Play Online

Privacy Policy

Last revised November 25, 2024

This privacy policy (“Privacy Policy”) describes how WPT Enterprises, Inc., its affiliates, subsidiaries, and parent companies (collectively, “Company”, “WPT”, “us”, “our”, or “we”) collect and process personal information related to our website, www.worldpokertour.com, any other websites and applications operated by WPT (“Site”), and our online or offline services (collectively, “Services”). In some cases, additional or supplemental privacy notices may be provided and will apply to certain personal information collected and processed by us.

If you are a California resident, please review the “California Privacy Policy and Notice at Collection” section below.

Your use of our Services and any dispute over privacy is subject to this Privacy Policy and our Terms of Service, available at: https://www.worldpokertour.com/terms-of-service/. The information we collect is controlled by WPT Enterprises, Inc., which is headquartered in the United States at 17877 Von Karman Avenue, Ste. 300, Irvine, CA 92614.

Types of Personal Information WPT Collects:

  • Registration information. If you register to use the Site and Services, we may collect first and last name, phone number, and e-mail address.
  • Player Tracking. We track live events, player rankings, Player of the Year, how many titles players have won, how many WPT final tables they have made, how many times they have cashed in a tournament, and their total amount of WPT earnings. We may also track website usage and demographic data.
  • Website Activities and Usage Information. When you visit our Sites or use our Services, we and third parties automatically collect usage information including information about how visitors use and navigate our Site, the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses. We may also determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail, advertisement, promotional announcement, or similar service. Vimeo may also collect personal information from our Site, for example, to track user engagement and video performance. Please review its privacy policy at: vimeo.com/privacy for more information.
  • With Your Consent. In certain circumstances, WPT collects personal information with your consent. For instance, when you enter a sweepstakes, complete a survey, make a purchase, subscribe to our newsletter, or register for any portion of our Services, you may be asked to provide personal information such as your e-mail address, name, gender, or phone number. Additional information such as your age may also be requested and will be used to verify your eligibility to win sweepstakes.

How WPT Uses and Discloses Personal Information:

  • To Provide Our Services. WPT may use personal information related to our Services, for example, to send our newsletter; communicate with you about the Services; provide troubleshooting and technical support; fulfill orders and requests; plan and manage events; improve the Site and Services; and for other similar purposes. We may disclose personal information to vendors who provide us with services such as technical maintenance or forums software, for them to provide us with relevant services. If you make a purchase, we may disclose your information to third parties for purposes of credit card processing and order fulfillment. If you enter an online sweepstakes, we may use your personal information to notify you if you are a winner and may disclose the names of sweepstakes and contests winners in accordance with applicable law.
  • For Our Featured Partnerships. You may also provide personal information in areas of the Site that are managed by third parties, such as our featured partners. In such cases, the personal information will be used by us and by such third party(ies), each pursuant to its own policies.
  • To Our Licensees. We may license our trademark to third parties who may offer certain products, services, websites, and features, which are governed by separate terms of use and privacy policies.
  • Related to Other Corporate and Third-Party Partnerships. We may work with other entities to co-sponsor events and activities. Please note that personal information collected during joint registrations may be collected under this Privacy Policy, the privacy policy of the other entity, and/or the privacy policy you see when you register. Links from our Site to a third-party site are also governed by the third party’s privacy policy which we urge you to read carefully.
  • For Advertising, Marketing, and Analytics Purposes. We may use personal information to send you information that you sign up for or that we think may be interesting to you, and to manage analyze, measure, and improve our outreach. In certain circumstances, we provide your personal information to our advertisers, so that they can serve ads to you that meet your needs or match your interests, and/or with our key partners in the industry to market their products that we think will be of interest to you. For example, similar sweepstakes products, poker related materials and promotions, online gaming partners, etc. WPT does not bear any responsibility for any actions or policies of third parties.
  • Security and Protection of Rights. To protect the Services and our business operations, to prevent and detect fraud, unauthorized activities and access, and other misuse, where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our terms or this Privacy Policy.
  • As Required by Law. There may be occasions when we are legally required to provide access to our database in order to cooperate with governmental agency investigations or other legal proceedings. In those instances, personal information is disclosed for the specified purpose.
  • For General Business and Operational Support. We reserve the right to disclose, share, and/or otherwise transfer user information, including without limitation personal information, to assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

Cookies and Tracking:
We and other third-party providers use cookies and similar tracking mechanisms to track your use of our Site.

  • Cookies. Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics activities.
  • Web beacons, pixel tags, and similar technologies. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use web beacons (also known as clear GIFs, web bugs, pixel tags, or action tags, among other names), in connection with our Site and Services to perform functions like tracking the activities of visitors to our Site, helping us manage content, and compiling statistics about usage of our Site. We or our third-party providers may also use clear GIFs in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
  • Analytics. We and third parties, such as Google Analytics, use cookies and other tracking technologies to evaluate how visitors interact with our Site. We use these tools to help us improve our Site, performance, and user experience. See below for Your Choices.

Privacy Choices:
You may manage your preferences and privacy choices, as described below:

  • Cookie Settings. To prevent cookies from tracking your activity on our Site or your visits across multiple websites, you can set your browser to block certain cookies or to notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the website, but some features may not function. Please note that third parties may collect personal information about your online activities over time and across different websites when you use the Site. If you no longer wish to have your information shared for these purposes, contact us at [email protected].
  • Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). You also may opt out of receiving Interest-Based Ads from many third-party ad networks, such as those provided by members of the NAI and DAA. For more information regarding Interest-Based Ads by NAI and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org and optout.aboutads.info. You must opt out on each browser and on each device.
  • Marketing Communications. You may consent or withdraw your consent to our use of your personal information for marketing at any time by following the instructions to unsubscribe included in each marketing-related e-mail sent to you. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you administrative messages relevant to any specific Services you may have signed up for. If you do not wish to receive marketing communications from us you may, subject to applicable law, refuse to give consent or opt out at any time by following the unsubscribe instructions contained within our e-mails, or by contacting us at [email protected].
  • Google Analytics. We and third parties, such as Google Analytics, use cookies and other tracking technologies to evaluate how visitors interact with our Site. We use these tools to help us improve our Site, performance, and user experience. You can download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Minors:
WPT.com is not directed toward minors. We do not knowingly permit registration or use of WPT.com by minors, and we do not knowingly collect personal information from minors. If we discover that a minor has provided us with personal information, we will use commercially reasonable efforts to delete such person’s personal information from our system.

Security:
We employ a number of measures designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. WPT urges you to take steps to keep your information safe such as choosing a strong password, avoiding sharing your password, logging out of your account, and closing your web browser.

External Links:
Our Site may contain links to or advertisements about non-WPT websites. Other websites may also reference, advertise, or link to WPT Sites. WPT does not endorse or sponsor other websites, is not responsible for the privacy practices or the content of non-WPT sites, expressly disclaims any statements or assertions made on such websites, and denies all liability associated with your use of and the content on such other websites. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through other websites. We encourage you to read the privacy policies of other websites you may visit.
Consent to Processing in the United States:
This Site is operated in the United States. By providing us your personal information, all users, including, without limitation, users in the member states of the European Union, Canada or elsewhere outside of the United States, fully understand and unambiguously acknowledge this Privacy Policy. By using our Site, participating in any of our Services and/or providing us with your personal information, you consent and agree to the collection, transfer, storage and processing of your personal information to and in the United States.

International Transfers:
Personal information collected on the Site may be stored and processed in any country in which we or our affiliates, suppliers, or agents maintain facilities. By using the Site, you expressly consent to any transfer of information outside of your country or jurisdiction of residence. Where personal information that we collect is transferred to and processed in the United States or anywhere else outside the European Economic Area (“EEA”) for the purposes described in this Privacy Policy, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements such as the EU Commission approved Standard Contractual Clauses. You may have a right to request more information about the mechanisms under which your data is transferred outside the EEA. If you reside in Australia, your personal information may be transferred outside of Australia to recipients located in the United States.

ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN STATES

A. California Privacy Policy and Notice at Collection
This Section of the Privacy Policy provides additional information for California residents and describes our information practices pursuant to applicable privacy laws, including the California Consumer Privacy Act and the regulations issued thereto, each as amended (“CCPA”). To the extent you are a California resident, and we collect “personal information” subject to the CCPA, the following applies.
This Section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or de-identified or aggregated information.
Categories of Personal Information Collected. Generally, we collect the following categories of personal information:

  • Identifiers such as name, alias, address, unique personal identifier, online identifier, IP address, e-mail address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
  • Customer records such as signature, physical characteristics or description, address, telephone number, Social Security number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial or payment information.
  • Protected classifications such as characteristics of protected classifications under California or federal law such as sex, age, and national origin.
  • Commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
  • Internet or other electronic network activity information such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Geolocation data such as location information about a particular individual or device.
  • Audio, Electronic, Visual, or Similar Information such as audio call recordings (e.g., of customer support calls).
  • Inferences such as inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior, or attitudes.
  • Sensitive personal information in limited circumstances, we may collect Social Security, driver’s license, state ID, or passport number.

Disclosures of Personal Information to Third Parties for a Business or Commercial Purpose. We may disclose each of the following categories of personal information to the following third parties for a business or commercial purpose. We may disclose identifiers, internet and other electronic activity information, and inferences to advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, data brokers, and others as permitted by law. We may disclose protected classifications, commercial information, and geolocation data to advertising networks, internet service providers, data analytics providers, government entities, and others as permitted by law. We may disclose consumer records, sensitive personal information, and audio, electronic, visual, or similar information to government entities, and others as permitted by law.

Sales and Sharing of Personal Information. California privacy law defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” as disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. We may “sell” or “share” the following categories of personal information for advertising purposes: identifiers and internet or other electronic network activity information to third-party advertising networks, analytics providers and social networks for purposes of marketing and advertising products and services we believe may be of interest to you.

We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

Purposes for Collecting and Disclosing Personal Information. As more fully described in the “How WPT Uses and Discloses the Information We Collect” section, we may collect and process the above listed personal information for the following business or commercial purposes and as otherwise directed or consented to by you: operate our business; communicate with you; for marketing and promotions; customization and personalization; research and development; surveys and feedback; promotions and contests; planning and managing events; audits and assessments; analytics and improvement; business transfers; security and protection of rights; compliance and legal process; auditing, reporting, and other internal operations; and general business and operational purposes.

Sources of Personal Information. In general, we may collect personal information from the following sources: directly or indirectly from you; vendors and service providers; advertising networks; data analytics providers; social networks; internet service providers; operating systems and platforms; government entities; data brokers; and business customers.
Sensitive Personal Information. We do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA.

Retention. We retain the personal information that we collect only as reasonably necessary for the purposes described above or as otherwise disclosed to you at the time of collection. For example, we will retain your account information for as long as you have an active account with us and additional information as necessary to comply with our tax, accounting, and recordkeeping obligations, to provide you with the Services you have requested, as well as an additional period of time as necessary to protect, defend, or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may deidentify or aggregate it and use it in compliance with the CCPA.

California Residents’ Rights. California residents have the following rights (subject to certain conditions and exceptions):

  • Right to Know. The right to know what personal information we have collected about you, including the categories of personal information we collected about you; the categories of sources from which we collected your personal information; the business or commercial purpose for collecting, selling, or sharing your personal information; the categories of third parties to whom we have disclosed your personal information; and the specific pieces of personal information we have collected about you.
  • Right to Delete. The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
  • Right to Correct. The right to request that we correct inaccuracies in your personal information, subject to certain conditions and exceptions.
  • Right to Opt-out of Sales and Sharing. The right to opt-out of the “sale” and “sharing” of your personal information. To opt-out of sale/sharing please click the Do Not Sell or Share My Personal Information / Your Privacy Choices link in the footer of our website. We will also honor your right to opt out as signaled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC, you can visit the Global Privacy Control page at https://www.globalprivacycontrol.org. If you visit our Site from a different device or from a different browser on the same device, you will need to opt-out or use an opt-out preference signal for that browser and/or device.
  • Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of sensitive personal information that would trigger this right under the CCPA.
  • Right to Non-Discrimination. You have the right not to be subject to discriminatory treatment for exercising your rights under the CCPA.

Submitting CCPA Requests. California residents may exercise their CCPA rights through the following methods:

  • Calling our toll-free phone number at (800) 987-9096.
  • E-mailing us at [email protected].

Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify the identity and authority of the authorized agent.

Your California Privacy Rights under Shine the Light Law. California’s “Shine the Light” law permits California residents who provide us certain personal information to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes. To make a California Shine the Light request, please email us at [email protected]. You must include this Site as the subject line, and your full name, e-mail address, and postal address in your message. Requests may be made once per year.

Contact Us. For more information about our privacy practices, you may e-mail us at [email protected] or contact us at:
Privacy Administrator
WPT Enterprises, Inc.
17877 Von Karman Avenue, Suite 300
Irvine, CA 92614

B. Additional Information for Texas Residents
Residents of Texas, may have rights under the Texas Data Privacy and Security Act (“TDPSA”), subject to certain limitations, which may include:

  • Access. The right to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
  • Delete. The right to delete their personal information provided to or obtained by us.
  • Correct. The right to correct inaccuracies in their personal information, taking into account the nature and purposes for processing the personal information.
  • Opt-Out. The right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their personal information, as such term is defined under the TDPSA; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

If you are a Texas resident, you may submit a request to exercise most of your privacy rights under the TDPSA online by emailing [email protected].

To opt out of sales and targeted advertising by us, you can adjust your cookies settings by clicking on the cookie preference manager on a WPT webpage or download an opt-out preference signal, such as the GPC. We will respond to your request as required under applicable privacy law. If we deny your request, you may appeal our decision by emailing us at [email protected].

ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS

This Section governs the way in which we process the personal information of individuals who reside in Canada. This Section is an integral part of our Privacy Policy and therefore, any definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

When you access our website and use our Services, we collect certain information about you. For the purpose of this section, “personal information” is defined as information about an identifiable individual and that allows that individual to be identified directly or indirectly.

Purposes for Collecting and Disclosing Personal Information. In general, we collect, process and disclose personal information identified in the “Categories of Personal Information” section above for the following business and commercial purposes, as more fully described in the “How WPT Uses and Discloses the Information We Collect” section above. This includes, but is not limited to operate our business, communicate with you, marketing and promotions, customization and personalization, research and development, surveys and feedback, sweepstakes and contests, planning and managing events, audits and assessments, analytics and improvement, business transfers, security and protection of rights, compliance and legal process, auditing, reporting, and other internal operations, other purposes required or authorized by law.

Unless allowed by applicable law, we will not collect additional personal information or use or disclose the personal information we collected in a way that is materially different, unrelated, or incompatible with the identified purposes without providing you with prior notice of our intention to do so and, if required by law, seeking your consent.

In general, we collect, use, or communicate your personal information with your consent. We may however use or communicate your personal information without your consent in certain situations when permitted by applicable law. For example, we may use your personal information without your consent for security or for fraud prevention purposes. In certain cases, we may not be able to provide certain services to you or process an application on your behalf if you do not agree to the collection of personal information.
You have the right to withdraw your consent to the use or communication of your personal information: however, this will not affect the legality of any processing done prior to this withdrawal.

Right to Request Access and Correction of Personal Information. You have the right to request access to and correction of the personal information that we have collected about you. Your right to access personal information is not absolute but subject to restrictions in applicable law. If we do not make the correction you have requested, we will annotate the records to show that you made the request and explain to you why we did not make the correction.

To make a request for access or correction, you may contact us as described below.

Rights for Quebec Residents. If you are a resident of the province of Quebec, in addition to the rights stated above for Canadian residents, the following provisions and rights apply to you.

You may request a copy of your personal information in a commonly used technological format and to have such information communicated to a third party you designate (data portability). You also have the right to request, in certain circumstances, that we cease disseminating your personal information or that we de-index any hyperlink attached to your name (right to be forgotten).

ADDITIONAL INFORMATION FOR EU AND EEA RESIDENTS

Definitions. Data Protection Legislation means the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”) and/or any other applicable data protection or national/federal or state/provincial/emirate privacy legislation in force, including where applicable, statutes, decisions, guidelines, guidance notes, codes of practice, codes of conduct and data protection certification mechanisms issued from time to time by courts, any supervisory authority and other competent authorities.

All the terms “personal data”, “data controller”, “data processor”, “processing”, “recipients”, “data subjects”, “consent”, “supervisory authority” have the same meaning as in the GDPR.

Contact Us. When you visit our Site or use our Services, the data controller of your personal data is WPT Enterprises, Inc., which is headquartered in the United States at 17877 Von Karman Avenue, Ste. 300, Irvine, CA 92614.
WPT Enterprises, Inc.’s representative in the EEA is: Peerless Media Limited.
If you have concerns or questions about any aspect of this Policy, you may e-mail our Privacy Policy Coordinator at [email protected]. We welcome your feedback. You can also send us regular mail at the following address:
Privacy Administrator
Peerless Media Limited,
Suite Burns House,
19 Town Range,
Gibraltar

Categories of Personal Data. The categories of personal data we process are the following and correspond to those qualified as personal information in the main body of the Privacy Policy:

  • Contact information. Some areas of our Site require you to register and provide information such as first name, last name, date of birth, phone number, or e-mail address.
  • Age. Your age is requested to verify your eligibility to subscribe or win sweepstakes.
  • Player Tracking. We track live events, player rankings, Player of the Year, the number of titles players have won, how many WPT final tables they made, how many times they cashed in a tournament, and their total amount of WPT earnings. We may also track website usage and demographic data.
  • Website Activities and Usage Information. When your computer or mobile device contacts our web servers (for example, when you visit this Site or view an HTML e-mail), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate our Site, the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses. We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail, advertising or promotional announcement or similar service. This information is used to analyze and improve this Site and to provide you with a more fulfilling and relevant experience. See the section below titled Cookies for more information on how we use automated tracking technologies.
  • Whenever you provide us with your personal data voluntarily to participate in sweepstakes, complete a survey, make a purchase, subscribe to our newsletter or register for any portion of our Services, you are asked to provide information (e.g., your e-mail address, name or phone number).

Please note that you can always choose not to provide certain personal data. However, in such case, you will not be able to benefit from certain aspects of the Site’s features.

Purposes and legal basis for processing. We process your personal data for specified, explicit and legitimate purposes, and ensure that we have an appropriate legal basis process it.

You will find below the legal basis associated to each purpose:

Purpose Legal basis
Provide our Services Performance of our contract with you
Ensure security and protection of our Site Our legitimate interest to prevent fraud
Market and promote our Services or those of our key partners Your consent when required or our legitimate interest when consent is not required
Assess your financial capacity Necessity to comply with our legal obligations
Process your requests to exercise your GDPR rights Necessity to comply with our legal obligations

Data Recipients. We may share your personal data for the purposes mentioned above. The recipients of your personal data may be the following:

  • Vendors and service providers. (Notably for technical maintenance or forums software, provision of credit card services or order fulfillment when you make a purchase), third party advertising networks, analytics providers and social networks, our featured partners when you provide your personal data on our Site to areas of the Site managed by said partners, or through cookies.
  • Subsidiaries and affiliates. We may disclose personal data on a need-to-know basis to our subsidiaries, parent or affiliated companies to help us support our Services. These subsidiaries and affiliates will use the disclosed personal data only for the purpose mentioned in this Privacy Policy.
  • Business transfers. We may share information if all or part of WPT is sold, merged, dissolved, acquired, or in a similar transaction. We may also share certain personal data as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence, or as necessary to plan for the transfer.
  • Compliance and legal obligations. We may also disclose personal data to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process.

Data Retention. We retain your personal data in our active database as long as necessary to provide the Services (i.e., as long as your account is active). Once your account is deleted, the personal data related to your account is stored in an intermediary archive on a separate space accessible only on a restricted basis by the relevant personnel (mainly the legal department). Only the personal data relevant to comply with our legal obligations or defend our rights in the event of a claim or a dispute is kept for 5 years after the closing of your account. After the data retention term defined above, your personal data is deleted or anonymized.

International Transfers. Your personal data may be transferred outside the EEA to a country which does not benefit from an adequacy decision of the EU Commission and is not considered as providing an adequate level of data protection, such as the United States of America.

We have implemented appropriate and suitable safeguards to protect your personal data, including the EU Commission’s relevant Standard Contractual Clauses (SSCs), and, where applicable based on a transfer impact assessment, supplemented such safeguards by additional contractual, organizational, and technical measures. For further information on the safeguards implemented to protect the transfer of your personal data or to obtain a copy of same, you can contact our Privacy Policy Coordinator at [email protected].

Your Legal Rights. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data:

  • Right to Access Personal Data. You have the right to ask us to confirm whether we are processing your personal data and, if so, to inform you of the characteristics of the processing(s) of your personal data and to obtain a copy of such personal data.
  • Right to Rectify or Erase Personal Data. You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it. You can also request that we erase your personal data in limited circumstances where:
    • it is no longer needed for the purposes for which it was collected; or
    • you have withdrawn your consent (where the data processing was based on consent); or
    • following a successful right to object (see Right to Object below); or
    • it has been processed unlawfully; or
    • to comply with a legal obligation to which we are subject.

      • We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:

    • for compliance with a legal obligation; or
    • for the establishment, exercise, or defence of legal claims.
  • Right to Restrict the Processing of Your Personal Data. You can ask us to restrict your personal data (i.e., to retain it without using it), but only where:
    • its accuracy is contested, to allow us to verify its accuracy; or
    • the processing is unlawful, but you do not want it erased; or
    • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
    • you have exercised the right to object, and verification of overriding grounds is pending.
      We can continue to use your personal data following a request for restriction, where:
    • we have your consent; or
    • to establish, exercise or defend legal claims; or
    • to protect the rights of another natural or legal person.
  • Right to Transfer Your Personal Data (Right to Portability). You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
    • the processing is based on your consent or on the performance of a contract with you; and
    • the processing is conducted by automated means.
  • Right to Object to the Processing of Your Personal Data. You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
    If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
  • Right to Object to the Use of Your Personal Data for Direct Marketing Purposes. You have the right to object at any time to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
  • Right to Withdraw Consent. If the processing of your personal data is based on consent, you can withdraw your consent at any time, without affecting the lawfulness of the processing carried out prior to your withdrawal of consent.
    For example, if you would like us to stop sending promotional communications to your e-mail address, you may opt out of receiving them by following the “unsubscribe” instructions at the bottom of each communication.
  • Digital Legacy. Individuals residing in France have the right to set out instructions (general or specific) about what happens to your personal data after your death.
  • Right to Obtain a Copy of Personal Data Safeguards Used for Transfers Outside Your Jurisdiction. You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the EEA.
    We may redact data transfer agreements to protect commercial terms.
  • Right to Lodge a Complaint with Your Local Supervisory Authority. You have a right to lodge a complaint with your local data protection reglatory authority if you have concerns about how we are processing your personal data. In France, the supervisory authority is the Commission Nationale de l’Informatique et des Libertés (CNIL) – https://www.cnil.fr.

    We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How To Exercise Your Rights. If you would like to exercise any of the rights described above, please send us a request at [email protected]. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee, where permitted by law, for instance if your request is manifestly unfounded or excessive.

Subject to legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.