This privacy policy (“Policy”) sets out how we use data relating to you and applies to all use of your personal data by Low 6 Limited, a company registered in England and Wales under company number 10799636 with registered office Oakmoore Court, Kingswood Road, Hampton Lovett, Droitwich, Worcestershire, United Kingdom, WR9 0QH (“Low6”, “we”, “us”, or “our”).

This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our digital performances for which we make this policy available (the “Performance(s)”). This Policy also applies for our application where we make this Policy available (the “App“). Our Performances and App are together the “Services”. Please read the Policy carefully to understand our views and practices regarding your personal data.

  1. Introduction

We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018). Where we decide the purpose or means for the processing of the personal data that you provide when using our Services, we are the “data controller”. 

As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold and in meeting our data protection obligations when processing personal data. Low6 are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure. 

We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates. 

  1. What information do we process?

Personal data is any information relating to an identified or identifiable natural person. We process the information you give us, whether through interactions with our app, our website or by any other form of correspondence.  

Information you provide to us 

The categories of personal data we process include: 

  • Contact details (title/name/address/email address/phone number) 
  • Date of Birth 
  • Gender 
  • Bank details (name/account number/sort code) 
  • Any information you share through our social media channels 

 

Information we collect from you 

When you use our app, we may collect: 

  • Device details 
  • App login information – when creating an account user name, we strongly advise you not to use your real name or any other information specific or personal which may identify you. 
  • App usage data 
  • Location data 
  • Information required for legal and regulatory compliance 

We may use tools to personalise the user experience of our App, which may be disabled at any time using the Privacy Settings in the App or on your device.  

  1. Purposes and bases for processing your personal data

We may use your data for the following purposes and on the following lawful bases: 

Purpose 

Lawful Bases for Processing 

Delivery and performance of our App services in accordance with our Terms and Conditions  

It is necessary to process your personal data to facilitate performance of the service contract  

 

Providing information on your account, such as transaction history, cashback rewards and spending trends 

It is necessary to process your personal data to facilitate performance of the service contract  

 

Prevention and detection of crime including money laundering, fraud or other crimes   

We have a legal obligation to report any such activity to the relevant authorities and regulators 

Compliance with sector-specific laws, regulations, and guidelines 

We have a legal obligation to provide our services within the law and regulations set down by our Regulators  

Providing you with updates about our Apps, additional features, and providing you with exclusive promotions and deals.  

It is our legitimate interest to provide accurate and up-to-date information to App users and to increase features of the App in order to continually improve and expand the services we provide 

Marketing of our products and services and the products of selected partners including sports, betting and gaming products. 

Direct marketing is based on customer consent. Where an individual has given consent for us to send direct marketing to the customer.  

Delivering the benefits of our App by connecting you to the services and products of our merchants 

It is our legitimate interest to promote our services and products 

Improving our App and website and the overall App user and website visitor experience 

It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website and App 

Ensure maintenance of a secure connection between the App and your device 

It is our legitimate interest to ensure the integrity and security of personal data flowing through our systems 

Initiate action against any user who acts outside any laws, regulations or our Terms and Conditions or Terms of Use policies 

It is our legitimate interest to ensure protection of our company products, services, and reputation 

Analyse and track use of the App for reporting and analytical purposes 

It is our legitimate interest to monitor App usage in order to continually improve the user experience 

Where personal data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information. 

  1. Sharing your information

We will share your personal data outside the United Kingdom (UK) or the European Economic Area (EEA). This is necessary for the purposes of providing our Services to you, but we will only share it where appropriate safeguards are in place to ensure your personal data is protected to the same standard expected within the UK and EEA. 

 We may share your data with service providers and suppliers to our business who process data on our behalf. In such cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the contract between Low6 and the service providers and suppliers. 

In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the App of any changes in ownership or use of your personal data, as well as any choices you may have.

We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.

We may also disclose your personal data, to the extent necessary, to application stores or platforms (such as the Apple App Store and Google Play Store) if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil an App/Performance order) or in order to investigate or prevent fraud.

Our App includes links to our social media pages which enable you to view our content through selected sites. These applications may collect your IP address or Device ID and may set a cookie on your device. When you use one of these links, you are sharing information to another website or service and this privacy policy will no longer apply. Please read the privacy notices provided by the particular social media website you are sharing through before posting any personal information using these links. 

 

Please see the below list of key external providers with whom we share your data, the purpose of this sharing and where possible a link to their privacy policy. 

Provider 

Purpose of sharing 

Privacy policy 

Worldpay 

We share payment and personal details relating to your account and payment methods. This is necessary to process payments to and from customer accounts and in order to facilitate the product and contract.  

www.fisglobal.com/en-gb/privacy   

Facebook 

We share marketing and demographic information. 

This is necessary to create exemption lists to optimise and remove certain customers from marketing campaigns.  

en-gb.facebook.com/privacy/explanation  

Xtreme Push 

To trigger in-app messages, push notifications and text messages to users 

xtremepush.com/privacy-policy 

White label partners 

If you have given consent to receive direct marketing from one of our white label partners, we will share your data with them for this purpose 

The privacy policy of the white label partner will apply 

Brand partners 

If you have given consent upon registration to receive direct marketing from one of our brand partners, we will share your data with them for this purpose.  

 

Brand partners for whom we request your consent to share your data for direct marketing purposes include, without limitation, DP World Tour and PGA Tour.  

This privacy policy of the brand partner will apply. You can usually obtain this by visiting their website.  

Service providers 

These may include partners who conduct marketing activity on our behalf where consent is given as required for such marketing.  

This privacy policy will apply 

  1. Your rights

The GDPR provides you with certain rights in relation to the processing of your personal data, including to: 

  • Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it. 
  • Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected 
  • Request personal data provided by you to be transferred in machine-readable format (“data portability”) 
  • Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below) 
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it) 
  • Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of Low6 
  • Complain to your local supervisory authority if you are not satisfied with the way we are handling your data. For UK residents, you can complain to the ICO here. 

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at privacy@low6.co.uk . You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data. 

  1. Data retention period

We will retain your personal data for as long as is necessary to provide you with our products and ongoing Services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.  

In some circumstances we are legally obligated to retain information to comply with legal obligations relating to crime prevention or gambling specific regulations.  

At the end of the retention period, your personal data will be securely deleted in accordance with the Low6 Personal Data Retention and Destruction Policy and Schedule. 

  1. Security

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Service visitors and customers.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

  1. Contact

  2. If you are based in the UK

You can contact Low6 in relation to data protection and this privacy notice by emailing privacy@low6.co.uk

  1. If you are based in the EU

We have appointed DataRep as our data protection representative for users based in the EU. If you would like to contact Low6 in relation to data protection and this privacy notice you may do so by: 

  • Sending an email to DataRep at datarequest@datarep.com quoting <Low6 USA Inc> in the subject line, 
  • Using DataRep’s online webform at www.datarep.com/data-request, or 
  • Mailing your inquiry to DataRep at the most convenient address in the table below. 

PLEASE NOTE: when mailing inquires it is essential that you mark your letters for ‘DataRep’ and not ‘Low6 Limited’, or your enquiry may not reach us. Please refer clearly to ‘Low6 Limited’ in your correspondence.  

If you have any concerns over how DataRep will handle your data to undertake their services, then please refer to their privacy notice at www.datarep.com/privacy-policy  

Country 

Address 

Austria 

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria 

Belgium 

DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium 

Bulgaria 

DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria 

Croatia 

DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia 

Cyprus 

DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus 

Czech Republic 

DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic 

Denmark 

DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark 

Estonia 

DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia 

Finland 

DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland 

France 

DataRep, 72 rue de Lessard, Rouen, 76100, France 

Germany 

DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany 

Greece 

DataRep, 24 Lagoumitzi str, Athens, 17671, Greece 

Hungary 

DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary 

Iceland 

DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland 

Ireland 

DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland 

Italy 

DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy 

Latvia 

DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia 

Liechtenstein 

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria 

Lithuania 

DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania 

Luxembourg 

DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg 

Malta 

DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta 

Netherlands 

DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands 

Norway 

DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway 

Poland 

DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland 

Portugal 

DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal 

Romania 

DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, 

Romania 

Slovakia 

DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia 

Slovenia 

DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia 

Spain 

DataRep, Calle de Manzanares 4, Madrid, 28005, Spain 

Sweden 

DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden 

  1. QUESTIONS ABOUT THIS POLICY

For questions or comments regarding our Policy, you can email us at privacy@low6.co.uk   

Last Updated: 4 August 2023 

 

North America Privacy Policy 

This privacy policy (the “Policy”) describes how Low6 USA Inc. (“Low6,” “we,” “us,” or “our”) collect, use, and share your information in North America, provided by you through our mobile applications and/or websites (in alphabetical order): 

  • Bengals Picks – available at bengalspicks.com;  
  • Han Pick’em – available at hanpickem.com; 
  • PGA TOUR Pick ‘Em Live – available at pickemlive.pgatour.com and via the PGA TOUR app;
  • Pistons Picks – available at pistonspicks.com;  
  • Ultimate Bengals – available via the Google Play and Apple App stores;  
  • Ultimate Jags – available via the Google Play and Apple App stores; and  
  • UltimateUSA – available via the Google Play and Apple App stores 

(each a “Platform” and collectively the “Platforms”)  

The Policy also informs you about your rights regarding the information we collect. By using any of our Platforms, submitting information, and/or using our online sports gamification services available through the Platforms, you agree to let us collect and use your information as described in this Policy. If you object to the collection, use, and sharing practices described in this Policy, you may not use our Platforms. Therefore, before you provide us with any information, you should read through this Policy in its entirety and understand its terms. 

We may update the Policy from time to time, so please check it occasionally.  

This Policy describes: 

  • Personal Information We Collect; 
  • How We Collect Your Personal Information; 
  • How We Use Your Personal Information; 
  • How We Share Your Personal Information With Third Parties; 
  • California Privacy Rights; 
  • Changes to the Policy; 
  • Questions About This Policy. 

PERSONAL INFORMATION WE COLLECT 

Low6 collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). Low6 also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows: 

  • Identifiers such as your first name, last name, alias, username or similar unique personal identifier, account name, online identifier, gender, and/or date of birth. 
  • Contact Information such as your billing address, email address and telephone numbers. 
  • Financial Information such as credit or debit card information, payment details, or other payment information. 
  • Profile Data such as user name, password, profile picture, details about gameplay selections, payments you have made, and/or other details of products and services you have purchased from us, social media account, and message content from support requests. 
  • Technical Information such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platforms. 
  • Usage Data includes information about how you use our Platforms and services, such as length of stay, clickstream, and activity on the site (login times, pages viewed, etc.). 
  • Marketing and Communications Information such as click-throughs, your preferences and consent in receiving marketing from us and our third parties, email communications, and your communication preferences. 
  • Inference Data including inferences drawn from the Personal Information identified above. 

If You Do Not Provide Personal Information. Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

Children’s Privacy. The Platforms are intended for adult use only and is not directed towards anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files. 

HOW WE COLLECT YOUR PERSONAL INFORMATION 

Information You Provide To Us: 

Low6 may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to: 

  • Create an account with us 
  • Obtain winnings from gameplay selection 
  • Call, email, text, or otherwise communicate with us 
  • Register for a Low6 contest 
  • Sign up to receive newsletters 
  • Respond to marketing emails 
  • Otherwise interact with the Platforms  

Information We Collect When You Use Our Services 

Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use any of our Platforms from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. 

Cookies and Tracking Technologies. We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our Platforms. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features of the Platforms may not function properly. 

Information We Collect From Third Parties 

We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties. 

Third Party Service Providers. We collect Personal Information from service providers including payment processors, website hosting providers, email service providers, SMS marketing providers, and social media platforms. 

Social Media Sites.  When you contact us, we receive Personal Information from those third party social media sites, which may include your public profile information.   

 

Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various online advertisements and ad platforms such as Facebook Pixel, Google Ads, and Twitter Pixel.  This may be combined with the website analytics data described below.   

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our Platform visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Platform. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For information on how to opt-out from Google Analytics, visit https://tools.google.com/dlpage/gaoptout.   

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our Platforms do not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites. 

HOW WE USE YOUR PERSONAL INFORMATION  

Purposes For Which We Will Use Your Personal Information 

Our primary purpose in collecting Personal Information is to provide you the products and services that you have ordered or requested with a safe, smooth, efficient, and customized experience.  We may also use your Personal Information for the following business purposes:  

  • Collect and process payments and complete transactions. 
  • Provide the products, services, and customer support you request. 
  • Verify your identity and account information in connection with products or services you request. 
  • Provide you with recommendations for products and services that we believe would be of interest to you. 
  • Contact you with promotional email and text messages. 
  • Provide you with our newsletter if you have subscribed to it. 
  • Assist you with setting up and managing your customer account with us. 
  • Resolve disputes. 
  • Troubleshoot problems and support. 
  • Enforce our General Terms and the terms of this Policy. 
  • Customize, measure and improve our services and content. 
  • Inform you about our products, services, updates and promotional offers. 
  • To customize the advertising and content you see. 
  • To protect our interests, including establishing, exercising and defending legal rights and claims. 
  • As necessary to comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities. 
  • For purposes disclosed at the time you provide/we request your Personal Information or as otherwise set forth in this Policy. 

HOW WE SHARE YOUR PERSONAL INFORMATION 

We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our goods and services and perform any contract we enter into with them or you. 

User Disclosures.  Some Personal Information is disclosed as a matter of course as a result of your use of the Platform.  Any Personal Information shared via any public forum on our Platform will become public information.   

Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, communications services, website development services, payment processing services, and analytics services. 

We may use the Google reCAPTCHA tool to protect our Platforms from various types of abusive processing attempts.  In order for this tool to work, reCAPTCHA analyzes various information that it collects from each visitor, which may include the IP address, mouse movements, length of stay, and other information gathered by Google.  By using reCAPTCHA, this data is sent to Google and used to determine whether the visitor is a natural person or an abusive automated program (e.g. bot).  You can find more information about reCAPTCHA at https://www.google.com/recaptcha.  All information captured by the Google reCAPTCHA tool is subject to Google’s Terms and Privacy Policy. 

Affiliates, Successors and Assigns. We may share Personal Information with our parent company, subsidiaries, successors, assigns and affiliates, including where disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Low6 who may use the Personal Information for the purposes described above. 

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy. 

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity. 

Targeted Advertising and Sales of Personal Information. Like most companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our Platform, which is then associated with your browser or device. These companies may use this data to serve you more relevant interest based ads as you browse the internet.  

Users in the United States may opt out of many advertising networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies.  For information about opting out of targeted advertising on mobile applications, users in the United States may download the DAA’s AppChoices mobile application from the Apple AppStore or Google  Play Store.  

Low6 also shares some Personal Information with its brand partners (including, without limitation, PGA Tour Inc. and Learfield Sports LLC), sportsbook partners (including, without limitation, PointsBet USA Inc.), media partners (including, without limitation, NBCUniversal) and other commercial partners who may use this information for their own commercial purposes. Under some north American and state laws, these activities may be considered a “sale” of information. Low6 may also share Identifiers, Contact Information, Profile Data, Usage Data, Technical Information, and Inference Data (as those terms are used in “Personal Information We Collect” above) with sportsbooks in exchange for monetary compensation. Low6 has no actual knowledge of any sales of Personal Information of minors under 16 years of age.  

In respect of Personal Information shared with NBCUniversal (only), Personal Information will only be shared when: (a) a user has registered via PGA Tour Pick’Em Live; and (b) a user has explicitly opted in to the sharing of Personal Information at the time of registration.  

COMMUNICATIONS AND OPT OUT  

By establishing an account or registering to receive the Low6 Newsletter, you may consent to receive periodic commercial/promotional email communications from us. You may opt-out of receiving such promotional communications at any time by following the unsubscribe instructions in a promotional email. This opt out will not apply to operational or informational emails related to your account and purchases. You may continue to receive promotional email messages for a short period while we process your request. 

CALIFORNIA PRIVACY RIGHTS  

California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. 

Upon verification of your identity you may: 

  • No more than twice in any 12-month period, request disclosure of the following information: 
  • Categories of Personal Information we collect. 
  • Categories of sources from which Personal Information is collected. 
  • Categories of Personal Information sold or disclosed to third parties. 
  • Categories of third parties with whom such Personal Information is sold or disclosed. 
  • Business or commercial purpose for collecting or selling Personal Information. 
  • Specific pieces of Personal Information we collect. 
  • Request deletion of your Personal Information, subject to the exceptions provided by law. 
  • Opt-out from having your Personal Information sold to third parties, if applicable.  

Requests to know or delete can be submitted by e-mailing us at privacy@low6.co.uk. You can opt out of having your Personal Information sold to third parties by clicking on the “Do not sell my personal information” link. 

Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. Except where you have provided an agent with a Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code, when using an authorized agent you must: (1) provide the agent with signed permission clearly describing their authority to make a request on your behalf; (ii) verify your own identity; and (iii) directly confirm that you have provided the authorized agent permission to submit the request. That agent must also be able to verify their identity with us and provide us with their authority to act on your behalf. 

The verifiable consumer request initiated by you or your authorized agent must: 

  • Include your full legal name, email, and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative. 
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. One of our representatives will contact you in order to verify your identity. You may need to provide additional information in order to verify your request. Depending on the nature of the request, we may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will only use this information to verify the requestor’s identity or authority to make the request. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  • Complete the transaction for which we collected the Personal Information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
  • Debug products to identify and repair errors that impair existing intended functionality. 
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
  • Comply with a legal obligation. 
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  

The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and we will not discriminate by: 

  • Denying you products or services. 
  • Charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties. 
  • Providing you a different level or quality of products or services. 
  • Suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services. 

Other California Privacy Rights. California residents have the right to receive information that identifies any third party companies or individuals that Low6 has shared your Personal Information  with for their direct marketing purposes in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at the address below. 

CHANGES TO THIS PRIVACY NOTICE 

Low6 may modify or update this Policy periodically in our sole discretion. Any changes will be effective upon the revised Policy being posted to our Platform. You are solely responsible for reviewing this Policy for any changes. As such, we encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy. 

Your continued use of any of the Platforms following any changes to this Policy will indicate your acknowledgement of and consent to such changes and to be bound by the terms of such changes, with the understanding that the updated Policy applies to all of your Personal Information, including the Personal Information collected before the changes went into effect. 

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