At UBETSMART, we want you to know that we respect your privacy, the privacy of our Users. This document provides information regarding our policy as it relates to the collection, use and disclosure of personal information. It also outlines our customer's rights to limit the collection use or disclosure of personal information. Personal information may include your name, email, mailing and/or business address, phone numbers, or other information that identifies you personally. We at UBETSMART hold this personal information seriously and we maintain this information in the strictest of confidence. We do not sell any information to any third party. We also maintain a secured web site on all pages that require you to provide any personal information. This policy applies to users of UBETSMART services anywhere in the world.
The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region.
1. Definition of Personal Information
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated user information.
- Other information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
2. California "Shine the Light" Law/Your California Privacy Rights
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties' direct marketing purposes. Our disclosure requirements apply only if we share our users’ personal information with third parties for them to directly market their own products to those users, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.
3. What personal information do we collect?
We may have collected Personal Information in the following categories from users within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about users. We will update this disclosure from time to time as appropriate.
|A. Identifiers.||A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|F. Internet or other similar network activity.||Browsing history, search history, information on a user's interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||ducation records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
UBETSMART collects information on the Site at two different stages. First, we collect anonymous aggregate information (such as a domain name or IP address) from all visitors to the Site. This type of information if never linked to any personally identifiable information and is only used in the aggregate to general statistical reports about the use of the Site.
Second, we require the submission of certain personally identifiable information when you use the services available for the site. We collect information from you when you register on our site, place an order or fill out a form. When ordering or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, phone number, credit card information, banking information or social security number. You may, however, visit our site anonymously.
4. Sources of Personal Information.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, during account registration from forms you complete, subscriptions you purchase or comments you provide on our Websites.
- Indirectly from you. For example, from observing your actions on our Website.
- From third parties. For example, third party social networking providers and advertising companies, our affiliates and service providers who provide services or information to us. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to our Websites.
- From publicly available sources. For example, online database searches.
5. Use and Disclosure ("Sale") of Personal Information
We may have "sold" (as that term is defined in the CCPA) Personal Information in the following categories from users within the last twelve (12) months. Please note that the CCPA uses an expanded definition of the term, in which "sell" means:
"Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a user's personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a user's personal information with a third party, whether for valuable consideration or for no consideration, for the third party's commercial purposes."
When we disclose that we may have sold Personal Information, it means that we may have received some kind of benefit to our UBetSmart in return for sharing Personal Information, but not necessarily received any money in exchange.
The categories below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact "sold" but reflects our good faith belief to the best of our knowledge that some of that information may have been shared for value in return. We will update this disclosure from time to time as appropriate.
- Personal information categories listed in the California Customer Records statute.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
- Non-public education information
- Inferences drawn from other personal information.
6. Use of Personal Information for Business Purposes or Commercial Purposes.
We may use or disclose Personal Information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.
(a) Auditing Interactions with Users. For example: monitoring traffic to our Websites, counting ad impressions, and auditing legal and regulatory compliance.
(b) Security. For example, maintaining the safety, security, and integrity of our Website, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.