Last modified April 7, 2017
We, at Sportority Limited Ltd. (the “Company), understand you want to keep your information private and that you value our emphasis on keeping your information safe and discrete. We respect your privacy and are committed to protect the privacy of our users (“user” or “you”).
The Company provides its services to you when you use its 12up.com services, including 12up mobile applications and 12up website, and when you use online services, websites and applications of our trusted third parties' brands' (each a "Brand"), as well as any of our online services )collectively: the “Services”).
What type of information we collect
We collect two types of data and information from our users:
The first type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), which includes the following:
The second type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Such information includes the following:
Cookies and Google Analytics
A cookie is a piece of data stored on your browser containing information about your access to the Services. We and our trusted partners may use such cookies for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. When you visit our site, two types of cookies may be set on your computer. The cookies set by us are called First Party Cookies. Third Party Cookies are the cookies set by someone else, such as service providers who help us operate and improve our site.
First Party Cookies
Our cookies are limited to authentication and basic service provision purposes:
o Cookies required to enable your access to the Services and to provide you with the services or content you have requested. These cookies expire at the end of each browsing session.
o Cookies used to identify whether you are a registered user returning to the site. These cookies generally expire within two weeks.
Our cookies contain an alphanumeric string allowing us to identify your device which does not contain any personally identifying information about you
· Third Party Cookies
In addition to these first party cookies, you may also encounter cookies set by third parties for various purposes such as those specified below. Because we frequently update our site and Services, add/ remove site features and change service providers on a regular basis, the identity of the third party serving cookies may change from time to time. We expect, however, that the following categories of third party cookies will typically be set by third parties when you use our site and Services, depending on how you interact with our Services:
o Social Networking Platform Cookies: Cookies set by social networking platforms to enable social media logins or to facilitate the sharing and liking of site content on social networks;
o Analytics and Performance Cookies: Cookies used to help us analyze how people interact with our site so we can improve the site layout and features for users, to improve performance of the Services, and to help us with site maintenance;
o Content Recommendation Cookies: Cookies set by service providers who recommend additional content to you while browsing our website;
o Fraud Detection Cookies: Cookies set by service providers in order to detect fraud and improve the security of our online communications;
o Targeting and Advertising Cookies: Cookies used to target and deliver advertisements and to measure the effectiveness of advertising on our Services.
These cookies will expire when set by the respective third party service provider.
· Google Analytics and Display Advertising
We are currently using Google Analytics on our site and have implemented the following Google Analytics features based on Display Advertising:
o Google Display Network Impression Reporting: We, together with third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick Cookie) to report how our ad impressions, use of ad services, and interactions with these ad impressions and ad services are related to visits to our site.
o Google Analytics Demographics and Interest Reporting: We use data from Google’s interest-based advertising or 3rd-party audience data with Google Analytics to better understand the demographics of users on our site. This allows us to provide more relevant and interesting content to users.
You can opt-out of Google Analytics for Display Advertising and customize Google’s Display Network ads by using Google’s Ads Settings (https://www.google.com/settings/ads). Google also offers additional tools which you can use to manage opt-outs for Google Analytics (https://tools.google.com/dlpage/gaoptout).
How we use the information we collect
To provide our Services (e.g. enable you to share User Content; follow other users’ shared content; etc.).
To identify and authenticate your access to certain features of the Services;
To communicate with you and to keep you informed of our latest updates;
To send you marketing communications regarding special offers, products, services and periodic newsletters. You can control receipt of certain messages through your "settings" page in the Services;
To serve you advertisements when you use our Services;
To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
To test changes to the Services and make improvements to their functionality;
To support and troubleshoot our Services and to respond to your queries;
To detect and prevent frauds as well as online security threats; and
To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
Sharing of Personal Information
In addition to the different uses listed above, we may transfer or disclose Personal Information to Brand owners, subsidiaries, affiliated companies and subcontractors. In addition, we may transfer or disclose Personal Information with other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf; (b) assisting us with our business operations and the providing and improvement of our Services; and (c) performing research, technical diagnostics and analytics with regard to the Services.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
We may also share Non-personal Information or anonymized information with other third parties for different purposes, such as advertising (see below specific information with regard to our advertising practices, under "Advertisements").
Data Protection Officer
If You feel that your privacy was treated not in accordance with our policy, or if any person attempted to misuse our Services or acted in an inappropriate or unlawful manner, please contact our Data Protection Officer (“DPO”) at this email address: firstname.lastname@example.org and our DPO shall investigate promptly.
Third party collection of information
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
We may use advertising technology to serve advertisements (including targeted ads) when you use our Services. This technology may use Non-personal Information with regards to your use of the Services to serve advertisements to you. We may also use third parties and share with them Non-personal Information to assist us in evaluating the success of our advertising campaigns and help us retargeting our users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices.
How do we safeguard and transfer your information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact our DPO at email@example.com
If you are unsatisfied with our response, you can reach out to the applicable data protection authority.
For how long we retain the information we collect?
We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by emailing us at please contact our DPO at firstname.lastname@example.org
You can also request that we will correct errors or that we will erase your Personal Information (except for data that we are required to keep under applicable laws) by emailing us.
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
The Services are not designated to users under the age of 13. If you are under 13, you should not use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user under the age of 13 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact our DPO at email@example.com
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we will collect and use it for advertising and user analytic purposes.
By downloading or using our Services you explicitly agree that we may associate your Advertising ID with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID, we will use other identifiers.
How to contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact our DPO at firstname.lastname@example.org