A. INFORMATION HUDDLE COLLECTS
Our Website typically collects two (2) kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you that we automatically collect when you visit our Website or that you provide us.
1) Personally Identifiable Information.
Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, cell phone number, email address, student identification number, credit card information, and other types of personally identifiable information that we collect about you or you provide to us (“Personally Identifiable Information”). As a general policy, we do not automatically collect your Personally Identifiable Information when you visit our Website. In certain circumstances, we may request, allow, or otherwise provide you an opportunity to submit your Personally Identifiable Information in connection with a feature, program, promotion, or some other aspect of our Website. For instance, you may: (a) provide your name, cell phone number, email address, and student identification number when registering with our Website or in connection with a contest entry; or (b) provide certain demographic information about you (e.g., age, gender, high school affiliation, purchase preference, or usage frequency) when purchasing a ticket, participating in a survey, or attending an event. Certain information may not be personally identifiable when standing alone (e.g., your age) but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website.
2) Non-personally Identifiable Information.
Our definition of non-personally identifiable information includes any information, whether standing alone or when combined with other information, that does not personally identify you (“Non-personally Identifiable Information”). As mentioned above, this information may be personally identifiable if provided along with other information about you. Non-personally Identifiable Information can include certain Personally Identifiable Information that has been de-identified; that is, information that has been rendered anonymous. We obtain Non-personally Identifiable Information about you from information that you provide us, either separately or together with your Personally Identifiable Information. We also automatically collect certain Non-personally Identifiable Information from you when you access our Website, such as what areas of the Website you visit and what services you access, and information from the Device with which you access the Website. By using Huddle’s services, you consent to Huddle sharing your Non-personally Identifiable Information with third parties and Affiliated Entities (as defined below) as necessary to complete your transactions and for other services for which you have registered.
B. HOW WE USE & SHARE THE INFORMATION COLLECTED
1) Personally Identifiable Information.
The Personally Identifiable Information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways associated with the circumstances in which you provided the Personally Identifiable Information. We may also use this Personally Identifiable Information to later contact you for a variety of reasons, such as customer service; to provide you with information or services or process transactions that you have requested or agreed to receive; to provide you with marketing or promotional information for our products, including tickets to other events at your high school, or products of our subsidiaries, other affiliated entities (“Affiliated Entities”), or other third parties that provide services relating to high school events; or to communicate with you about content or other information you have posted or shared with us via our Website or with regard to your use of the Website. For instance, if you purchased a Roswell High School football ticket, we may send you an email or push notification promoting all high school games available through the National Federation of State High School Associations (NFHS).
If you send us an email with questions or comments, we may use the Personally Identifiable Information you voluntarily provide to respond to your questions or comments, and we may save your questions or comments for future reference and to improve our product offerings. For security reasons, we do not recommend that you send non-public Personally Identifiable Information, such as passwords, social security numbers or bank account information, to us by email. Further, we may send you email under the following circumstances: (a) if you request a particular service or sign up for a feature that involves email communications; (b) if the email relates to purchases you have made with us (e.g., reviews, event updates, customer support, etc.); (c) if we are sending you information about our other products and services; (d) if you consented to being contacted by email for a particular purpose; (e) if you send us an email, post content on the Website (i.e., a photo or video from an event) or otherwise submit information to us electronically, we may email you to follow-up or otherwise communicate with you with respect thereto; (f) to provide you legal notices or notices with respect to your use of the Website; or (g) to otherwise facilitate a transaction between us. In certain instances, we may provide you with tools on the Website that will allow you to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may "opt out" of receiving future commercial email communications from us by clicking the "unsubscribe" link or following the other instructions included at the bottom of most emails we send, or as provided below in Section F; provided, however, we reserve the right to send you transactional emails such as customer service communications.
2) Non-Personally Identifiable Information.
In addition to any Personally Identifiable Information or other information that you choose to provide to us on the Website, we and our Affiliated Entities may use a variety of technologies, now and hereafter devised, that automatically collect certain website usage information whenever you visit or interact with the Website. Information collected through passive means may be non-identifying or may be associated with you. In the latter case, such information associated with you will be treated as Personally Identifiable Information. This Non-personally Identifiable Information collected may include browser type; operating system; click-stream data, including the page served, the time, the source of the request, the preceding page view; and other similar information (“Website Usage Information”). We may use Website Usage Information for a variety of purposes, including to enhance or otherwise improve the Website. In addition, we may also collect your IP address or some other unique identifier for your Device, as applicable (collectively, referred to herein as a "Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device, and we may identify your Device by its Device Identifier. When analyzed, Website Usage Information helps us determine how our Website is used, such as what types of visitors arrive at the Website, what type of content is most popular, what type of content you may find most relevant, and what type of visitors are interested in particular kinds of content and advertising. We may associate your Device Identifier or Website Usage Information with the Personally Identifiable Information you provide, and we will treat such combined information as Personally Identifiable Information. Website Usage Information may be collected using various methods, such as the following:
a) Cookies. A cookie is a data file placed on a Device when such data file is used to visit the Website, and a Flash cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device (collectively, “Cookies”). Cookies may be used for many purposes, including, without limitation, tracking user preferences and web pages visited while using the Website. You may be able to remove, reject and/or disable some types of Cookies using your browser's preferences or other programs. Some features of the Website may not function properly or may operate slowly if you disable, delete, or refuse to accept Cookies.
b) Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Website, and is deactivated or deleted thereafter.
c) Web Beacons. Small graphic images or other web programming codes called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
d) Mobile Device Identifiers. Certain mobile service providers uniquely identify Devices, and we or our Affiliated Entities or third parties may receive such Device information if you access the Website through such Devices. Certain features of our Website may require collection of mobile phone number(s), and we may associate such phone number to such Device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of Devices that use their service (“Location Services”). When you consent to our use of Location Services, or otherwise depend on the settings on your Device, we or our Affiliated Entities or third parties may collect the precise location information provided by your Device, including data provided by your GPS, WiFi, or otherwise obtained when the GoFan mobile application or your Device interacts with a proximity beacon at the event venue.
We primarily collect information from your Device to facilitate the functionality of the GoFan mobile application and deliver valuable, entertaining content to you at or relating to the event. For example, we collect your registration information so we or trusted third parties can show you content that interests you and to process transactions on your behalf. We may collect your Device’s location in order to show you offers or features available near you at the event venue, deliver more relevant information and ads, and understand how users interact with the event venue. We or our trusted third parties may combine data collected through the GoFan mobile application with other information collected about you so that we and such third parties can personalize or improve the relevance and quality of the services provided to you.
e) Proximity Beacons. We may also collect data from physical proximity beacons, or similar tracking technologies, located at the high school events where our services are used. Using radio signals, these proximity beacons detect when a Device enters a specific area and may collect data about your location when you are near a beacon. Depending on your mobile settings, this information may be collected when you are using the GoFan mobile application or in the background. We may use the information collected from proximity beacons to determine which events and services you are visiting, analyze and improve your experience at events, and send you relevant, targeted offers (for example, a discount on food concession packages at the event, or merchandise appropriate for the weather at the time and place of the event (e.g., a sweatshirt if the weather is cold, and a t-shirt if the weather is hot)).
f) Aggregate Information. We use Non-personally Identifiable Information in a variety of ways, and we may use your Non-personally Identifiable Information by itself or aggregate such information with information we have obtained from others. We may share your Non-personally Identifiable Information with our Affiliated Entities and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain Non-personally Identifiable Information to third parties, but this will not involve disclosing any of your Personally Identifiable Information without your consent.
C. OTHER USES
1) Sweepstakes, Contests, and Other Promotions.
We may offer sweepstakes, contests, and other promotions through the Website that may require registration (“Promotion(s)”). By entering any Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personally Identifiable Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize or Promotion fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
2) Information You Provide About A Third Party.
If you send someone else a communication from the Website, such as sending Website content to a friend, the information you provide (e.g., names and email addresses) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any “send-to-a-friend” functionality on our Website, your email address may be included in the communication sent to a third party.
3) Information Third Parties Provide About You.
4) Transfer of Assets.
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the Personally Identifiable Information and Non-personally Identifiable Information we have about you will be transferred to and used by such acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
5) Legal Requirements.
Notwithstanding anything herein to the contrary, we reserve the right to disclose any Personally Identifiable or Non-personally Identifiable Information about you if we are required to do so by law, with respect to notices and counter-notices pursuant to our DMCA notice and takedown policy and procedures and/or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website's users or the general public.
D. THIRD PARTY AD SERVER NETWORKS, WEBSITES/LINKS,
1) Third Party Ad Server Networks.
If you would like to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out webpage at http://www.aboutads.info/choices. Most modern browsers include a do-not-track feature that may help protect your privacy. However, please note that because a defined response to do-not-track requests has not been established, Huddle does not respond to these requests at this time.
2) Third Party Websites/Links.
Our Website may link to or contain links to other third party websites that we do not control or maintain, such as in connection with purchasing products referenced on our Website and banner advertisements. We are not responsible for the privacy practices employed by any third party website. We will send you a notification when you are navigating away from our Website and encourage you to read the privacy statements of all third party websites before submitting any Personally Identifiable Information or otherwise interacting with such third party website.
3) Third Party Applications.
Third party applications may be available via the Website. The owners of these applications ("Third Party Owners") may collect Personally Identifiable Information from you and may have their own policies and practices. We are not responsible for how Third Party Owners or their applications use your Personally Identifiable Information. These Third Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these policies or the practices of Third Party Owners. We will send you a notification when you are navigating away from our Website and encourage you to read any available policies before submitting any Personally Identifiable Information to a third party application or otherwise interacting with it.
4) Social Media Features.
5) Single Sign-on.
You can log in to our Website using single sign-on services such as Facebook Connect or VNN (a high school sports marketing and communications platform). These services will authenticate your identity and provide you the option to share certain Personally Identifiable Information with us, such as your name and email address, to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Website to your profile page to share with others within your network. Before you log in to our Website using a sign-on service, we will ask you to confirm that you consent to your login information being shared with such sign-on service.
E. KEEPING YOUR INFORMATION SECURE
We have implemented reasonable security measures to protect against the loss, misuse and alteration of the information under our control. For example, we use encrypted passwords for all users, and all data access is password protected. Additionally, to most effectively serve you, credit card transactions are handled by established third party banking institutions and processing agents. Such third partying banking institutions and processing agents receive the information needed to verify and authorize your credit card or other payment information. The third party we currently use to process credit card data maintains the highest-level PCI compliance available, which is a set of security standards designed to ensure all third parties that accept, process, store or transmit credit card information maintain a secure environment.
Please be advised, however, that while we strive to protect your Personally Identifiable Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your Personally Identifiable Information. From time to time, we evaluate new technology for protecting information, and, when appropriate, we upgrade our information security systems. In the unfortunate event that your Personally Identifiable Information is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided to us in the most expedient time frame that is reasonable under the circumstances. Please note, however, that delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system, or to accommodate the legitimate needs of law enforcement if notification would impede a criminal investigation.
F. CONTACT & OPT-OUT INFORMATION
You have the ability to modify and limit some of the information provided to Huddle and third parties. For example, you can change your passwords and, in the next release of the GoFan mobile application, you will be able to modify your high school affiliation.
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please, note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website. Also, please note that it is not always possible to completely change, remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. If you have made any public postings on the Website such as in forums or blogs, these communications are generally not removed by us.
Additionally, as mentioned above, you have the opportunity to reject Location Services on your Device. Please be aware that disabling Location Services may limit Huddle’s ability to best serve you and optimize your experience when using GoFan Service.
G. A NOTE FOR PARENTS CONCERNING PRIVACY
The features, programs, promotions and other aspects of our Website requiring Personally Identifiable Information are not intended for children. Huddle does not currently collect any Personally Identifiable Information from children under the age of thirteen (13) on the Website. If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personally Identifiable Information to us, please contact us at email@example.com. A parent or guardian of a child under the age of thirteen (13) may review and request deletion of such child's Personally Identifiable Information as well as prohibit the use thereof. If in the future, the Website collects Personally Identifiable Information from children, the Website collect such Personally Identifiable Information from children in compliance with the Children's Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.).
Please note that we have entered into separate agreements with high schools for the purpose of delivering its services and will share your Personally Identifiable Information as set forth in its agreements with such high schools in addition to sharing your Personally Identifiable Information and as described in this Agreement. We acknowledge that certain student Directory Information (as defined herein) may lawfully be shared by high schools with persons other than parents and specified agencies. “Directory Information” includes the student’s name, address, telephone number, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous private or public school attended by the student. In the event a parent has notified a high school or the applicable school district that such Directory Information should not be released, however, we acknowledge that such Directory Information shall not be shared. Accordingly, we expect that any student Directory Information shared with Huddle from the high schools with which Huddle has contracted has not been objected to by such students’ parents.
H. YOUR CALIFORNIA PRIVACY RIGHTS
1) California Student Data Privacy Agreement Compliance.
Under Chapter 22.2 of the California Business and Professions Code, the California Student Online Personal Information Protection Act (SOPIPA) prohibits operators of websites used primarily for K-12 school purposes from sharing student data and using such data for targeted advertising on students for a non-educational purpose. To comply with SOPIPA, we will not use any California student resident’s data to conduct or assist targeted advertising directed at students or their families for any commercial purpose other than providing you GoFan Service. Please note, this does not prohibit us from using data to make product or service recommendations to high schools using GoFan Service.
2) Data Requests.
Under certain provisions of the California Civil Code, residents of California have the right to request from entities conducting business in California a list of all third parties to which such entities have disclosed certain Personally Identifiable Information, as defined under California law during the preceding year for third party direct marketing purposes. If you would like to make a request, you are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for Huddle’s response. You may request the information in writing at:
6445 Shiloh Road, Suite 200
Alpharetta, GA 30005
3) Notice for California Users.
Under California Civil Code Section 1789.3, you are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
I. YOUR NEW YORK PRIVACY RIGHTS
Pursuant to New York Education Law §2-d, high schools that use our services and that are subject to New York law must provide the parents of their students with a “Parent’s Bill of Rights”, and must cause their third party contractors to agree to honor the Parent’s Bill of Rights. Where requested by a school or school district subject to New York law that uses our services, we have signed such school or school district’s Parent’s Bill of Rights.
Last Updated September 1st, 2018