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National Women’s Soccer League, LLC
PRIVACY POLICY
Effective Date: February 1, 2021
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The Chicago Red Stars (“CRS”) is committed to respecting the privacy rights of all of the visitors and users of the websites and apps operated by or on behalf of CRS, including any websites on or apps in which this Privacy Policy appears and all www.chicagoredstars.com URLs (collectively, the “Sites”), and any other service that displays or provides an authorized link or reference to this Privacy Policy (the “Services”). This Privacy Policy sets forth what personal and usage information CRS collects through the Sites and in connection with the Services, as well as how that information is used, maintained, and in some cases, shared with third parties. This Privacy Policy also sets forth how to contact CRS if you have any questions about privacy of your information.

 

Please read this Privacy Policy carefully. This Privacy Policy is meant to help you understand our practices regarding the collection, use, and disclosure of personal information in connection with the Sites and Services as well as inform you of your rights and choices about the use of your information. We will not use, disclose, or share your information except as described in this Privacy Policy.

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Please remember that by visiting the Sites or using any of the Services you acknowledge that you are expressly accepting and consenting to the practices and policies outlined in this Privacy Policy. If you provide Personal Information (as defined below), you also agree that that information may be transferred from your current location to the offices and servers of CRS and its authorized third parties. If you do not agree with this Privacy Policy, please do not use the Sites or any Service.

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This Privacy Policy applies only to information that you provide to CRS while visiting or using the Sites or Services, and does not apply to any information that CRS has received, obtained or may obtain through third parties, offline or through other means, or any third parties which may obtain information about you from the Sites and Services. If you enter or choose to leave the Sites via links to other non-CRS websites or apps, your visits and actions on those websites and apps are not covered by this Privacy Policy.

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1. Types of Information We Collect

When you interact with us through the Services, we collect the information you provide, usage information, and information about your device. We also collect information about you from other sources like service providers, and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:

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(A) Personal Information
“Personal Information” is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. We may collect Personal Information from you on or through the Services in a variety of ways, including when you register on the Sites, purchase a Service, participate in online contests, surveys, or games, sign-up for a newsletter or subscription, or purchase merchandise. We also may, from time to time, receive Personal Information about you from third-party sources to improve the Services, and for the various purposes outlined in this Privacy Policy.

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We have grouped together the following categories of Personal Information to explain how we use this type of information. These terms are used throughout this Privacy Policy:

  1. Personal Identifiers, including your first and last name, birthdate, age, gender, username, and social security number.

  2. Contact Information, including your email address, phone number, and home address.

  3. Biographical Information, including your level of education and professional background.

  4. Financial Information, including your credit card number and purchasing history.

 

(B) Device Identifiable Information
We may collect information that may not reasonably identify you or a household personally, but is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the Services. When you visit our Sites to browse, read, or download information, we automatically collect information about your computer that your browser sends, such as your IP address, browser type and language, access times, pages visited, and referring website addresses. We may use Device Identifiable Information to analyze trends, help administer the Services, track the online movement of users, to learn about and determine how much time visitors spend on each page of the Sites, how visitors navigate throughout the Sites or use other Services, and to gather broad demographic information for aggregate use. We may also collect Device Identifiable Information through “cookies” or “web beacons” as explained below.

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In addition, we may collect information about your mobile device such as the type and model, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), applications using our Sites, and identifiers assigned to your device, such as its iOS Identifier for Advertising (“IDFA”), Android Advertising ID (“AAID”), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.

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We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (“ISP”) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

When aggregated or deidentified information, including Device Identifiable Information, is directly associated with Personal Information, such that the aggregated or deidentified information can be reasonably associated with a particular individual User or household, then this aggregated or deidentified information is treated as Personal Information.

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2. How We Collect Your Information

(A) Cookies and Web Beacons
To help us serve you better, we may collect Device Identifiable Information from you through technologies such as “cookies” and “web beacons” (which are also called clear GIFs, pixel tags, or pixels) or by tracking internet protocol (“IP”) addresses.

  • “Cookies” are small data files that are stored by your web browser when you interact with a website. When you visit a webpage, the cookie sends back Device Identifiable Information.

  • “Web beacons” are small graphic images (usually invisible) that can be embedded in content and ads on a webpage that track usage of the Sites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.

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Cookies operate in the background and you can turn them off by adjusting your Web browser settings, but doing so may make it difficult to use some of the features on the Sites or the features may not be available to you. We may use cookies to make your Sites experience easier by, for example, remembering your preferences, like favorite club.

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We may also use cookies and other activity tracking tools on the Sites and through other Services to collect your engagement metrics, including your Personal Identifiers and Device Identifiable Information, related to your activity on the Sites and Services.

For more information on your choices regarding cookies, you can review the FTC’s guide to opting out of online tracking for computers and mobile devices. You can also see the “All Users: Your Choices and Controls” section below for ways to opt-out.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Sites and Services do not currently support Do Not Track requests at this time.

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(B) Other Direct Interactions with You
You give us your information in your direct interactions with us. We collect information you provide to us when you register accounts on our Sites and other Services; request newsletters, and other products, services, or information from us; respond to surveys; participate in sweepstakes or contests; or otherwise interact with us. This information includes Personal Identifiers, Contact Information, Biographical Information, Financial Information, and Device Identifiable Information, which you give us from time to time.

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Except for IP addresses, we may match Device Identifiable Information with Personal Information that we may have from or about you, which would allow us to identify you. We may use this information to provide you with offers that are available where you are physically located.

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(C) Social Media
When using the Services or when using certain third party social networking services (e.g., Facebook, Twitter) (each, a “Social Network”), you may have the option to connect your Service information and activity with your Social Network information and activity. If you authorize such a connection, you permit us to share or publish information about your Service activity with that Social Network and its users, and to access certain of your Social Network information, as disclosed to you at the time you consent to the connection. Information we may share with a Social Network may include technical information about your Service activity, your Service comments, or the videos you watch on the Service. Information we may access about you, with your consent, from a Social Network may include, but is not limited to, your basic Social Network information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Network. If you permit a connection between a Social Network and a Service, we (and that Social Network) may be able to identify you and to associate information received pursuant to the connection with information we already have about you. For more information, please review the privacy disclosures and terms of your Social Network account, which govern how that account information is collected and shared with us.

(D) Other Third Party Sources
CRS may also receive other information from Service Providers (as defined below) in connection with the operation of our Services, including when you take our surveys through a third-party vendor. We may also receive information from Service Providers through marketing and demographic studies that we use to supplement Personal Information and deidentified information provided directly by you.

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3. How We Use Your Information
(A) For the Purpose Collected: If you provide Personal Information for a certain reason, we will use the Personal Information in connection with the reason for which it was provided. For example, we may use this information to:

  • Create accounts and process your registration with our Services;

  • Process transactions, including purchases and donations;

  • Provide technical support and respond to user inquiries; and

  • Notify you about updates to our Services or send other communications that are relevant to your use of our Services.

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(B) Support from Service Providers: In addition, Personal Information and Device Identifiable Information we collect may be used by us and by third-party service providers, such as hosting providers, data management companies, address list hosting companies, e-mail service providers, analytics companies (e.g., Google Analytics), distribution companies, fulfillment companies, and payment processors (collectively, “Service Providers”) for a variety of purposes, including to:

  • contact you about the Sites and/or Services you have requested;

  • provide you with Services or information you have requested, or products or services you have ordered or signed up for, such as newsletters;

  • confirm or fulfill an order you have made;

  • administer your participation in a contest, sweepstakes, promotion, survey, or voting poll; and

  • facilitate the operation, maintenance and improvement of the Services, our business operations, and internal record keeping.

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Our Service Providers are given the information they need to perform their designated functions in connection with the Services, and we do not authorize them to use or disclose your Personal Information for their own marketing or other purposes.

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(C) To provide effective advertising and marketing: We also use the information we collect and receive to provide ads for our Services and certain third-party services, and to send you promotional communications. For example, we may use this information:

  • To show you personalized ads (on and off our Services, including on Social Networks) based on location information or your online activities, including the content you view, the products you purchase, the other Services of ours that you use, and other information we collect and receive. We may provide a hashed version of your email address or other information to the third party for such purposes. (Please also see below the “All Users: Your Choices and Controls” section of the Privacy Policy);

  • To send you electronic and other marketing messages about CRS, the NWSL, or third-party business partners of CRS that may be tailored to your preferences and interests – for example, content related to your favorite Member Club. (Please see below the “All Users: Your Choices and Controls” section.);

  • To measure and evaluate the effectiveness of online advertising campaigns;

  • For performing internal analysis and building models to better understand CRS fans and fan engagement across the CRS so that we can customize and improve our Services, advertising and communications; and

  • To administer your participation in our contests, sweepstakes, fantasy or interactive games, or other promotions.

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(D) Identity Verification and Security: We also may obtain information about you from other businesses to verify your identity so we can properly process your requests and prevent fraud. By accessing and using our Services, you agree that we may use your submitted and obtained Personal Information and Device Identifiable Information for such purposes and to maintain the security of the Services.

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(E) Product Improvement and Marketing: CRS may also use your Personal Information, Device Identifiable Information, and other personally non-identifiable information collected through the Sites and Services to help us improve the content and functionality of the Sites and Services, to better understand our users and to provide customer support, to personalize control and experiences on our Sites and applications, and to improve the Services. CRS may use this information to communicate with you regarding the Sites and Services and, to the extent permitted by law, to tell you about services we believe will be of interest to you.

(F) Enforcement and Legal Obligations: CRS may use your Personal Information to enforce our Terms of Use, or investigate and prevent activities that may violate our policies or be illegal, and to respond to legal proceedings and obligations.

We also may use the information we collect and receive for other purposes that may be described to you at the point of collection or for which you provide your consent.

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4. How We May Share Your Information

(A) Business Transfers
As we develop our business, we might sell or buy businesses or assets, such as the sale of all or most of CRS’s assets or equity to another company. In the event of a corporate sale, merger, reorganization, dissolution, or similar event in which a third party assumes control of all or part of our business, Personal Information may be part of the transferred assets or business.

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(B) Service Providers and Third Parties
We share Personal Information and Device Identifiable Information with Service Providers, as described above in “How We Use Your Information”. We do not sell your Personal Information to third parties, whether for monetary or other valuable consideration.

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We may share with third parties aggregated demographic information collected on or through the Services for various purposes such as fan research and audience analysis. Aggregated demographic information does not include and is not linked to any Personal Information that can identify you or another individual person, but we may use your IP Addresses to verify users’ locations for various purposes, including blackout restrictions.

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(C) User Referrals
Users may send information about our Member Clubs, our products, or the Services, to their friends and family members by using an “E-mail to Friend” or similar feature in the Services or in an e-mail that we have sent them. We do not further contact those individuals without their consent to do so.

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(D) Business Partners and Third-Party Marketers
When you consent to receive news and offers from them, we share information about you with select business partners and other third parties that are not service providers, such as our sponsors, retailers, and broadcast partners, so that they can provide you with special offers, promotional materials, and other materials and information that may be of interest to you. These other business partners and third-party marketers are expected to protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners and other third-party marketers, which may use your information for their own purposes. If you have consented to share your Personal Information with third parties for such third parties’ marketing purposes, you can change your mind at any time. To opt out of receiving communications directly from these third parties, please contact the third party, and you may let us know by following the instructions in the “All Users: Your Choices and Controls” section below.

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(E) Legal Requirements
We may also share Personal Information and Device Identifiable Information under the following circumstances:

  • if required by law, such as by a court order, statute, regulation or rule, through legal process, or for law enforcement purposes;

  • in the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of our creditors;

  • if we determine it necessary in connection with an investigation or in order to protect our legal rights; or

  • in response to requests from federal, state, local or foreign law and civil enforcement agencies, such as a search warrant, subpoena or court order.

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5. Communication Services and Community Features

(A) Chat Rooms, Forums, and Message Boards
The Services may make chat rooms, forums, blogs, message boards, and other community features and activities available to you and other users. If you post Personal Information online, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose Personal Information in these areas. We reserve the right (but assume no obligation) to review and/or monitor any such community areas on the Services.

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(B) Short Message Service
We may make available a service through which you can receive messages on your wireless device via short message service (“SMS Service”). You understand that your wireless carrier’s standard rates apply to these messages.

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If you subscribe to one of our SMS Services, you may be required to register and provide Personal Information. We may also collect the date, time, and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service for the purpose of sending the SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information to facilitate the transaction in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We may also contact your carrier, which may access the content of your wireless account, for the purpose of identifying and resolving technical problems and/or Service-related complaints. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. You may change your mind and unsubscribe to SMS Services at any time by following the instructions in the “All Users: Your Choices and Controls” section below.

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6. Third-Party Advertising
We may allow other companies that are providing advertising content, social networking services, or other services on our Sites to set and access tracking technologies such as cookies on your computer. These companies may collect information about your visits to the Sites in order to measure and assess the effectiveness of online advertising and to provide and better target advertisements about goods and services of interest to you. While the information collected by these third parties from you while you are visiting our Sites is not personally identifiable, some of these third parties may also combine such deidentified information with other information they have collected from various other sources, such as their own past online and/or offline purchase information and web usage from other sites. Such other information may include Personal Information, as well as demographic and behavioral information. Those companies’ use of cookies, and the information collected, are governed by those companies’ privacy policies, not ours. Please see the “All Users: Your Choices and Controls” section below for ways to opt-out of this third party advertising.

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7. All Users: Your Choices and Controls
You have various choices with respect to the collection of and certain of our uses of the Personal Information we collect from you on or through the Sites or Services. If you have not consented to us using your Personal Information as described in this Privacy Policy, we will only use it to complete the transaction or provide the service or product you have requested.

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(A) Accessing, Reviewing, Updating, Correcting or Deleting Your Personal Information


If you want to access, review, update, or correct inaccuracies in your Personal Information, or delete your Personal Information, you can:

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Upon receiving your communication, we will take appropriate steps to update or correct such information in our possession, or to remove you from our catalog and mailing list. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records. 

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(B) Opting Out of Direct Marketing and Other Advertising
If you have agreed to receive communications or solicitations from us, and you later change your mind, you can revise your preferences by contacting us at the email address listed above. You also may opt out of receiving all future promotional e-mails from us by clicking on an opt-out or “unsubscribe” link within the promotional e-mail you receive. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your other relationship, activities, transactions and communications with us.

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You may also opt out of our SMS messages by texting “STOP” or another applicable keyword to the short code applicable to the particular SMS Service (as further described below).

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You may opt-out of receiving ads from network advertisers by clicking the AdChoices icon on advertisements that are sent to you, visiting the opt-out pages on the NAI website and the DAA website. Opting out does not prevent you from seeing ads; it simply means that network advertisers will no longer collect data for the purpose of providing you targeted ads. The DAA and NAI opt-out tools are cookie-based. They signal network advertisers so that they do not collect data online or deliver specific ads targeting you, and only affect the Internet/web browser on the computer where the cookies are installed. These opt-out tools will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie or all your cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is again reset on that browser. Opting out using one browser on one computer will not opt you out using any other browser on the same or another computer.

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8. California Residents: California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please contact us at appfeedback@chicagoredstars.com with the subject line "Shine the Light". Not all information sharing is covered by the “Shine The Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.

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If you are a California resident, then you also have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal Information:

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(A) Right to Know
You have the right to know and see what data we have collected about you over the past 12 months, including:

  • The categories of Personal Information we have collected about you;

  • The categories of sources from which the Personal Information is collected;

  • The business or commercial purpose for collecting your Personal Information;

  • The categories of third parties with whom we have shared your Personal Information; and

  • The specific pieces of Personal Information we have collected about you.

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(B) Right to Delete
You have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

  • Complete your transaction;

  • Provide you a good or service;

  • Perform a contract between us and you;

  • Protect your security and prosecute those responsible for breaching it;

  • Fix our system in the case of a bug;

  • Protect the free speech rights of you or other users;

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;

  • Comply with a legal obligation; or

  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

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(C) Exercising Your Rights
To exercise your right to know or your right to delete, please submit a verifiable consumer request to us as indicated in the “Contact Us” section of this Privacy Policy. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request to exercise your right to know twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

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We will not discriminate against you for exercising any of your CCPA rights described above. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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9. Security Practices
We use reasonable security efforts to protect the Personal Information in our possession. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data, the unauthorized access to or use of information, the theft, destruction, or inadvertent disclosure of your information, whether Personal Information or Device Identifiable Information, or any other disclosures out of our control. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information. Your online access to some of your information may be protected with a password that you select. We strongly recommend that you select a unique password that is difficult to guess and that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages).

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10. Links to Other Services
The Sites and Services may contain links to other websites and online services. When you link to such other sites and services (including by means of clicking on hyperlinks, logos, widgets, banners or advertisements), you become subject to their terms of use and privacy policies posted thereon and/or applicable thereto. Because we cannot control the activities of third parties, please note that we are not responsible for the privacy practices of third-party websites. We encourage you to be aware of this when you click on a link and leave the Sites, and to read the privacy policies of every website that collects Personal Information from you.

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11. Additional Information
The Services are operated and maintained within the U.S. We make no assurances or representations of any kind that the Services are suitable for use outside the U.S. or in the country in which you reside. The information we collect is kept on servers in the U.S. and may be transferred to servers in other countries, subject to the terms of this Privacy Policy. We retain the Personal Information that we collect for so long as we continue to have a business purpose for it.

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By accessing and using a Site or Service, establishing an account, or making a purchase, you consent to the processing of your Personal Information as provided in this Privacy Policy. You may withdraw that consent by contacting us as indicated in the “Contact Us” section of this Privacy Policy. Please know that when you withdraw your consent, we may still use your information to the extent necessary to complete a transaction with you or as otherwise permitted by law. You are required to provide certain Personal Information in order to use a Service, to make a purchase or to take advantage of certain features available through the Sites. Your choice not to provide this information may prevent you from using the Services or may result in a need to terminate your account or an inability for you to use certain features. It is not our intent to discriminate against you for exercising your rights or the choices available to you. But, without certain information, the Sites and Services may not work as designed.

If you wish to raise a complaint on how we have handled your Personal Information, you may contact us at appfeedback@chicagoredstars.com with the subject line "Privacy Complaint".

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12. Changes to this Privacy Policy
This Privacy Policy replaces any earlier version. You should review this Privacy Policy periodically as we may modify it from time to time. If we change our Privacy Policy in the future, we will post the changed Privacy Policy on the homepage of the Sites and other locations where the policy was previously posted. You will be able to determine what version of the Privacy Policy applies by the “Effective Date” placed under the title. Where consistent with applicable law, your continued use of the Services after we have changed the Privacy Policy signifies your acceptance of the revised terms. Under certain circumstances (e.g., with respect to certain material changes to this Privacy Policy), we may also elect to notify you through additional means, such as posting a notice on the front page of the Sites or by means of an e-mail.

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13. Children’s Data
Our Sites and Services do not knowingly collect, use, or disclose personal information from children under the age of 13 or as otherwise defined by local law without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”) or other applicable local law. If we learn we have collected or received Personal Information from a child under the age of 13 without verification of parental consent, we will endeavor to delete that information. 

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14. Exclusions
This Privacy Policy does not apply to any Personal Information collected by CRS other than Personal Information collected through the Sites and Services. This Privacy Policy also does not apply to information about businesses or other non-individual users. CRS reserves the right to use and disclose aggregated or deidentified information for any commercially reasonable purpose.

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15. Contact Us
Please feel free to contact us if you have questions or concerns about this Privacy Policy or if you would like to exercise your applicable data protection rights by emailing us at appfeedback@chicagoredstars.com with the subject line "Privacy Policy".

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