Effective Date: April 1, 2020 | 

 

 

Table of Contents

  1. About This Privacy Policy

  2. Data That We Collect and Receive

  3. How We Use Data

  4. What Choices You Have

  5. Cookies and Similar Technologies

  6. Security of Data

  7. Third Party Sites and Sections

  8. Children and Parents

  9. Storing Data

  10. California Privacy Rights

  11. European Privacy Rights

  12. Changes to This Privacy Policy

  13. How to Contact Us

 

 

1. About This Privacy Policy

This privacy policy (the “Policy”) explains what data Social Beast Enterprises, LLC (DBA as “ShotCaller”) collects from you through our interactions with you and through our products, services, events and programs – including our websites, apps and digital platforms (each a “Service,” and collectively, the “Services”).

“Social Beast Enterprises, LLC” is doing business as “ShotCaller” and also is referred to as “we,” “our” or “us”.

By using any of the Services, you consent to the terms of this Policy.

 

2. Data That We Collect and Receive

When you interact with us through the Services, we may collect data from you or from other sources.  This “data” may be information that you directly provide to us, such as information you provide when you visit the Services, or information that is passively or automatically collected from you, such as anonymous information collected from your browser or device.

More specifically, the data we collect includes:

  • Data that you provide directly when you register for, or use, the Services.  This data will vary, but typically consists of name, email address, phone number and other similar contact data.  We also receive data from the communications you send to us, such as customer service inquiries, product reviews and other feedback regarding the Services.

  • Account data, such as name, email, gender, birthday, current city and profile picture URL.

  • Meta/Communications data, such as type of device, operating system, IP address, device identifiers and error reports.

  • Usage data, such as interest’s, websites visited, usage behavior, access times, log data, frequency and duration of your interactions through the Services.

  • Content data, such as text input, photographs & videos. 

  • Information about your interests and preferences, such as your favorite teams, players, game sessions played within the application or your communications preferences.  In addition to what you provide directly, we may infer your interests and preferences from other data we collect, such as the content and advertisements you interact with while using the Services.

  • Third party integrations.  If you connect your use of the Services through a third party service (e.g., a social media platform), the third party may share certain information from your third party account with us.

 

 

3. How We Use Data

 

We use the data we collect for the following purposes:

 

Operating our business. 

 

We use the data we collect to operate our business, including providing and improving the Services. 

 

Specifically:

  • To fulfill transactions that you request.

  • To diagnose and fix problems with the Services and providing other customer support services.

  • For analytical purposes to better understand our fans and how they use the Services, which allows us to continually improve and expand the Services.

Communicating with you. 

 

We use the data we collect to communicate with you, including responding to your requests or inquiries. 

 

Specifically:

  • To respond to your request if you contact us with a question or concern.

  • To provide information about your account, your use of the Services or other transactions that you request.

  • To deliver news, updates and other types of communications, according to your subscriptions, alerts and other preferences.

 

Marketing and advertising.  

We use the data we collect for marketing or advertising purposes, on behalf of ourselves, as well as our partners and other parties. 

 

Specifically:

  • To send you promotional messages and deliver advertisements about products, services, programs or events that may be of interest to you.  These may be offered by, or on behalf of, Social Beast Enterprises, LLC, or by our partners and other third parties with whom we have a relationship.

The promotional messages and advertisements that you see may be determined by data that we collect or receive about you, such as your demographic data, location data, usage data, interests and preferences.  We refer to this as “interest-based advertising”.

 

Security, compliance and enforcement. 

 

We use the data we collect for security, compliance and enforcement purposes. 

 

Specifically:

  • To protect the safety and security of our fans and our Services.

  • To detect and prevent abuse, fraud or other unlawful or unauthorized activities.

  • To resolve disputes.

  • To enforce our agreements, including our policies and terms of service that govern your use of the Services.

 

We may also use your data in any other manner as disclosed at the time of collection, or when we have otherwise obtained consent. 

4. What Choices You Have

 

You have many choices about how we collect, use and share your data.

 

Communications choices. 

 

You can choose whether you wish to receive notification messages from ShotCaller.  If you receive notification messages from us and would like to opt out, you may do so by turning off notifications sent to your device under the settings section of the application.

Advertising choices. 

 

When using a mobile application, you may receive interest-based in-application advertisements.  Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your device.  In addition, each operating system (e.g., iOS for Apple devices, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements.  You may review the support materials and/or the privacy settings for the respective operating system in order to opt-out of interest-based in-application advertisements.  For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

 

 

Other choices. 

 

You also have choices about the data you provide directly to us when you register for or use the Services.  Please note, however, that if you choose not to provide data that is necessary to provide certain features of the Services, the services may not be operational for you.

If you would like to request that we delete other personal data referenced in this Policy, you may also contact us using any of the methods described in the “How to Contact Us” section of this Policy.

5. Cookies and Similar Technologies

 

We use cookies and similar technologies (collectively, “Tracking Technologies”) to provide the Services and to collect data.  In addition, third parties may also use Tracking Technologies when you use the Services; for example, if we engaged a third party to operate the Services, or because the Services contain content or advertisements delivered by third parties.  These Tracking Technologies consist of:

  • Cookies.  Cookies are small text files that are unique to your device or browser.  They can either be session-based (i.e., lasting only while your browser is open and automatically deleted when you close your browser) or persistent (i.e., lasting until you delete them or they expire).

  • Locally stored objects.  Locally stored objects (“LSOs”), also commonly called “Flash cookies,” are stored on your device or browser to provide Services that use Adobe Flash technology.

  • Web beacons.  “Web beacons” or clear GIFs are small pieces of code placed on a Service to collect data about users of that Service.

  • Software development kits.  Mobile Software Development Kits (“SDKs”) are bits of computer code used by mobile app developers to enable or enhance various features of a mobile app.  For example, an app developer may include an SDK within a mobile app that enables advertisements to be shown, data to be collected, and related services or analytics to be performed in connection with the mobile app.

 

We use Tracking Technologies for the following purposes:

  • Sign-in/authentication.  When you sign into your account to use the Services, we use Tracking Technologies to store your sign-in information.  This allows the Services to remember your user preferences and give you a more tailored experience based on those preferences.  It also allows you to use the Services without having to sign-in on each page or each time you return.

  • Security.  We use Tracking Technologies to help detect fraud and abuse of the Services, including attempts to access the Services without authorization.

  • Analytics.  We use Tracking Technologies to gather usage and performance data about the Services, including counting the number of unique visitors to a particular Service.

  • Advertising.  We use Tracking Technologies to track how many users have seen or clicked on an advertisement.  This allows us to learn which advertising campaigns are most effective and also to help limit the number of times a user is shown the same advertisement.

  • Interest-based advertising.  We use Tracking Technologies to collect information about your interests so that we can deliver advertising that is most relevant to your interests.

  • Tailoring the Services.  We use Tracking Technologies to collect information about how you use the Services so that we can tailor your experience based on what is most relevant to your interests.

In some cases, we may work with third parties (for example, third party operators of the Services) to synchronize our unique, anonymous identifiers (such as those associated with Tracking Technologies) with the third party’s own identifiers.  This enables us to better achieve each of the purposes described above.

Managing Tracking Technologies.  Most web browsers give you the ability to manage Tracking Technologies used on a website, including blocking or deleting them.  Please note that if you choose to block Tracking Technologies, you may not be able to use certain features that depend on those Tracking Technologies (such as keeping you signed in or remembering your preferences).  If you choose to delete Tracking Technologies, any settings and preferences that were associated with those Tracking Technologies will also be deleted and may need to be reset. 

You also have the following options to manage Tracking Technologies and opt out of interest-based advertising:

  • For Flash cookies, you can access Flash management tools from Adobe’s website.  In addition, some, but not all, browsers provide the ability to remove LSOs within cookie and privacy settings.

  • You may opt out of receiving interest-based advertising on websites by visiting our Ad Choices page.

  • You may opt out of interest-based advertising from companies that participate in the Digital Advertising Alliance (“DAA”) by visiting their website.

  • You may opt out of interest-based advertising from companies that participate in the Network Advertising Initiative by visiting their website.

  • Finally, you may opt-out of interest-based advertising by adjusting your device or browser settings.

Please note that opting out of interest-based advertising does not mean you will stop seeing, or see fewer, advertisements.  It does, however, mean that the advertisements you do see will not be interest-based and may be less relevant to your interests.

Some browsers have incorporated “Do Not Track” features that send an automated signal to the websites that you visit using that browser.  At this time, the Services do not recognize or respond to these signals.  However, you can adjust your preferences regarding the data we collect using the tools and methods described above.

6. Security of Data

 

Social Beast Enterprises LLC takes security seriously.  We take a number of steps to protect your data from unauthorized access, use or disclosure.  These steps take into account the sensitivity of the data we collect and use, as well as the current state of technology.  This includes, for example, storing your data on systems that have limited access and are maintained in controlled facilities. 

 

It is important to remember that no system can be guaranteed to be 100% secure.  We recommend that you help us keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data in places that can be accessed publicly.

7. Third Party Sites and Sections

We work with a number of third parties to operate the Services.  When we engage third parties in connection with operating the Services, those third parties may only collect, use or access your data as needed for them to perform these functions.  These third parties include:

  • Wix.  We have engaged Wix.com Ltd., (“Wix”) to operate the ShotCaller website and mobile site.  To learn more about how Wix collects, uses, protects and discloses your personal data, please visit https://www.wix.com/about/privacy .

 

  • Facebook. We have engaged Facebook, Inc., (“Facebook”) to operate the ShotCaller social media website and mobile game application.  To learn more about how Facebook collects, uses, protects and discloses your personal data, please visit https://www.facebook.com/policy.php .

 

  • AWS.  We have engaged Amazon Web Services, Inc., (“AWS”), a Amazon.com, Inc. property that provides on-demand cloud computing platforms and APIs, to operate the ShotCaller cloud computing services.  To learn more about how AWS collects, uses, protects and discloses your personal data, please visit https://aws.amazon.com/privacy/.

 

 

These third parties are only authorized to use your data as permitted under this Policy, or as disclosed to you at the time your data is collected.  Please note, however, that these third parties may supplement data collected or received in connection with the Services with data they collect or receive through other websites, platforms and services, in accordance with the policies and disclosures posted on those websites, platforms and services.

The Services may also contain links to, or integrations with, other websites, platforms or services that are not operated or controlled by ShotCaller (each a “Third Party Site,” and collectively, the “Third Party Sites”).  Please note that this Policy does not apply to those Third Party Sites.  For more information on how those Third Party Sites collect, use and share data, we suggest that you contact the operators of those Third Party Sites directly.

8. Children and Parents

 

Although there are sports fans of all ages, the Services are not directed at children under the age of 16, and our policy is to not knowingly collect personal data from children under the age of 13.  We encourage parents and guardians to monitor their children’s online behavior, put parental control tools in place, and teach children not to provide their personal data through the Services without parental consent.

If you have reason to believe that a child under the age of 13 has provided personal data to us without parental consent, please contact us using any of the methods described in the “How to Contact Us” section of this Policy, and we will endeavor to delete that data from our systems.

For children located in jurisdictions within the EU, we comply with the age limits applicable in each Member State.  In these instances, the references above to the age of 13 will be deemed to be references to the age limits applicable in each Member State.  Where this Policy refers to consent, this will require the consent of a parent or legal guardian in relation to any person under the age limits applicable in each Member State.

9. Storing Data

Data collected by the ShotCaller may be stored and processed in the region in which it is collected, in the United States, and in any other region where we maintain major operations.  We take steps to ensure that the data we collect under this Policy is stored and processed in accordance with this Policy regardless of where the data is located.  By providing data in connection with the Services, you acknowledge and agree that such data may be transferred from your current location to the offices and servers of ShotCaller and our authorized third party service providers located in the United States.  Our practice when transferring personal data is to rely on standard data protection contract clauses or individual consent.

We retain data for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements.  Because these factors vary for different types of data, actual retention periods may vary.  The criteria we use to determine the appropriate retention periods include:

  • How long is the data needed to provide the Services?  This is the baseline for most data retention periods.

  • Is the data of a sensitive type?  If so, a shortened data retention period will generally apply.

  • Has the user provided consent for a longer retention period?  If so, we will retain the data in accordance with the user’s consent.

  • Are we subject to a legal, contractual or similar obligation to retain the personal data?  If so, we will retain the data in accordance with our obligations.

 

10. California Privacy Rights

This section supplements our privacy policy with additional information for California residents only.  As noted above, we collect data that you provide directly when you register for or use the Services, user credentials that you supply directly when you register for or update your login information to use the Services, account data, meta/communications data, content data, usage data, information about your interests and preferences, third party integrations, and other third party data.  In accordance with the California Consumer Privacy Act (“CCPA”), California residents have the right to request that we disclose the following information about our collection and use of personal information over the twelve months prior to your request:

  • The categories of personal information we collect about you.

  • The categories of sources for the personal information we collect about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information collected about you.

  • If we disclosed your personal information for a business purpose, a list of the categories of personal information we have disclosed in the prior twelve months.

  • If we sold your personal information for a business purpose, a list of the categories of personal information we have sold in the prior twelve months.

You also have the right to request that we delete any of your personal information.  In some circumstances we may not be able to honor your request for deletion – for example, if we need to hold on to your information to protect the security or functionality of our operations, to service your account, or to comply with legal obligations.

To ask for a record of the information we hold about you, or to ask us to delete your information, please email us at hello@playshotcaller or via our web form

 

If you would like to submit a request to any third party operator of any of the Services, please visit the “Third Party Sites and Sections” section of this Policy and navigate to the third party’s website, where you can submit your request.  You must provide enough information that we can verify who you are and that you are a California resident.  We will only use personal information provided in a request to verify the requester’s identity and authority to make the request. 

You also have the right to direct us not to sell your personal information at any time.  To opt out of the sale of your personal information, you may submit a request to us by email at hello@playshotcaller

You have the right to designate an authorized agent to make any of these requests under the CCPA on your behalf.  We will not deny services, charge different prices, offer a different quality of service or otherwise discriminate against you for exercising your rights under the CCPA.

11. European Privacy Rights

 

We adhere to applicable data protection laws in the European Union (“EU”).  In accordance with the General Data Protection Regulation (“GDPR”), users who are located in the EU have the following rights:

  • If the processing of personal data is based on your consent, the right to withdraw consent for future processing of that data.

  • The right to request from Social Beast Enterprises, LLC., a “data controller” as defined under the GDPR, access to and rectification of your personal data.

  • Subject to limitations as provided for in the GDPR, the right to request restriction of the processing of your personal data.

  • Subject to limitations as provided for in the GDPR, the right to request erasure of your personal data.

 

You may contact Social Beast Enterprises, LLC. using any of the methods described in the “How to Contact Us” section of this Policy.   

 

12. Changes to This Privacy Policy

We may change this Policy from time to time to reflect changes in our business, the Services, or our practices and procedures.  If we do make changes, we will post any changes on this page and indicate the date on which the Policy was last revised.  We encourage you to review this Policy periodically, especially before you provide personal data directly to us through the Services.  Your continued use of the Services after any changes to this Policy are in effect constitutes your acceptance of the revised Policy.

13. How to Contact Us

Although we strive to make this Policy as comprehensive as possible, we know you may still have questions or concerns about how we collect, use and share data.  If you have a question, concern or complaint regarding our data privacy practices, you may contact us by any of the following methods: