Low6 USA Inc (“Low6”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. Low6 is committed to the protection of the personal data that we process in line with the UK General Data Protection Regulation and the EU General Data Protection Regulation (2016/679) (where applicable) (together the “GDPR”) and the UK Data Protection Act (2018).
This privacy notice explains what personal data we collect from individuals who use the Low6 App. It also explains what information we collect automatically when you use our App.
Low6 USA Inc is the data controller for the purposes of the GDPR.
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.
2. 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:
Any information you share through our social media channels
Information we collect from you
When you use our app, we may collect:
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.
3. Purposes and bases for processing your personal data
We may use your data for the following purposes and on the following lawful bases:
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
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.
4. 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.
Purpose of sharing
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.
We share marketing and demographic information.
This is necessary to create exemption lists to optimise and remove certain customers from marketing campaigns.
To trigger in-app messages, push notifications and text messages to users
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
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.
These may include partners who conduct marketing activity on our behalf where consent is given as required for such marketing.
5. Your rights
The GDPR provides you with certain rights in relation to the processing of your personal data, including to:
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 firstname.lastname@example.org . 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.
6. 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.
A. If you are based in the UK
You can contact Low6 in relation to data protection and this privacy notice by emailing email@example.com.
B. 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:
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
DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium
DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic
DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
DataRep, 72 rue de Lessard, Rouen, 76100, France
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
DataRep, 24 Lagoumitzi str, Athens, 17671, Greece
DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary
DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland
DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857,
DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden
QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, you can email us at firstname.lastname@example.org
Last Updated: 28th April 2022
(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:
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:
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.
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:
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.
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.
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:
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.
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.
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 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:
Requests to know or delete can be submitted by e-mailing us at email@example.com. 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:
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:
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:
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.
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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