COLLECTION OF INFORMATION
We collect the following categories of information when you use our Services:
Information you provide to us directly or indirectly through using or otherwise accessing our Services.
Sign-in information, including username, email address, telephone or mobile phone number, and any password you create.
Profile information, including your interests, preferences, feedback, photograph, and avatar.
Identification and other verification information, if you seek to register for our paid entry contests of skill. This information may include copies and information from identification documents, such as your passport or driver’s license, tax-related information, and any other information we would need to verify your identify or comply with applicable laws and regulations.
Services engagement, including discussion topics you create or comment on in our Services, league information, information we collect from you when you connect our Services to third-party platforms, websites, or social network services or use other social or player-to-player functionality, and information collected when you invite your friends to use our Services.
Photos, chat, and messages, including photos, animated images, and direct or private messages sent to other users, as well as group messages sent to members of a particular group or League using our League-specific chat feature.
Commercial information, including records of products or services purchased or obtained, as well as other purchasing or consuming histories. For example, if you use our paid entry contests of skill, we collect information about the contest entry fees you have paid, prize history, and withdrawal information. As another example, where applicable, we collect information about your purchase of virtual currencies and virtual items within relevant portions of the Services. Address book or contact information, in accordance with your device permissions.
Correspondence you send to us or through the Services and other information you provide, including information that you provide us with when you fill in forms or answer questions or surveys when using any of our Services, contact us through our Sleeper customer service channels, respond to messages and communications that we send you, or interact with us on our social media channels.
Payment information, from you or on behalf of our payment service providers, including billing or PayPal information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful. When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play), we do not receive any payment information from you.
Information we collect automatically. We may collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers; default device language; app usage information; browser type and version; operating system and platform; Internet service provider; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use and interact with the Services (for example, details about how and when you play our games or visit our website); the technology on the devices you use to access these Services; standard server log information; probabilistic identifiers, other unique personal or online identifiers; time zone setting and location; browser plug in types and versions; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; and inferences used to create a profile about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of information identified above for the following business purposes:
to administer and provide the products and services that you request, including to allow you to participate in games and other features of our Services, to engage with other users through our social features, to manage your account and to process your payments, deposits, withdrawals, and other account activity;
to verify your identity and information, such as when you register to play paid entry contests of skill or whether otherwise appropriate;
to improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device, including troubleshooting, data analytics, testing, research, and statistical and survey purposes. We also may use personal information to create aggregate or de-identified information that is no longer subject to this policy;
to provide you relevant advertising, including advertising that you see off the Services;
to keep our Services, businesses and users safe and secure, to comply with applicable laws and regulations, and to protect or exercise our legal rights or defend against legal claims. For example, this includes use of your information to detect, prevent, and investigate fraud and other illegal activity and violations of our terms. We may monitor chat, direct messaging, and other messages sent through the Services for these purposes; and
for any other purpose that we may notify you of from time to time.
DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as identify verification, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, and processing or fulfilling orders and transactions. These third parties collect, use, and access your data to perform their functions, and we may allow them to use information about you for their own purposes in accordance with applicable law.
Chat, testimonial, and other social features. Your information may be shared with other players and made public if you use certain functionalities. For example, the Services may include social features that enable you to interact with other players. These features will enable other players to see your username, avatar, scoring and other gameplay-related information. Depending on your settings in your social network or Sleeper account, other information in your profile may be shared with other players. Also, other players will be able to see anything that you post to any public discussion topic, channel, chat or other similarly open areas in our Services. We may publish the information you submitted alongside your name and home country on our website(s), scores, social media channels, or other information related to our Services for promotional purposes. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.
Corporate affiliates. We may share your information with our corporate affiliates.
Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries (including those by the Internal Revenue Service and other appropriate taxing authorities), and to protect and defend the rights, interests, safety, and security of Sleeper, our affiliates, users, or the public.
With your consent or direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction. For example, to process a payment instruction we must provide your personal information to our payment processors.
ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
The following types of cookies are used on our Services:
Essential Cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these Cookies, certain services cannot be provided. These Cookies also help keep our Services safe and secure.
Preference Cookies – These Cookies store information such as your preferred country and language selection, login data and website preferences. Without these Cookies, our Services may not be able to remember certain choices you have previously made (such as a saved country or language preference) or personalize your browsing experience by providing you with relevant information. These Cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
Performance Cookies – These Cookies collect information about how you use our Services such as which pages or parts of the app you visit regularly. These Cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
YOUR RIGHTS AND CHOICES
Access, Erasure, and Similar Rights. You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. We may verify your request, such as by requesting additional information from you. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent.
E-mail Marketing Communications. We may use your information to send you direct marketing and promotional materials relating to our Services or related products (including by email) on our or a third party's behalf. For example, we might send you information about new product tools and features relating to our Services. If you do not want us to use your information in this way, please let us know using the contact information below.
Choices Related to Tracking Technologies, Including for Online Advertising. You have choices about collection of information about your use of our Services through cookies and other tracking technologies, including by third parties whose privacy practices we cannot control. For example, you may also be able to limit certain interest-based mobile advertising or reset your mobile advertising ID through the settings on your mobile device.
Opting out of Personalized Advertising. Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.
You also may be able to control our collection and use of your location information through your mobile device or app settings.
By using the Services and providing us with information, you understand that your information is being collected and stored on, and may be transferred to, servers located outside your resident jurisdiction. We and many of our third-party vendors are based in the United States, and your information is being processed by us in the United States and other jurisdictions where laws may not be equivalent to those where you reside. To the extent we disclose your information to third-party vendors, we use contractual safeguards to help ensure that such third-party vendors are bound to duties of confidentiality. Where local law permits, you are deemed to have consented to these data transfer practices through your use of the Services. If you do not consent to these data transfer practices, please do not use the Services.
DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
We maintain security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. However, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
VIII.CHANGES TO THE PRIVACY
JURISDICTION SPECIFIC DISCLOSURES
Please see “Your Rights and Choices” for information about how to exercise rights to access your personal information or submit a request for deletion of information under certain circumstances. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Consistent with California law, if you choose to exercise your rights and choices, we will not provide different quality of services unless otherwise permitted by law, although some of the functionality and features available on the Service may change or no longer be available to you.
United Kingdom and European Economic Area (“EEA”)
UK/EEA lawful basis for processing, including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)
To communicate with you; to make suggestions and recommendations to you; to send you promotional materials from us or on a third party's behalf; and to provide you relevant advertising.
Necessity for our legitimate interests (to grow our business)
To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.
(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and other services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation
Where legally required, and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information or share information with third parties), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.
Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with goods or services.
You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful. Please submit your request by sending an email to [email protected].