This Privacy Policy covers our treatment of personally identifiable information, including “Personal Data” as it is defined in the GDPR (“Personal Data”), that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. For this Privacy Policy, we also use the term “processing” as it is defined in the GDPR, which generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We will be the controller of your Personal Data processed in connection with the Services.

We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.

Our Services are not intended for children under the age of 13 and we do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we obtain actual knowledge that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at [email protected].

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to significant changes by placing a notice on the stateaffairs.com or our app, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive direct marketing from us, you may still receive necessary service updates. If you haven’t provided us with your email address, those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. Please check back regularly for any updates to this Privacy Policy. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Information You Provide to Us:

We receive and store any information you knowingly and directly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data, including without limitation, the following:

• First and last name
• Username
• Email address
• Mailing Address
• Preferred teams, leagues and other sports preferences
• User content and other information you directly upload to the
  Services (i.e., in comments sections) which can include Personal Data
  if you include Personal Data in such content

Certain information is required to register with us, subscribe to our Services, or to take advantage of our features.

We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services. If you do not want to receive communications from us, please indicate your preference by updating your account settings or clicking ‘unsubscribe’ in our emails.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which include the following:

• IP address
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
• Device identifiers
• Web browser information
• Operating system information
• Page view statistics
• Usage information
• Search information
• Location information

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

We use third party analytics services in order to better understand user engagement with the Website. When a user browses or uses the Website, these third party analytics services may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device.

If you click on a link to a third party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

When you use the Services, we may collect precise location data. For instance, if you allow the Services to access location services through the permission system used by your device’s mobile operating system or browser, we may collect the precise location of your device.

We may use the data described herein to customize content for you that we think you might like based on your usage patterns or for other similar purposes. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Do Not Track Policy

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. By using your browser settings, you may block cookies or adjust notifications when a cookie is set.

Information Collected from Third Parties

We collect Personal Data about you when third parties, such as our business partners or service providers, provide us with Personal Data about you. Such third parties provide us with Personal Data about you, such as the following:

Third Party Services Account Information: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service. Such information may include your name, email address, or information from your public profile. You can check the privacy policies of such third party services and your settings there for more information.

Referrals: If you’d like to invite your friends to use the Services, we will store this information for the sole purposes of allowing you to send your friends referral offers, for determining whether your friends use the Services after a referral is sent, and, for United States residents, to remind your friends of the referral sent on your behalf.

Advertising Partner Information: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications. We may also use third-party advertising companies to serve interest-based advertisements to you.

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• To create and manage user profiles and content
• To charge you for the Services costs through one or more payment processing partners
• To communicate with you about the Services
• To contact you about Service announcements or updates, or other marketing and promotional material
• To provide support and assistance for the Services and respond to user inquiries
• To personalize and calibrate content and communications based on your preferences
• To understand how users interact with the Services as a whole and to test new features or changes in such features
• To comply with our legal or contractual obligations
• To resolve disputes
• To protect against or deter fraudulent, illegal or harmful actions
• To enforce our Terms of Service

You can opt out of receiving promotional communications from us by adjusting your settings on your account page or by using the unsubscribe mechanism included in the message, where applicable.

We do not rent or sell your Personal Data to anyone at this time. We may share your Personal Data with third parties only as described in this section:

Non-Personal or Aggregate Information: We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). For example, we may partner with a local sports team to run a promotion for our users. You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

Our Agents: We employ other companies and people, such as vendors and third party service providers, who work on our behalf and provide us with services related to the purposes described in this Privacy Policy. These parties include:

• Payment processors (e.g. to receive and process your credit card transactions for us)
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers
• Telecommunications service providers

Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

User Profiles and Submissions: Certain user profile information, including your name, location, and any content that you have uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer user information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Protection of State Affairs and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to:

• comply with applicable law, court order, or respond to valid legal process, including from law enforcement or other government agencies;
• enforce or apply our Terms of Service, Privacy Policy and other agreements;
• prevent spam or other unwanted communications and investigate or protect against fraud;
• maintain the security of our products and Services;
• protect the rights, property, or safety of State Affairs, our employees, our users, or others.

Consent: We also share information with third parties when you give us consent to do so.

Affiliates: we share Personal Data with our affiliates or other members of our corporate family.

Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. Our information is stored on secure servers in the United States. Our security measures vary based on the sensitivity of the Personal Data we collect, process and store and the current state of technology. We also take measures to ensure subprocessors that process Personal Data on our behalf also have appropriate security controls in place.

We endeavor to reasonably protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We take various steps to protect your information, including, but not limited to, the following:

• We implement technical measures to prevent unauthorized access, and keep security patches and software up-to-date
• We restrict employee access to your information on a need-to-know basis
• We store sensitive Personal Data in encrypted form
• We encrypt all Personal Data during transfer

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

• Name and password
• Email address
• Location
• User profile information

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].

If you are a resident of the United States, you have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Opt not to Disclose: You can always opt not to disclose information to us by emailing us at [email protected]; however, keep in mind some information is required to register with us and to maintain an account.
• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by contacting us at [email protected]. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.

The CCPA provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Data to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For more information about these rights, or to submit a request, please email [email protected].

• Notice of Collection: The categories of Personal Data that we have collected, as described by the CCPA, in the preceding twelve (12) months includes identifiers, commercial information, internet activity, geolocation data and inferences. The information we collect is described in greater detail in the section above titled “What Information Does State Affairs Collect?” We collect and use these categories of information for the purposes described in the section above titled “How Do We Use Personal Data?” The information we share with third parties and the underlying principles that guide our sharing practices are further described in the section above titled “Will State Affairs Share Any of the Personal Data it Receives?”
• Right to Know and Delete: California Residents have the right to delete the Personal Data we have collected from you, and the right to know certain information about our data practices in the preceding twelve (12) months. If you would like to receive or delete your personal information, you can email us at [email protected]. We will confirm receipt of your request within ten (10) days.
• Right to Opt Out: We do not sell Personal Data as the term “sale” is traditionally understood. However, if and to the extent “sale” under CCPA is interpreted to include advertising technology activities specifically for interest-based advertising, we will comply with all applicable laws as to such activity.
• Authorized Agent: You may choose to designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
• Shine the Light: As a California resident, you may ask us for a notice describing what categories of personal information we share with third parties or affiliates for those third parties or affiliates’ direct marketing purposes and identify the name and address of the third parties that receive such personal information. Please submit a written request to the address provided below and specify you would like to receive a copy of your California Shine the Light Notice. We may require additional information from you to verify your identity. Please note that we are only required to respond to requests once during any calendar year.
• Consumer Affairs: Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice: If you have a question or complaint regarding the Services, please send an email to [email protected]. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at 916-445-1254 or 800-952-5210.

We retain Personal Data about you for as long as you have an open account with us and for six (6) years after you terminate your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.