Privacy Policy - Cowboys Fit

Last Edited: May 17, 2023

Football Fit, LLC; Football Fit Plano, LLC; Football Fit Discovery, LLC; Football Fit Pflugerville, LLC; and Football Fit East Dallas, LLC (collectively, “Cowboys Fit,” “we,” “our,” “us”) respect your privacy and value your trust and confidence. This privacy notice (the “Privacy Notice”) applies to our websites, mobile applications, and other offline or online and mobile services that link to or post this Privacy Notice (collectively, the “Services”), and explains how we collect, use, and disclose information through the Services.

It is our policy to comply with applicable privacy laws, and so our privacy practices may vary depending on where you live. Please see the region-specific disclosures and applicable supplemental notices for more information relevant to data collected in certain regions and by individual member clubs. By using the Services, you acknowledge that you have read and understood the terms of this Privacy Notice. Please note that this Privacy Notice does not apply to information collected in employment or job applicant contexts. Likewise, this Privacy Notice does not apply to products and services that link to a separate privacy notice instead of this Privacy Notice.

Please also note that in some instances, we may direct you to a site or page that is operated by one of our partners or use framing techniques to serve you content from partners while preserving the look and feel of our website. Even though the page where you provide information may have the look and feel of the Services, a different privacy policy may govern that information collection by such partners.

Table of Contents

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1. Information Collection

Information Provided by You

We may collect some or all of the following types of information, some of which may be considered sensitive information, including when you register with us, use our Services, sign up for contests or sweepstakes, participate in surveys, create a profile, access various content or features, submit comments or content, use a send-to-a-friend feature, attend events, or directly contact us with questions or feedback:

Identifiers, such as contact information, such as name, email address, postal address, telephone number, and date of birth;
Other unique identifiers, such as a username or password, and, where appropriate, other identifiers such as Social Security Numbers and government-issued identifiers. For example, we may need to collect these identifiers to award you certain types of prizes under relevant laws;
Demographic information, which may include gender, race, ethnicity, and sexual orientation, and other protected classifications under relevant state or federal law;
Financial and commercial information, such as credit card or other payment information and records of products or services purchased;
Real-time geolocation information, which may include precise geolocation information;
Communications and marketing preferences;
Inferences about you and your personal preferences;
Audio, electronic, or visual information, such as photographs that you provide to us;
Biometric information, such as when you elect to use biometric authentication at check-in that offer this functionality for entry or other relevant functionality. Where required by law, we collect this information pursuant to your consent and may provide additional notice about relevant data handling practices;
Information about your contacts, such as name and email address, when you share that information with us. If you authorize us to access your contacts, calendar, or photos, we may also collect that information to provide you with relevant functionality;
Search queries;
Comments and other information posted in our interactive online forums;
Professional and employment information;
Education information;
Information that could be considered health information;
Correspondence, waivers or acceptances and other information that you send to us; and
Additional information as otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

If you decide not to provide this information, it may limit our ability to provide the Services or some of our content.

Information We Collect Automatically

We also may collect internet and electronic network activity information, device identifiers, and information about your use of the Services automatically when you visit or use the Services, including:

Your Internet Protocol (“IP”) address, which is the number automatically assigned to your computer or mobile device whenever you access the Internet and that can sometimes be used to derive your general geographic area;
Your Media Access Control (“MAC”) address, which is a unique identifier assigned to a network interface controller;
Your device type or mobile carrier;
Other unique identifiers, including mobile device identification numbers and advertising identifiers (e.g., IDFA);
Your browser type and operating system;
Sites and apps you visited before and after visiting, or while using, the Services;
Pages you view and links you click on within the Services;
Information collected through cookies, web beacons, Local Shared Objects, and other technologies, as described further below;
Information about your interactions with email messages, such as the links clicked on and whether the messages were received, opened, or forwarded;
If you link your social media account to your profile, information from those social media accounts in accordance with your settings on the social platform and their privacy policy;
App usage information, including how often you use our application, the events that occur within the application, usage, and performance data, and where the application was downloaded from;
Other Standard Server Log Information;
Standard Network Traffic Information, when you are connected to a gym’s Wi-Fi network; and
We may also collect audio, electronic, or visual information from you automatically, such as information collected from CCTV cameras and when we film or photograph you in a public location.
In addition, when you connect to our wireless internet service, depending on your mobile device, mobile network operator, and preferences, our sponsors and business partners may automatically collect your personal information to provide you their services. We do not control the services our sponsors and business partners provide you. You may choose not to accept services from our sponsors and business partners by adjusting the settings on your mobile device.

Information We Collect from Other Sources

In addition to information we receive from you and collect automatically, we may receive information about you from other sources, such as your friends, social networks, publicly available sources, data brokers, advertising partners, and our business partners and sponsors, including to facilitate co-branded programs. We may combine this data with information we already have about you, including to create inferences about you and your personal preferences.

2. Use of Information

We may use information that we collect about you for a variety of purposes, including to:

Provide you with products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you, including, where relevant, to facilitate your purchases (e.g., to process returns or streamline the checkout process);
Contact you about your account or relationship with us;
Conduct analysis on your behavior in order to customize and personalize your use of the Services and to better serve you with offers and content that we think may be of interest to you, such as by providing you with tailored advertising both on and off the Services. For more information on how we use cookies and similar technologies for advertising, please see Cookies and Similar Technologies;
Communicate with you about products, services, contests, and events that we think might be of interest to you, and otherwise send you promotional material or special offers on our behalf or on behalf of our marketing partners, their respective affiliates or subsidiaries, and other third parties. We will obtain your consent to send such communications to the extent required by law;
Maintain or administer the Services (e.g., to maintain the security and integrity of the Services), perform business analyses, create aggregated or anonymized information that no longer identifies you and therefore is no longer subject to this Privacy Notice, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer, such as internal administrative purposes or to manage our relationships;
Publish stories, comments, photos, and other information posted in our interactive online features;
In the case of location information, for example, to determine your market location, to validate your location to geo-gate certain features or information, to locate a place that you may be searching for in your area, for determining teams and offers in which you may have an interest and providing you with information or relevant advertising based on where you are located;
In the case of Social Security Numbers, for example, for tax purposes when administering prizes to certain contest winners;
Protect the health and safety of our members, guests, personnel, and the public;
Protect or enforce the legal and contractual rights, safety, and security of the gyms, enforce applicable agreements with you or others, and prevent fraud; and
As otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

If you choose to use our referral service to tell a friend about memberships, guest passes and/or offers, we will ask for your friend’s name, phone number, and email address, to send your friend information about us.

3. Disclosure of Information

We may disclose each of the categories of personal information described above with others for the purposes described above, including as follows:

Authorized Third Parties and Service Providers: We may disclose your information to third-party vendors and service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us).
Within the NFL Family: We may disclose your information to the Dallas Cowboys. The Dallas Cowboys may disclose your information to other companies that may be subject to separate privacy policies, including so that they may directly offer you products, services, contest, and events that may be of interest to you and send you promotional material or offers that may be of interest to you.
Select Business Partners: We may disclose your information to select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, we may disclose your information to our co-brand partners when you choose to be involved in those programs, such as when you enter contests or sweepstakes that are conducted with those business partners. We are not responsible for the privacy practices of our business partners, and we urge you to review their privacy notices for more detail on how they might process your information and for information about how to exercise your marketing and other choices with such partners.
Third-Party Advertising and Audience and Traffic Measurement Services: We use third party advertising, analytics, and measurement partners to serve you advertisements on the Services as well as across other sites and services. These third parties may set their own cookies or similar web technologies on the Services and elsewhere online to collect information about users’ online activities over time and across different websites. In some cases, the use of these third-party solutions involves the sharing of your information for purposes of serving you targeted advertising (as defined below). We may also disclose non cookie-based information for advertising purposes, including for targeted advertising. For example, we may disclose information to social networking platforms, so that they may send tailored communications on our behalf via their platforms.

For more information about cookies and similar technologies on our Services, please see Cookies and Similar Technologies. For information about the opt-out methods and choices available to you related to targeted advertising, please see Your Other Choices.

Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction.
Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of Cowboys Fit, our corporate affiliates, subsidiaries, business partners, and the users of our Services; enforce our terms of use and other agreements; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
Other Parties With Your Consent: We may disclose information to third parties or the public when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.
Aggregate Information: We may disclose aggregate information, such as demographics and usage statistics, to advertisers, sponsors, or other organizations.
Geolocation Information: We may disclose your geolocation information to service providers that perform certain functions or services on our behalf. We also may disclose your geolocation information to third parties so that they may provide you with geographically relevant advertising. If you wish to stop the further collection of your geolocation information, please opt-out using your device settings.

Please also note that if you choose to engage in public activities on the Services, such as through interactive features like a chat room, forum, blog, or other community tool, you should be aware that the information you share there will be publicly available and can be read, collected, or used by other users of these features. You may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.

4. Cookies and Similar Technologies

We and others use cookies and similar technologies such as beacons, tags, HTML5 local storage, and scripts, to collect information from your browser or device. By using the Services, you acknowledge the use of cookies and similar technologies on the Services, subject to the cookie-related choices we make available to you and, where required by law, your additional consent.

The following types of cookies are used on our Services:

Strictly necessary cookies: These cookies are necessary for the Services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for Services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Services will not then work.
Functional cookies: These cookies enable the Services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you disable these cookies then some or all of these services may not function properly.
Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around the Services. If you disable these cookies we will not know when you have visited our Services, and will not be able to monitor its performance.
Targeting cookies: We partner with third party advertisers to serve and display advertising on the Services and elsewhere online across different sites and services. These partners may use cookies and other tracking technologies to collect information about your activities across different websites and services to build a profile of your interests and provide you with relevant advertising (“targeted advertising”). This is typically done based on uniquely identifying your browser and internet device. If you disable these cookies, you will experience less targeted advertising.

To disable optional cookies, please utilize the Cookie Settings of the applicable website. Additional choices, including with respect to targeted advertising, are described below under Your Other Choices.

You also may be able to reject cookies and similar technologies through your browser settings. If you reject cookies through your browser settings, you may still use our Services, but your ability to use certain features may be limited.

5. Social Networking

We work with certain third-party social media providers to offer you their social networking services through our Services. For example, you can use third-party social networking services to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. Your interactions with those social networking services are governed by the privacy policy of the company providing the relevant service.

You also may be able to link an account from a social networking service (e.g., Facebook, Twitter, or Snapchat) to an account through our Services. This may allow you to use your credentials from the other site or service to sign into certain features on our Services. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Privacy Notice.

6. Links to Other Websites

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under our control or maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Notice does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

7. Data Security and Data Integrity

The security and confidentiality of your personal information is very important to us. We have implemented technical and organizational safeguards designed to appropriately protect your personal information against accidental, unauthorized, or unlawful access, use, loss, destruction, or damage. Still, no system can be guaranteed to be 100% secure.

As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

8. Data Transfers

When we transfer your personal information to third parties as described in this Privacy Notice, some of these parties may be located in countries other than your own, such as the United States, whose privacy and data protection laws may not be equivalent to those in your country of residence. When we transfer your personal information to other countries, we apply appropriate safeguards, to protect your information in accordance with applicable laws. If you would like to know more about the processing of your personal information and whether your personal information is transferred to a third country, please contact us using any of the methods described in Contact Us.

9. Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain personal information, even after your account has been deleted and/or we no longer provide the Services to you; for example:

To comply with legal provisions on tax and accounting: We may retain your personal information as required by tax law and to comply with bookkeeping requirements.
To pursue or defend a legal action: We may retain relevant personal information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your personal information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.

In some circumstances we will anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Children's Privacy

We do not knowingly collect personal information from children as defined by local law. If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

11. Communications and Geolocation Preferences

You may choose to receive promotional emails, text messages, newsletters, push notifications, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial emails you receive. You may opt out of receiving marketing text messages from us by replying “STOP.” You may also opt out of receiving push notifications by turning off push notifications through your device settings.

If you have multiple accounts or relationships with different gyms, you may need to opt out separately for each account and relationship in relation to these choices. In addition, if you would like to opt out of receiving push notifications on all of your devices, you must turn off the feature on each device.

Please note that opt-out requests may take some time to be effective where permitted by applicable law. Your opt-out requests will not apply to messages that you request or that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.

You may also have choices available to you to opt out of the collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology. Where collected, this information may be used in accordance with local laws to serve and display advertising relevant to your location. To understand your choices and opt out if desired, please visit your device settings.

12. Your Other Choices

You may have additional choices depending on where you live.

In some jurisdictions, you may have the right to opt out of the sale of your personal information and the sharing or processing of personal information for targeted advertising purposes.

If you wish to opt out of the sale or sharing for targeted advertising of online data through the use of cookies and similar technologies, please utilize the Cookie Settings of the applicable website. Our websites also support the Global Privacy Control (“GPC”), which is a browser-based opt-out preference signal that can communicate your opt-out to the websites you visit. For more information on how the GPC works, visit their website here. Because the GPC is browser-based, note that your choices will be tied to online data that is associated with your browser, and you should enable the signal separately for each browser and/or device from which you would like to be opted out.

Note that we do not knowingly sell or share the personal information of consumers under 16 years of age.

You may also have additional choices available to you, such as certain vendor-specific choices, including:

You can opt out of receiving some types of ads by managing your preferences at https://optout.aboutads.info/.
Certain of our Services may feature Nielsen proprietary measurement software, which will allow users to contribute to market research, such as Nielsen TV Ratings. Nielsen believes that you should have a choice about whether to contribute to our research and insights. To learn more about Nielsen measurement and your choices, including how to opt out, please visit http://www.nielsen.com/digitalprivacy.
We may participate in the Adobe Marketing Cloud Device Co-op to better understand how you use our website and apps across the various devices you use, and to deliver tailored promotions. Learn more about how Adobe does this at https://cross-device-privacy.adobe.com.

Do-Not-Track Signals: Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

13. Data Subject Rights

You may be afforded, in accordance with applicable law, the following rights:

To access the information that we have collected about you in a portable and (if technically feasible) readily usable form, including the categories and specific pieces of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting, selling, or sharing the information, and the categories of third parties with which the information was shared.
To delete the personal information we have collected about you.
To correct inaccurate personal information we have collected about you.
To object to or request the restriction of processing of your personal information.
To withdraw your consent.

To exercise your access, deletion, and correction rights, please submit your request by emailing [email protected]. California residents may also exercise their rights under applicable law by calling 1-855-265-6894. If you would like to object to, or request the restriction of, processing of your personal information, withdraw your consent, you can contact us at 972-437-5000. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

We reserve the right to deny requests as allowed by applicable law, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your information consistent with applicable law. You can, however, appeal those requests that we deny by email at [email protected] or by regular mail at: Cowboys Fit, 5 Cowboys Way, Frisco, TX 75034.

You may also be afforded, in accordance with applicable law, the right to limit certain uses and disclosures of sensitive personal information. Please note that we may still maintain, use, and disclose your sensitive personal information for certain purposes, such as to provide you with services that you have requested, protect the safety and security of services, and comply with our legal obligations.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you.

14. Changes To This Privacy Notice

We may update this Privacy Notice, including any supplemental privacy disclosures, to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

15. Contact Us

If you have any questions about this Privacy Notice or the privacy practices of the Services, please contact us by submitting an inquiry to [email protected] or at the following address:

Cowboys Fit

Attn: Website Privacy Notice

5 Cowboys Way

Frisco, TX 75034

16. California Users

This section provides additional information with respect to personal information that is subject to the California Consumer Privacy Act (“CCPA”). This section should be read together with the rest of our Privacy Notice, which includes other important information about our handling of your personal information.

Some of the practices described may not be relevant to you, since the ways we collect, use, and disclose personal information vary based on our relationship with an individual. For information about our retention practices, please click here.

As described further in the Information We Collect section above, the categories of personal information we collect, and have collected in the prior 12 months, include:

Identifiers;
Other unique identifiers, such as where appropriate, Social Security Numbers and government-issued identifiers;
Demographic information, which may include gender, race, ethnicity, and sexual orientation, and other protected classifications;
Financial and commercial information;
Real-time geolocation information, which may include precise geolocation information; communications and marketing preferences;
Inferences about you and your personal preferences; audio, electronic, or visual information;
Biometric information;
Information about your contacts and other information from your device;
Search queries;
Comments and other information posted in our interactive online forums;
Professional and employment information;
Education information;
Information that could be considered health information;
Correspondence, waivers or acceptances and other information that you send to us;
Internet and electronic network activity information, device identifiers, and information about your use of the Services when you visit or use the Services; and
Additional information as otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

As described further in the Use of Information section, we process, and have processed over the prior 12 months, personal information for the following business purposes:

Provide you with products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
Contact you about your account or relationship with us;
Conduct analysis on your behavior in order to customize and personalize your use of the Services and to better serve you with offers and content that we think may be of interest to you;
Communicate with you and otherwise send you promotional material or special offers on our behalf or on behalf of our marketing partners, their respective affiliates or subsidiaries, and other third parties;
Maintain or administer the Services, perform business analyses, create aggregated or anonymized information that no longer identifies you and therefore is no longer subject to this Privacy Notice, or for other internal purposes;
Publish stories, comments, photos, and other information posted in our interactive online features;
In the case of location information, for example, to determine your market location, to validate your location to geo-gate certain features or information, to locate a place that you may be searching for in your area, and for determining teams and offers in which you may have an interest and providing you with information or relevant advertising based on where you are located;
In the case of Social Security Numbers, for example, for tax purposes when administering prizes to certain contest winners;
Protect the health and safety of our guests, personnel, and the public; protect or enforce the legal and contractual rights, safety, and security of the gyms, enforce applicable agreements with you or others, and prevent fraud; and
As otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

Depending on the nature of your relationship with us, and as described further in the Disclosure of Information section, we disclose, and have disclosed over the prior 12 months, each category of personal information to the following:

Authorized third parties and service providers;
Select business partners;
Third-party advertising and audience and traffic measurement services; and
Other partners, including as part of a business transfer; for administrative or legal process; or with your consent.

Please review the Your Other Choices section for more information about the circumstances in which we sell or share personal information, such as internet and electronic network activity information, device identifiers, and other information about your use of the Services we collect automatically when you visit or use the Services, and to exercise your rights to opt out.

If you are a California resident and your personal information is subject to CCPA, then you have certain rights under California law. For more information about the rights you have and how to exercise these rights, please review the Data Subject Rights section above.

Shine the Light: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

To make such a request, or if you have questions as to how your information is handled in compliance with CCPA, please contact us at [email protected] or write us at CA Privacy Rights, Cowboys Fit, 5 Cowboys Way, Frisco, TX 75034.

17. International Users

This section of the Privacy Notice is supplemental and provides disclosures in addition to those made elsewhere in this Privacy Notice. This supplemental section applies only if you use our website or Services otherwise covered by this Privacy Notice from a country that is not the United States, and where we are subject to jurisdiction-specific laws.

Legal Basis for Data Processing: We process personal information for the specific purposes set out in this Privacy Notice, as described above. Where such concept is recognized, our legal basis to process personal information includes:

Necessary for the entry into or performance of a contract: When you enter into a transaction with us, we will need to collect, process, and share your personal information. Failure to provide the requisite personal information when entering into such an agreement, objecting to this type of processing, and/or exercising your deletion rights may mean that products and/or services cannot be provided to you.

Legitimate interest: In certain circumstances we may use your personal information to pursue legitimate interests of our own, but this is provided your interests and fundamental rights do not override those interests. This is on the basis of our legitimate interest to:
- provide you with information and services as requested by you on a non-contractual basis;
- develop and improve our services to you and to our other customers;
- communicate with you and manage our relationship with you;
- administer our websites and applications;
- carry out management analysis, audit, forecasts, business planning, and transactions;
- ensure our compliance with applicable laws, regulatory requirements, and our policies; and
- deal with legal claims and related administrative activities.

We consider that it is reasonable for us to process your personal information for achieving our legitimate interests, as outlined above, as:

- We process your personal information only so far as is necessary to achieve the purpose outlined in this Privacy Notice; and
- The processing of your personal information does not unreasonably intrude on your privacy and ultimately benefits you in optimizing our provision of services to you.

Consent: We may, on occasion and where permitted by law, process your personal information based on your consent. For example, we may process sensitive categories of information or send you marketing messages by email with your consent. You may opt out of receiving certain marketing messages by exercising the choices described in Communications and Geolocation Preferences. To the extent our processing is based on consent, you can withdraw your consent at any time. However, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Compliance with legal obligations: To meet our regulatory and legal obligations, we may need to process some of your personal information.

In some instances, you may be required to provide us with personal information for processing, as described above, in order for us to be able to provide you all of our Services and for you to use all the features of our website.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with your local supervisory authority if you consider that our processing of your personal information infringes applicable law.

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Notice, the English language version will prevail.

Your Rights: If you would like to request to access, correct, update, suppress, restrict, or delete personal information, object to or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive a copy of your personal information for purposes of transmitting it to another organization (to the extent these rights are provided to you by applicable law), you may submit your request by emailing [email protected]. We will respond to your request consistent with applicable law.

18. Kids Club

Our website is a general audience website. However, we do collect information about children under 13 from parents so they may sign their child up for our kids club (the “Kids Club”). The information we collect may include your child’s name, date of birth, grade, and the address provided by a parent, guardian or purchaser of Kids Club memberships. We use this information to allow you to sign your child up for the Kids Club. If you no longer wish to allow your child to be part of the Kids Club or wish to delete all information collected about your child, please contact us at [email protected]. If you feel we have collected personal information from your child directly, please contact us at [email protected] to request immediate deletion of that information.