NFL.COM – SUBSCRIPTIONS – PRIVACY POLICY (CHINA)

Effective Date: August 16, 2001
Updated: April 5, 2021

NFL Enterprises LLC, the National Football League, and the other members of the NFL Family (collectively, “

NFL,” “we,” “our,” “us”) respect your privacy and value your trust and confidence. This privacy notice (the “Privacy Notice”) applies to our websites, mobile applications, and other online and mobile services, such as stadium WiFi network, that link to or post this Privacy Notice (collectively, the “Services”), and explains how we collect, use, and disclose information through the Services. This Privacy Notice also provides certain region specific disclosures, including additional information about data collected in those regions. By using the Services, you agree that you have read and understood the terms of this Privacy Notice.

Please note that the Services do not include NFL properties that do not link to this Privacy Notice and this Privacy Notice does not apply to information collected by the thirty-two individual member clubs (the “Member Clubs”), unless otherwise specified. In some instances, we may direct you to a site that is operated by a third party service provider. Even though the page where you provide information may have the look and feel of the Services, a different privacy policy may govern that information collection by our third party service provider.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

· Information Collection

· Sharing of Information

· Cookies and Similar Technologies

· Links to Other Websites

· Data Security and Data Integrity

· Communications Preferences and Access

· Changes To This Privacy Notice

· Region Specific Disclosures

· Individuals Located in California

· Users from the European Economic Area (“EEA”)

1. Information Collection

Information Provided by You

You generally are not required to provide information about yourself when you visit the Services. However, we may collect some or all of the following types of information when you register with or use our Services, sign up for contests or sweepstakes, participate in surveys, access various content or features, submit comments or content, use a send-to-a-friend feature, or directly contact us with questions or feedback:

o Contact information, such as name, e-mail address, postal address, and telephone number;

o Unique identifiers, such as a user name or password;

o Demographic information, such as gender;

o Financial information, such as credit card or other payment information;

o Real-time Geolocation information;

o Communications and marketing preferences;

o Favorite team and other personal preferences

o Photographs, if you provide a photograph of yourself to us

o Comments and other information posted in our interactive online forums;

o Correspondence, waivers or acceptances and other information that you send to us; and

o Additional information as otherwise described to you in this Policy, at the point of collection, or pursuant to your consent.

If you decide not to provide this information, it may limit our ability to provide some of our content.

Information We Collect Automatically

We also may collect certain information automatically when you visit or use the Services, such as stadium WiFi networks, including:

o Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;

o Your Media Access Control (MAC) address, which is a unique identifier assigned to a network interface controller

o Your device type or mobile carrier;

o Other unique identifiers, including mobile device identification numbers; and advertising identifiers (e.g., IDFA);

o Your browser type and operating system;

o Sites and apps you visited before and after visiting, or while using, the Services;

o Pages you view and links you click on within the Services;

o Information collected through cookies, web beacons, Local Shared Objects, and other technologies, as described further below;

o Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded;

o If you link your social media account to your NFL account we will receive information from those social media accounts in accordance with your settings on the social platform and their privacy policy;

o Standard Server Log Information; and

o Standard Network Traffic Information when you are connected to an NFL stadium’s WiFi network.

We may use information that we collect through the Services for a variety of purposes, including to:

o Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;

o Contact you via email and otherwise about your account;

o Conduct analysis on your behavior in order to better serve you with offers and content that is of interest to you;

o With your separate consent, contact you via email and otherwise about products, services, contests, and events that we think might be of interest to you, and otherwise send you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties;

o Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;

o Publish stories, comments, photos, and other information posted in our interactive online features;

o Process employment applications and inquiries;

o Customize and personalize your use of the Services, including providing you with tailored advertising;

o In the case of location information, to determine your market location for purposes of administering broadcast restrictions for live games, and for determining teams and offers in which you may have an interest;

o Protect or enforce the legal and contractual rights, safety and security of the NFL and NFL stadiums, enforce our Terms of Use and prevent fraud; and

o As otherwise described to you in this Policy, at the point of collection or pursuant to your consent.

3. Sharing of Information

Limited members of the NFL Fan Marketing and IT departments, as well as the third party vendors that processes your data on behalf of the NFL, may access and otherwise process Personal Information in connection with their job responsibilities or contractual obligations.

We may share your personal information with others for the purposes described above, as follows:

o Service Providers: We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). We may share information with third-parties, such as social networking platforms, so that they may send tailored communications on our behalf via their platforms. These companies are authorized to use your personal information only as necessary to provide these services to us.

o Subsidiaries and Affiliates: We may share your information with all members of the NFL Family, including, without limitation, our subsidiaries and affiliates (e.g., NFL Properties LLC, NFL International LLC, NFL Enterprises LLC, NFL Ventures, L.P., and NFL Ventures, Inc.).

o Member Clubs: We may share your information with Member Clubs where you have indicated a preference, based upon your location, or when you attend or purchase a ticket for an event sponsored by a particular Member Club, each of whom has its own privacy notice, which is available on the Member Club’s respective website.

o Select Business Partners: With your prior permission, we may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, you may be presented with an opportunity to have certain information shared with our third party business partners when you enter a contest or sweepstakes or elect to receive marketing offers or other information. If you do not elect to have your information shared, it will not be shared with such third parties. We are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.

o Contests and Sweepstakes: In some cases, a third party may operate or host a contest or sweepstakes on the Services, and collect your information. In those cases, we urge you to review the third party’s privacy notice for that contest or sweepstakes before participating. We are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.

o Third-Party Ad Serving and Audience and Traffic Measurement Services: We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users’ online activities over time and across different websites. To manage your preferences you may opt out here http://preferences-mgr.truste.com/. The Services may feature Nielsen proprietary measurement software, which will allow users to contribute to market research, such as Nielsen TV Ratings. Nielsen believes that you should have a choice about whether to contribute to our research and insights. To learn more about Nielsen measurement and your choices, including how to opt-out, please visit http://www.nielsen.com/digitalprivacy. To opt-out of Nielsen measurement through the app, please use the toggle feature [available in settings].

o Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction.

o Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of the NFL, our corporate affiliates, subsidiaries, business partners, and the users of our Services; enforce our Terms of Use; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.

o Interactive Features: We may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.

o Other Parties With Your Consent: We may share information with third parties when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.

o Aggregate Information: We may share aggregate information, such as demographics and usage statistics, with advertisers, sponsors or other organizations.

o Geolocation Information: We may share your geolocation information with service providers that perform certain functions or services on our behalf. These companies are authorized to use precise geolocation information only as necessary to provide these services to us. We also may share your geolocation information with third parties so that they may provide you with geographically relevant advertising. If you wish to stop the further collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology, please opt-out using your device settings.

4. Cookies and Similar Technologies

The Services use technologies such as cookies, beacons, tags and scripts. These technologies are used for a variety of purposes, such as analyzing trends, administering the Services, analyzing how users interact with the Services, and gathering demographic information. By using the Services, you consent to our use of cookies and similar technologies.

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Services, but your ability to use certain features may be limited.

The Services may use Local Storage Objects (LSOs) to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

We may use analytics software to allow us to better understand the use and functionality of our Services. This software may record information such as how much you use stadium WiFi networks, the sites and apps you visit while on the network and how you interact with them, how often you use an application, the events that occur within the application, aggregated usage, performance data, and where an application was downloaded from.

We participate in the Adobe Marketing Cloud Device Co-op to better understand how you use our website and apps across the various devices you use, and to deliver tailored promotions. Learn more (https://cross-device-privacy.adobe.com) about how Adobe does this.

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals. In some cases, third parties may be able to collect information about a user’s online activities over time and across different websites when he or she uses our Services.

We partner with third party advertisers to serve and display advertising on the Services. These partners may use cookies and Web beacons to collect information about your activities across different websites and services to provide you with relevant advertising. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. To serve and display advertising relevant to your location, the Services may also track your device’s precise geolocation by responding to beacons or inaudible signals sent to your device’s microphone. If you do not want the location of your device to be tracked by the Services, please opt-out using your device settings.

The NFL has worked with certain third-party social media providers to offer you their social networking services through our Services. For example, you can use third-party social networking services to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. Your interactions with those social networking services are governed by the privacy policy of the company providing the relevant service.

You also may be able to link an account from a social networking service (e.g., Facebook, Google+, Yahoo!) to an account through our Services. This may allow you to use your credentials from the other site or service to sign in to certain features on our Services. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Privacy Notice.

7. Links to Other Websites

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under our control or maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Notice does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

8. Data Security and Data Integrity

The security and confidentiality of your personal information is very important to the NFL. We have implemented technical and organizational safeguards to appropriately protect your personal information against accidental, unauthorized, or unlawful access, use, loss, destruction or damage.

Still, no system can be guaranteed to be 100% secure.

As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

We will retain your information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our website and receipt of our Services. For additional Region Specific Disclosures, see below.

The Services do not knowingly collect, use, or disclose Personal Information from children under the age of 13 unless permitted by law. If you have reason to believe that a child under the age of 13 has provided personal data to us, please contact us using any of the methods described in the “Contact Us” section of this Privacy Notice, and we will endeavor to delete that data from our systems.

For children located in jurisdictions within the European Economic Area, we comply with the age limits applicable in each Member State. In these instances, the references above to the age of 13 will be deemed to be references to the age limits applicable in each Member State.

11. Communications Preferences and Access

You may choose to receive promotional emails, newsletters, push notifications, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. You may opt out of receiving push notifications by turning off push notifications at the device level. Please note that opt-out requests may take some time to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.

If your information changes, or if you no longer desire to use the Services, you may request that we update or remove certain information by signing into your account and making the required changes, by emailing our Customer Support at [email protected], or by contacting us by postal mail at the contact information listed below. We will respond to your request within a reasonable time.

You may opt-out of location-based services at any time by editing your device settings.

We will retain your information for as long as your account is active or as needed to provide you services. We use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information When You Attend An NFL Event: When you attend an NFL-event or NFL co-hosted event, including NFL games at an NFL stadium or at a third party stadium or other NFL fan events (including events at which a fan mobile pass is utilized) (“NFL Event”), we may capture your image, voice and/or likeness, including through the use of CCTV cameras and/or when we film or photograph you in a public location at an NFL Event. You should therefore expect to be filmed or photographed by CCTV and/or by cameras when you are in a public location at an NFL Event (e.g. as an audience-member in the stadium if you are attending a game). In addition to describing how we capture and use your image, voice and/or likeness in this Privacy Notice, we may also display signs at any NFL Event indicating that you may be filmed or photographed.

How we use the Personal Information collected at an NFL Event: We will use the personal information:

o to produce, exhibit, advertise or otherwise use your image, voice or likeness in any and all media now or existing in future as part of NFL’s commercial, advertising and marketing activities; and

o in the case of images or footage captured on CCTV cameras, to ensure the safety of the venues hosting NFL Events and of individuals attending NFL Events.

Sharing your Personal Information from an NFL Event: We may share your personal information captured at an NFL Event with any of the entities set out in this Privacy Notice (see section entitled “Sharing of Information”). Additionally, when you appear in a photograph or film footage at an NFL Event, we may share that photograph or film footage containing your image, voice and/or likeness with our third party partners. These partners include our sponsors, licensees, advertisers and/or broadcasters. We will share the photographs or film footage containing your image, voice and/or likeness when it is in our legitimate business interests to do so. However, each of the third party partners may use your personal information for their independent commercial purposes without reference to the NFL.

Please also note that broadcasters and other third parties that are unconnected to NFL may be independently filming or photographing you when you attend an NFL Event. Although we only give permission to a small group of entities (such as certain broadcasters) to film or photograph NFL Events, these entities are separate data controllers in respect of your personal information and NFL is not responsible for how those parties use your personal information and for what purposes.

13. Changes To This Privacy Notice

We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about this Privacy Notice or the privacy practices of the Services, please contact us by email at [email protected] (or, if you are a user from the EU, at [email protected]) or at the following address:

345 Park Avenue, 5th Floor

Attn: Website Privacy Notice

REGION SPECIFIC DISCLOSURES

15. Individuals Located in California

This section provides additional information to California residents whose personal information is processed by the NFL pursuant to California law such as the California Consumer Privacy Act (“CCPA”). If you are not a California resident, this section does not apply to you.

Categories of Personal Information Collected and Disclosed: During the preceding 12 months, the NFL has collected the following categories of personal information that are processed pursuant to the CCPA: (1) identifiers, such as your contact information[ and online account information]; (2) Internet and electronic network activity information, such as information about your interactions with NFL websites, mobile applications, and social media pages; (3) audio, electronic, or visual information; (4) professional information; (5) education information; (6) inferences about you, including about your preferences; (7) financial information and other information as described above that may be considered personal information under Cal. Civ. Code Section 1798.80; (8) protected classifications under California or federal law; (9) commercial information including records or products or services purchased; (10) biometric information; (11) geolocation data.

We do not, and will not without your consent, “sell” personal information for purposes of the CCPA. As set forth in the Policy, we disclose personal information to third parties for business purposes, including without limitation, for purposes of advertising, marketing, and other services performed on our behalf, to protect against fraud and malicious activity, and for other business purposes described in the Policy. During the preceding 12 months, we have disclosed each of the above-listed categories of personal information for such business purposes. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our services.

CCPA Rights: The CCPA allows California residents to request that a business that collects consumers’ personal information give consumers access, upon a verifiable consumer request, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of personal information under certain circumstances, although there may be legal or other reasons that the NFL must retain your information consistent with California law. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you. Any differences in the services are related to the value provided.

Please submit your request by visiting the NFL CCPA Web Portal or by calling 1-855-265-6894]. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent or where your identity cannot be confirmed.

Shine the Light: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, or if you have questions as to how your information is handled in compliance with CCPA, please send an email to [email protected] or write us at CA Privacy Rights, NFL Digital Media Group, 345 Park Avenue, New York, NY 10154.

16. Users from the European Economic Area (“EEA”)

This section of the Privacy Notice applies only if you attend an event in the EEA or use our website or Services otherwise covered by this Privacy Notice from a country that is part of the EEA, and supplements the information in this Privacy Notice.

NFL Enterprises LLC is the data controller for processing of personal information when you use the Services.

NFL International LLC is the data controller for processing personal information collected when you attend an NFL Event in the EEA.

Legal Basis for Data Processing: We process personal information for the purposes set out in this Privacy Notice, as described above. Our legal basis to process personal information includes processing that is: necessary for the performance of the contract between you and the NFL (for example, to provide you with the Services you request and to identify and authenticate you so you may use the website); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement as well as to ensure your safety and the safety of our venues if you attend an NFL Event); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the website and our Services, and for NFL’s commercial, advertising and marketing activities); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time (by submitting a request through our standard Data Rights Request Form or by emailing [email protected]) without affecting the lawfulness of processing based on consent before its withdrawal.

In some instances, you may be required to provide us with personal information for processing, as described above, in order for us to be able to provide you all of our Services and for you to use all the features of our website.

Transfers: When we transfer your personal information to third parties as described in this Privacy Notice, some of these parties (for example, many members of the NFL Family) may be located in countries, such as the United States, other than your own, whose privacy and data protection laws may not be equivalent to those in your country of residence. When we transfer your Personal Information to other countries, including the United States, we apply appropriate safeguards, to protect your information and comply with applicable laws. For example, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data, remains protected and secure. A copy of these clauses can be obtained by emailing [email protected].

Your Rights: You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your personal information, and to request access to, rectification of, erasure of and portability of your own personal information in certain circumstances. Requests should be submitted through our standard Data Rights Request Form or by emailing us at [email protected].

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with your local supervisory authority if you consider that our processing of your personal information infringes applicable law.