Effective Date/Last Updated: January 8, 2024
Connecticut Sports Group (“CT United”, “we”, “us”, or “our”) respects your privacy. We are excited to engage with you through your use of the CT United website (the “Website”) and through our various online services and applications provided by CT United through the Websites (collectively, the “Services”). This policy (this “Privacy Policy”) is meant to help you understand our practices regarding the collection, use, and disclosure of personal information in connection with these Services as well as to 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.
This Privacy Policy applies to visitors to the Website and users of any Services. Please remember that you are agreeing that you acknowledge the practices and procedures described in this Privacy Policy and agree to the CT United Terms of Service when you use the Services. If you provide Personal Information (as defined in this Privacy Policy), you also agree that Personal Information you provide may be transferred from your current location to the offices and servers of CT United and its authorized third parties. If you do not agree with this Privacy Policy and the CT United Terms of Service_, please do not use the Websites or any Service_.
This Privacy Policy also applies to employees, contractors, applicants to become employees or contractors, and owners, directors, and officers of CT United subject to the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), including as applicable, emergency contacts and beneficiaries of the foregoing. The Personal Information collected from the foregoing in this context shall be referred to in this Privacy Policy as “Employee Personal Information”. Internal website and intranet web pages of CT United shall be included within the definition of Websites under this Privacy Policy to the extent they are used to collect, use, or disclose Employee Personal Information. Please note there may be additional or different contracts, privacy notices or disclosures that govern our use of your Employee Personal Information beyond the CCPA. Where the CCPA specifically applies to collection, use and disclosure of information, this Privacy Policy shall prevail and be applicable to such obligations or requirements. Any terms defined in the CCPA have the same meaning when used in this notice.
1. Types of Information We Collect
2. How We Collect Your Information
3. How We Use Your Information
4. How We May Share Your Information
5. Communication Services and Community Features
6. Third-Party Advertising
7. All Users: Your Rights, Choices and Controls
8. California Residents: Your California Privacy Rights
9. Your Additional Rights in the UK and European Economic Area
10. Security Practices
11. Links to Other Services
12. U.S. Operations, Non-Discrimination, and Making a Complaint
13. Changes to this Privacy Policy
14. Children’s Data
15. Performance Monitoring and Wearable Devices
16. Automated Decision Making and Profiling
17. Exclusions
18. Contact Us
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. In the case of Employee Personal Information, we collect information relating to recruitment, applications and employment. Here are the types of information we collect about you:
(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 (as we have done for the past twelve months) from you on or through the Services in a variety of ways, including when you register on the Websites, purchase or engage with 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. We collect both Non-Sensitive and Sensitive Personal Information, as discussed below.
We have grouped together the following categories of Non-Sensitive and Sensitive Personal Information to explain how we use this type of information. In the case of Employee Personal Information, we also collect both Non-Sensitive and Sensitive Personal Information relating to recruitment, applications and employment. These terms are used throughout this Privacy Policy.
In the past 12 months we have collected and may collect the following Non-Sensitive Personal Information, from users of the Websites and Services:
(i) Personal Identifiers, including your first and last name, birthdate, age, gender, and username.
(ii) Contact Information, including your email address, phone number, and home address.
(ii) Biographical Information, including your level of education and professional background.
(iv) Commercial Information, such as products or services purchased
(v) Inferences drawn from other Personal Information, such as your favorite player.
(vi) Financial Information, including your credit card number and purchasing history.
(vii) Internet or Other Electronic Network Activity Information, including, but not limited to, your internet browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
In the past 12 months we have collected and may collect the following Non-Sensitive Employee Personal Information:
(i) Dependents or Other Individual’s Information, such as their full name, address, date of birth.
(ii) National or Government Identifiers, such as SSN, passport and visa information, and immigration status and documentation.
(ii) Educational and Professional Background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
(iv) Contract Engagement Details, such as your title, service dates, and amount of contract or engagement.
(v) Employment Details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
(vi) Financial Information, such as banking details, tax information, payroll information, and withholdings.
(vii) Health and Safety Information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
(viii) Information Systems (IS) Information, such as your search history, browsing history, login information, and IP addresses on the Company’s information systems and networks.
(ix) Sensory or Surveillance Information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
(x) Employee Profile Information, such as a profile or summary about an applicant or employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
In the past 12 months we have collected and/or may collect the following Sensitive Personal Information from users of the Websites and Services:
(i) National or government identifiers, including your social security number.In the past 12 months we have also collected and may collect the following Sensitive Employee Personal Information:
(i) Additional national or government identifiers, such as SSN (including that of dependents if applicable), passport and visa information, and immigration status and documentation including your social security number.
(ii) Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns.
(iii) Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a Company office location.
(iv) Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
(v) Physiological data, such as allergies, food aversions and physiological information, including heart rate, heart rate variability, skin temperature, blood oxygen, hydration, lactate, and/or glucose level data.
(vi) Performance tracking data, such as geolocation data and other information related to movement or location, including time, distance, speed, velocity, deceleration, stress, load, and impact.
(vii) Physical characteristics, such as height, weight, and clothing sizes
(viii) Inferences drawn from other Personal Information, such as notes reflecting a player’s preferences, characteristics, or abilities.
(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 Websites 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 Websites, how visitors navigate throughout the Websites 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.
In addition, we may collect information about your mobile device such as the type and model, operating system (e.g. iOS or Android) and version, carrier name, mobile browser (e.g. Chrome, Safari), applications using our Websites, 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.
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.
(C) Aggregated and De-Identified Information
We also collect and use aggregated or de-identified information. Aggregated or de-identified information may be derived from or include data collected from optical tracking devices but is not considered Personal Information under applicable law or this Privacy Policy because this data does not directly or indirectly identify a person. For example, we may aggregate birth years and months along with data collected from optical trackers in order to perform sports-science research designed to improve our understanding of how to support player development. We may also share aggregated or de-identified information with the manufacturer of the optical tracking devices to improve the devices, conduct research and development, establish benchmarking metrics, and similar efforts designed to improve overall player development.
However, when aggregated or de-identified information, including Device Identifiable Information, is directly associated with Personal Information, such that the aggregated or de-identified information can be reasonably associated with a particular individual person or household, then this aggregated or de-identified information is treated as Personal Information. We commit to maintain, use and otherwise process de-identified information only in a de-identified fashion and will not attempt to reidentify such information.
2. How We Collect Your Information
(A) Cookies and Web Beacons
To help us serve you better, through the Websites 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 Websites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.
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 Websites or the features may not be available to you. We may use cookies to make your Website experience easier by, for example, remembering your preferences, keeping track of your login name and password.
We may also use cookies, web beacons and other activity tracking tools on the Websites and through other Services to collect your engagement metrics, including your Personal Identifiers and Device Identifiable Information, related to your activity on the Websites 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 Rights, 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 Websites and Services do not currently support Do Not Track requests.
(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 Websites and other Services; request tickets, 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 the categories of Personal Information described in Section 1(A) and Device Identifiable Information, which you give us from time to time. As an employee, job applicant, or contractor, we may collect Personal Information when you create an account on our careers website or submit a job application. Additionally we may receive physiological data about Employees who are involved in CT United from optical trackers.
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 physically are located.
(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
CT United may also receive other information from Service Providers (as defined in this Privacy Policy) in connection with the operation of our Services, including when you purchase our tickets or 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 de-identified information provided directly by you. Similarly, we may receive Personal Information from advertising partners. We may also receive information from background check service providers in connection with our employee and contractor applications. Additionally, we may receive Employee Personal Information including Inferences drawn from other Personal Information from coaches or managers of Employees (as defined in Section 1(A)—Sensitive Employee Information (viii)).
3. How We Use Your Information
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 instance, if you sign up for an email newsletter, we will use your email address to send you the newsletter. In addition, if you register or open an account on the Services, the Personal Information you provide may be used to maintain your account, provide you access to certain features of our Services, or offer you the benefits and privileges that typically come along with registration. These benefits may include access to and use of exclusive or personalized content or activities (such as message boards or digital ticket access), participation in special events and promotions (such as contests and sweepstakes), and delivery of food, beverages, and/or merchandise. As part of these activities, we may use your Personal Information to determine your eligibility, notify you whether you are a winner, and/or fulfill and deliver prizes and orders.
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 (as has been for the past twelve months), 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, payment processors, and other partners that may offer you certain products or services in connection with your use of the Websites and Services (collectively, “Service Providers”) for a variety of purposes, including to:
· contact you about the Websites 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;
· facilitate the operation, maintenance and improvement of the Services, our business operations, and internal record keeping;
· Share or Sell (as defined by the CCPA) Non-Sensitive Personal Information to our marketing partners to provide you with advertising that may be more relevant to you;
· with your permission, send you, or facilitate your receiving, promotional material or special offers from CT United, our partners or other third parties.
If you no longer wish to receive promotional e-mails from us or our partners, or have your information shared with third parties as previously described, you may change your mind and/or your preferences by following the directions in the “All Users: Your Rights, Choices and Controls” section of the Privacy Policy below.
Our Service Providers are given the information they need to perform their designated functions in connection with the Services, and, except for those instances we specifically allow, we do not generally authorize them to use or disclose your Personal Information for their own marketing or other purposes.
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.
Product Improvement and Marketing: CT United and our Service Providers may also use your Personal Identifiers, Contact Information, Biographical Information, Financial Information, Device Identifiable Information, and other information collected through the Services to:
· help us improve the content and functionality of the Services;
· better understand our users and their preferences;
· provide customer support;
· personalize experiences and product offerings, including targeted advertising, for our Services or the products and services provided by some of our Service Providers; and
· tailor payment plan offerings.
CT United may also use this information to communicate with you regarding the Services and, to the extent permitted by law, to tell you about services provided by others we believe may be of interest to you, including for those of legal age, sports betting and other gaming services.
Enforcement and Legal Obligations: CT United may use your Personal Information to enforce our Terms of Service or investigate and prevent activities that may violate our policies or be illegal, and to respond to legal proceedings and obligations.
Recruitment of Employees and Contractors: CT United collects Employee Personal Information in connection with recruitment, applications and employment to use or disclose as appropriate to:
· Comply with all applicable laws and regulations.
· Recruit and evaluate job applicants and candidates for employment.
· Conduct background checks.
· Manage your employment relationship with us, including for:
o identity verification;
o onboarding processes;
o timekeeping, payroll, and expense report administration;
o employee benefits administration;
o employee training and development requirements;
o the creation, maintenance, and security of your online employee accounts;
o reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
o workers’ compensation claims management;
o employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
o other human resources purposes.
· Manage and monitor employee access to our facilities, equipment, and systems.
· Conduct internal audits and workplace investigations.
· Investigate and enforce compliance with and potential breaches of our policies and procedures.
· Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions.
· Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
· Perform workforce analytics, data analytics, and benchmarking.
· Administer and maintain our operations, including for safety purposes.
· For client marketing purposes.
· Exercise or defend our legal rights, and those of our employees, customers, contractors, and agents.
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 CT United’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.
(B) Sale and Sharing of Personal Information
Under the CCPA, “Share” is defined to include sharing, renting, releasing, disclosing, disseminating, or making available Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, and a “Sale” is defined broadly to include the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating the Personal Information of a consumer to another business or third party for anything of value.
In the last twelve months, CT United has Shared and Sold some Non-Sensitive Personal Information, including Personal Identifiers, Contact Information, Commercial Information, and Inferences drawn from other Personal Information to some of its sponsors and partners (e.g., jersey sponsors, sports betting and gaming partners, and club operator affiliates) for the purpose of those sponsors and partners marketing products and services that may be of interest to our fans. We do not Sell, and to our actual knowledge, we have never Sold Personal Information of consumers we know are less than 16 years of age.
We do not use or disclose Sensitive Personal Information for purposes other than the purposes listed in section 7027(m) of the CCPA Regulations.
If you are a California resident and would like to opt-out of the Sale of your Personal Information to our sponsors, partners, and other third parties, please follow the instructions Do Not Sell or Share My Personal Information. We do not and will not discriminate against you because you opt-out of the sale of your Personal Information. But, please note that if we are unable to provide your Personal Information to our sponsors or partners it may mean that you will not receive some of the benefits or offers provided to others.
(C) 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”. In addition to the information sharing described in Section (B) above, we may share with third parties aggregated and de-identified information collected on or through the Services for various purposes such as fan research and audience analysis. Aggregated and de-identified 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.
Examples of service providers and third parties are below.
1. Service Provider:
· HubSpot
· Salesforce
We may permit access or provide Personal Information to third parties that are providing services on our behalf in connection with the Services, such as hosting, payment processing, and consent verification.
2. Soccer Club
· MLS NEXT Pro
When you provide Personal Information through the Services that information is shared with MLS NEXT Pro. MLS NEXT Pro may use that Personal Information to manage your interactions with CT United as part of MLS NEXT Pro, including team registration, tournament submission, and communications.
3. Soccer Organization, Including Federations:
· United States Soccer Federation
· Canadian Soccer Association
· Fédération Internationale de Football Association (“FIFA”)
We may share certain categories of Employee Personal Information (including date of birth, mailing address, email address, telephone number, name, nationality, and proof of identity, such as passport or other photo ID) to certain soccer organizations for purposes of verifying eligibility or participation and to give Employees an opportunity to participate in events hosted by these organizations.
4. Public, Governmental, and Regulatory Authority:
· United States Government
· Courts
· Sport Tribunals
We may use or disclose your Personal Information as appropriate under applicable laws to respond to requests from public, governmental, and regulatory authorities; to comply with court orders, litigation procedures, and other legal processes; to obtain legal remedies or limit our damages; to protect the operations of our group entities; and to protect the rights, safety, or property of you or others.
(D) User Referrals
Users may send information about our CT United, 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.
(E) Third-Party Marketers
With your permission, we may share your Personal Information with our marketing partners and other third parties so that they may contact you directly regarding special promotions or offers (such as subscriptions to and promotions for goods and services, including, for example, through participation in a co-sponsored sweepstakes or contest, or sports betting or gaming promotions). We are not responsible for how these third parties may use your Personal Information, and such uses are subject to their own policies. If you have consented to our sharing of your Personal Information with third parties for such third parties’ marketing purposes, you can change your mind at any time and may let us know by following the instructions in the “All Users: Your Rights, Choices and Controls” section below.
(F) 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.
(G) Sharing of Video Viewing Activity
To the extent that you consent to sharing any of your video viewing activity with third parties, your consent for such sharing is valid for two years unless you earlier withdraw your consent.
(H) Data Retention
We will only retain Personal Information for as long as necessary to fulfill the purposes for which we have collected such information, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention periods for all Personal Information, we consider the amount, nature and sensitivity of the Personal Information, legal requirements, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means. If we collect “biometric identifiers” or “biometric information,” as those terms are defined by the Illinois Biometric Information Privacy Act (740 ILCS 14), we will delete those biometric identifiers and information when our initial purpose for collecting or obtaining your identifiers or information has been satisfied or within three (3) years of your last interaction with us, whichever occurs first.
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.
(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.
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 during 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 as well as for sharing with advertising partners. 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 Rights, Choices and Controls” section below.
6. Third-Party Advertising
We may allow other companies that are providing advertising content, social networking services, or other services on our Websites to set and access tracking technologies such as cookies on your computer. These companies may collect information about your visits to the Websites 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 Websites is not personally identifiable, some of these third parties may also combine such de-identified 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 Rights, Choices and Controls” section below for ways to opt-out of this third party advertising.
7. All Users: Your Rights, 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 Websites 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. Please note that not all of these rights may be available to users in all jurisdictions.
(A) Your Rights
(1) Right to Opt-Out/Opt-In
You have the right to direct us not to process your Personal Information for the purpose of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling (meaning automated processing performed on your Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movement) in furtherance of decisions that produce legal or similarly significant effects concerning you, including denial of financial and lending services, housing, insurance, education enrollment, criminal justice, employment opportunities, health care services, or access to basic necessities, such as food and water. Please note that CT United may conduct targeted advertising through our Websites but only with your affirmative consent.
If you have agreed to receive communications or solicitations from us (and/or signed up for an account with us), and you later change your mind, you can revise your preferences on the “Account” section of the Websites or through the CT United Preferences Center, or contact us at CT United Privacy Policy Request. 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.
If you have agreed to have us share your Personal Information with third parties so that they may contact you about promotions (and/or signed up for an account with us), offers and other information, you can revise your preferences on the “Account” section of the Websites or contact us at privacy@ctunited.com If you do request to have us stop sharing your Personal Information with other entities for their direct marketing purposes, such request will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly or click on the opt-out or “unsubscribe” link that should be included within the promotional e-mail you receive from such third party.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the processing of your Personal Information for the above purposes. You may change your mind and opt back in to the processing of your Personal Information at any time by revising your preferences on the “Account” section of the Websites or contact us at privacy@ctunited.com
You may opt-out of receiving ads from network advertisers by clicking the AdChoices icon on advertisements that are sent to you or 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.
If you are a resident of the Commonwealth of Virginia (and, beginning on July 1, 2023, Colorado and Connecticut; and January 1, 2024, Tennessee; beginning on July 1, 2024, Texas; beginning on October 1, 2024, Montana; beginning on January 1, 2025, Iowa; and beginning on January 1, 2026, Indiana), applicable law requires us to receive your opt-in consent before processing any “sensitive data”, which includes (1) Personal Information revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (2) the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; (3) Personal Information collected from a known child; or (4) precise geolocation data. We may process some of your sensitive data in connection with the Services and will ask for your opt-in consent before doing so. If you opt-in and change your mind, you may opt-out by revising your preferences on the “Account” section of the Websites or contact us at privacy@ctunited.com.
(1) Right to Know
You have the right to know and confirm that we are processing your Personal Information. You also have a right to access and see what data and Personal information we have collected about you. To the extent feasible, you may request for us to also provide a copy of your Personal Information that you previously provided in readily usable format to permit you to transfer your data to another entity.
(2) Right to Modify
You have the right to correct any inaccuracies in the data and Personal Information you provide to us.
(3) 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:
· Comply with a federal, state or local laws, rules, regulations or other legal obligations;
· Investigate, establish, exercise, prepare for, or defend any legal claims;
· Provide you a good or service;
· Perform a contract between us and you;
· Protect an interest that is essential for your or another natural person’s life or physical safety;
· Prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any illegal activity; or prosecute those responsible for any such action;
· Preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
· Protect the free speech rights of you or other users;
· 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; or
· Conduct internal research to develop, improve or repair our products, services or technology.
(B) Exercising Your Rights
To exercise your rights under this Privacy Policy, 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 also make a request to know or delete on behalf of your child by providing proof of identity. You may only make a verifiable consumer request to exercise your right to know twice within a 12-month period at no additional cost to you. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify whether you are the person about whom we collected Personal Information or an authorized representative.
· 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. We will not discriminate against you for exercising any of your rights described above. Unless permitted by the law, 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.
(C) Response Timing and Format
We will confirm receipt of your request, including requests received pursuant to the CCPA (as amended by the CPRA) (as discussed below), within ten (10) business days. If you do not receive confirmation within such timeframe, please contact us as indicated in the “Contact Us” section of this Privacy Policy. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account, or to the email address associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Subsection (D) below describes how you can appeal our refusal to take action on a request to exercise your rights.
For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
(D) * Right to Appeal*
If we refuse to take action on your request to exercise your rights, you may appeal our refusal. To appeal a refusal, please submit a copy of your request for an appeal and the original request to us as indicated in the “Contact Us” section of this Privacy Policy. Unless otherwise indicated in this Privacy Policy, within sixty (60) days of our receipt of your request for an appeal, we will inform you, in writing, of any action taken or not taken in response to your appeal. We will include a written explanation of the reasons for our decisions. If we deny your appeal, you may contact your local privacy enforcement authority to submit a complaint based on the below information.
(1) Virginia
If you are a resident of the Commonwealth of Virginia, you can file a complaint with the Consumer Protection Section of the Office of the Attorney General of Virginia at:
Mailing address:
202 North Ninth Street
Richmond, VA 23219
Toll Free: 800-552-9963
Phone number: 804-786-2042
Fax number: 804-225-4378
Online: https://www.oag.state.va.us/consumercomplaintform/form/start
(2) Colorado
Effective July 1, 2023, if you are a resident of Colorado, we will inform you, in writing, of any action taken or not taken in response to your appeal (discussed above in Subsection D) within forty-five (45) days of receipt of your appeal. If we require more time (up to another sixty (60) days), we will inform you of the reason and extension period in writing. If we deny your appeal, you can file a complaint with the Office of the Attorney General of Colorado at:
Mailing address:
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
Phone number: 720-508-6000
Online: https://coag.gov/file-complaint/
(3) Connecticut
Effective July 1, 2023, if you are a resident of Connecticut, you can file a complaint with the Office of the Attorney General of Connecticut at:
Mailing address:
165 Capitol Avenue
Hartford, CT 06106
Phone number: 860-808-5420
Online: https://www.dir.ct.gov/ag/complaint/
(4) Utah
Effective December 31, 2023, if you are a resident of Utah, you can file a complaint with the Office of the Attorney General of Utah:
Mailing address:
Utah Attorney General's Office
Utah State Capitol
P.O. Box 142320
Salt Lake City, UT 84114-2320
Online: https://attorneygeneral.utah.gov/contact/complaint-form/
(5) Iowa
Effective January 1, 2025, if you are a resident of Iowa, you can file a complaint with the Office of the Attorney General of Iowa:
Mailing address:
Office of the Attorney General of Iowa
Consumer Protection Division
Hoover State Office Building
1305 E. Walnut Street
Des Moines, Iowa 50319-0106
Online: https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint
8. California Residents: Your 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 CT United Privacy Policy Request or write to us at 9 West Broad Street, Stamford, CT 06902. Attn: Legal Dept. 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.
If you are a California resident, then you also have certain rights under the CCPA, as amended and expanded by the CPRA, regarding your Personal Information:
(A) Right to Opt-Out
You have the right to direct us not to sell your personal information (the “right to opt-out”). If you have opted-in to the sale of your Personal Information, you may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to privacy@ctunited.comOnce you make an opt-out request, we will wait at least twelve months before asking you to reauthorize the sale of your personal information. You do not need to create an account with us to exercise your opt-out rights. We will only use the Personal Information provided in an opt-out request to review and comply with the request.
(B) Right to Limit Use of Sensitive Personal Information
Under the CCPA, some Personal Information you may provide to us is considered “sensitive” Personal Information, such as your driver’s license, state identification card, financial information, racial or ethnic origin and geolocation. You may, at any time, direct us (and our Service Providers) to limit our use and disclosure of your “sensitive” Personal Information to only those uses which are necessary to perform the Services, or for any other lawful purpose. Once you exercise this right, we will not use or disclose your sensitive Personal Information for any other purposes without your express consent unless permitted by the CCPA or applicable law. However, we may continue to use or disclose your Personal Information that is not considered “sensitive” as set forth in this Privacy Policy.
(C) Right to Know
You have the right to know and see what data we have collected about you over the past twelve 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.
(D) Right to Modify
You have the right to correct any inaccuracies in the data and Personal Information you provide to us.
(E) 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.
(F) 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 also make a request to know or delete on behalf of your child by providing proof of identity. However, please note that we may retain certain Personal Information as permitted by law and will maintain a record of the request as required by § 999.317(b) of the CCPA regulations. 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.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. To have an authorized agent make a request under the CCPA on your behalf, please ask the authorized agent to contact us as set forth in the “Contact Us” section below. Please note that we may require the agent to provide us with proof that you have given them signed permission to submit the request. We may also require that you either verify your identity directly or directly confirm that you provided permission to your authorized agent. 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.
The requirements above do not apply if you have provided the authorized agent with power of attorney under the California Probate Code sections 4121 to 4130.
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. However, please note that if we are unable to provide your Personal Information to our sponsors or partners it may mean that you will not receive benefits provided to other consumers (e.g., sample products or services).
9. Your Additional Rights in the UK and European Economic Area
If your personal data has been collected in connection with our activities in the UK or European Economic Area (“EEA”), you have the following rights:
· Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data.
· Access: You have the right to access your personal data.
· Rectification: You have the right to rectify inaccurate personal data.
· Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you believe that it has been unlawfully processed.
· Restriction: You have the right to have the processing of your personal data restricted if you contest its accuracy, if its processing is unlawful, if we no longer need it but you need it preserved for purposes of a legal claim, or if you have objected to its processing and are awaiting verification of our legitimate grounds for processing it.
· Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format.
· Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes.
In order to exercise any of these rights, or for more information, please use the contact details specified in Section 18. Please note that these rights are subject to certain preconditions and qualifications under applicable law.
You also have the right (where applicable) to withdraw any consent given in relation to the processing of your personal information.
Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including for example where the personal information must be retained to comply with a legal obligation.
If you are in the UK, you may lodge a complaint with the Information Commissioner’s Officer (https://ico.org.uk/make-a-complaint/)). If you are in the EEA, you may lodge a complaint with a supervisory authority that has authority in your country or region. Please click here for contact information for such authorities. CT United is the controller of personal data collected through the Services.
10. 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 or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. 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.
11. Links to Other Services
The Services may contain links to other websites and online services, including links to our Service Providers, partners’ or advertisers’ websites. 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 Websites, and to read the privacy policies of every website that collects Personal Information from you.
12. U.S. Operations, Non-Discrimination, and Making a Complaint
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.
By accessing and/or using a 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 at privacy@ctunited.com 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 to use a Service, to make a purchase or to take advantage of certain features available through the Websites. 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 Websites and Services may not work as designed.
If you wish to object to or raise a complaint on how we have handled your Personal Information, you may contact us at privacy@ctunited.com.
If you are not satisfied with our response or believe our processing of your Personal Information is not in accordance with law, you may register a complaint with the appropriate governmental authority. Major League Soccer, L.L.C. controls the Personal Information collected via the Websites and Services.
13. 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 Websites 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, including the way we use or share Personal Information previously collected from you through the Services), we may also elect to notify you through additional means, such as posting a notice on the front page of the Websites or by means of an e-mail.
14. Children’s Data
General Rules: We collect Personal Information from children under the age of 18 in certain areas of the Websites and as Employees of CT United, but only with affirmative parental consent. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will endeavor to delete that information.
Information Collected and Parental Rights: If your child wants to register on or participate in certain activities in the areas of the Services (including, without limitation, MLS NEXT Pro) that are directed to children under 18, we will only allow such registration/participation to proceed if we have your affirmative consent. During the registration process, we may collect certain information from your child, including Personal Information such as their name or e-mail address, as well as a parent or guardian’s email address to obtain your affirmative consent. We will then send you an e-mail (which will include a link to this Privacy Policy), advising you about the portion of the Services in which your child has expressed interest, and request that you reply by e-mail if you consent to your child’s participation. In the reply e-mail, we may request further Personal Information from you (as defined in the main part of this Privacy Policy) about you and/or your child, but we will not request such information from your child. We will then send you a confirmatory e-mail of your child’s registration. Once your child is registered, we may request them to provide general information such as their favorite player. Under the Children’s Online Privacy Protection Act (“COPPA”), Parents have the right to:
· Review their child’s Personal Information, direct us to delete it, and refuse to allow any further collection or use of their child’s Personal Information, and
· Agree to the collection and use of their child’s Personal Information without allowing sharing with third parties, unless the disclosure is part of the service offered.
Parents can contact the Privacy Administrator at the address or email asset forth at the end of this policy and we will respond to their requests.
Information Use and Disclosure: We may use the Personal Information to provide the child with the special services for which he or she has registered, such as membership in a Kids club, receipt of newsletters, or participation in contests. We do not condition a child's participation in any of our online activities on the disclosure of more information than is reasonably necessary to participate in the activity.
Currently, the portions of the Websites that are directed to children under 18 do not have unscreened chat rooms, blogs, or other similar community functionality that would permit your child to disclose information to others or publicly. In addition, any “postcard” or “share with a friend” feature that may be available on these portions of the Websites will collect the recipient’s e-mail address, but not the sender’s; permit the sender to type in a first name and last initial; supply the content or allow the sender to select a pre-determined message from a menu; and be sent immediately, at which time the recipient’s e-mail address as collected from the sender is deleted from our records.
Personal Information collected on or through any portions of our Services that are directed to children under 18 may be shared with Service Providers (as defined above) with whom we contract to operate the Services. However, we will not share any Personal Information collected from children through our Services to our Service Providers, partners or any other third party in connection with sports betting and gaming services. As set forth above, we endeavor to maintain the confidentiality, security, and integrity of the Personal Information collected from your child. Other than our Service Providers and as described above, we will not share your child’s Personal Information with third parties. We may also collect, use and disclose this Personal Information as described in the other sections of this Privacy Policy.
15. Performance Monitoring and Wearable Devices
The use of GPS-based performance monitoring within elite soccer in the U.S., Canada, and Europe is common and is widely considered to be a safe and effective method of gaining valuable, objective data on player performance that can be used not only to improve individual player development, but also to identify players at risk of injury and potentially help reduce the risk of future injury. Employees participating in CT United through MLS NEXT Pro may be tracked through optical tracking systems during training and matches. Physical metrics derived from optical tracking include distance, speed, acceleration, deceleration, shot velocity and high-speed running.
16. Automated Decision Making and Profiling
We do not foresee making any substantive decisions about individuals using automated means or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the subject individuals; however, we will notify you in writing if this position changes.
17. Exclusions
This Privacy Policy does not apply to any Personal Information collected by CT United other than Personal Information collected through the Services or, in the case of Employee Personal Information, relating to recruitment, applications and employment. This Privacy Policy also does not apply to information about businesses or other non-individual users. CT United reserves the right to use and disclose aggregated or de-identified information for any commercially reasonable purpose.
18. 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 via the web at CT United Privacy Request, by calling toll-free at 855-657-2245, or by mailing us at:
CT United
9 West Broad Street
Stamford, CT 06902
Attention: Privacy Administrator/Legal Department
