PRIVACY POLICY

Introduction

This Privacy Policy outlines HBA Media's (“we”, “us”, “our”) practices with respect to information collected from users who access our website at www.hbamedia.tv, https://fantasy.crownjewelsracing.com/ and other websites we operate and make available from time to time (“Sites”), use our services (including playing our games) or otherwise share personal information with us (“Users”, “you”, “your”). We are the “data controller” in respect of your personal information. Please read the following carefully to understand our practices regarding your personal information and how it will be treated.

Grounds for data collection

Processing of your personal information (meaning, any information which may directly or indirectly identify you, also referred to in this Privacy Policy as "Personal Information") is necessary for:

• the performance of our contractual obligations towards you and providing you with our services (for example, where you have purchased our services from us and we need to use your contact details and payment information in order to process your order);
• where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights;
• compliance with legal and financial regulatory obligations to which we are subject; and/or
• where you have provided your consent (for example, to receive certain marketing from us). You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.

What information do we collect?

We collect two types of data and information from Users.

The first 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 Sites (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Sites. We may also collect information on your activity on the Sites (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Sites or our services/channels.
• Your name
• Your job title
• Your job role
• Your email address and contact number
• Your postal address
• The name of the organisation you work for
• Information about your activity on our channels, websites, games, third party apps or similar technologies

When and how do we collect/receive information about you?

We receive your Personal Information:

• When you voluntarily provide us your personal details in order to register on our Sites;
• When you visit, use or access our Sites in connection with your use of our services;
• When you contact our customer service centres or request information from us in any other way;
• When you participate in our customer satisfaction surveys or other market research, feedback and survey responses; and/or
• When you communicate with us via social networking websites, third party apps/platforms or similar technologies.

We may also collect your personal information from third party providers, services and public registers (for example, traffic analytics vendors). We may also collect your email address, name, gender, date of birth and post/ZIP code from platform providers where we have a channel and post videos, such as Recast TV, including how you interact with our content on these channels.

How do we use the information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
• To communicate with you and to keep you informed of our latest updates and services;
• To serve you advertisements when you use our Sites (see more under "Advertisements");
• To market our websites and products (see more under "Marketing");
• Conducting statistical and analytical purposes, intended to improve the Sites and our services;
• To make content more relevant to you;
• For system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To provide customer support and ensure we provide a good level of customer service;
• To tailor any marketing or advertising so that it is more relevant to you;
• For security and fraud prevention;
• To ensure that our Sites are safe and secure; and
• To comply with applicable laws and regulations.

Who do we share your personal information with?

We may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

• Hosting and operating our Sites;
• Providing you with our services, including providing a personalised display of our Sites;
• Storing and processing such information on our behalf;
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
• Providing you with marketing offers and promotional materials related to our Sites and services; and
• Performing research, technical diagnostics or analytics.

We may also disclose information if we have good faith to believe 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.

User Rights

You may request to:

1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your personal information that is in our control.
4. Request erasure of your personal information.
5. Object to the processing of personal information by us.
6. Request to restrict processing of your personal information by us.
7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) on racing@hbamedia.tv.

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Sites or access our services. A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used 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. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Sites uses the following types of cookies:

a) 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;

b) 'persistent cookies' which are read only by the Sites, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c) 'strictly necessary cookies' which are cookies essential for you to be able to navigate the Sites and use its features. Without these cookies, the services you have asked for could not be provided.

d) 'performance cookies' which are cookies that collect information about how you use our Sites, e.g. which pages you go to most often. We use a tool called “Google Analytics” to collect information about your use of the Sites. Google Analytics collects information such as how often users access the Sites, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Sites and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. For more information, please see the Google Analytics Terms of Use and the Google Privacy Policy.

e) 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

You may remove the cookies by following the instructions of your device preferences. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). However, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Sites and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted during your use of our Sites.

Transfer of data outside the UK and/or EEA

The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK.

Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Sites. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

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 about this practice by NAI 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: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you. 

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Sites are not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us at racing@hbamedia.tv.

Updates or amendments to this Privacy Policy

We may amend or revise the Privacy Policy from time to time. The last revision will be reflected in the "Last modified" section.

How to contact us

If you have any general questions about the Sites, this privacy policy or the information we collect about you and how we use it, you can contact us at racing@hbamedia.tv.

HBA Media Ltd.

Last Modified: 20/06/2024