PRIVACY POLICY
LAST REVISION: DECEMBER 13, 2021
This Privacy Policy (“Privacy Policy”) becomes effective immediately for users of the Mobile Applications, as defined below. This Privacy Policy is applicable to all those who use or visit the Mobile Applications (“you”). The mobile application ‘SPORTEMON GO’, available on the Google Play Store and the Apple App Store, (the “Mobile Applications”) are owned and operated by Sportemon Go, the trading business of RJ & CO Marketing Ltd. (Herein referred to as “SPORTEMON GO”).
SPORTEMON GO is committed to respecting the privacy rights of all the visitors and users of the Mobile Applications. This Privacy Policy sets forth the personal and usage information that SPORTEMON GO will collect through the Mobile Applications, as well as how that information shall be used, maintained, and in some cases, shared with third parties. This Privacy Policy also sets forth how to contact SPORTEMON GO if you have any questions about the privacy of your information.
Please read this Privacy Policy carefully to understand SPORTEMON GO’s practices regarding your information and how SPORTEMON GO will treat it. By visiting or using the Mobile Applications, you acknowledge that you are expressly accepting and consenting to the practices and policies outlined in this Privacy Policy. If you object to this Privacy Policy after it becomes effective for you, you may no longer use the Mobile Application.
This Privacy Policy applies only to information that you provide to SPORTEMON GO while visiting or using the Mobile Application, and does not apply to any information that SPORTEMON GO has received, obtained or may obtain through third parties, offline or through other means, or any third parties that may obtain information about you from the Mobile Application. If you enter or choose to leave SPORTEMON GO’s Mobile Applications via links to other non-SPORTEMON GO websites or mobile applications, your visits and actions on those websites and apps are not covered by this Privacy Policy. If you are directed to SPORTEMON GO. website (“Website”), you will be bound by the Privacy Policy applicable to and provided on the Website.
We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the Mobile Applications. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies, you may visit https://support.apple.com/en-us/HT208108.
What information does SPORTEMON GO Collect about Users?
General Information Collected
To enhance the content contained on or in the Mobile Applications, SPORTEMON GO may gather and store certain general information about your visit. “General Information” is information about you or your activities through which you cannot be identified. This information may include some or all of the following items:
1. The Internet Protocol (“IP”) address of your Internet Service Provider (“ISP”) and/or your mobile device, if it has its own static IP address. Your IP location information may be used during your visit to the Mobile Applications to serve you location specific information or advertisements for goods or services available in your specific location, however, such information will not be collected or maintained by SPORTEMON GO except in aggregate or generic form;
2. The date, time, length of stay and specific SPORTEMON GO web pages, images, videos, documents or forms accessed by you on Mobile Applications;
3. Whether you are using the Mobile Applications for the first time or are a return visitor;
4. Demographic information concerning your country of origin and language(s) used;
5. Information regarding your device, including GPS location when you use the Mobile Applications and associated services from your mobile device if your device has location services enabled;
6. Information relating to identifier, device type, IP address, phone, browser type and version, time zone, browser plug-ins and versions, operating system and device platform and information regarding errors when using the Mobile Applications;
7. Pages you viewed or searched for, page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
SPORTEMON GO collects this General Information and may use it to generate generic or aggregate statistics about users of the Mobile Applications. In situations where it is possible to do so, General Information may be linked to Personal Information.
Personal Information Collected
“Personal Information” is information through which you can be identified. You can choose to not provide your Personal Information to SPORTEMON GO. SPORTEMON GO maintains one or more databases to store your Personal Information and may keep such information indefinitely.
To participate in the various services provided on the Mobile Applications, SPORTEMON GO asks for Personal Information, which may include your full name and email address. SPORTEMON GO also may collect other information such as city and/or state, and country, which SPORTEMON GO considers Personal Information only if combined with any of the items of Personal Information listed above. SPORTEMON GO uses the Personal Information collected in the following manner:
1. Social Media
The Mobile Applications include social media features, including links to share, post or link SPORTEMON GO’s content through your accounts with third party social media services. If you choose to interact with social media features on or from the Mobile Applications, or if you are logged in to your social media accounts while using the Mobile Applications, social media services may collect information about your use of the Mobile Applications. Information collected by third party social media services is governed by the privacy policies of those third parties, and not the privacy policy of SPORTEMON GO.
SPORTEMON GO may collect your social media username or ID, social media plug-in information, and URL clickstream to, through and from the Mobile Applications (including date and time). Information collected by social media sites may include names, titles or descriptions of videos or content viewed through your use of the Mobile Applications. Your use of the Mobile Applications and any third party social media services constitutes your agreement and consent to the collection and use of information about the videos and content you view through the Mobile Application.
2. Third Party Advertising
SPORTEMON GO may share information about your activity on the Mobile Applications with third parties for ad distribution and ad optimization (defined as the tailoring, targeting [i.e., behavioral, contextual], retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect information for such purposes. Pixel tags enable SPORTEMON GO and these third-party advertising companies to recognize a device’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, SPORTEMON GO may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data. These third parties may collect any of the types of information described in this Privacy Policy. SPORTEMON GO’s third-party partners may combine information collected about you through your use of the Mobile Applications with information they collect through other websites, applications or services you use. For more information on these third parties, including how to opt out from certain data collection, refer to their privacy policy and terms of use.
3. Third Party Analytics
SPORTEMON GO and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which SPORTEMON GO work use third-party analytics services (e.g., Google Firebase) to evaluate your use of the Mobile Applications, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Mobile Applications and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide SPORTEMON GO the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. These third parties may collect any of the types of information described in this Privacy Policy. SPORTEMON GO’s third-party partners may combine information collected about you through your use of Mobile Applications with information they collect through other websites, mobile applications or services you use.
4. Video Content
SPORTEMON GO may collect, use and share information about videos you view on the Mobile Applications with SPORTEMON GO’s third-party partners as described in this Privacy Policy. SPORTEMON GO may also collect information from third parties regarding videos you view on third party sites. You agree and consent to this sharing and collection for two years or until you affirmatively withdraw consent, whichever is later. You may also be able to control information shared with SPORTEMON GO through third parties, such as social media services, through your privacy settings on those services.
By associating your social media or other third-party website account with your use of the Mobile Applications and authorizing SPORTEMON GO to have access to this information, you consent to this collection, use, and disclosure of video and content viewing information to these social media services and websites in accordance with this Privacy Policy.
Does SPORTEMON GO Collect Any Information About Users Under Age 13?
SPORTEMON GO does not knowingly solicit or collect information from anyone under the age of 13, unless explicitly stated on a Mobile Application, and unless stated therein, all the Mobile Applications are directed at persons 13 years of age or older. If you are the parent or guardian of a child under the age of 13, or the legal age of contract majority in your jurisdiction, and have authorized your child to use a mobile device, SPORTEMON GO urges you to instruct your child never to give out his or her real name, address, phone number, email address, social media username or other personally identifying information while on the Mobile Application. There are no computer applications on the Mobile Applications which allow for the determination of your age. If SPORTEMON GO discovers that personal information of a child under 13 has been collected without parental or guardian consent, SPORTEMON GO will take reasonable steps to delete this information. All information volunteered to SPORTEMON GO will be treated the same as information given by an adult. SPORTEMON GO recommends that the Internet browsing behavior of any child should be carefully supervised by a responsible adult at all times.
How Does SPORTEMON GO Collect Information?
Your information is collected from SPORTEMON GO’s Mobile Applications, through email and/or through online applications or forms you complete, requests for newsletters, requests for SPORTEMON GO or Mobile Application information, entering a sweepstakes or prize promotions, taking surveys, reporting problems, information you volunteer to SPORTEMON GO, and through any of your other activities with SPORTEMON GO. The Personal Information that SPORTEMON GO collects depends on the nature of your activities. For example, SPORTEMON GO collects your information via the Profile section, Tickets or Shop of the Mobile Application.
How Does SPORTEMON GO Use the Information SPORTEMON GO Collects?
Personal Information you share is used by SPORTEMON GO for internal verification, to complete requested transactions, to ensure appropriate legal use of SPORTEMON GO’s goods and/or services, to provide you notification about updates to the Mobile Applications, goods and services and to help provide you with technical support for the Mobile Applications. For example, SPORTEMON GO uses the information it collects about you to:
1. Notify you of changes to the Mobile Applications or any of SPORTEMON GO’s agreements or policies, including this Privacy Policy;
2. Solicit your feedback about the Mobile Applications;
3. Communicate with you regarding messages you enter into the Contact form;
4. Deliver goods and services you request, purchase or subscribe for;
5. Enable SPORTEMON GO to provide, improve and maintain the Mobile Applications, including administration and internal operations such as data usage and analysis, research, testing, and troubleshooting;
6. Keep the Mobile Applications safe and secure;
7. Administer promotional programs;
8. Provide you, or permit selected third parties to provide you, with information and content, goods and services, that SPORTEMON GO feels may interest you, including internet-based or online advertisements, newsletters, brand or company promotions, re-targeted advertisements displayed on third party websites, and promotions, contests, and sweepstakes offered in partnership with third parties;
9. Measure or understand the effectiveness of advertising SPORTEMON GO and third party partners serve to you and others; and
10. Comply with administrative, regulatory and legal requirements.
We may anonymize personal information and share it in an aggregated form with third parties, advertisers and/or business partners in order to analyze the Mobile Applications, improve the Mobile Applications and user experience, or for other similar purposes. The use and disclosure of such anonymous information is not subject to any restrictions under this Privacy Policy.
How Does SPORTEMON GO Share Your Information with Third Parties?
We do not share your Personal Information with any third parties except as described in this Privacy Policy. SPORTEMON GO may share information about you, including your Personal Information, with third parties, including to:
1. Business partners, suppliers and subcontractors to the extent necessary to assist SPORTEMON GO in providing and maintaining the Mobile Applications. For example, SPORTEMON GO may hire companies to help provide products or services, like a shipping company that may deliver packages, a marketing company that may deliver SPORTEMON GO’s newsletters, a financial partner that assists in the completion of transactions you request, a prize may be provided by a third-party fulfillment company, or any other third party that is needed to assist in the completion of transactions or the provision of goods or services you request. Others include data processors, marketers, and customer service providers;
2. Service providers and business partners who supplement information SPORTEMON GO collects with additional information about visitors or users of the Mobile Applications and who help SPORTEMON GO better connect with SPORTEMON GO’s intended audience;
3. Analytics and search engine providers aid SPORTEMON GO in the improvement and optimization of the Mobile Applications;
4. Any of SPORTEMON GO’s parent companies, subsidiaries, joint ventures, or other companies under common control with SPORTEMON GO; and
5. To any other third party with your consent to do so.
SPORTEMON GO may also disclose your Personal Information:
1. In response to judicial or governmental subpoenas, warrants or orders served on SPORTEMON GO;
2. To protect SPORTEMON GO’s rights or property, to enforce the provisions of this Privacy Policy and/or any other SPORTEMON GO terms and conditions or agreements, and/or to prevent harm to yourself or to another;
3. In the event of a corporate sale, merger, re-organization, sale of assets, or dissolution of SPORTEMON GO; or
4. A petition for relief is filed under bankruptcy laws for or against SPORTEMON GO or if SPORTEMON GO becomes subject to an order of appointment of a trustee or receiver.
SPORTEMON GO reserves the right to release and/or use all information contained within SPORTEMON GO’s databases, access logs or other records concerning you, including your Personal Information, if you violate this Privacy Policy, the Terms of Use, and any SPORTEMON GO terms and conditions, or other rules, policies, notices, agreements or guidelines, or if you intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including but not limited to hacking, even without a warrant or other court order, and to release such information in response to court and governmental orders, discovery requests and as otherwise required by law and/or to initiate SPORTEMON GO’s own legal proceedings. SPORTEMON GO cooperates with law enforcement agencies in identifying those who may be using the Mobile Applications (or any part thereof) for illegal activities. SPORTEMON GO also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.
How Does SPORTEMON GO Share Information with Third-Party Internet-Based Advertising Companies?
SPORTEMON GO may share information about you, including your Personal Information, with third-party Internet-based advertising companies. This information is used to help such advertisers reach the kind of audience they want to target. This information is also used to assist such advertisers and advertising networks in selecting and serving relevant advertisements to you.
You may opt out of third-party interest-based advertising in the following manner:
Android Users
Open your Google Settings app from your app drawer, tap “Ads” and select “Opt out of interest-based ads.”
Google Account Users
For opting out via Google, regardless of device: See Google’s instructions for how to do click on the following – Google Ads Help.
iOS Users
Open the Settings app, select “Privacy,” scroll to the bottom and select “Advertising,” and tap to turn on “Limit Ad Tracking.”
What About Information Shared on Community Services?
SPORTEMON GO may make message boards, blogs, and other community services available to you on the Mobile Applications. Please understand that any information that is disclosed by you in these areas becomes public information. When you disclose such information on a message board, blog or any other public forum, you do so at your own risk. SPORTEMON GO has no control over its use and you should exercise caution when deciding to disclose your Personal Information or any other information about yourself. The information presented in these areas reflects the views of the individual users or hosts and does not necessarily reflect the views of SPORTEMON GO. SPORTEMON GO reserves the right (but has no obligation) to monitor the use of message boards, blogs or other public forums on the Mobile Applications.
Does SPORTEMON GO Use De-Identified Information?
SPORTEMON GO may take your Personal Information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon the right of SPORTEMON GO to aggregate or de-personalize your Personal Information, and SPORTEMON GO may use and/or share with third parties the resulting non-personally identifiable information in any manner in SPORTEMON GO’s sole discretion.
How Does SPORTEMON GO Maintain and Secure the Personal Information SPORTEMON GO Collects?
We make good faith efforts to provide you with access to your Personal Information and either to correct such data at your request if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. If you wish to request the correction or deletion of such data, you may contact SPORTEMON GO at [email protected]
Please note in order to protect the security of your information, you will be required to properly identify yourself before SPORTEMON GO can process such a request.
The security and confidentiality of your Personal Information is important to SPORTEMON GO and SPORTEMON GO will take reasonable measures to protect it, including measures to protect against unauthorized access, alteration, and disclosure. These security measures include, for example, internal reviews of SPORTEMON GO’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where SPORTEMON GO store personal data.
When the use of Mobile Applications involves the transmission of Personal Information, SPORTEMON GO may use Secure Socket Layer (“SSL”) technology to establish a secure connection between your mobile device and SPORTEMON GO and/or the Mobile Applications. SPORTEMON GO may also allow the transmission of encrypted information from your mobile device to SPORTEMON GO and back again.
SPORTEMON GO reserves the right to monitor all network traffic to the Mobile Applications to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to any of the Mobile Applications in any manner. Anyone using a Mobile Application expressly consents to such monitoring.
Please be aware that no data transmission over the Internet or which is stored on a computer connected to the Internet can be guaranteed to be 100% secure, so while SPORTEMON GO strives to protect your Personal Information, SPORTEMON GO cannot ensure or warrant the security of any information that you voluntarily give to us.
Information provided via TrueDepth API technologies is stored on the device only for the duration of creating AR effects within the Mobile Application. When the effect is rendered, the data is discarded.
Does SPORTEMON GO Use Cookies?
When you visit or use the Mobile Application, SPORTEMON GO may place a cookie in a file directory on your mobile device. A cookie is a small text file that is placed on your computer or mobile device to uniquely distinguish your visit to a website or use of an online service or mobile application. The information that cookies collect includes the date and time of your visit and your registration information. Cookies may offer you many conveniences for Mobile Applications and allow SPORTEMON GO to recognize certain information, such as your browser type, so SPORTEMON GO knows if you can view certain plug-ins or extensions. They also allow SPORTEMON GO to streamline your visit to the Mobile Applications based on your previous visits.
Cookies may be either permanent or temporary. SPORTEMON GO may use both temporary and permanent cookies. A temporary or “session” cookie is placed on your computer or mobile device during your use of a Mobile Application is deleted when you exit the Mobile Application and/or turn off your mobile device. A permanent or “persistent” cookie means that the cookie stays on your mobile device until you delete it. You can delete SPORTEMON GO’s permanent cookie at any time by contacting the company providing your mobile device’s technical support. SPORTEMON GO does not use cookies to store information such as credit card numbers, social security numbers or any other highly sensitive Personal Information.
You may also be able to reset or restrict the advertising cookies contained on your mobile device by accessing the privacy settings for such mobile devices. Please follow the instructions by contacting the company providing your mobile device’s technical support to do so, such as Apple for iOS devices.
You may configure your browser or device to accept or deny cookies from the Mobile Applications. However, disabling or denying cookies from the Mobile Applications may render parts of them inaccessible or may cause certain parts of the Mobile Application not to properly load. There are also several services and websites which allow you to use Mobile Applications anonymously. Again, you may not be able to access or use all of the content or services available on the Mobile Applications if you use these anonymizing services or websites. If you change mobile devices or use multiple mobile devices or delete SPORTEMON GO’s cookies, you will need to repeat this process for each mobile device.
Does SPORTEMON GO Use Web Beacons/Pixel Tags?
SPORTEMON GO may use “Web Beacons,” sometimes referred to as “pixels,” “clear gifs,” or “web bugs,” which is another way (instead of cookies) to help personalize your experience on the Mobile Applications. Web Beacons are typically invisible to you and are generally embedded in very small clear graphics files. “Pixel Tags” are small strings of computer code that provide a method for delivering a graphic image on a web page or other medium. Pixel Tags allow SPORTEMON GO or a third party who serves the Pixel Tag, to set, read, and modify some of SPORTEMON GO’s cookies.
SPORTEMON GO may use Web Beacons and Pixel Tags to monitor certain non-personally identifiable information about you, including the URL of the page from which the Web Beacon or Pixel Tag originated, the type of browser used, the IP address of your mobile device and the time you viewed the Web Beacon or Pixel Tag. SPORTEMON GO may also use Web Beacons and Pixel Tags to assist SPORTEMON GO’s third-party advertising and/or content companies in providing the content they believe you want to see. Web Beacons and Pixel Tags are also used to allow such third parties to determine how many people view the advertisements and/or click through, and to assist in serving and managing advertisements and content. While Web Beacons and Pixel Tags do not collect Personal Information, the information collected by them may be used in conjunction with Cookies to identify aggregate information about users of the Mobile Applications.
Links or Usage of Third-Party Websites/App Stores
The Mobile Applications may contain links to third-party websites. SPORTEMON GO has no control over the privacy practices or the content of such third-party websites. Neither SPORTEMON GO, nor any of its officers, directors, partners, employees, agents, representatives, vendors or suppliers are responsible for the content, privacy policies, products, services, reliability, viewpoint or accuracy of information on any such websites. SPORTEMON GO does not control and is not responsible for the collection of personal information by third party websites, including websites owned or controlled by SPORTEMON GO’s preferred financial partners, advertisers, vendors and/or websites not controlled by SPORTEMON GO.
The app stores (App Store or Google Play) may collect certain information in connection with your use of the Mobile Application, including Personal Information, geo-locational information, payment information, and other usage-based data. SPORTEMON GO has no control over the collection of such information by any third-party app store, and any such collection or use will be subject to such third-party app store’s applicable privacy policy.
Governing Law/Jurisdiction
The Mobile Applications are controlled and operated from SPORTEMON GO’s offices in London, England. All disputes are governed by the terms set forth in SPORTEMON GO’s Terms of Use.
If you are accessing Mobile Applications from any location with regulations or laws governing personal data collection, use or disclosure from the USA laws or regulations, please note that through your continued use of the Mobile Applications, which is governed by the laws of USA and this Privacy Policy, you are transferring Personal Information to USA and you consent to that collection, transfer to and any associated processing, usage and storage.
Opt-Out of SPORTEMON GO Communications
You may choose to opt-out of receiving electronic communications from us. To opt-out of electronic communications from SPORTEMON GO, please contact SPORTEMON GO at [email protected] to request that you be unsubscribed from any of SPORTEMON GO’s marketing emails. You should provide your name and email address(es) to us, so that SPORTEMON GO can do its best to ensure that you stop receiving such communications from us.
Changes to this Privacy Policy
SPORTEMON GO reserves the right to make changes to any terms of this Privacy Policy at any time, however, SPORTEMON GO shall provide notification to you in advance of any changes becoming effective, such as by posting a notification on the Mobile Applications or via email if you have provided SPORTEMON GO with your email address. If you continue to access and/or use any of the Mobile Application after the effective date of such changes, then such access and/or use will be deemed an acceptance of and an agreement to follow and be bound by the terms as changed. The revised Privacy Policy supersedes all previous notices or statements regarding the Mobile Applications. For this reason, SPORTEMON GO encourages you to review this Privacy Policy any time you access or use the Mobile Applications, and SPORTEMON GO recommends that you print out a copy for your records.