Effective: January 1. 2022

FOS (“FOS” or “we”, “our” or “us”) respects the privacy of visitors to our online property, Front Office Sports (available at: frontofficesports.com; the “Website”) and users of our Services (including subscribers to our online newsletters).  This Privacy Policy describes our policies and practices regarding the collection, use and disclosure of Personal Information and other information through the Website and Services.  It also applies to other websites or services owned or provided by FOS and that post this policy.

This Privacy Policy is part of and subject to our Terms of Service [link].  Please review this Privacy Policy carefully. By using or accessing the Website and/or Services, you are accepting the terms and conditions of this Privacy Policy, and you expressly consent to the treatment of your Personal Information as defined in this Privacy Policy.  If you do not agree with any terms and conditions in this Privacy Policy, your only remedy is not to access the Website or the Services.

If you are a resident of California or the EEA, UK, Switzerland or Canada, please see the terms specific to California and European users, respectively, below.

  1. INFORMATION WE COLLECT

Personal information about you that is personally identifiable to you, like your name, address, and email address, as well as other non-public information

Information You Provide Directly to Us. We may collect Personal Information that you submit to us directly through the Website or Services, and via passive technologies integrated into the Services, including via third parties.  For example, to subscribe to any of our newsletters, you need only provide a valid email address.  

Passive Collection. The Website or Services also passively collect certain types of Personal information, including information relating to the device you use to access the Website and Services: email addresses, device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, and location.      

Cookies. A cookie is a small text file that’s placed on your computer or mobile device when you visit one  our Website. We, and some of our affiliates and third-party service providers, may use a few different types of cookies. Some are persistent cookies (cookies that remain on your hard drive for an extended period of time) and some are session ID cookies (cookies that expire when you close your browser).

Cookies help us to operate our Website and Services, enhance and customize your experience, perform analytics and deliver advertising and marketing that may be relevant to you.  The following types of cookies are deployed on the Website:

In addition, the following third-party cookies are deployed on our Website:

You can accept or reject cookies by amending your web browser controls. Because they’re important, our Website and Services might not work like they’re supposed to, and in some cases, might not work at all, if you decide to reject our cookies. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org. You also can manage your cookie settings by following your browser’s instructions. Here are some links that might be of assistance:

Beacons and Pixels. We also use web beacons and pixels on our Website and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email.

Online Behavioral Advertising — In some instances, you can opt-out of receiving online behavioral ads from third party advertisers and ad networks. We do not control third parties’ collection or use of your information to serve online behavioral advertising. Advertisers and ad networks that are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising provide opt-out choices at the following websites:

Be advised that these opt-out tools are provided by third parties and may not be available with respect to all online behavioral advertising that is presented to you. We do not control or operate these tools or the choices that advertisers and others provide through these tools.  Even if you opt out of receiving online behavioral advertising, you may still receive generic ads.

Google Analytics. We use Google Analytics to help us manage and improve the Website and Services. For more information on how Google Analytics collects and processes data, see www.google.com/policies/privacy/partners/. Google provides a Browser Add-On that allows you to opt-out of Google Analytics by downloading and installing the add-on for your web browser, available at:  https://tools.google.com/dlpage/gaoptout.

We may use your Personal Information for the following general and business purposes:

We use non-Personal Information such as web or mobile pages you have viewed, in order to analyze request and usage patterns so that we may improve our products and services, enhance our user experience, and gather broad demographic information for aggregate use. We may disclose non-Personal Information to third parties that promote our products and services. We reserve the right to use and disclose non-Personal Information to third parties in our discretion.

Your IP address is a code which is assigned to your computer every time you connect to the Internet. IP addresses are used to help diagnose problems with our server and to administer our Website. We use aggregated IP address information to compile reports on the demographics of the usage of the Website and Services for purposes of system administration, marketing, and to track potential abuse of our Terms of Service and this Privacy Policy

Unless you have opted-in to allow us to share your Personal Information with third parties (such as for marketing communications purposes), we do not sell, trade, rent, or share your Personal Information with third parties for their marketing purposes, and we will not disclose financial information that is part of your Personal Information, in each case unless you request or authorize that we do so.

If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address from which you contacted us.

We may disclose Personal Information to our corporate subsidiaries or affiliated entities. Any Personal Information provided to our subsidiaries or entities affiliated with us will be treated by those subsidiaries and affiliated entities in accordance with the terms of this Privacy Policy.

We may share your Personal Information with third party vendor and suppliers to provide you with the products and services, such as to send you our newsletters or to send you information regarding a webinar you have registered to attend. You expressly consent to the sharing of your Personal Information with our contractors and third-party service providers for the sole purpose of providing products and services to you. These service providers are contractually obligated to ensure the confidentiality of Personal Information and implement appropriate security measures.

We use third-party payment processors for any purchases you make through the Services. Be advised that we do not have access to or store any Personal Information, including credit card numbers or other financial information, you provide to these processors. This Privacy Policy does not apply to them, and we do not accept any responsibility or liability for their policies.

We may participate in co-branding or co-promotional agreements with third parties pursuant to which we may share Personal Information with such third parties (“Partner Companies”). For example, we may participate in agreements with Partner Companies pursuant to which we provide the Partner Companies with a URL and a customer registration page co-branded with, or private labeled by, the Partner Companies, such as for a sponsored webinar, and the Partner Companies distributes and promotes the URL to its customers. A Partner Company may have access to Personal Information that we collect from their customers. As a result, if you register on the Services through a Partner Company, we may provide your Personal Information to the Partner Company. We do not control the privacy practices of these Partner Companies.

We may use your Personal Information in order to provide to third parties non-personal aggregated information about you that does not allow you to be identified or contacted and that is combined with the Personal Information of other users (“Aggregate Information”). For example, we might inform third parties regarding the number of users of the Services and the activities they conduct while on the Services. We might also inform a company that performs services or that provides products and/or services to us (that may or may not be a business partner or an advertiser on the Services) that 50% of our users live in the USA” or that “85% of our users have purchased products and/or services which can be downloaded from the Services.” Depending on the circumstances, we may or may not charge third parties for this Aggregate Information.

Under the following scenarios, we may be required to share your Personal Information:

Other legal basis for collecting Personal Information are: (i) where we need the Personal Information for performance of a contract or requested service; or (ii) where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collect your Personal Information with your consent, you may withdraw your consent at any time as provided below.

If you reside or are located outside of the United States, you understand and agree that we may (i) collect, use, disclose and otherwise process the Personal Information you provide even if you are located outside the United States and (ii) collect, use, maintain, store, disclose and otherwise process your Personal Information using servers and systems located within the United States.

Subject to applicable law, an individual has the right to request from us a copy of what Personal Information that we have collected or to ask to correct or update their it. Individuals can also request that we delete their Personal Information from our systems and records. We strive to respond to these requests with 30 days or as required by applicable law.

Whenever you directly provide us with your Personal Information, please be sure it is accurate and complete. We cannot be responsible for any information you provide to us that is incomplete or incorrect.

We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will obtain your consent first and offer you the choice to opt-out of such proposed collection, use, or disclosure.

Our communications also provide you with the opportunity to update your preferences to select what messages to receive from us and their frequency. 

You also have options regarding the collection, use and sharing of your Personal Information under certain circumstances. When you receive promotional communications from us, you may specify a preference to stop receiving further promotional communications from us and you will have the chance to “opt-out” by following the unsubscribe instructions indicated in the communication you receive. You may also contact us at privacy@fos.company to opt-out of receiving any promotional communications. (Please include “Opt-Out” in the subject line.) Despite your selected preferences, we may need to send you non-marketing communications regarding the services we provide to you, such as notices about administrative updates, transaction reports, and notices regarding changes to the Services, this Privacy Policy or the Terms of Service.  You cannot opt out of receiving these types of communications.

Should you no longer wish to receive our any of our Newsletters to your inbox, you may click on the unsubscribe link located at the bottom of each message received, and/or contact us at privacy@fos.company, and we will immediately remove you from our distribution list and do not retain your email address.

California “Shine The Light” – As provided by California Civil Code 1798.83, if you are a California resident, you have the right to receive (a) information identifying any third party company(ies) to whom we have disclosed your Personal Information to in the past year; and (b) a description of the categories of Personal Information disclosed. To obtain such information, please email your request to privacy@fos.company with “California Privacy Rights Request” in the subject line.

For California residents under the age of 18 and registered users, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on the App or Site. Any such request should be sent to us at privacy@fos.company along with a description of the posted content or other information to be removed. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.

Further, the Website does not currently recognize “Do Not Track” settings or technologies.

California Consumer Privacy Act – The California Consumer Privacy Act (CCPA) gives California consumers enhanced rights with respect to their personal information that is collected by businesses. The CCPA provides California consumers with three rights regarding their personal information.

First, California consumers can opt out of the sale of their Personal Information. However, FOS does not sell your Personal Information.

Second, California consumers may opt out of having their personal information sold to other persons or parties. Second, California consumers can request to know:

Third, California consumers can request that a business delete Personal Information about the consumer that a business has collected from the consumer.

FOS is a covered business under the CCPA as it collects and processes the Personal Information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the CCPA.

In the preceding twelve (12) months we have: (1) collected the following categories of personal information; and (2) disclosed such categories of personal information for a business purpose.  (For the categories of third parties with whom we may disclose or sell personal information, please see the section above, “How We Share Your Information”.)

CategoryExamplesCollected?Disclosed for Business Purpose?
A. IdentifiersName, postal address, e-mail address, IP address.YesYes
B. Personal information categories listed in the California Customer Records statuteName, telephone number, credit card and debit card information or other financial informationNoNo
C. Protected classification characteristics under California or federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender, sexual orientation, veteran or military status, genetic information (including familial genetic information).NoNo
D. Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NoNo
E. Biometric informationGenetic, physiological, biological or behavioral characteristics.NoNo
F. Internet or other similar network activityBrowsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YesNo
G. Geolocation dataPhysical location or movements.NoNo
H. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NoNo
I. Professional or employment-related informationCurrent or past job history or performance evaluations.NoNo
J. Non-public education information collected by certain federally funded institutionsEducation records directly related to a student maintained by an educational institution or party acting on its behalf.NoNo
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NoNo

To make a “Request to know” or “Request to Delete” your personal information, please use our CCPA Interactive Request Form. Authorized agents may also complete and submit the online Request Form [link] on behalf of a California Consumer.

We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.

Before responding, we must verify that the person making the request is the person about whom we have collected their personal information. We may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our account authentication process. This is also to protect against fraud. We will not retain this Personal Information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any Personal information about you or we are not able to verify your identity for matching purposes. Deleting your Personal Information may result in the closing of your account and inability to access the Services. However, you can always re-register at any time.

(Residents of Nevada and other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at privacy@fos.company.)

FOS and the Services are located in the United States and governed by US law. If you are outside the United States when you visit the Services or engage in communications with us, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Services and will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note that your Personal Information may be available to the US Government or its agencies under legal process in the United States.

The Legal Basis for Using EEA, UK and Swiss Personal Information

For residents of the European Economic Area (EEA), United Kingdom and Switzerland, we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”) or from the United Kingdom under Article 45 of the UK GDPR.

Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, including to provide you with our daily Newsletter, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.

To exercise rights under the GDPR or UK GDPR, please use our online Request Form [link] or send us an email at privacy@fos.company.

Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.

To the extent that we transfer Personal Information from the EEA, UK or Switzerland to a jurisdiction outside the EEA, UK or Switzerland that has not been adduced by the European Commission or UK Secretary of State or Information Commissioner’s Office as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.

Rights for EEA. UK or Swiss Residents

In addition, if you are a resident of the EEA, UK or Switzerland, you have the right to:

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.

If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us.

Similarly, if we collect and use your Personal Information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.

We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.

To withdraw consent or exercise these rights, please contact us via email at privacy@fos.company.

If you are not satisfied with our response, or believe we are processing your personally identifiable information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State, UK or Switzerland. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.  The data controller is Front Office Sports LLC

10. USERS IN CANADA

Users of the Website and Services from Canada are informed we take appropriate steps to comply with applicable Canadian data privacy requirements, including the Anti-Spam Legislation (CASL) and the Personally identifiable information Protection and Electronic Documents Act (PIPEDA). Note, however, that personally identifiable information stored or processed outside of Canada, including in the US or another foreign country, may not be subject to the PIPEDA. In addition, personally identifiable information stored or processed outside of Canada is subject to the laws of that other country and may be available to the foreign government of the country in which the Personal Information or the entity controlling it is located pursuant to a lawful order in that jurisdiction. This Privacy Policy is intended to provide the required notices regarding our collection and use of personally identifiable information, including transfer to the United States.

You may request to access, correct, or delete your personally identifiable information, or withdraw consent to our collection, use or disclosure of your personally identifiable information, by contacting us at privacy@fos.company.

These rights are subject to applicable contractual and legal restrictions and reasonable notice. We may take reasonable steps to verify your identity before honoring any such requests.

11. SECURITY

FOS has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use as described. While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

We will retain your information for the time necessary to provide a requested service, realize our legitimate business purposes and to comply with the law. We will only retain personal information for the longer of the period if: (a) required by law, or (b) there is a time-bound determination business need.  If you unsubscribe to a newsletter, we do not retain your email address.

12. NO RIGHTS OF THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personally identifiable information relating to users of the Website or Services.

13. CHILDREN’S INFORMATION

The Website and Services are not intended to be used by children under the age of 13, and we will not knowingly collect Personal Information from children under this age. We do not use an application or other mechanism to determine the age of users of the Website and Services. All information provided to FOS will be treated as if it was provided by an adult. If, however, we learn that a child has submitted information about himself/herself to us, we will delete the information as soon as possible.

14. LINKS TO THIRD-PARTY WEBSITES

The Services may contain links to and from third party websites of our business partners and various contact management services and other service providers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check their individual privacy policies before you submit any Personal Information to those websites.

Our provision of a link to any other website or location is for your convenience and does not indicate our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites.

15. UPDATES TO PRIVACY POLICY

We may modify this Privacy Policy from time to time.  We will notify you of changes by posting changes the Website or by other appropriate means and the effective date of the updated policy. Your continued access to and use of the Website and Services after the effective date constitutes your consent to the updated policy. 

16. CONTACT US

Should you have any questions, concerns or feedback regarding this Privacy Policy, please contact us by email at privacy@fos.company.

You can also mail us at:

FOS

80 Pine Street

Suite 3202

New York, NY 10005