Effective Date: September 30, 2016
Raptor Sports Holdings, Inc. and Raptor Sports Properties, LLC (collectively, “Raptor” or the “Company”) are committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), our clients (“Clients”), and individuals whose information is transferred to us by our Clients (“Fans”). This Privacy Statement describes Raptor’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Raptor (the “Services”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Raptor participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Raptor is committed to subjecting all personal data received from European Union (“EU”) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
Raptor is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Raptor complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Raptor is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Raptor may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Raptor complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Raptor has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Raptor’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
1. Web sites covered
This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including: http://www.fanmanager.com; Raptor Fan Manager; (collectively referred to as “Raptor’s Web sites” or “the Company’s Web sites”).
Raptor Fan Manager is an online hosted service that allows our Clients to interact with their Fans. The Web site will link to this Privacy Statement, and this Privacy Statement will apply.
Raptor’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. If you submit personal information to any of those sites, your information is governed by their privacy policies. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
2. Information collected
When expressing an interest in obtaining additional information about the Services or registering to use the Services, Raptor requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). Raptor may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information and Optional Information about Clients are referred to collectively as “Data About Raptor Clients”.
3. Use of information collected
The Company uses Data about Raptor Clients to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.
The Company may also use Data about Raptor Clients for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.
Raptor uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data about Raptor Clients to provide personalized information about the Company.
4. Web Site Navigational Information
Cookies and Tracking Technologies
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.
5. Sharing of information collected
Raptor may share Data about Raptor Clients & Fans with the Company’s contracted service providers so that these service providers can provide services on our behalf such as shipping your order or offering Fan Manager services. Raptor may also share Data about Raptor Clients & Fans with the Company’s service providers to ensure the quality of information provided. Unless described in this Privacy Statement, Raptor does not share, sell, rent, or trade any information with third parties for their promotional purposes. These companies are authorized to use your personal information only as necessary to provide these services to us.
The Company may share Data about Raptor Clients & Fans with other companies in order to work with them, including affiliates of the Raptor corporate group. For example, the Company may need to share Data about Raptor Clients & Fans for client relationship management purposes.
From time to time, Raptor may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Raptor, the Company may share Data about Raptor Clients collected in connection with your purchase or expression of interest with our joint promotion partner(s). Raptor does not control our business partners’ use of the Data about Raptor Clients we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
Raptor reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, legal process, or to any other third party without your prior consent to do so. If the Company is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
6. International transfer of information collected
To facilitate Raptor’s global operations, the Company may transfer and access Data about Raptor Clients & Fans from around the world, including the United States. This Privacy Statement shall apply even if Raptor transfers Data about Raptor Clients & Fans to other countries.
7. Communications preferences
Raptor offers Visitors and Clients who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to firstname.lastname@example.org. Clients cannot opt out of receiving transactional emails related to their account with Raptor or the Services.
8. Correcting and updating your information
Upon request Raptor will provide you with information about whether we hold any of your personal information. Clients may access, update or change their registration information or request deletion of their personal information by editing their user or organization record. To update a user profile, please login to Raptor Fan Manager with your username and password and click “Account Settings.” To update an organization’s information, please login to Raptor Fan Manager with your username and password and select “Organization Setup.” Clients may update or change their registration information on the event’s Web site after logging in. To update Billing Information or have your registration information deleted, please email email@example.com. To discontinue your account and to have information you maintained in the Services returned to you, please email firstname.lastname@example.org. Requests to access, change, or delete your information will be handled within thirty (30) days.
Raptor Sports will retain your information for as long as your account is active or as needed to provide you services. Raptor Sports will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Client Data
Raptor Clients may electronically submit data or information to the Services for hosting, processing, and controlling purposes (“Client Data”). Raptor will not review, share, distribute, or reference any such Client Data except as agreed in the Raptor Fan Manager Master License Agreement, or as may be required by law. In accordance with the Raptor Fan Manager Master License Agreement, Raptor may access Client Data only for the purpose of providing the Services, preventing or addressing service or technical problems, at a Client’s request in connection with client support matters, as agreed to in the Raptor Fan Manager Master License Agreement, or as may be required by law.
Information Related to Data Collected through the Raptor Fan Manager
Raptor collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal information it processes. Raptor works with its Clients to help them provide notice to their customers concerning, the purpose for which personal information is collected.
We collect and aggregate information for our Clients; if you are a Fan of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. If you are a Client and would like to update your account please contact us at email@example.com.
Raptor may transfer information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Statement regarding notice and choice and the service agreements with our Clients.
Raptor acknowledges that you have the right to access your personal information. Raptor has no direct relationship with the individuals whose personal information it processes. An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to Raptor’s Client (the data controller). If the Client requests Raptor to remove the data, we will respond to their request within thirty (30) days.
Raptor will retain personal information we process on behalf of our Clients for as long as needed to provide services to our Client. Raptor will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Raptor uses robust security measures to protect Client Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Client Data. When the Services are accessed using Internet Explorer version 7.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket Layer (.SSL.) technology protects sensitive information (such as login credentials) using both server authentication and data encryption. These technologies help ensure that Client Data is safe, secure, and only available to the Client to whom the information belongs and those to whom the Client has granted access. Raptor also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. Raptor also offers enhanced security features within the Services that permit Clients to configure security settings to the level they deem necessary. Clients are responsible for maintaining the security and confidentiality of their Raptor usernames and passwords.
Because the Company uses the Services to maintain Data about Fans, this information, which is stored in the Services, is secured in the same manner as described above for Client Data.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at firstname.lastname@example.org.
11. Changes to this Privacy Statement
Raptor reserves the right to change this Privacy Statement. Raptor will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.
12. Social Media Widgets
13. Contacting us
Questions regarding this Privacy Statement or the information practices of the Company’s Web sites, please contact us through the information below:
Raptor Sports Holdings, Inc.
280 Congress Street, 12th Floor
Boston, MA 02210