KW UNITED FC PRIVACY STATEMENT

This web site is made available by Kitchener-Waterloo United Football Club, (the “Team” or "KW FC"), on behalf of itself and on behalf of the Member Clubs that are part of and licensed by the Team (collectively,  “we” or “us” or “our”). This Privacy Policy ("Privacy Policy") governs our privacy practices and procedures with respect to the KW FC web site currently located at www.kwunited.com, and the subdomains thereof, on which this Privacy Policy is posted (collectively, the "Web Site"). This Privacy Policy also applies to various online services and applications provided by KW FC through the Web Site (the "Services").

This Privacy Policy does not apply to data collected by any means other than from users via the Web Site or Services (including, for example, through any offline means).  By visiting the Web Site or using any Services, you are consenting to the practices and procedures described in this Privacy Policy and in the KW FC Terms of Service, into which this Privacy Policy is incorporated. 

If we have obtained your consent to share your Personally Identifiable Information (as defined herein) with third parties for such third parties’ marketing purposes (whether through “opt-in” or “opt-out” means), you may opt-out by following the directions in the “Choices” section below.  

Please note that we and certain of our third party providers and partners may also collect information from and about you and your visits to the Web Site, to use for various purposes, including to display or transmit to you advertisements and other content, on this Web Site and on other web sites you may visit, which are designed to be targeted to your interests and preferences based on such information.  Please see the “Third-Party Advertising” section of this Privacy Policy below for further information.

INFORMATION COLLECTED
Personally Identifiable Information

You can visit and enjoy the Web Site without disclosing any Personally Identifiable Information about yourself.  However, in the course of using the Web Site and the Services, it may be necessary for you to, or you may choose to, provide us with certain Personally Identifiable Information.  “Personally Identifiable Information” includes, for example, your name, street address, e-mail address, phone number, mobile phone number, short message service (SMS) or text message address, date of birth, credit card and other payment information, and/or other information that may identify you as an individual or allow online or offline contact with you as an individual.  We also may, from time to time, receive Personally Identifiable Information about you from third party sources to improve the Web Site and our Services, and for the various purposes outlined herein.

Personally Identifiable Information may be collected on or through the Web Site or Services in a variety of ways and in a variety of circumstances, including, for example:

when you register on the Web Site; 
when you participate in contests, sweepstakes, promotions, surveys or voting; 
when you participate in games; 
when you apply for a job on this Web Site; 
in connection with your purchase of certain products or services (such as club merchandise or tickets); 
when you participate in an online auction; 
when you request or use certain Services or content, when you conduct in other types of transactions (e.g., signing-up for a newsletter or other subscription); and 
when you contact us through the Web Site with a comment, question or complaint (such as by using a “Contact Us” or similar feature on the Web Site, or by sending us an e-mail). 
Web Site Usage Information

Cookies.  To help us serve you better, we collect information that alone does not identify you personally, but rather identifies your computer or browser. This is done by using small files called "cookies" and by tracking internet protocol (IP) addresses. A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a Web site's computers and stored on your computer's hard drive so that we can recognize you when you return. Cookies operate in the background, and you can turn them off if you wish by adjusting your Web browser settings, but doing so may impair your ability to use some of the features on the Web Site. We may use cookies to make the Web Site work better by, for example, remembering your preferences, keeping track of your login name, password and, if you want to buy things while on the Web Site, your "shopping cart." 

Other Tracking Technologies.  We also may use Web beacons and other similar tracking technologies (such as “clear GIFs,” “Web beacons” and “pixel tags”) in the Web Site, the Services and/or in our communications with you to enable us to know whether you have visited a Web page or received a message.  Such technologies are typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, enabling the verification of an individual’s viewing or receipt of a Web page or message.

IP Addresses.  Our servers collect the IP addresses of computers that visit the Web Site, which we may use to analyze trends, help administer the Web Site, track the movement of visitors and gather broad demographic information for aggregate use.  IP addresses are not linked to any Personally Identifiable Information, except as may be necessary to verify users’ locations for various purposes, such as to identify problematic accounts, and to determine the applicability of blackout restrictions for certain audio/video subscription products, as applicable. 

Any or all of the above-described activities with respect to non-personally identifiable information may be performed on our behalf by our authorized Service Providers, agents or representatives.  Except for IP Addresses (as described above), we may match information that does not alone identify you as an individual with other information we may have from or about you, including your Personally Identifiable Information.

HOW WE MAY USE YOUR INFORMATION
In addition to other uses described in this Privacy Policy, the information we collect on or through the Web Site or Services, including both Personally Identifiable Information and non-personally identifiable information, may be used by us (and by our Services Providers, on our behalf) for a variety of purposes, including to: 

(i) contact you about the Web Site and/or Services you have requested; 

(ii) provide you with Services or information you have requested, or products or services you have ordered or signed up for, such as newsletters;

(iii) confirm or fulfill an order you have made; 

(iv) administer your participation in a contest, sweepstakes, promotion, survey or voting;

(v) maintain our Web Site, our Services, our operations and internal record keeping; and 

(vii) with your permission, send you promotional material or special offers from KW FC, on  behalf of ourselves (including, for clarity the Team) and occasionally on behalf of our marketing partners and other third parties, or share your information with our marketing partners and other third parties so that they may contact you directly.  If you no longer wish to receive promotional e-mails from us, or have your information shared with third parties as previously described, you may change your mind and/or your preferences by following the directions in the “Choices” section of the Privacy Policy below. 

Users may be able to send information about our products, our Services and/or our Web Site to their friends and family members by using an “E-mail to Friend” or similar feature on the Web Site or in an e-mail that we have sent them.  In some of these cases (unless a user simply forwards our e-mail on his or her own), the user may provide the name and e-mail address of his or her friend or family member to us.  We do not use the names or e-mail addresses submitted in these circumstances for any other purpose without the consent of the e-mail recipient to do so.

DISCLOSURE OF INFORMATION 
We will not sell, lease, or share your Personally Identifiable Information with or to anyone else, except as described in this Privacy Policy, including as set forth below, or as otherwise required by law: 

Services Providers: We may provide information (including Personally Identifiable Information and non-personally identifiable information) to our affiliates and third-party service providers, such as hosting providers, data management companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies and payment processors (collectively, “Service Providers”), who provide services on our behalf in order to facilitate our operation of the Web Site and the Services.  Our Service Providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personally Identifiable Information for their own marketing or other purposes. For further information about the manner in which our Service Providers may use and process your Personally Identifiable Information, contact the Privacy Administrator as set out in the “Contact Us” section below.

Third-Party Marketers. On occasion, our users may have the opportunity to receive special promotions or offers (such as subscriptions to and promotions for goods and services, including, for example, through participation in a co-sponsored sweepstakes or contest) from or involving third party marketers.  If we have your permission (which we may obtain through either opt-in or opt-out means), we may share your Personally Identifiable Information with such third parties for these purposes.  We are not responsible for how these third parties may use your information, and such uses are subject to their own policies. If you have consented to, but you change your mind and no longer want us to, share your information on a going-forward basis, you may let us know by following the instructions in the “Choices” section below.

Aggregated Demographic Information. We may use and share with third parties aggregated demographic information collected on or through the Web Site and Services for various purposes, but this information does not include and is not linked to any Personally Identifiable Information that can identify you or another individual person (except, however, with respect to IP Addresses, in the limited case of us verifying users' locations for various purposes, such as to determine the applicability of blackout restrictions for various video/audio subscription products, as applicable). 

Disclosure for Legal Purposes. The law may require that we, our affiliates, and our third party service providers provide your Personally Identifiable Information and non-personally identifiable information pursuant to judicial or governmental subpoenas, warrants or orders, or as otherwise permitted or required by applicable law. If we are required to do so, we will, of course, obey the law. In addition, notwithstanding any term to the contrary in this Privacy Policy, and where required or permitted by law, we may use and share your Personally Identifiable Information and non-personally identifiable information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or the integrity of the Web Site or our Services, violations of this Web Site's Terms of Service or as otherwise required by law.

Business Transfers. As time passes, Kitchener-Waterloo United Football Club (or a part thereof), may be sold along with its assets, or other transactions may occur (such as a corporate reorganization, asset sale or other change in corporate control) in which customer information (including Personally Identifiable Information) is one of the business assets transferred.  In such a case, the customer information (including Personally Identifiable Information), which we have gathered, may be one of the business assets we transfer. 


CHOICES
You have various choices with respect to certain of our uses of the Personally Identifiable Information we collect from you on or through the Web Site or Services.  For example, many of our registration and order forms contain a box for you to indicate whether you consent to receive special offers and promotions from us. They may also contain a box for you to indicate whether you would like us to share your Personally Identifiable Information with third parties that may contact you in connection with their own promotions and offers.  You should be aware that in many cases, these check boxes may be pre-checked, which means that if you do not un-check them, you will be opted-in to the various activities.  If you have not consented to us using your Personally Identifiable Information for these purposes, we will only use it to complete the transaction or provide the service or product you have requested.  

If you have agreed to receive communications or solicitations from us, but you later change your mind, you can revise your preferences on the "Account" section of the Web Site or email us at niki@santiosport.com.  You also may opt out of receiving all future promotional e-mails from us by clicking on an opt-out or “unsubscribe” link within the promotional e-mail you receive.  Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.  

If you have agreed to have us share your Personally Identifiable Information with third parties so that they may contact you about promotions, offers and other information, but you change your mind and no longer want us to share your personally identifiable information with third parties for their direct marketing use, you can revise your preferences on the "Account" section of the Web Site or email us at niki@santiosport.com. If you do request to have us stop sharing your Personally Identifiable Information with other entities for their direct marketing purposes, such request will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personally Identifiable Information prior to such request.  In these cases, please contact that entity directly or click on the opt-out or “unsubscribe” link that should be included within the promotional e-mail you receive from such third party.

THIRD PARTY ADVERTISING
We may allow other companies (e.g., 24/7 Real Media) that are presenting advertisements or providing services on our pages to set and access cookies and other tracking technologies on your computer. These companies may collect information about your visits to the Web Site in order to measure and assess the effectiveness of online advertising and to provide and better target advertisements about goods and services of interest to you. While the information collected by these third parties from you while you are visiting our Web Site is not personally identifiable, some of these third parties may also combine such non-personally identifiable information with other information they have collected from various other sources, such as their own past online and/or offline purchase information and Web usage from other sites.  Such other information may include Personally Identifiable Information, as well as demographic and behavioral information. Those companies’ use of cookies, and the information collected therethrough, will be covered by their own privacy policies, not ours.

Examples of some of the third parties that collect information from users of this Web Site are ad networks, some of which are members of the Network Advertising Initiative, an industry group which offers a single location to opt out of its members’ cookies.  For more information about these practices in general, we encourage you to visit the Network Advertising Initiative’s consumer web site, at http://www.networkadvertising.org/consumer/.  

LINKS TO OTHER WEBSITES AND SERVICES
The Web Site may contain links to other websites and online services. When you link to such other sites and services (including by means of clicking on hyperlinks, logos, widgets, banners or advertisements), you become subject to their terms of use and privacy policies posted thereon and/or applicable thereto. For example, these other websites may send their own cookies to you, independently collect data or solicit Personally Identifiable Information directly from you on their sites. Please note that we are not responsible for the privacy practices of third-party websites. We encourage you to be aware of this when you click on a link and leave the Web Site, and to read the privacy policies of every website that collects Personally Identifiable Information from you. The Privacy Policy applies only to this Web Site. 

CONSENT TO PROCESSING
By using the Web Site, you are consenting that your information (including your Personally Identifiable Information) may be collected, maintained, transferred and processed by us, our affiliates and/or other third-party Service Providers in and to the United States and other countries and territories.

CHANGES TO THIS PRIVACY POLICY
You should review this Privacy Policy periodically as we may modify it from time to time, and such changes will be effective upon our posting them to the Web Site. Where consistent with applicable law, your continued use of the Web Site and/or the Services after we have changed the Privacy Policy signifies your acceptance of the revised terms.  Under certain circumstances (e.g., with respect to certain material changes to this Privacy Policy), we may also elect to notify you through additional means, such as posting a notice on the front page of the Web Site or by means of an e-mail that gives you the opportunity to indicate whether you consent to the proposed change.

SPECIAL RULES FOR CHILDREN 
General Rules.  Most portions of the Web Site are directed to general audiences, and we do not knowingly collect information from children under 13 in such areas.  At those general audience portions, if we request a date of birth that includes a birth year, we screen out children under 13 and do not collect information from them.  The Web Site, however, may include one or more portions that are directed to children under 13, and the statements in this Privacy Policy generally about our collection and use of non-personally identifiable information also apply to any such areas, with the added protection of the special rules that follow with respect to Personally Identifiable Information.  

Information Collected and Parental Rights.  If your child wants to register on or participate in certain activities in the areas of the Web Site that are directed to children under 13, and such participation requires that we collect Personally Identifiable Information from your child, we will collect from your child your and your child’s name and/or e-mail address in order to obtain your consent.  We will then send you an e-mail (which will include a link to this Privacy Policy), advising you about the portion of the Web Site in which your child has expressed interest, and request that you reply by e-mail if you consent to your child’s participation.  In the reply e-mail, we may request further Personally Identifiable Information from you (as defined in the main part of this Privacy Policy) about you and/or your child, but we will not request such information from your child.  We will then send you a confirmatory e-mail of your child’s registration.  Once your children are registered, we may request them to provide general information such as their favorite player.  You have the right to review your child’s Personally Identifiable Information, to have that information deleted, and/or to refuse to permit its further collection or use.  Parents can contact the Privacy Administrator at the address or email as  set forth at the end of this policy and we will respond to their requests.

Information Use and Disclosure.  We – and any of our Member Club(s) the child indicates interest in – may use the Personally Identifiable Information to provide the child with the special services for which he or she has registered, such as membership in a Kids Club, receipt of newsletters, or participation in contests.  We do not condition a child's participation in any of our online activities on the disclosure of more information than is reasonably necessary to participate in the activity.

Currently, the portions of our Web Site that are directed to children under 13 do not have unscreened chat rooms, blogs or other similar community functionality that would permit your child to disclose information to others or publicly.  In addition, any “postcard” or “share with a friend” feature that may be available on these portions of our Web Site will collect the recipient’s e-mail address, but not the sender’s; permit the sender to type in a first name and last initial; supply the content or allow the sender to select a pre-determined message from a menu; and be sent immediately, at which time the recipient’s e-mail address as collected from the sender is deleted from our records. 

Personally Identifiable Information collected on or through any portions of our Web Site that are directed to children under 13 may be shared with Service Providers (as defined above) with whom we contract to operate this Web Site and some of our Services. These Service Providers will use such Personally Identifiable Information of Web Site visitors only for the purposes of carrying out these operations. To the extent required or permitted by law, we may also collect, use and disclose such Personal Identifiable Information in connection with security-related or law enforcement investigations or in the course of cooperating with authorities or complying with legal requirements. We may also use Web Site users’ information as permitted by law to protect our rights or property, our website, or its users and their safety.  As set forth above, we endeavor to maintain the confidentiality, security, and integrity of the Personally Identifiable Information collected from your child.  Other than our Service Providers and as described above, we will not share your child’s Personally Identifiable Information with third parties.

CONTACT US
If you have questions or concerns about this Privacy Policy, you can contact us at: 

Kitchener-Waterloo United Football Club
Address
Address
Attention: TBD
Phone: xxx-xxx-xxxx
E-mail: nbudalic@kwunitedfc.com

Last Updated: January 26th, 2012