Privacy Policy

Last revised: February 28, 2024

Purpose

This Privacy Policy describes how we process, collect, use, and disclose your personal data when you use our Websites. By continuing to use the Websites, you promise us that you have read, understand, and agree to be bound by this Privacy Policy, as amended from time to time by the Company at its sole and absolute discretion.

We encourage you to review this Privacy Policy regularly. If we make material changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy on our Websites and updating the "Last revised" date.

Types of personal data collected

A. Personal data provided by you through the Websites

We collect personal data that you provide to us when you contact us, such as your name and email address.

B. Usage Data

Usage Data is collected automatically when using the Websites. Usage Data may include information such as your device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Websites that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

C. Cookies

We use cookies and similar tracking technologies to track activity on our Websites and store certain information.

How do we use your personal data

A. When you request us to contact you

We may use your personal data for our legitimate business interests when you request us to contact you.

B. Data we collect automatically when you use these Websites

We may use Usage Data and cookies to improve and administer our Websites, analyze how you use our Websites, and troubleshoot technical problems. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

With whom we may share your personal data

A. With Service providers

We may share your personal data with service providers to monitor and analyze the use of our Websites, to contact you, to store your data, to show advertisements to you, to support and maintain our Websites, or to perform other services for us.

B. For business transfers

We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

C. With business partners

We may share your personal data with our business partners to offer you certain products, services, or promotions.

D. With Google

Google may use your personal data as an independent data controller. For more information on how Google manages personal data in its ads products, please visit this page.

E. Law enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities.

F. Other legal requirements

We may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Websites
  • Protect the personal safety of users of the Websites or the public
  • Protect against legal liability

Cookies and similar tracking technologies

We use cookies and similar tracking technologies to track activity on our Websites and store certain information. The technologies we use may include:

Essential, Functionality, Operation & Security cookies.

These cookies are essential for the Websites to function properly and securely.

Analytic, Measurement & Performance cookies.

These cookies help us understand how visitors interact with our Websites by collecting and reporting information anonymously.

Preference, Targeting & Advertising cookies.

These cookies are used to deliver advertisements and track their effectiveness, or to remember your preferences.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Websites.

Children's privacy

Our Websites do not address anyone under the age of 18. We do not knowingly collect personally identifiable data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, we take steps to remove that data from our servers.

If you have reason to believe that a child under the age of 18 has provided us with personal data, please contact us with sufficient detail to enable us to delete that data.

How long do we keep your personal data

We will only retain your personal data for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Transfer of personal data

We may store or process your personal data in the EEA or in other countries. If you visit our Websites from locations outside of the EEA, please note that any data you provide to us through your use of our Websites may be transferred to and processed in countries other than the country from which you accessed our Websites. If you are a resident of the EEA, we will take appropriate measures to ensure that your personal data receives adequate data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transfer of your personal data requires consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

Security of the personal data

We take great care in implementing and maintaining the security measures of the Websites and your personal data. We employ industry standard procedures and policies and implement technical and administrative security measures to ensure the safety of our user's personal data and prevent unauthorized access or use of any such personal data. However, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure, and we can not be responsible for the acts of those who gain unauthorized access or abuse our Websites, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We may adopt what we believe are appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access to such data and according to applicable law requirements. If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted to abuse our Websites or acted in an appropriate manner, please contact us directly at contact@Pinseekerleague.com.

Changes to Privacy Policy

We reserve the right to amend this Privacy Policy at our sole discretion and at any time. If we make changes to this Privacy Policy, we will immediately post the updated Privacy Policy on our Websites and update the relevant, effective date. Any such changes will be effective immediately upon being posted unless otherwise stated in the change. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

Terms related to EU/EEA users

Legal basis for processing personal data (for EU/EEA users)

If you are an individual in the European Union or European Economic Area (EEA), we collect and process data about you only where we have a legal basis for doing so under applicable EU laws, including the General Data Protection Regulation (GDPR). The legal basis depends on the way in which you use Websites. This means we collect and use your data only where:

  • A. It is necessary for the performance of a contract, such as to provide you with the services you requested, including operating the services, providing customer support and personalized features, and protecting the safety and security of the services, including all processing necessary for the performance of our contract(s) with you;
  • B. It satisfies a legitimate interest that is not outweighed by your data protection rights and interests, such as for research and development, to market and promote our services, and protect our legal rights and interests;
  • C. You give us consent to do so for a specific purpose; or
  • D. We need to process your data to comply with a legal obligation.

In any case, we will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Your rights as a data subject

We respect the confidentiality of your personal data and guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law, if you are within the EU/EEA, to:

  • Request access to your personal data. The right to access, update, or delete the data we have on you. Whenever made possible, you can access, update, or request the deletion of your personal data directly by contacting us at contact@Pinseekerleague.com. This also enables you to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. You have the right to have incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your personal data. This right exists where we rely on legitimate interest as the legal basis for our processing, and there is something about your particular situation that makes you want to object to our processing of your personal data on this ground. You also have the right to object to where we are processing your personal data for direct marketing purposes.
  • Request the erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
  • Request the transfer of your personal data. We will provide your personal data to you, or to a third party you have chosen, in a structured, commonly used, machine-readable format. Please note that this right only applies to automated data, which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent to use your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Websites.

If you wish to exercise any of the rights set out above, please contact us at contact@Pinseekerleague.com.

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Timeframe for responding to a request

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Disclosure of your personal data

We may disclose aggregated data about our users and information that does not identify any individual without restriction. We may disclose personal data that we collect or you provide as described in this Privacy Policy:

  • A. To our subsidiaries and affiliates;
  • B. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them;
  • C. 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 Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Company about our Websites users is among the assets transferred;
  • D. To fulfill the purpose for which you provide it;
  • E. With your consent.

We may also disclose your personal data:

  • A. To comply with any court order, law, or legal process, including responding to any government or regulatory request;
  • B. To enforce or apply our Terms of use or Privacy Policy and other agreements; and
  • C. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third-party links

The Websites contain links to websites operated and maintained by third parties over which the Company has no control. Any data you provide to third-party websites will be governed under the terms of use or privacy policy of those respective third parties. Accordingly, we strongly encourage you to investigate and ask questions before disclosing any data to the operators of third-party websites and to familiarise yourself with their privacy practices by reviewing their privacy notices and privacy policies.

The inclusion of third-party websites on or through our Websites in no way constitutes an express or implied endorsement of such websites' policies or notices.

Privacy Policy for California and Virginia residents

Types of personal data collected

We collect data that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal data that we may have collected from California residents within the last twelve (12) months.

Please be aware that the categories and examples provided in the list below are those defined in the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"). This does not mean that all examples of that category of personal data were, in fact, collected by us but reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal data would only be collected if you provided such personal data directly to us.

  • Category A. Identifiers

    Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

    Collected: Yes.

  • Category B. Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

    Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

    Collected: Yes.

  • Category C. Protected classification characteristics under California or federal law

    Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

    Collected: Yes.

  • Category D. Commercial information

    Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    Collected: Yes.

  • Category E. Biometric information

    Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    Collected: No.

  • Category F. Internet or other similar network activity

    Examples: Browsing history, search history, information regarding a consumer's interaction with an internet website, application, or advertisement.

    Collected: Yes.

  • Category G. Geolocation data

    Examples: Physical location or movements.

    Collected: Yes.

  • Category H. Sensory data

    Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

    Collected: Yes.

  • Category I. Professional or employment-related information

    Examples: Current or past job history or performance evaluations.

    Collected: Yes.

  • Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

    Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    Collected: No.

  • Category K. Inferences drawn from other personal information

    Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    Collected: Yes.

  • Category L. Sensitive Personal Information

    Personal information that reveals: A consumer's Social Security, driver's license, state identification card, or passport number. A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. A consumer's precise geolocation. A consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication. A consumer's genetic data. The processing of biometric information for the purpose of uniquely identifying a consumer. Personal information collected and analyzed concerning a consumer's health. Personal information collected and analyzed concerning a consumer's sex life or sexual orientation.

    Collected: Yes (for some categories, e.g., financial info, precise geolocation, racial/ethnic origin, religious beliefs, health info, sex life/sexual orientation, if provided by user for services).

Sale of personal data

As defined in the CCPA and CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal data by the business to a third party for monetary or other valuable consideration. This means that we may have received some kind of benefit in return for sharing personal data, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA and CPRA. This does not mean that all examples of that category of personal data were, in fact, sold, but it reflects our good faith belief, to the best of our knowledge, that some of that data from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal data:

  • Category A. Identifiers.
  • Category B. Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(o)).
  • Category D. Commercial data.
  • Category F. Internet or other similar network activity.

Sale of personal data of minors under 16 years of age

We do not knowingly collect personal data from minors under the age of 16 through our Websites, although certain third-party Websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children never to provide data on other websites without their permission.

We do not sell the personal data of consumers we actually know less than 16 years of age unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal data may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to us at contact@Pinseekerleague.com.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal data, please contact us with sufficient detail to enable us to delete that data.

Your rights under the CPPA, CPRA, and VCDPA

The CCPA and CPRA provide California residents, and VCDPA provides Virginia residents with specific rights regarding their personal data. If you are a resident of California and/or Virginia, you have the following rights:

  • The right to notice. You have the right to be notified of which categories of personal data are being collected and the purposes for which the personal data is being used.
  • The right to request. Under CCPA, CPRA, and VCDPA, you have the right to request that we disclose to you about our collection, use, sale, disclosure for business purposes, and sharing of personal data. Once we receive and confirm your request, we will disclose to you:
    • The categories of personal data we collected about you.
    • The categories of sources for the personal data we collected about you.
    • Our business or commercial purpose for collecting or selling that personal data.
    • The categories of third parties with whom we share that personal data.
    • The specific pieces of personal data we collected about you.
    • If we sold your personal data or disclose your personal data for a business purpose, we will disclose to you:
      • a) The categories of personal data sold;
      • b) The categories of personal data disclosed.
  • The right to say no to the sale or sharing of personal data (opt out) for California residents. You have the right to direct us not to sell or share your personal data. To submit an opt out request, please contact us at contact@Pinseekerleague.com.
  • The right to opt out of the processing of the personal data for Virginia residents for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. To submit an opt out request, please contact us at contact@Pinseekerleague.com.
  • The right to correct inaccuracies. Under CCPA, CPRA, and VCDPA, you have the right to request us to correct the inaccurate personal data that we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • The right to limit the use and disclosure of sensitive personal data. Under CPRA, you have the right to direct us to limit our use of your sensitive personal data to that use which is necessary to perform the services. To submit such a request, please contact us at contact@Pinseekerleague.com.
  • The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete your personal data from our records unless an exception applies. We may deny your deletion request if retaining the data is necessary for our service providers or us:
    • To complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • To debug products to identify and repair errors that impair existing intended functionality.
    • To exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • To comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the data's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
    • To enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • To comply with a legal obligation.
    • To make other internal and lawful uses of that data that are compatible with the context in which you provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer rights, including by:
    • Denying goods or services to you.
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
    • Providing a different level or quality of goods or services to you.
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

The right to opt out

For California residents

If you are 16 years of age or older, you have the right to direct us not to sell or share your personal data at any time (the "right to opt out"). We do not sell or share the personal data of consumers we actually know less than 16 years of age unless we receive affirmative authorization (the "right to opt in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal data sales or sharing may opt out of future sales at any time.

To exercise the right to opt out, you (or your authorized representative) may submit a request to us at contact@Pinseekerleague.com.

For Virginia residents

Virginia residents have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise the right to opt out, you may submit a request to us at contact@Pinseekerleague.com.

"Do not track" policy is required by California Online Privacy Protection Act (CalOPPA)

Our Websites do not respond to do not track ("DNT") signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Other California privacy rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at contact@Pinseekerleague.com.

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