17 July 2015

Privacy Policy


Welcome to our website. Drone Racing League, Inc. (“DRL”) respects your privacy and is committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Thank you for visiting THEDRONERACINGLEAGUE.COM.  DRL (also referred to herein as “we”, “us” or “our”) operates this website, which is a general audience site and includes this website (including its subdomains), associated applications and digital services (such as mobile and other device applications), and other associated offerings that are owned, offered or operated by or on behalf of DRL.  Your privacy is important to us. As such, we provide this privacy statement explaining our online information practices and the choices you can make about the way your information is collected and used at THEDRONERACINGLEAGUE.COM. Please be advised that the practices described in this privacy policy apply only to information gathered through and in connection with THEDRONERACINGLEAGUE.COM.

This privacy policy aims to give you information on how DRL collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for our newsletter, purchase a product or service, or take part in a competition, among other features.

Children’s Privacy

DRL’s website(s) do not knowingly collect personal information from visitors under age 13 and are in no way directed a children under the age of 13. In the event that we learn that we have collected personal information from a children under age 13 without parental consent (other than collection for the support of internal operations), we will delete that information as quickly as practicable.


DRL is the controller and responsible for your personal data (collective referred to as “we”, “us”, or “our” in this privacy policy).  We have appointed a data privacy manager at DRL who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:

Drone Racing League, Inc.
1 State Street, NY, NY 10004
Attention: Privacy Manager


Although you always have the right to make a complaint at any time to the data privacy regulatory authority in your respective country and jurisdiction, we would appreciate the opportunity to address your concerns beforehand, so please contact us in the first instance.

Third Party Links

This website may include links to or integrations with other third-party websites, plug-ins, and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, you are subject to the terms and conditions of those third party websites, and we encourage you to read the privacy policies of every website you visit.

  • The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (i.e., anonymous data). Unless specified, such personal data is generally referred to in this policy as “Information”.  For privacy with respect to individuals located in the EU, see Section 6 (“International Transfers”) below.

We may collect, use, store, and transfer different kinds of personal data about you, including potentially the following categories and examples:

  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  1. Contact Data includes billing address, delivery address, email address and telephone numbers.
  1. Financial Data includes bank account and payment card details.
  1. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  1. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  1. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  1. Usage Data includes information about how you use our website, products and services.
  1. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

When you order tickets for DRL events via third-party service providers, the respective service provider will gather and store Information about you. This could include, but not be limited to Identity and Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, and more. This information will be transferred to DRL and used by us to identify you and for administration, communication, enforcement and access control purposes for proper performance of the contractual obligations to which we are committed to.

If you are accessing THEDRONERACINGLEAGUE.COM from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on THEDRONERACINGLEAGUE.COM or on other services, when we work with a Partner such as a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.  For a description of your rights to opt out of this collection, see Section 9 (“Your Legal Rights”).


  • How Is Your Personal Data Collected?


We use different methods to collect data from and about you including through:

  1. Information you provide directly to us. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. Register or create an account on our website;
  2. Apply for or order our products or services;
  3. Vote in polls, or otherwise express an opinion;
  4. Subscribe to our online newsletters, text message alerts, or other services;
  5. Participate in one of our online forums or communities;
  1. Subscribe to our service or publications;
  1. Request marketing to be sent to you;
  1. Enter a competition, promotion or survey;
  2. Purchase merchandise through our website; or
  1. Give us feedback or contact us.
  1. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. This may include, but is not limited to: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as Apple IDFA or an Android Advertising ID), device settings, browser settings, the web pages of THEDRONERACINGLEAGUE.COM you have visited, sites visited before and after you visit THEDRONERACINGLEAGUE.COM, the type of handheld or mobile device used to view THEDRONERACINGLEAGUE.COM (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on.

We may also receive Technical Data about you if you visit other websites employing our cookies. We, and our “Partners” who include our third party service providers, advertisers, advertising networks and platforms, agencies, and distribution or other partners may use automated means to collect various types of Information about you, your computer or other device used to access THEDRONERACINGLEAGUE.COM. Please see the Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.

  1. Third parties or publicly available sources. We will receive personal data about you from various third parties and/or public sources] as set out below:
  1. Technical Data from the following parties: (a) analytics providers; (b) advertising networks; and (c) search information providers;
  2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  3. Identity and Contact Data from data brokers or aggregators;
  4. Identity and Contact Data from publicly available sources.
  5. Identity and Contact Data from someone who may order you an electronic greeting card or online gift to be sent directly to you.  This may include name, addresses, email address, and telephone number.


You also can engage with our content, such as video, games, applications, and other offerings, on or through social media services or other third-party platforms and social networking sites, such as Facebook, or other third-party social media plug-ins, integrations and applications. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Identity or Contact data in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or the ‘likes’. For a description of how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.


  • How We Use Your Personal Data  



We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

We, along with our Partners, may use the Information to:

  1. provide and communicate with you about THEDRONERACINGLEAGUE.COM, such as to fulfill a request by you for an online newsletter or notification, or to contact you about your account with us,
  2. fulfill your requests for our products, programs, and services, including without limitation requests for newsletters and notifications,
  3. respond to your inquiries, and notify you if you have won one of our contests,
  4. communicate with you about other products, programs or services that we believe may be of interest to you,
  5. enforce the legal terms (including without limitation this privacy statement and our terms of use) that govern your use of THEDRONERACINGLEAGUE.COM, and/or for the purposes for which you provided the information.
  6. provide technical support for THEDRONERACINGLEAGUE.COM,
  7. prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through THEDRONERACINGLEAGUE.COM,
  8. protect the safety of our users,
  9. customize or personalize ads, offers and content made available to you based on your visits to and/or usage of THEDRONERACINGLEAGUE.COM or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them,
  10. perform analysis regarding how you use THEDRONERACINGLEAGUE.COM or any part thereof,
  11. send gifts, cards, invitations or emails if you use these services, to your designated recipients.

When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our applications or websites, (3) contact you through the social media service or directly by sending you the latest news, special offerings, and rewards, and (4) enable you to share your experience and content via social media services. When you provide information about yourself to us through an application, on our sites, or on social media services or other third party platforms, it may be publicly viewed by other members of these sites and we cannot prevent further use of the information by third parties.

We or a Partner may use “cookies” or similar technologies to associate certain of your Information with a unique identifier that then associates the Information with your device or browser. For information about how these technologies work and how we may use them, please go to the subsection below (“Cookies, And Other User and Ad-Targeting Technologies”).
Sometimes, we may associate cookies with the Information, including de-identified, “hashed,” or anonymous versions of Information you have provided (such as during registration), in order to send or help our Partners send ads and offers based on your presumed interests or demographic information.

We may combine any of the Information we collect, for any of the above purposes, and may sometimes enhance the Information with other information that we obtain from third party sources. Please also be aware that if you choose to submit Information or content for publication (e.g., a letter to our editors, comments sent to our writers and/or personalities, a posting to a blog or a discussion board, or a video), we may publish that Information and content, along with other Information about you (such as your name, screen name or location). Likewise, if you register and create a profile with THEDRONERACINGLEAGUE.COM, the screen name you select as well as other content you submit to your profile (e.g., photos, comments, video, reviews) will be displayed publicly on THEDRONERACINGLEAGUE.COM, is searchable, can be found by third parties and may be reused and redistributed by us in our sole discretion. See our Terms of Use for details on our use of content you submit.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed, your game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on.




We  may use “cookies” (as described below) and other technologies both to provide our services to you and to advertise to you. We may also work with Partners to help them advertise to you when you visit other websites or mobile applications, and to help them perform user analytics. These technologies may also be used to analyze how our users interact with advertising on THEDRONERACINGLEAGUE.COM and elsewhere, and more generally, to learn more about our users and what services or offers you might prefer to receive. We describe some of these technologies below.

  1. Cookies. To enhance your online experience, we use “cookies”, “web beacons” or other tracking technologies. Cookies are text files placed in your computer’s browser to store your preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the products, content, offerings, services or advertisements on THEDRONERACINGLEAGUE.COM. For example, we may use cookies to personalize your experience on THEDRONERACINGLEAGUE.COM (e.g., to recognize you by name when you return to THEDRONERACINGLEAGUE.COM), save your password in password-protected areas, and enable you to use shopping carts on THEDRONERACINGLEAGUE.COM. We also may use cookies or other tracking technologies to help us offer you products, content, offerings, or services that may be of interest to you and to deliver relevant advertising when you visit THEDRONERACINGLEAGUE.COM, an affiliate’s website, or when you visit other websites or applications. We or a third party platform with whom we work may place or recognize a unique cookie on your browser to enable you to receive customized content, offers, services or advertisements on THEDRONERACINGLEAGUE.COM or other sites. These cookies contain no information intended to identify you personally. The cookies may be associated with de-identified demographic or other data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider solely in hashed, non-human readable form.

We, our third party service providers, advertisers, advertising networks and platforms, agencies, or our Partners also may use cookies or other tracking technologies to manage and measure the performance of advertisements displayed on or delivered by or through THEDRONERACINGLEAGUE.COM and/or other networks or sites. This also helps us, our service providers and Partners provide more relevant advertising. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this privacy statement.

  1. Synching Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partner’s uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match users to their likely product interests, or better synchronize, cap, or optimize advertising.
  2. Locally Stored Objects. THEDRONERACINGLEAGUE.COM may employ locally stored objects (“LSOs”) and other client side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our Partners target ads, analyze ads performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access your Flash management tools from Adobe’s website. In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.
  3. Disabling Cookies.

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of THEDRONERACINGLEAGUE.COM may be difficult to use or inoperable.

We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with THEDRONERACINGLEAGUE.COM. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising or to opt-out of this type of advertising by those third parties that are members of DAA’s opt-out program, please go to

  1. Web Beacons. We and our Partners may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
  2. Mobile Device Identifiers and SDKs.

We also sometimes use, or partner with publishers, publisher-facing, or app developer platforms that use mobile Software Development Kits (“SDKs”), or use an SDK with a mobile app that we offer, to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and Information connected to how mobile devices interact with THEDRONERACINGLEAGUE.COM products and services and those using THEDRONERACINGLEAGUE.COM. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services or analytics to be performed. We may use this technology to deliver or help our Partners deliver certain advertising through mobile applications and browsers based on information associated with your mobile device. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the “Your Ad Choices” section below.

By visiting THEDRONERACINGLEAGUE.COM, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of THEDRONERACINGLEAGUE.COM through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.

Our unaffiliated Partners and third parties may themselves set and access their own tracking technologies when you visit THEDRONERACINGLEAGUE.COM and they may have access to information about you and your online activities over time and across different websites or applications when you use THEDRONERACINGLEAGUE.COM. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.

  1. Your Ad Choices

Advertising enables us to provide the rich content, and to provide much of this content free of cost to our users. Thus, we strive to provide you with ads that are relevant to you and for products you may want. However, we also offer you choices with regard to interest-based ads.
To learn more about interest-based ads and the choices available to you, please visit our Ad Choices page, which has general information about certain companies that place these ads.

Additionally, we sometimes utilize Adobe technology to customize advertising you may see on our site or other sites. You can opt out of the receipt of targeted advertising utilizing Adobe technology by clicking here.

You may also find more information about entities involved in online advertising and additional choices you may make through the Network Advertising Initiative (“NAI”) at the NAI site and the Digital Advertising Alliance (the “DAA”) a the DAA Self Regulatory Program site. Turner is a participant in the online industry’s self regulatory program administered by the and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided on the Ad Choices page, as well as the DAA opt-out page and the NAI opt-out page, are provided by third parties, not DRL or Turner, we do not control or operate these tools or the choices that advertisers and others provide through these tools.
When using a mobile application, you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

  1. How We Respond to Do Not Track Signals

At this time THEDRONERACINGLEAGUE.COM does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.




We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.




We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.




You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at the contact information provided in this policy. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account. For convenience, this contact information is provided again below:

Drone Racing League, Inc.
1 State Street, NY, NY 10004
Attention: Email Administration


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.

If you have signed up to receive our e-mails and prefer not to receive marketing information from this site, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from this site. If you have signed up to receive text messages from us and no longer wish to receive such messages, you may follow the instructions to stop delivery of such messages, which may include by replying “STOP” to the received text message.




We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, to the extent we are legally required to do so, we will notify you and we will either obtain your express consent or, if consent is not needed, explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


  • Disclosures of Your Personal Data 

We may share your personal data with the internal or external parties set out below for the purposes described below.  With respect to third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



  • Information Sharing and Disclosure.  We may disclose the Information as follows:


  1. To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill orders and user requests; (f) handle payments; (g) host THEDRONERACINGLEAGUE.COM, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support THEDRONERACINGLEAGUE.COM.
  2. In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request, or where we believe in our sole discretion it is necessary.

iii. With third parties in order to investigate, prevent, or take action ( in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or THEDRONERACINGLEAGUE.COM, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing THEDRONERACINGLEAGUE.COM and applicable laws or as otherwise required or permitted by law or consistent with legal requirements.

  1. We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way.
  2. We may share the Information with affiliates, so they can provide, improve and communicate with you about their own, or their marketing partners’ products and services.
  3. We may share the Information with unaffiliated Partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you. In addition, we may disclose Information that identifies your mobile device, telecommunications carrier and information regarding your access/use of THEDRONERACINGLEAGUE.COM mobile applications to DRL’s wireless communications partner.

vii. If you wish to opt out from such sharing please visit the How to Contact Us/Opting Out of Marketing Communications section below for further instructions.
Please note that THEDRONERACINGLEAGUE.COM may offer content (e.g., contests, sweepstakes, promotions, games, applications, or social network integrations) that is sponsored or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain information from their visitors. We have no control over these third parties’ use of this information, which is subject to their own privacy policies.




DRL operates globally so it may be necessary to transfer your information internationally. In particular, your information will likely be transferred to and processed in the United States where of our central databases operate.

Although DRL’s website and products and services are available online to a global audience, it neither targets EU citizens for offering goods and services, nor does it monitor their behavior.  In addition, DRL operates from the United States and does not have an established presence in the European Union. Therefore, DRL’s business activities currently are not subject to the EU Data Protection Laws, but DRL will promptly take reasonable steps to become compliance with such laws at an appropriate time, if necessary and applicable.  

Notwithstanding the above, to the extent that any European citizens visit DRL’s website or purchase goods and services, DRL will provide reasonable assistance, including through appropriate technical or organizational measures, insofar as this is possible, to fulfill any requests by data subjects, specifically the right to access, rectification, erasure, restriction, objection, or portability, as set forth in the Directive or GDPR and as outlined in this Privacy Policy.  

Please contact us if you want further information on the specific mechanism used by us when processing or transferring your personal data out of the EEA, or with respect to the treatment of personal data concerning citizens located in the EU or EEA.




We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information that will never be disclosed, altered or destroyed in a manner that is inconsistent with this privacy statement.  We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.







We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us at the contact information provided in this policy.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information. 

In some circumstances we will anonymize your personal data (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.



Under certain circumstances, you have rights under data protection laws in relation to your personal data. These may include the right to:

  • Access your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data; or
  • Withdraw consent to the collection or processing of your personal data.

If you wish to exercise any of the rights set out above, please contact our data privacy manager at the contact information provided in this policy.




You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.




We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 




We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex, if our resources are constrained, or you have made a number of requests. In this case, we will make commercially reasonable attempts to notify you and keep you updated.




California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.
As discussed above in How to Contact Us/Opting Out of Marketing Communications, if you wish to opt-out of our sharing of your personal Information with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact us as described above.




From time to time, we may update this privacy statement. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our site. We encourage you to periodically check back and review this statement so that you always will know what information we collect, how we use it, and with whom we share it.

This Privacy Policy was last updated on October 1, 2018.   Historic versions can be obtained by contacting the data privacy manager at the contact information provided above.





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