Effective Date: January 1, 2020
Not Covered by this Policy. This Policy does not apply to our job applicants who apply for employment with us, or to employees and other non-employee workers, such as our contractors.
Overview of Our Collection and Use of personal information
Name, contact information, and other identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
Customer records: other paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number.
Characteristics of protected classifications under New Jersey or federal law: characteristics of protected classifications under New Jersey or federal law such as race, color, sex, age, religion, national origin, and disability.
Commercial information: including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data: such as internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding an interaction with an internet website, application, or advertisement.
Biometric information: physiological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including facial recognition (subject to applicable laws and where relevant to the Services we provide to you).
Geolocation data: precise geographic location information about a particular individual or device.
Audio, video, and other electronic data: audio, electronic, visual, or similar information such as, CCTV footage, photographs, and call recordings.
Profiles and Inferences: inferences drawn from personal information to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Uses of Personal Information
New Jersey residents. If you are a New Jersey resident, please be sure to review the section Additional Information for New Jersey Residents below for important information about the categories of personal information we collect and disclose and your rights under New Jersey privacy laws.
Information We Collect
Sources of Personal Information. The information we collect varies depending upon the circumstances and the Services you use. We may collect personal information directly from individuals, for example if you register for a TEAM FREEDOM account or communicate with us. We also may collect personal information from external third parties, such as platform providers, ticket sellers, social media sources, and others with whom we work with to make available our Services to you. We also collect personal information automatically about how individuals access and use our Services or otherwise interact with our Services.
Information We Collect Directly from You. We collect your personal information when you voluntary provide it to us. However, if you decline to provide us with certain personal information, you may not be able to access certain Services or we may be unable to fully respond to your inquiry. We generally collect the following personal information from you:
Information We Collect from Third Parties.
We also may collect personal information about you from third parties, such as partners or ticket sellers we work with. We may combine such information with information we already have collected about you. For example, we may enhance or update the personal information we have about you with information obtained from third party sources. We also may collect device identifier information from mobile applications you use or e-mail or similar lists from third parties for advertising and marketing purposes. We also collect information about how individuals interact with us or comment about TEAM FREEDOM and our products and services available through social media. Additionally, if you take advantage of a third party or affiliate offer through the Services, we may collect certain information from that third party about your interaction with them.
Third-Party Sign-On. We may allow you to login through certain third-party accounts (e.g., Google, Apple, or Facebook) (each a “Third Party Account”) to your account with us or connect such accounts. Third Party Accounts are operated and managed by third parties (each a “Third Party Platform”), and subject to the respective privacy policies of each Third Party Platform. When you link a Third Party Account to use our Services, you may be able to connect and interact with and share certain information and content with your friends and network from that Third Party Account, and, in some cases, you may be able to make purchases through or earn rewards (subject to applicable program terms) from that Third Party Account. If you choose to login this way, you are asked to share certain information with us (which may include name, email, friends, and public profile information); the specific information and whether it is required or optional is stated on the permissions page when you log in with the Third Party Account.
Information We Collect Automatically. We collect personal information about how you use the Services and interact with us and others, such as information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. We may link this personal information with the other information we have collected about you.
How We Use Personal Information
We may use the personal information we collect for the following purposes:
Aggregate and De-identified Information. We also may use and disclose de-identified information and create anonymous and aggregated data sets and reports in order to assess, improve, and develop our business, products, and services, prepare benchmarking reports, and for other research and analytics purposes.
How We Disclose Personal Information
We disclose personal information to our vendors and others who we work with to make certain services available and in order to provide and improve our products and services, reach users with more relevant information and offers, to make available third party offers you may be interested in, and as otherwise set out below.
Aggregate and De-Identified Information. We may use and disclose aggregate, anonymous, or de-identified information about individuals for marketing, advertising, research, compliance, or other purposes. For example, we use for such purposes the number of users who visited the website during a specific time period or redeemed a prize through the Services.
Cookies and Other Tracking Information
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 Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. 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. Some of the Services may not work properly if you disable cookies.
Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs, or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do Not Track (DNT). Our Sites currently do not respond to “do not track” signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking mechanisms in the cookie preference settings of your web browser and opt out of certain third-party ad cookies on our websites.
Online and Interest Based Advertising
Advertising TEAM FREEDOM Products & Services: After you use the Services, our advertising partners may deliver TEAM FREEDOM ads to your web browser when you are visiting other sites on the Internet. These ads are delivered based on cookies that are set by us or by our Third Party Ad Partners when you visit or use the Services, and that are recognized by these companies when you visit other sites. Please see the section above on cookies and the section below on ad choices to learn more about setting your web browser to block cookies.
Ad Choices. Certain Third Party Ad Companies participate in the Digital Advertising Alliance self-regulatory principles for online behavioral advertising. As part of this program, consumers have an ability to opt out of behavioral (targeted) advertising. Pursuant to these principles, you may control how participating Third Party Ad Companies use the information that they collect about your visits to our websites, applications, and Services, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out please email us at firstname.lastname@example.org
You may also click on the AdChoices icon for more information and to opt out. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You also may continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
Custom Audiences and Matching. We may share certain hashed customer list information (such as your email address) with third parties—such as Facebook and Google—so that we can better target ads and content to you, and others with similar interests, within their services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers. You may opt out of this as set forth in our Your Rights and Choices section below.
TEAM FREEDOM’s Services are not directed or targeted at children under 10 years of age. If you are a parent or guardian who has discovered that your child has submitted his or her personal information to TEAM FREEDOM, we will make commercially reasonable efforts to delete the information from its database, at your request. To request the deletion of your child’s information, please email us at email@example.com and be sure to include in your message the same member name and password that your child submitted.
We have implemented a variety of safeguards designed to protect personal information from unauthorized access, use, or disclosure. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee its absolute security. You should take steps to protect against unauthorized access to your password, phone, computer, and other devices 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.
Third Party Links
The Services are operated in the United States. By using our Services or providing any personal information to the Services, you acknowledge and understand and unambiguously consent to the collection, transfer, storage and processing of your personal information to and in the United States and this Policy in general.
Your Rights and Choices
You may access and update certain of your personal information by accessing and adjusting your account settings. Please note that we may maintain copies of information that you have updated, modified, or deleted in our business records and in the normal course of our business operations, as permitted or required by applicable law.
Marketing Communications. You may opt-out of receiving marketing communications from us by emailing us at firstname.lastname@example.org, or by contacting us via our telephone number as set out in the Contact Us section below. You also may opt out of email marketing by using the unsubscribe link in any such email we send to you. Further, if you have opted into and no longer wish to receive text messages from us you may opt out by texting STOP to cancel future text message (reply HELP for more information or help).
Please note that marketing opt-out requests will only remove you from our direct marketing list and the list of any Service Provider performing services on our behalf. We are not responsible for the use any other party may makes of your personal information transferred prior to your opt-out and in accordance with this Policy. In such case, you will need to contact the relevant entity to have your personal information removed from such entity’s database.
New Jersey Residents. New Jersey residents have certain rights, under New Jersey privacy laws, regarding their personal information, which are set forth in the Additional Information for New Jersey Residents section below.
Changes to this Policy
We encourage you to periodically review this Policy, as we may change our Policy from time to time, in which case we will post the updated Policy on our Services. 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, such as by changing the effective date of the Policy or notifying you at your email address of record. Your continued use of the Services following a change in this Policy represents consent to the updated Policy to the fullest extent permitted by law.
If you have any questions about this Policy or our privacy practices, please contact us via email at email@example.com, our phone number (833) 298-5588, or by mail to: TEAM FREEDOM, 26 Law Drive, Fairfield, NJ 07004.
Additional Information for New Jersey Residents
In this section, we provide information, as required under New Jersey privacy laws, including the New Jersey Consumer Privacy Act (“CCPA”), which requires that we provide New Jersey residents certain specific information about how handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
Categories of personal information that we collect and disclose. Our collection, use, and disclosure of personal information about a New Jersey resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about New Jersey residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Information We Collect section above, and for the purposes described in the How We Use Personal Information section above.
|Categories Of Personal Information Collected||Do we collect?||Do we disclose for business purposes?|
|Name, contact information, and other identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||Yes||Yes|
|Customer records such as other paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number.||Yes||Yes|
|Characteristics of protected classifications under New Jersey or federal law such as characteristics of protected classifications under New Jersey or federal law such as race, color, sex, age, religion, national origin, and disability.||Yes||Yes|
|Commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||Yes||Yes|
|Usage data such as internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.||Yes||Yes|
|Biometric Information such as physiological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including facial recognition (subject to applicable laws and where relevant to the Services we provide to you).||Yes||Yes|
|Geolocation data such as precise geographic location information about a particular individual or device.||Yes||Yes|
|Audio, video and other electronic data: audio, electronic, visual, or similar information such as, CCTV footage, photographs, and call recordings.||Yes||Yes|
|Profiles and Inferences such as inferences drawn from personal information to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.||Yes||Yes|
New Jersey Residents’ Rights. New Jersey law grants New Jersey resident’s certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell. New Jersey residents have the right to opt-out of our sale of their personal information. We do not sell or otherwise share personal information about you except as described in this Policy.
Initial Notice: We are required to notify New Jersey residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. You can find our Initial Notice at the top of this Policy.
Verifiable Requests to Delete and Requests to Know. Subject to certain exceptions, New Jersey residents have the right to make the following requests, at no charge:
Request to Delete: New Jersey residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.
Request to Know: New Jersey residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. New Jersey residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
New Jersey residents may make a Request to Know up to twice every twelve (12) months.
Submitting Requests. To submit a Request to Know or Request to Delete, please submit a request by call us at (833) 298-5588, or by mail to: TEAM FREEDOM, 26 Law Drive, Fairfield, NJ 07004.
We will respond to verifiable requests received from New Jersey residents as required by law.
Right to Non-Discrimination. The CCPA prohibits discrimination against New Jersey residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
Financial Incentives. A business may offer financial incentives for the collection, sale, or deletion of New Jersey residents’ personal information, provided it is not unjust, unreasonable, coercive, or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. New Jersey residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent.
You Rights Under New Jersey’s Shine-the-Light Law. Under New Jersey’s “Shine the Light” law, New Jersey residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (so, requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a New Jersey resident and would like to make such a request, please submit your request in writing by emailing us at firstname.lastname@example.org or mailing us at TEAM FREEDOM, 26 Law Drive, Fairfield, NJ 07004, using the subject line “Request for New Jersey Privacy Information.” In your request, please attest to the fact that you are a New Jersey resident and provide a current New Jersey address. We will reply to valid requests by sending a response to the email address or physical address from which you submitted your request. Please note that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.
For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.