TrueSport believes in winning the right way and that, in a positive setting, sports can provide young athletes with the skills to be successful both in sport and in life. Our applications, programs, and sites are designed to inspire future generations of U.S. athletes to embrace the principles of true sport – fair play, respect for one’s competitor, and respect for the fundamentals of fairness of competition – as they reach their highest natural potential.
- PERSONALLY IDENTIFIABLE INFORMATION.
- DISCLOSURE REQUIRED BY LAW.
- CHOICE AND OPT-OUT.
- NON-PERSONALLY IDENTIFIABLE INFORMATION.
- COOKIES, FLASH COOKIES, AND WEB BEACONS.
- OTHER WEBSITES; LINKS.
- CONSENT TO THE USE OF THIRD PARTY PROVIDERS.
Amendments to this Policy will be posted on the Site and will be effective when posted. Your continued use of the Site following the posting of any amendment will constitute your acceptance of that amendment.
If you have questions or concerns regarding this Policy, you should contact TrueSport at email@example.com or by phone at (719) 323-6833.
- PERSONALLY IDENTIFIABLE INFORMATION.
- We only collect and share personally identifiable information regarding users of the Site as described in this Policy. Except as noted in this Policy, personally identifiable information collected on the Site is not shared with third parties without your consent.
- We may automatically collect personally identifiable information from you when you access the Site. We may also collect personally identifiable information from you through a number of voluntary sources on the Site, such as responses, registrations, reviews, comments, e-mails, postings, messages, photos or other electronic submissions and communications sent by you to TrueSport or the Site. The personally identifiable information we may collect from you includes, without limitation: domain name and IP address; e-mail address; contact information (including name, address, zip code, and phone number); age; employment, biographical, and education information; location information, including location information provide by a mobile device or associated with your IP address; user-specific and aggregate information on areas of the Site accessed; username and password information for the Site; and other information volunteered by you, such as information provided through responses, registrations, reviews, comments, e-mails, postings, messages, photos or other electronic submissions and communications sent by you to TrueSport or the Site.
- The United States Anti-Doping Agency will be the data controller for your information. The personally identifiable information that TrueSport collects from users of the Site (both registered and unregistered) may be used for a variety of purposes; for example, to provide the services and products offered through the Site to users of the Site, to customize advertising and other content displayed on the Site and/or the layout of the Site for each individual user of the Site, to notify users of the Site about updates to and activities on the Site and about goods and services that we feel may be of interest to you, to improve the content of the Site, to analyze data and patterns regarding usage of the Site, to contact users of the Site for marketing purposes, and to contact users of the Site for information verification purposes.
- CHOICE AND OPT-OUT. We provide you with a choice whether to receive certain e-mails. We provide you the opportunity to “opt-out” of having your personally identifiable information used for certain purposes. If you are a user of the Site and you no longer wish to receive e-mail, mail, or telephone calls from us or have your e-mail address or postal address shared with third parties, you may opt-out of receiving e-mail, mail, or telephone calls from us or having your e-mail address or postal address shared with third parties. All opt-out requests can be made by emailing us at firstname.lastname@example.org, or writing us at TrueSport, 5555 Tech Center Drive, Suite 200, Colorado Springs, CO 80919-2372.
- NON-PERSONALLY IDENTIFIABLE INFORMATION. Where possible, the TrueSport server automatically recognizes each visitor’s Internet Protocol address. We also collect information about how visitors use the Site (for example, what pages are viewed). This information allows us to improve the content of the Site and facilitate market research.
- COOKIES, FLASH COOKIES, AND WEB BEACONS.
- A cookie does not collect or keep your name or other personally identifiable information; however, we may link the information obtained through cookies to other personally identifiable information to give us a better understanding of your preferences, so that we can provide a more meaningful experience to you on the Site.
- OTHER WEBSITES; LINKS. Certain websites of TrueSport’s affiliates, promotional partners, advertisers, sponsors, and other third party websites are accessible through the Site. These third party websites have their own privacy and data collection policies and practices. TRUESPORT IS NOT RESPONSIBLE FOR ANY ACTIONS OR PRIVACY POLICIES OF SUCH THIRD PARTIES. YOU SHOULD CHECK THE APPLICABLE PRIVACY POLICIES OF THOSE THIRD PARTIES WHEN PROVIDING PERSONALLY IDENTIFIABLE INFORMATION THROUGH LINKED WEBSITES.
- CONSENT TO THE USE OF THIRD PARTY PROVIDERS. In addition to the specific third parties noted in this Policy, TrueSport may also contract with other third parties to provide various services to TrueSport relating to the Site on an outsourced basis rather than performing the services itself. By visiting the Site, all visitors consent to TrueSport providing both personal and non-personal information received from those visitors to these third party providers for the purpose of enabling the third party provider to provide these outsourced services to TrueSport. In addition, all visitors consent to the collection, maintenance, and processing of their personal and non-personal information by TrueSport and these third party providers.
- SECURITY. We will use reasonable security measures on the Site to protect the loss, misuse, and alteration of the information under TrueSport’s control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to insure the safety of your personal information.
- GENERAL. This Policy is governed by the internal substantive laws of the State of Colorado, without regard to its conflict of laws principles. Jurisdiction for any disputes, controversies, and claims arising under, in connection with, or out of this Policy shall lie exclusively with the state courts located in Colorado Springs, Colorado, or the federal courts located in Denver, Colorado. If any provision of this Policy is found to be invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect. UNDER NO CIRCUMSTANCES SHALL TRUESPORT OR THE UNITED STATES ANTI-DOPING AGENCY HAVE ANY LIABILITY WHATSOEVER FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT OR SPECIAL DAMAGES ARISING OUT OF THIS POLICY, HOWEVER OCCASIONED.
- INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS. TrueSport offers to its users a range of activities and services, some of which may collect information from children. Below, we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as is reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
- Registration. Children can, in many cases, register with the Site and applications to view content, play games, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. Please note that children can choose whether to share their information with us, but certain features may not function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.Collection of parent email addresses: Consistent with the requirements of COPPA, in any instance in which we ask for age and determine the user is a child, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at email@example.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
- Content Generated by a Child. Certain activities on the Site and applications may allow children to create or manipulate content and save it with TrueSport. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, drawings that allow text or free-hand entry of information, or photo submissions. If, in addition to collecting content that includes personal information, TrueSport also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.About Verifiable Parental Consent:
- Email Consent. In the event TrueSport wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
- High-Level Consent. In the event TrueSport collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include, without limitation, asking for a credit card or other payment method for verification (with a nominal charge potentially involved), speaking to a trained representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
- Teacher Consent in Lieu of a Parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
- CHAT. Certain activities may allow users to communicate directly with other users by means of a chat system. We may employ live moderation and/or encourage other users to flag inappropriate communications to prevent the communication of both personal information and age-inappropriate words and phrases. We strongly encourage children who use these interactive features never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our moderation. We recommend that parents carefully supervise their children when the children participate in online activities.
- CONTESTS AND SWEEPSTAKES. For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes. Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission.
- EMAIL CONTACT WITH A CHILD. On occasion, in order to respond to a question or request from a child, TrueSport may need to ask for the child’s online contact information, such as an email address. TrueSport will delete this information immediately after responding to the question or request. In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than one. In such instances, we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions, a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
- PERSISTENT IDENTIFIERS. When children interact with us, certain information may automatically be collected, both to make our Site and applications more interesting and useful and for various purposes related to TrueSport. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our Site or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by TrueSport or by a third party. This data is principally used for internal purposes only, in order to:
- provide users with access to features and activities on our Site and applications
- customize content and improve our Site and applications
- conduct research and analysis to address the performance of our Site and applications
- generate anonymous reporting for use by TrueSport
In the event we collect (or allow others to collect) such information from children on our Site and applications for other purposes, we will notify parents and obtain consent prior to such collection.
- WHEN INFORMATION COLLECTED FROM CHILDREN IS AVAILABLE TO OTHERS. In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (a) in response to a law enforcement or public agency’s (including schools or children services) request; (b) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our Site or applications; (c) to protect the security or integrity of our Site, applications, and other technology, as well as the technology of our service providers; or (d) to enable us to take precautions against liability.
- PARENTAL CHOICES AND CONTROLS. At any time, parents can refuse to permit us to collect further personal information from their children, and can request that we delete from our records the personal information we have collected from their children. Inquiries may be directed to:TrueSport
5555 Tech Center Drive, Suite 200
Colorado Springs, CO 80919-2372
Phone: (719) 323-6833
In any correspondence such as email or mail, please include the child’s name and/or username on the Site or application (if any) and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.