The Rightlu Inc. (Rightlu) is the national governing body of the sport of polo and we respect and take your privacy seriously. This Privacy Notice describes our privacy practices regarding the collection, use, and disclosure of your information through the Rightlu websites and other services we provide both online and offline (collectively referred to as “Services”), along with our marketing and advertising practices.
1. INFORMATION WE MAY COLLECT
We May Collect Personal Information
If you submit any personal information relating to yourself or others to us, our subsidiaries, or to any of our service providers, you represent that you have the authority to do so and to permit each of us to use submitted personal information in accordance with this Privacy Notice. Personal information includes, but is not limited to, such information as your name, address, billing information, account name or password, and email address. If payment is required for the Services you have selected, we will request credit card or other payment or billing information, which is also personal information.
The Rightlu, its subsidiaries and our service providers may collect personal information from a variety of sources, including:
From you: This includes personal information you elect to share with us such as your name, email address or contact information. For example, you may provide this information when you use Rightlu Services, when you attend a Righ tlusanctioned polo event or tournament, when you sign up for our newsletter, or sign-up for or renew your membership.
Through Third Parties’ Services: This includes personal information you provide when you use third party services that utilize or interface with the Rightlu Services. For example, when you use or access Rightlu Services through your mobile device.
Community or Public Forums and Third Party Links. Rightlu Services offers publicly accessible community services such as feeds, profiles, sharing and public links. You should be aware that any personal information or Content you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account and shared files cannot be un-shared or deleted. We may collect your personal information from such public databases, social media platforms or joint marketing partners. We may also receive your personal information from people with whom you are "friends" or otherwise connected on social media platforms. For example, if you elect to connect your social media account to your Rightlu Services account, certain personal information from your social media account will be shared with us, which may include personal information that is part of your social media profile or your friends’ profiles. The reverse is also true if your social media "friends" connect their social media account to their or your Rightlu Services account.
Non-Personal Information We May Collect
The Rightlu may also collect information which is not personally identifying (non-personal), such as gender, preferred language, age, occupation, household income, ZIP Code or country, or other information from your app, browser or device that does not reveal your (or anyone else's) real world identity, for example:
Browser and device information
App or device usage data
Information collected through cookies, pixel tags and similar technologies
IP address
Location data
Aggregated, anonymized, or de-identified information
Demographic information and other information (i.e., language, occupation, postal code)
2. Information Collection Methods
We and our third-party service providers may collect this information in a variety of ways, including:
Through your browser or device: Most browsers and devices collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, and the name and version of the Rightlu Services (such as the app) you are using. We use this information, for example, to make sure that the Rightlu Services function properly, analyze the performance of our products, and improve and maintain the Rightlu Services and products.
Through your use of a Rightlu app: When you download and use a Rightlu app, we and our service providers may track and collect usage data, such as the date and time the Rightlu app on your device accesses our servers and what information and files have been downloaded to the Rightlu app.
Through cookies and similar technologies: “Cookies” are small files that collect information to track trends and patterns of how people search. We may send one or more cookies to your computer that uniquely identifies your user account or computer. We use Cookies and Similar Technologies to ensure that we give our visitors the best possible experience by providing you personalized information, remembering your marketing and product preferences, and helping you obtain the right information. We use cookies for such functions as:
Verifying that you are one of our users;
Maintaining a history of services provided and enabling the fulfillment of our Services;
Help us and third parties obtain information about your visits to the Websites;
Process your orders;
Analyze your visiting patterns to improve our Websites;
Deliver advertising, communications, and content from us and third parties, on our Websites and those of third parties, specific to your interests;
Help you obtain information you are looking for;
Provide a safe and secure service for online transactions;
Measure how many people use our Websites, and how they use them, to keep our Websites running efficiently and to better understand our Websites’ audiences;
If you email us or contact us or register on one of our Websites, or otherwise provide us with your personal information, we may associate that information with other information we collect from or about you or that you provide, information regarding your use of our Websites, or information we receive from or about you from third parties. We will use this combined data for marketing and analytics purposes.
For example, this is how non-personal data collection may contribute to or be used to improve our Services and your experience:
Advertising Research - non-personally identifiable data, which includes web use and demographic information, may be shared anonymously with third parties so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions.
Media Use Analysis - non-personally identifiable data may be shared anonymously with clients so they can understand where consumers go online and how consumers interact with digital media which includes website content and advertising that is seen through web and mobile browsers.
Profile Building – third parties may use the data we have collected, either explicitly provided or collected from online behaviors, to obtain additional information from other public and private data sources. These third party data sources may provide information on the types of purchases relative to household and lifestyle information, and broader demographic details. We or third parties may then use the combined data to create non-personally identifiable profiles that are shared as consumer segments.
Addressable Marketing Segments - we may use non-personally identifiable data to identify certain consumer segments reachable with advertising.
If you would like more information and to know your choices about this practice, please visit: http://www.networkadvertising.org/managing/opt_out.asp.
IP Address: IP addresses are automatically transmitted as part of any Internet communication. For example, servers automatically record information that your browser sends and the Uniform Resource Locator ("URL") of the web page from which you came to us whenever you visit our websites. These server logs may include information such as your Internet Protocol ("IP") address, browser type, browser language, date and time of your request, search terms and may include a domain name and the date and time for each page you view. We may also collect the name of and information about any advertisement or other link that brought you to us. This information does not personally identify you. We use IP addresses to diagnose problems with our servers and to administer our websites. Your IP address may be used to gather broad demographic information, such as your general geographic location and internet service provider. IP addresses are further used to help determine the number of our users to maintain efficient administration of our Services. This demographic information may also be used by us to analyze aggregate usage behavior.
Location Data: We may collect the physical location of a connected device, for example, some devices, mobile or otherwise, allow applications to access real-time location-based information (for example, GPS). We may use your device’s physical location to provide you with personalized location-based Rightlu Services, content and advertising. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized Rightlu Services, content and advertising.
3. INFORMATION USE AND DISCLOSURE
How We May Use and Disclose Personal Information
We may use your personal information:
To respond to your inquiries and fulfill your requests, such as to send you Rightlu member club information or member benefits.
To send you marketing communications that we believe may be of interest to you, such as newsletters, in accordance with your communication preferences.
To personalize your experience on the Rightlu Services by presenting marketing messages, offers and content tailored to you.
To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain more information about how we use and disclose your personal information, so we suggest that you read these rules carefully.
To complete and fulfill your purchases, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, testing, enhancing, improving or modifying our Rightlu Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
To send administrative information to you, for example, information regarding the Rightlu Services and changes to our terms, conditions, and policies.
To, where necessary, share such personal information including, but not limited to, email addresses and other contact information with Rightlu Member Clubs, Rightlu Committees, Rightlu subsidiaries and Rightlu leadership, employees, agents and representatives involved in administering the Rightlu Services.
Personal information may be shared or disclosed to others
To our authorized third-party service providers and suppliers who provide services to us such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
To third party sponsors of sweepstakes, contests and similar promotions.
By you, on message boards, forums, chat, profile pages and blogs to which you are able to post information and materials. Please note that any such information you post or disclose will become public information, and may be available to users and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, online.
As we believe is required, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process and/or to respond to requests from competent public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and those of any of our affiliates; (f) to protect our rights, privacy, safety and physical and intellectual property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Legal or Governmental Compliance. We may share your personal information, IP address or content with legal or governmental authorities if we have a good faith belief that access, use, preservation or disclosure of such information or content is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce agreements or resolve disputes between you and us, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of our company, its users or the public as required or permitted by law. We will disclose any information or content we possess that is directly responsive to subpoenas, court orders, or other legal or governmental inquiries, and such information might be used by the receiving party to determine your identity.
To our affiliate entities and subsidiaries for the purposes described in this Privacy Notice.
How We May Use and Disclose Non-Personal Information
Please note that we may use and disclose non-personal information we collect through cookies in accordance with our Rightlu Cookies and Similar Technologies Section.
In some instances, we may combine other information with personal information (such as combining your name with your postal code). If we combine any other information with personal information, we will treat the combined information as personal information as long as it is combined.
4. THIRD-PARTY SERVICES AND LINKS TO THIRD PARTY WEBSITES
Our Website includes links to other third party websites whose privacy practices may differ from those of ours. We have no control over the policies, actions or omissions of third party websites and are not responsible or liable for any such policies, acts or omissions. If you submit personal information to any of those websites, your information is governed by the applicable third party privacy policies and not by our privacy policy. We urge you to carefully review the privacy policy of any website you link to, visit or share information with prior to doing so. Rightlu is not responsible for, the policies and practices of third parties or other organizations that are not Rightlu, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any website or service to which the Rightlu Services link – the inclusion of a link on the Rightlu Services does not imply endorsement of the linked website or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any personal information you disclose to other organizations through or in connection with the Rightlu Services or our Social Media Pages. For example, we may use and direct you to a third party payment service to process payments made through the Rightlu Services. If you wish to make a payment through the Rightlu Services, your personal information may be collected by such third party and not by us, and will be subject to the third-party’s privacy policy, rather than this Privacy Notice.
5. THIRD-PARTY ADVERTISERS
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Rightlu Services and other websites, based on information relating to your access to and use of the Rightlu Services and other websites. Please refer to our Rightlu Cookies and Similar Technologies Section on how we use cookies. Use of Remarketing with Google Analytics™. We may send and use cookies to enable basic web traffic analysis using Google Analytics™ to capture information about page visits (showing us which areas of the website are popular and those that are not often visited, this allows us to prioritize our enhancements to our website). This information is anonymous and we use this information only internally - to deliver the most effective content to our visitors. We use analytics data to serve ads based on a user's prior visits to our websites. Website visitors may opt out of the Google Analytics™ cookie by visiting the Google® advertising opt-out page or they may opt out of Google Analytics™ by visiting the Google Analytics™ opt-out page. Google® has additional information available about their Remarketing Privacy Guidelines, Policies, and Restrictions.
Mobile Advertising
We and third parties, including technology partners, and service providers engage in interest-based advertising to deliver advertisements and personalized content that we and other advertisers believe will be of interest to you. To the extent third party vendors are using Cookies to perform these services for Rightluor others, Rightlu does not control the use of this technology or the resulting information, and is not responsible for any actions or policies of such third parties.
Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA). You may also see advertisements for third parties on Rightlu Websites or other websites or properties, based on your visits to, and activities on, Rightlu Websites and other websites.
6. SECURITY OF YOUR INFORMATION
The security of your information and content is important to us. If we collect information online, we encrypt it while it’s being transferred to us. Once the information reaches our secure servers, as part of our security program, we employ procedures and safeguards, such as maintaining firewalls and having an intrusion detection system, to protect the confidentiality, security and integrity of the information we maintain. However, as with any information travelling over the Internet and kept in servers, we cannot guarantee absolute security. The Rightlu Services are designed to provide reasonable organizational, technical and administrative measures to protect personal information within our organization against unauthorized or unlawful access, alteration, disclosure or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section located on our Website.
7. USE OF RIGHTLU SERVICES BY MINORS
The Rightlu Services are not directed to individuals under the age of thirteen (13), or to minors as otherwise defined in Federal, State or local law or regulation (Minors), and do not knowingly collect personal information fromMinors. We request that Minors do not provide personal information through the Rightlu Services. d
To the extent that the Rightlu inadvertently gathers, obtains or is provided with personal information from a Minor, parents and legal guardians of the Minor are advised as follows:
The Rightlu will not require a Minor to disclose more information than is reasonably necessary to participate in a Rightlu activity;
A parent or legal guardian of the Minor may review their child/ward’s personal information, direct that it be deleted, and refuse to allow any further collection or use of the Minor’s information;
A parent or legal guardian can agree to the collection and use of their child/ward’s information, but still not allow disclosure to third parties unless that is part of the Rightlu Services.
Notwithstanding that it does not knowingly seek, nor obtain, personal information from Minors, the Rightlu endeavors to at all times adhere to and comply with the Children’s Online Privacy Protection Act. If you believe that we may have collected personal information from a Minor, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and, if appropriate, delete that information.
8.CHOICES AND OPT-OUT, UPDATING/DELETING/CORRECTING PERSONAL INFORMATION
We understand and respect that people have different privacy concerns. Our goal is to be clear about what information we collect and how it may be used, so that you can make meaningful choices about your personal information.
For example, you can:
Cancel your account at any time;
You can decline to submit requested information, however, it is important to understand that the Rightlu Services may not function properly or we may not be able to provide the requested service to you;
You can uninstall the Rightlu mobile app at any time and discontinue use of our Services;
Control what information you post in public profiles and who you share information with;
Set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our services may not function properly if your cookies are disabled. For example, we may not remember your language preferences.
If we propose to use personal information for any purposes other than those described in this Privacy Policy, we will offer you an effective way to opt out of the use of personal information for those other purposes. If your personally identifiable information changes (such as ZIP code, phone, email or postal address), or if you no longer desire the Rightlu Services, we provide a way to correct, update or delete/deactivate users' personally identifiable information. This can usually be done by contacting us in accordance with the “Contact Us” section located on our Website.
9. UPDATES TO THIS PRIVACY NOTICE
We may change this Privacy Notice. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Rightlu Websites. Your use of the Rightlu Services following these changes means that you accept the revised Privacy Notice. If any change materially affects the privacy of your personal information, we will use reasonable endeavors to notify you in advance and give you a reasonable period of time to object to any changes (which you may do by ceasing to use the Rightlu Services).
You understand and agree to periodically review this Privacy Notice to stay informed about how we collect, use and share personal information.