menu Privacy Policy

DRAFT PRIVACY POLICY

EFFECTIVE DATE: AUGUST 29TH, 2017

Welcome! This privacy policy (“Privacy Policy”) governs the website www.draft.com (including both mobile and online versions) (the “Site”), the Draft mobile application (the “App”), and your use of any interactive features, fantasy services, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy (collectively with the Site and the App, the “Service”), which are made available by StarStreet, LLC (“StarStreet”, “we” “our” or “us”). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Service, which governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms and Conditions and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use this Service.

1. What Information Does the Service Collect?

  1. Information You Provide to Us

    On the Service, we may ask you to provide us, or our service providers, with certain categories of information, such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last your name, email address, mailing address, telephone numbers, social security number, birth date, credit card or bank account information (“Personal Information”); and (2) demographic information, such as information about your gender (“Demographic Information”). We may collect this information through various forms and in various places on the Service, including if you register for an account, through “contact us” forms, or when you otherwise interact with the Service. If we combine Demographic Information with the Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy.

  2. Information Collected and Stored As You Access and Use the Service

    In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. When your Device contacts our web servers (for example, when you visit this Service or view an HTML email), our web servers automatically collect Usage Information. We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, email, advertising or promotional announcement or similar service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.

    This Usage Information may include:

    • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
    • your Device functionality (including browser type, operating system, hardware, mobile network information);
    • the areas within our Service that you visit and your activities there, including remembering you and your preferences;
    • your Device location;
    • your Device characteristics; and
    • certain other Device data, including the time of day, referrer data that identifies the web page visited prior and subsequent to visiting our Service among other information.

    We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Service, include, without limitation, the following (and subsequent technology and methods later developed):

    • Browser Cookies. Like many websites, we use browser “cookies”. Cookies are a website’s way of remembering who you are. A cookie is a small text file that is stored on your computer’s hard drive or stored temporarily in your computer’s memory. There are two kinds of cookies: those that are “session” oriented and those that are “persistent”. Session cookies delete from your computer when you close your browser. Persistent cookies retain information for later use tomorrow, next week, next month, or whenever they are set to expire. We use cookies to help us to identify account holders and to optimize their experience on our Service. Also, we will use cookies to monitor and maintain information about your use of this Service. Most web browsers accept cookies automatically. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. If you decline to accept cookies, you may not be able to take advantage of or participate in certain features of this Service and when you revisit our Service your ability to limit cookies is subject to your browser settings and limitations. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.
    • Flash Cookies. Our Service enables the use of the Adobe Flash Player. Adobe’s Flash Player is a commonly used software use by websites that offer video and other interactive content. By default, your use of the Adobe Flash Player generates “flash cookies” (also known as “persistent identification elements” or “local shared objects”). Adobe provides a short disclosure about Flash Cookies in its End User License Agreement, stating: “Use of the web players, specifically the Flash Player, will enable the software to store certain user settings as a local shared object on our computer. These settings are not associated with you, but allow you to configure certain settings within the Flash Player.” The Adobe Flash Player (and similar applications) use flash cookies to remember user settings, preferences and usage similar to the browser cookies referenced above, but flash cookies can store more information than browser cookies and are managed through a different interface than the one provided by your web browser. You can control the degree to which you accept flash cookies by accessing your Adobe Flash Player management tools directly through the settings manager for Adobe Flash, located at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you do not allow flash cookies to take any disc space on your computer, you may not be able to take advantage of or participate in certain features on the Service. Users with a computer running the Windows operating system can view flash cookie files in this folder: \Documents and Settings\[username]\Application Data\Macromedia\Flash Player. Users with a computer running the Apple operating system can view flash cookie files in this folder: \/users\/[username]\/Library\/Preferences\/macromedia\/Flash Player. Flash cookies, or LSO files are stored typically with an “.SOL” extension. Although the Adobe Flash Player is a commonly used software used by websites that offer video content and/or games, it is not the only technology being used in the ever-shifting online and mobile content environment. HTML5 is an increasingly popular web standard used for presenting content, especially content delivered to mobile devices. HTML is the mark-up language used for the World Wide Web. Almost all web pages you visit on the internet are based around HTML code. HTML5 is simply the fifth and latest iteration of this mark-up language that allows for more interactive web pages. One of the real benefits of HTML5 is its potential to standardize the highly fragmented rich-media universe. Some HTML5 code may allow your response to advertising and other activities to be monitored across websites and such information to be stored on your computer or mobile device.
    • Web Beacons. Our web pages, online services and email messages may contain a small graphic image called a web beacon, which is sometimes also called a “clear gif”, that allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small or invisible to the user, but, in general, any electronic image viewed as part of a web page or email, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to our web pages or to monitor how our users navigate our Service, and we may include web beacons in email messages in order to count how many of the messages we sent were actually opened or acted upon. We use web beacons to compile aggregate statistics about our Service and our marketing campaigns.
    • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
    • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
    • ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
    • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

    We may use Tracking Technologies for a variety of purposes, including:

    • Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Service functionality.
    • Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, ads, products or services offered through the Service.
    • Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you use our Service or keeping track of your specified preferences.
    • Targeting-Related. We may use Tracking Technologies to deliver content, including ads relevant to your interests on our Service and third-party services based on how you interact with our advertisements and/or content. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you.

    There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Further, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services as well as across your Devices. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

  3. Location-Based Information

    Our Service may use location-based services in order to locate you so we may verify your location, deliver you relevant content and ads based on your location as well as to share your location with our vendors as part of the location-based services we offer. You may be able to change the settings on your Device to prevent it from providing us with such information. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by us and our partners and licensees to provide and improve location-based products and services. You should consider the risks involved in disclosing your location information to other people.

  4. Information Third Parties Provide About You

    We may receive information about you from your friends and others that use the Service. Additionally, we may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

  5. Interactions with Third-Party Services

    The Service may include functionality that allows certain kinds of interactions between the Service and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Service to facilitate your sending a communication from the Service such as facilitating emails, tweets or Facebook postings. These third parties may share information with us and they may also retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Service.

  6. Information You Provide About a Third Party

    You may send someone else a communication from the Service, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Service, your contact information, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.

  7. California / Delaware Do Not Track Disclosures

    Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

2. How Do We Use the Information Collected?

We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy:

  • to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, drafts or events;
  • to protect and administer your Service account;
  • to process and track the results of your contests and other transactions you enter into using the Service;
  • to verify your identity, including your accounts on the Service; manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
  • manage and protect our information technology infrastructure;
  • to provide the Service, including the fantasy game opportunities available on the Service;
  • to improve the Service, marketing endeavors or our Service offerings;
  • to customize your experience on the Service or to serve you specific content or ads that are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;
  • to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
  • to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
  • to identify your product and Service preferences so that you can be informed of new or additional products, services and promotions;
  • to enable you to participate in a variety of the Service’s features;
  • to improve the overall experience at the Service;
  • to comply with our legal and regulatory obligations;
  • for internal business purposes; and
  • for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, including Usage Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. If you are a California resident, you have the right to request additional information about this sharing, so please see Section (3)(f) below. Additionally, in our continuous effort to provide services that we believe you may find useful or of value, we may make your Personal Information available to third parties better facilitate your requests, provide more personalized services and communicate separately with you. StarStreet does not currently sell customer information to advertisers or third party marketers. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. StarStreet may additionally disclose your information as follows:

  1. When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

  2. dThird Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) to manage a database of customer information; (iii) hosting the Service; (iv) designing and/or operating the Service’s features; (v) tracking the Service’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; (vii) to process payments and deliver prizes; and (viii) other services designed to assist us in maximizing our business potential. For example, from time to time, we will use the information we collect to coordinate data entry and payments with the company that provides you with handicapping information, to coordinate marketing/rewards programs with partner racetracks, and to offer other enhancements to the Service. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the bottom of this page. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

  3. To Protect the Rights of StarStreet and Others. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Service’s Terms of Service or other policies applicable to the Service, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Service or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you. In circumstances where we inadvertently obtain information that appears to pertain to the commission of a crime or where we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person exists, StarStreet may voluntarily disclose the record or the contents of your communications or other information about you to law enforcement agencies and governmental entities without providing you advance notice. Upon receipt of an applicable search warrant or administrative, grand jury or trial subpoena, StarStreet may be required to disclose to the government or law enforcement agencies, without advance notice to you, the content of your communications and other records relating to your electronic communications, as well as the following records: your name and address; records of your online communication (including session times and duration); how long you have subscribed to our service(s) (including start date) and the type(s) of service(s) utilized; your telephone number or other subscriber account identifying number(s), including any Internet or network address(es) assigned to you by our network; and the means and source of your payment(s) (including any credit card or bank account number).

  4. Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates, including for their marketing or other purposes. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

  5. Your Connecticut Privacy Rights. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

  6. Your California Privacy Rights. We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: support@draft.com., with “California Privacy Rights” as the subject line or mail us a letter to: StarStreet, LLC, 217 West 21st Street, New York, NY 10011 (Attn: Privacy Officer). You must include your full name, email address, and postal address in your request.

4. What About Information I Disclose Publicly or to Others?

  1. User Content and Public Information. The Service may permit you to submit ideas, photographs, video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”). We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that StarStreet does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service.
  2. Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Service, please review our Service’s Terms of Service.

5. Ads and Information About You

We and third parties such as network advertisers and ad exchanges may serve advertisements on the Service or across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“Behavioral Ads”). Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below.

Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information via a Device Identifier. These third party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements; and (c) understand the usefulness of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

We may use third-party advertising companies to target advertisements to you on our Service, across the web, on your mobile Device and on any of your other Devices, based on the information we have collected from and about you, as well as information relating to your and other users’ visits to this and other websites and online services. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags) or recognize an identifier associated with your mobile device. These companies may also use these Tracking Technologies, along with personal information they or we collect on the different devices you use, to recognize you across the Devices you use, such as a mobile device and a laptop or other computer. Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the bottom of this page. Further, while sites use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver Behavioral Ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.

6. Does Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps Appear on the Service?

When you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control such as merchants who directly sell products and services to you. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-party owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party online service or otherwise interacting with it and exercise caution in connection with these services. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

7. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Service may allow you to review, correct or update Personal Information you have provided through the Service’s registration forms or otherwise by updating your Service account, and you may provide registration updates and changes by contacting us by email at: support@draft.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for StarStreet’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: StarStreet, LLC, 217 West 21st Street, New York, NY 10011 (Attn: Privacy Officer); Email: support@draft.com.

8. What about Data Retention?

StarStreet is committed to only retaining Personal Information for a period of time that is necessary to fulfill a legitimate business purpose and deleting or de-identifying the Personal Information thereafter. The legitimate business purposes for which we retain Personal Information are described in Section 2 above and throughout this Privacy Policy but may additionally include, without limitation: to provide, develop and improve the products and the services we make available through the Service, to maintain the security, integrity and operation of the Service, to comply with our legal and regulatory obligations and other third party requirements, to resolve disputes, and to enforce our agreements, to prevent fraud or criminal activity, to maintain business records and for other purposes we determine in our sole discretion. We destroy or de-identify Personal Information that is no longer necessary for the legitimate business purpose for which it was originally collected unless there is a legitimate request or order to inspect the information still outstanding or the information remains in routine records that are periodically discarded under our document retention policies. The Personal Information that you have provided us is maintained in our management information system and billing systems, and is updated as new information is added. Accounting and billing records are retained for ten (10) years for tax and accounting purposes or until the relevant income tax years for which the document was created have been closed for income tax purposes and/or all appeals have been exhausted. Records may remain on file even after you have terminated your account on our Service. Subject to applicable law, we may also keep records to facilitate collection and to evaluate credit worthiness.

9. What About the Transfer of Information to the United States?

Our Service is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

10. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under thirteen (13) years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at: Email: support@draft.com.

11. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk. We utilize the industry standard, Secure Socket Layer (SSL)-capable web browsers support encryption technology that helps prevent unauthorized users from viewing or manipulating your Personal Information as it travels over the Internet.

12. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

13. Your Rights and Responsibilities

It is extremely important that you keep your account information and other confidential account data protected and secure. Do not share your log-in information or leave your computer unattended during a draft or contest. Please make sure that all information you provide to StarStreet is accurate and complete. Contact us immediately by email at support@draft.com. if you find any discrepancies in your account data or if you wish to inspect the records pertaining to you at our offices.

//End Privacy Policy//

The following third parties that collect information from you on the Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

Party Service For More Information Use of Tracking Technologies Privacy Choices
Google Analytics Analytics http://www.google.com/analytics/learn/privacy.html Yes https://tools.google.com/dlpage/gaoptout/
Connexity Advertising http://connexity.com/privacy-policy/ Yes http://connexity.com/opt-out/
DataXu Advertising https://www.dataxu.com/about-us/privacy/ Yes https://www.dataxu.com/about-us/privacy/data-collection-platform/
DoubleClick Advertising https://www.doubleclickbygoogle.com/ Yes https://www.google.com/settings/u/0/ads/authenticated?hl=en
Dstillary Advertising http://dstillery.com/platform/ Yes http://dstillery.com/privacy-policy/
Google Dynamic Remarketing Advertising https://support.google.com/adwords/answer/3124536?hl=en Yes https://www.google.com/settings/u/0/ads/authenticated
Adobe Media Optimizer Advertising http://www.adobe.com/marketing-cloud/online-advertising-management.html Yes http://www.adobe.com/privacy.html
Optimizely Analytics https://www.optimizely.com/ Yes https://www.optimizely.com/opt_out/
RadiumOne Advertising https://radiumone.com/ Yes https://radiumone.com/opt/
SteelhouseMedia Advertising http://steelhousemedia.com/ Yes http://steelhousemedia.com/opt-out/
TradeDesk Advertising http://thetradedesk.com/ Yes http://www.adsrvr.org/
Turn Advertising https://www.turn.com/ Yes https://www.turn.com/trust/consumer-opt-out
Demand Media Advertising http://www.demandmedia.com/ Yes http://www.demandmedia.com/privacy-policy/