Privacy Policy

Last Modified: September 14, 2020

We at SDCF (Sports Data Capital Fund, LLC and our affiliates listed here) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by SDCF as a controller, including the information collected on our Websites (winnersandwhiners.com, statsalt.com, pickpapa.com) or through other channels as described below. This Privacy Policy describes how we collect, receive, use, store, share transfer, and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites.

This Privacy Policy does apply to your use of the Insiders’ Program, Premium Products, and other paid services offered by SDCF on the Websites (“Premium Services”) as a customer of SDCF.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@sdcapitalfund.com or by mail to (Sports Data Capital Fund, LLC, 722 Dulaney Valley Road #333, Towson, MD 21204 USA, Attn: Privacy.

1. What Information We Collect About You

When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you register for Premium Services, we request that you provide Personal Information about yourself, and we collect Navigational Information.

"Personal Information"
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, address, phone number, and other information about yourself. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.

Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.

Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.

Payment information includes information we collect and process from you when you subscribe to the Premium Services, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.

"Sensitive Information"
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by SDCF to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.

Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.

Information About Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16 If you believe that we have collected personal information about a child under 16, please contact us at privacy@sdcapitalfund.com, so that we may delete the information.

2. How We Use Information We Collect

Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy.

Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

  • improve your browsing experience by personalizing the Websites and to improve the Premium Services;
  • send information or SDCF content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
  • provide other companies with statistical information about our users -- but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • contact you about billing, account management, and other administrative matters;
  • send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements;
  • investigate and help prevent security issues and abuse; and meet legal requirements.
  • verify delivery and track performance of an advertising campaign and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently;
  • provide you with personalized advertising on some of the Websites based on your online activity.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.

Use of Navigational Information
We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with SDCF. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about SDCF. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.

You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time by emailing privacy@sdcapitalfund.com

Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

Use of Payment Information
If you give us Payment information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

Social Media Features
Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites
Our Websites provide links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Retention of Personal Information
How long we keep information we collect about you depends on the type of information as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "How to Access & Control Your Personal Data" below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your SDCF account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

3. How we Share Information we Collect

Service Providers
We employ other third-party service providers to provide services on our behalf to visitors to our Websites and our customers and users of the Premium Services and may need to share your information with them to provide information, products or services to you. Examples may include analyzing data or performing statistical analysis, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

Co-Marketing Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies. If you do not want us to share your personal information with these companies, please contact us at privacy@sdcapitalfund.com.

Third Parties
With appropriate consent when required, SDCF may share your contact information with third party marketing partners, and they may contact you by email, telephone, postal mail or other common communication methods with marketing and promotional messages about their products or services. Sometimes we will give you the option to receive further communications from one of our advertising partners, for example when we run a competition with that advertiser. When you provide consent to receive communications from that third party advertiser, your personal information will be managed by that third party’s own privacy policy.

Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by SDCF on the Websites and the Premium Services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. Cookies and Similar Technologies

Cookies
SDCF and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.

Advertising
We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/, https://optout.liveramp.com/opt_out (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

5. How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:

  • You can request access, correction, updates or deletion of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here .

To exercise any of these rights, please contact us at privacy@sdcapitalfund.com or by mail to Sports Data Capital Fund, LLC, 722 Dulaney Valley Road #333, Towson, MD 21204 USA, Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by emailing us at privacy@sdcapitalfund.com or by mail to Sports Data Capital Fund, LLC, 722 Dulaney Valley Road #333, Towson, MD 21204 USA, Attn: Privacy. Customers cannot opt out of receiving transactional emails related to their account with us or the Premium Services.

6. California Privacy Rights

This section applies only to California consumers. It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”).

How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:

  • Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
  • Commercial information, such as subscription records. We collect this information directly from you.
  • Internet or network information, such as browsing and search history. We collect this information directly from your device.
  • Geolocation data, such as IP address. We collect this information from your device.
  • Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
  • Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Premium Services.
  • Inferences

The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section 3 of this Privacy Policy.

Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.

The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

SDCF does not sell Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).

How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.

Please use the contact details below, if you would like to:

  • Access this policy in an alternative format;
  • Exercise your rights;
  • Learn more about your rights or our privacy practices; or
  • Designate an authorized agent to make a request on your behalf.

Email: privacy@sdcapitalfund.com

7. Questions

If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us at privacy@sdcapitalfund.com or by mail at:

Sports Data Capital Fund, LLC
722 Dulaney Valley Road #333
Towson, MD 21204 USA

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