Blitz: Draft™ Privacy Policy

Empyr Sports Inc. a Delaware Corporation that operates as Blitz: Draft™ (“Blitz: Draft™”, “we”, “us” or “our”) is committed to protecting your privacy in conjunction with the use of its website and app (collectively, “Service”).  This policy (“Privacy Policy”) describes, among other things, the types of information collected about you when you visit or use our Service, how your information may be used and disclosed, how you can control the use of your information, and how your information is protected.  It shall be interpreted in conjunction with our Terms of Service.  Capitalized terms outlined in this Privacy Policy but not defined shall have the meaning as set forth in our Terms of Service. By using the Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, your only choice is to not use our Services.
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By using our Service, you consent to the worldwide, perpetual collection, transfer, manipulation, storage, disclosure and other use of your information as described in this Privacy Policy.
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Please note that any content you submit via our Service which is personal information may be used, disclosed and retained by us in accordance with the terms of this Privacy Policy.

Summary of Data Collection, Disclosure and Sale
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Here is a short summary of data and the categories of data we have collected, disclosed, and sold over the last twelve (12) months. We do not sell data. The rest of this Privacy Policy provides more in-depth information on our privacy practices.

• Identifiers, such as contact details, such as real name, alias, address, telephone number, unique personal identifiers, online identifiers, IP address, email address, and account name.
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
• Categories of PI described in the California Consumer Privacy Act, GDPR or otherwise (including name, email, phone number, mailing address, birthday,)
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
  
• Commercial information: (Transaction information, purchase history, financial details, and payment information)
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
  
• Geolocation data: (device location)
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
  
• Internet or other electronic network activity information: (Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements)
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
  
• Inferences drawn from other personal information to create a profile about a consumer: (for example, an individual’s preferences and characteristics)
  - Do we collect? Yes
  - Will we disclose this data as part of our business? Yes
  - Will we sell this data? No
  
• Biometric information
  - Do we collect? No
  
• Characteristics of protected classifications under California or United States federal law
  - Do we collect? Yes
  
• Audio, visual or similar information
  - Do we collect? Yes
  
• Professional or employment related information
  - Do we collect? No
  
• Non-public education information (per the Family Educational Rights and Privacy Act)
  - Do we collect? No
  

You may also be asked to authenticate your account via Apple ID or Google Log In.
Some of this information may constitute sensitive personal information within the meaning of the comprehensive data privacy laws enacted in certain states.
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We will also collect other information which you choose to provide to us, including, without limitation, information that you may share when you contact our customer service by email or through the app, including through other tools we offer, such as our AI chatbot.  The content of your interactions with our AI chatbot may be used to train the chatbot, including the questions that you ask.  

Types of Information Collected
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Personal Data
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‍“Personal Data” is information by which you may be personally identified. We may collect the following Personal Data from you:

• Name;
• Email;
• Username;
• Photograph;
• Date of birth;
• Driver’s License Number;
• Social Security Number; and
• Any other information voluntarily supplied by you to us reasonably necessary to perform the Services.

Your bank account information, payment information, and other identifying information may be collected by us through third-party vendors, including our payment processors. Your data may be processed, collected, shared or stored by us and third-party vendors, including but not limited to website service providers, website analytics providers, third party payment processors, or other service providers we use to conduct business. Such processing, collection, sharing or storing of data by such third parties may be processed, collected, shared or stored by us, with the exception of our payment processors to process payments made via the Service.

Non-Personal Data
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‍Non-personal data includes any data that cannot be used on its own to identify, trace, or identify a person. We may collect your device information, including GPS data and IP address. When non-Personal Data you give to us is combined with Personal Data we collect about you, it will be treated as Personal Data and we will only use it in accordance with this Privacy Policy.
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How we collect information

‍We collect information when you provide it to us directly through an interaction with us; for example:

• When you apply or register for the Services;
• When you fill out contact or registration forms;
• When you fill out feedback forms;
• When you contact us through our Services;
• When you communicate through the Services or when using the Services;
• When you contact us for Service requests.

Why we collect and how we use your information.  (Legal Basis)

‍We collect and use your Personal Data when we have a legitimate purpose to do so, including but not limited to the following reasons:

• to verify your eligibility to use the Services (such as confirming you are 18 or older);
• when it is necessary for the general functioning of the Services, including to contact you;
• when it is necessary in connection with any contract you have entered into with us or to take steps prior to entering into a contract with us;
• when we have obtained your or a third party’s prior consent;
• when we have a legitimate interest in processing your information for the purpose of providing or improving our Services;
• when we have a legitimate interest in using the information for the purpose of contacting you, subject to compliance with applicable law; or
• when we have a legitimate interest in using the information for the purpose of detecting, and protecting against, breaches of our policies and applicable laws.

We may use aggregated (anonymized) information about our users, and information that does not identify any individual, without restriction.

The following information may be collected automatically from all visitors to the Service by either us or third parties acting on our behalf and may be used for tracking your activity on our website and for business purposes, as well as to comply with our legal obligations:

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by emailing us at Team@BlitzDraftFantasy.com. Please note that some Services features may be unavailable as a result.  

How We Use Information

We only use payment and identity verification information (such as bank account numbers, driver’s license numbers and social security numbers, or comparable national identifiers as necessary): for completing particular transactions; if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to protect the intellectual property rights of others; to address fraud, security or technical issues; or to protect our rights or property.
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All other information collected about you may be used for a wide range of other purposes, including to fulfill requests for services, to enable you to participate in Contests and polls, to provide information about your player rank on our leaderboard, to analyze the demographics of our customer base, to customize content to your needs, to improve our Services, to contact you when you have opted in to receive certain messaging, to respond to and address customer service requests, to market our brand, Contests and winners, to share with actual and potential sponsors for joint marketing purposes, to prevent potentially prohibited or illegal use of our Service or use of our Service in a manner that would violate the Terms of Service, and for any other purpose disclosed to you, or reasonably known by you, at the time we collect the information. By use of our Services, you agree to us using your information in the ways described herein and other sections of this Privacy Policy.

How We Disclose Information

‍We may disclose the information we collect from you to our third-party vendors, service providers, contractors, or agents who perform certain functions on our behalf, or help us provide, improve, and market our Service.  For example, we may share your personal information with our payment processors who will use this information to, without limitation: process transactions, engage in fraud prevention activities, and for regulatory compliance purposes.  We may also engage with service providers in connection with operating and improving the Service, to assist with certain functions, such as KYC verification, geotracking to ensure your location in a state where you are eligible to play, email transmission, data hosting, managing our ads, and some aspects of our technical and customer support. We will take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations, including through the execution of Data Privacy Agreements or Addenda, as applicable.  In certain circumstances, our service providers may share your personal information with us.  
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We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. This may involve the sharing of your information with law enforcement, government agencies, courts, and other organizations.

Security Measures in Use of Your Information

‍Access to your personal information within our organization will be limited to those individuals who require access to your personal information in order to perform their functions, and to the types and amount of such information necessary to perform those functions.  We are committed to the protection of your personal information from unauthorized access or use.  We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization.  Unfortunately, however, no data transmission or storage system can be guaranteed to be 100% secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted to the Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. In the event that there is a breach in the information that we hold; we shall notify of such breach via email or via a notice on the Services.
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We will only retain your personal information for so long as we have a business purpose for doing so; or, for the purpose of complying with applicable law, requests from law enforcement, or as necessary to fulfill any obligations in connection with a legal proceeding; or, because of any requirement to preserve any portion of your information in our backups.  

Depending on the state in which you reside, you may have certain additional rights with respect to your personal information.  These rights may include:  the right to access, correct and delete your personal information.  Additionally, where applicable, you may have the right to opt out from processing for: targeted advertising/cross contextual behavioral advertising, sale of your personal information, and profiling.  
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If you choose to share information with us, you may have the opportunity to update that information by contacting us at the following address: Team@BlitzDraftFantasy.com.
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In addition, under the United States’ California Consumer Privacy Act, Colorado Privacy Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Florida Data Privacy and Security Act, Iowa Consumer Data Protection Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Consumer Expectation of Privacy Act, New Jersey Personal Data Privacy Act, Oregon Consumer Privacy Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and Maryland’s, Indiana’s, Kentucky’s, and Rhode Island’s, other state-specific consumer privacy laws, regarding notice of information collected, residents of these states have statutory data rights. We provide the same control and rights over your data no matter where you choose to live in the United States. As a user of our Services, you have the following control over your data:

• Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.
• Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
• Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
• Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
• Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

We acknowledge your right to request access, amendment, or deletion of your data. We also recognize that you have the right to prohibit sale of your data, but we do not sell data.
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You can exercise the rights described above, by sending an email to Team@BlitzDraftFantasy.com. Only you, or an agent authorized to make a request on your behalf, may make a request related to your personal information.
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We cannot respond to your request if, (i) we cannot verify your identity; or (ii) your request lacks sufficient details to help us handle the request. We will make best efforts to respond to your request within forty-five (45) days of its receipt. If we cannot respond in forty-five (45) days, we will inform you, in writing, the reason for the delay and will respond to your request within ninety (90) days. Any information we provide will only cover the twelve (12)-month period preceding the request's receipt.

We do not charge a fee to process or respond to your 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. We are not obligated to provide responses to your data requests more than twice in a twelve (12)-month period.
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If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time, or as otherwise required by applicable law.  Please note, however, that we may retain certain information about you to satisfy both our legal and security obligations.  For example, some of your information may remain in backup storage even if you ask for it to be deleted. Additionally, if you have asked us to delete your personal information, we may no longer be able to provide certain services to you.  For instance, you will no longer be able to participate in Blitz: Draft™ contests, if you exercise this right.
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In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you.  

We honor the following universal opt out mechanism: Global Privacy Control supported by Take Control Of Your Privacy. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs.
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You may send your inquiries concerning the exercise of state privacy rights to Team@BlitzDraftFantasy.com.  For all requests, you must put the statement “My [STATE] Privacy Rights” in the subject line of the request.  
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Please note that Blitz: Draft™ may not be obligated to comply with the provisions of these laws, and in such case, any action we take in response to a request you may make is subject to our discretion and the terms set forth in this Privacy Policy.