Privacy Policy

‍

Adapt the Game, Inc. (“Adapt,” “Company,” “we,” or “us”) values your privacy. Our mobile applications enable fans with disabilities to have a more equal and accessible game day experience. 

In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of our website, https://www.adaptthegame.io/ (the “Website”), our mobile application (the “App”), and the services available through our Website and App (collectively, the Website, the App and the services available therein are the “Services”). By using or downloading the App, or otherwise using the Services, including accessing the Website, you agree that your information will be handled as described in this Policy. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, incorporated by reference herein, including its applicable limitations on damages and the resolution of disputes.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

‍

What Information Do We Collect?

We may collect and process the following information about you:

Information you give us. You may give us information when you register with our Services or by communicating with us by phone, email, social media or otherwise. This includes information you provide when you create a customer account, use our services, provide us with identification information required to verify your identity or in connection with the issue of your tickets, provide us with feedback, participate in surveys, when you report a problem with our Services, in the context of promotions, when you participate in a community board discussion chat, or when you otherwise correspond with us.

1. The information you give us may include your name, address, email address, phone number, date of birth, copies of formal identity documents such as your passport or ID card, business seller information, tax identification number and credit or debit card details.
2. It may also include information you provide us when creating a profile through our Services, which may include a profile picture and access to your camera and/or photo library (if you choose to enable this service on your computer or device).
3. We may monitor or record telephone conversations or other communications between you and us.

‍

Information we collect about you based on your use of our Services, including:

1. The Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, operating system, device information (such as the model and version of your device), platform, ID for advertising, and unique device token, Computer and connection information such as statistics on your page views, traffic to and from the Website, referral URL, ad data, your browsing history, and your web log information.
2. Information about your use of our Services, including products and events you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any data entered into the page during your visit.
3. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;
4. Events you will be attending or have attended based on your purchases through the Services (“My Activity”).
5. Your viewing history of events or teams. Your favorite, teams, venues, or any other event-related interests based on your use of the Services.

Physical Location. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

Information collected from cookies. We and our service providers collect information about your use of our Services using cookies. For information about our use of cookies and how to decline them or turn them off please read our Cookies Policy located herein. 

‍

Information we receive from other sources. We work closely with third parties including, for example, our fraud prevention providers and email address / telephone number verification service providers. We may receive information about you from these third parties to verify information you provide to us which helps us to identify suspicious or unusual transactions.

1. We allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
2. If you agree to provide us with access to any social media site with video content, then we may reshare or otherwise engage with your posts and interactions on third-party social media sites for at least two years or until you withdraw authorization or connection to the social media site, to the extent permitted by law.
3. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site, and your interactions thereon will be governed by such social media site’s applicable terms and conditions.

‍

Our use of your Personal Information helps us in providing your requested Services. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

‍

How Do We Use Your Information?

We and our service providers use personal information for the following purposes:

1. Providing the functionality of the Services and fulfilling your requests.

• To provide the Services’ functionality to you, such as arranging access to your registered account, enabling you to purchase tickets, managing your relationship with us, and providing you with related benefits, special promotions, or customer service;
• To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
• To complete your transactions, process returns and exchanges, verify your information, and provide you with related benefits, special promotions, or customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.
• To allow you to send messages to another person through the Services if you choose to do so.

‍

1. Communicating with you, providing you with our newsletter and/or other marketing materials, and facilitating social sharing.

• To send you marketing related emails, with information about our services, new products and other news about our company.
• To poll your opinions through surveys or questionnaires.
• To contact you about public policy matters, or other current events, related to your ability to use our Services. This could include an invitation to join a petition, letter writing, call or other sort of public policy related campaigns.
• To communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means, consistent with applicable law. We may use autodialed or pre-recorded calls and text messages as described in our Terms of Service and as authorized by applicable law. Message and data rates may apply.
• To facilitate social sharing functionality that you choose to use.

‍

1. Analyzing personal information for business reporting and providing personalized services.

• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers, coupons, discounts and special promotions tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

‍

1. Allowing you to participate in sweepstakes, contests or other promotions.

• We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
• Some of these promotions have additional rules containing information about how we will use and disclose your personal information. Please read those additional rules before choosing to participate.

‍

• Aggregating and/or anonymizing personal information.

• We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

‍

• Accomplishing our business purposes.

• For data analysis, for example, to improve the efficiency of our Services.
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
• For fraud prevention and detection and fraud security monitoring purposes, for example, to verify your identity as part of our identity authentication process, to comply with our legal or regulatory requirements, and to detect and prevent cyberattacks or attempts to commit identity theft.
• For training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.
• For developing new products and services.
• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

‍

We also use technology to help validate your transactions and keep our Services safe

We employ technology to analyze transactions you enter into against the information we collect from you or from third parties about you, such as from where you ordinarily use our service, at what times, and other characteristics specific to how you use our services. The technology is aimed to help us identify unusual or suspicious transactions in order to detect and prevent fraud. This means that an attempted transaction may be marked as suspicious, unusual or otherwise out of the ordinary, as a result of which your transaction may be declined. Where you are encountering that your validly executed transaction is declined, you can always contact customer service who will help you validate your current and futures transactions.

If you have any questions about our tool and how it relates to any of your personal information processed, you can contact us via [support@adaptthegame.io].

Third Party Advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.

Who Do We Share Your Information With?

We share your information with the following third parties:

• Our affiliates (including our subsidiaries), for the purposes described in this Privacy Policy.
• Other users and ticket sellers in order to enable them to verify your identity and/or provide you with tickets you have bought through our Services (e.g. for the purposes of posting your tickets to you). Buyers may see information about the seller in certain cases (e.g. where included as a return address on the ticket shipment).
• Our business partners, financial institutions, and credit agencies, consistent with applicable law.
• Partner teams, venues, leagues or other third parties involved in the event for which you sell or buy a ticket.
• Our third party service providers, to facilitate services they provide to us, such as website hosting, data analysis, payment processing, order fulfilment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
• Third party sponsors of sweepstakes, contests, and similar promotions.

‍

By using the Services, you may elect to disclose your personal information. When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

‍Other Uses And Disclosures Of Information

We also use and disclose your personal information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

• This may include laws outside your country of residence.

• To cooperate with public and government authorities.

• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.

• To cooperate with law enforcement.

• For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.

• To enforce our Terms of Service; and
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

• In connection with a sale or business transaction.

• We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

‍

How Do We Transfer Your Information?

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

‍

How Long Do We Keep Your Information?

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

‍

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

‍

Security

We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

‍

Third Party Payment Service

The Services may provide functionality allowing you to make payments to us using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your personal information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information.

‍

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the App or our Social Media Pages.

‍

Use Of Services By Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from individuals under 16.

Your Privacy Rights And Choices

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by selecting the ‘unsubscribe’ option in the marketing communications we send or at any time by changing your account preferences. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you no longer want to receive SMS/text messages from us on a going-forward basis, you may opt out by contacting [support@adaptthegame.io].

If you would like to request to access, correct, update, suppress, restrict, or delete personal information, object to or opt out of the processing of personal information, or if you would like to request to receive a copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us at [support@adaptthegame.io]. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to have changed or whether you would like to have your personal information suppressed from our database. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

If you would like to update personal information that you have provided to us, you may do so by updating your registered account with us.

Pursuant to California Business & Professions Code section 22581, if you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to [support@adaptthegame.io]. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

‍

Updates To This Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

‍

Additional Information Regarding the EEA

If you are based in the EEA and not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois R32 AP23, Ireland. Tel: +353 (0761) 104 800 or on its website at www.dataprotection.ie.

‍

GDPR Principles

Out of respect for your privacy, we aim to comply with the GDPR’s six guiding principles:

• Lawfulness, transparency, and fairness.
• Purpose limitation.
• Data minimization.
• Accuracy.
• Storage limitation.
• Confidentiality and integrity.

‍

California Consumer Privacy Act

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Adapt the Game, Inc. is providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This CCPA Privacy Policy does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

We do not sell Personal Information and have not sold Personal Information within the preceding 12 months, as “sale” is defined in the CCPA. We do not sell the Personal Information of minors under age 16.

The following chart details which categories of Personal Information we plan to collect, as well as the categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months. We collect this Personal Information from you and your devices, as well as from our corporate affiliates, publicly available databases, other Adapt the Game, Inc. customers, credit agencies (as allowed by applicable laws), and social media sites.

‍