and Services, to better understand our users and to provide customer support, to personalize control and experiences on our Sites and applications, and to improve the Services. NWSL may use this information to communicate with you regarding the Sites and Services and, to the extent permitted by law, to tell you about services we believe will be of interest to you.
We also may use the information we collect and receive for other purposes that may be described to you at the point of collection or for which you provide your consent.
(A) Business Transfers
As we develop our business, we might sell or buy businesses or assets, such as the sale of all or most of NWSL’s or a Member Club’s assets or equity to another company. In the event of a corporate sale, merger, reorganization, dissolution, or similar event in which a third party assumes control of all or part of our business, Personal Information may be part of the transferred assets or business.
(B) Service Providers and Third Parties
We share Personal Information and Device Identifiable Information with Service Providers, as described above in “How We Use Your Information”. We do not sell your Personal Information to third parties, whether for monetary or other valuable consideration.
We may share with third parties aggregated demographic information collected on or through the Services for various purposes such as fan research and audience analysis. Aggregated demographic information does not include and is not linked to any Personal Information that can identify you or another individual person, but we may use your IP Addresses to verify users’ locations for various purposes, including blackout restrictions.
(C) User Referrals
Users may send information about our Member Clubs, our products, or the Services, to their friends and family members by using an “E-mail to Friend” or similar feature in the Services or in an e-mail that we have sent them. We do not further contact those individuals without their consent to do so.
(D) Business Partners and Third-Party Marketers
When you consent to receive news and offers from them, we share information about you with select business partners and other third parties that are not service providers, such as our sponsors, retailers, and broadcast partners, so that they can provide you with special offers, promotional materials, and other materials and information that may be of interest to you. These other business partners and third-party marketers are expected to protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners and other third-party marketers, which may use your information for their own purposes. If you have consented to share your Personal Information with third parties for such third parties’ marketing purposes, you can change your mind at any time. To opt out of receiving communications directly from these third parties, please contact the third party, and you may let us know by following the instructions in the “All Users: Your Choices and Controls” section below.
- if required by law, such as by a court order, statute, regulation or rule, through legal process, or for law enforcement purposes;
- in the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of our creditors;
- if we determine it necessary in connection with an investigation or in order to protect our legal rights; or
- in response to requests from federal, state, local or foreign law and civil enforcement agencies, such as a search warrant, subpoena or court order.
(A) Chat Rooms, Forums, and Message Boards
The Services may make chat rooms, forums, blogs, message boards, and other community features and activities available to you and other users. If you post Personal Information online, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose Personal Information in these areas. We reserve the right (but assume no obligation) to review and/or monitor any such community areas on the Services.
(B) Short Message Service
We may make available a service through which you can receive messages on your wireless device via short message service (“SMS Service”). You understand that your wireless carrier’s standard rates apply to these messages.
If you subscribe to one of our SMS Services, you may be required to register and provide Personal Information. We may also collect the date, time, and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service for the purpose of sending the SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information to facilitate the transaction in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We may also contact your carrier, which may access the content of your wireless account, for the purpose of identifying and resolving technical problems and/or Service-related complaints. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. You may change your mind and unsubscribe to SMS Services at any time by following the instructions in the “All Users: Your Choices and Controls” section below.
6. Third-Party Advertising
7. All Users: Your Choices and Controls
(A) Accessing, Reviewing, Updating, Correcting or Deleting Your Personal Information
If you want to access, review, update, or correct inaccuracies in your Personal Information, or delete your Personal Information, you can:
- email us at: firstname.lastname@example.org;
- write to us at 1556 S. Michigan Avenue, Floor 2, Chicago, IL 60605, Attn: Privacy Administrator – Legal; or
- if a newsletter subscriber, revise your newsletter preferences and profile information through the “Manage Subscriptions” or “Update Profile” links within the newsletter.
Upon receiving your communication, we will take appropriate steps to update or correct such information in our possession, or to remove you from our catalog and mailing list. Your preferences may include, for example, your profile information, as well as any shipping, payment, and account information (if applicable), as well as whether you want to receive communications from us. If you want us to delete the Personal Information we have (except for information that we keep for record-keeping purposes), you should contact us via email at: email@example.com. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records.
(B) Opting Out of Direct Marketing and Other Advertising
If you have agreed to receive communications or solicitations from us, and you later change your mind, you can revise your preferences by contacting us at the address listed above, or via email at firstname.lastname@example.org. You also may opt out of receiving all future promotional e-mails from us by clicking on an opt-out or “unsubscribe” link within the promotional e-mail you receive. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your other relationship, activities, transactions and communications with us.
You may also opt out of our SMS messages by texting “STOP” or another applicable keyword to the short code applicable to the particular SMS Service (as further described below).
If you have agreed to have us share your Personal Information with third parties so that they may contact you about promotions, offers and other information, you can revise your preferences by contacting us at the address listed above, or email us at email@example.com. If you do request to have us stop sharing your Personal Information with other entities for their direct marketing purposes, such request will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly or click on the opt-out or “unsubscribe” link that should be included within the promotional e-mail you receive from such third party.
You may opt-out of receiving ads from network advertisers by clicking the AdChoices icon on advertisements that are sent to you, visiting the opt-out pages on the NAI website and the DAA website. Opting out does not prevent you from seeing ads; it simply means that network advertisers will no longer collect data for the purpose of providing you targeted ads. The DAA and NAI opt-out tools are cookie-based. They signal network advertisers so that they do not collect data online or deliver specific ads targeting you, and only affect the Internet/web browser on the computer where the cookies are installed. These opt-out tools will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie or all your cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is again reset on that browser. Opting out using one browser on one computer will not opt you out using any other browser on the same or another computer.
8. California Residents: California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please contact us at 1556 S. Michigan Avenue, Floor 2, Chicago, IL 60605 Attn: Privacy Administrator – Legal. Not all information sharing is covered by the “Shine The Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.
If you are a California resident, then you also have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information:
(A) Right to Know
You have the right to know and see what data we have collected about you over the past 12 months, including:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting your Personal Information;
- The categories of third parties with whom we have shared your Personal Information; and
- The specific pieces of Personal Information we have collected about you.
(B) Right to Delete
You have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
(C) Exercising Your Rights
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your CCPA rights described above. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
9. Security Practices
We use reasonable security efforts to protect the Personal Information in our possession. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data, the unauthorized access to or use of information, the theft, destruction, or inadvertent disclosure of your information, whether Personal Information or Device Identifiable Information, or any other disclosures out of our control. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information. Your online access to some of your information may be protected with a password that you select. We strongly recommend that you select a unique password that is difficult to guess and that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages).
10. Links to Other Services
11. Additional Information
If you wish to object to or raise a complaint on how we have handled your Personal Information, you may contact us at 1556 S. Michigan Avenue, Floor 2, Chicago, IL 60605 Attn: Privacy Administrator – Legal, or email us at firstname.lastname@example.org.
If you are not satisfied with our response or believe our processing of your Personal Information is not in accordance with law, you may register a complaint with the appropriate governmental authority. NWSL Media, LLC controls the Personal Information collected via the Sites and Services.
13. Children’s Data
Our Sites and Services do not knowingly collect, use, or disclose personal information from children under the age of 13 or as otherwise defined by local law without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”) or other applicable local law. If we learn we have collected or received Personal Information from a child under the age of 13 without verification of parental consent, we will endeavor to delete that information.
15. Contact Us
NWSL Media, LLC
1556 S. Michigan Avenue, Floor 2
Chicago, IL 60605
Attention: Privacy Administrator – Legal