Last Updated and Effective Date – June 20, 2019
- our business
- our community events and promotion
- our other services
- our websites and social media accounts
- our mobile and other software applications or services (each, an “app”)
3) Personal Information We Collect and Receive.
We collect and receive the following types of personal information:
- Personal information you provide directly.We receive the personal information you provide when using our Services.
- For example, when you register for our Services, bid on or purchase products or Services from us, sign up to receive electronic or other marketing communications, subscribe to a newsletter, post on social media, enter a contest or sweepstakes, download or use an app, communicate with customer service, participate in a survey or complete a questionnaire, you may be asked to provide some information about yourself depending upon which Services you are using. This personal information may include, but is not limited to, your first and last name, username, password, company name, mailing address, phone number, date of birth, email address, mobile phone number, payment information, favourite teams or players, favourite music genres or performers, a photograph, and/or information about your use of our Services.
- If you use a “share with a friend” or “invite a friend” feature on our Services, we may collect your name and email address, or an electronic address, as well as the name and email address of the recipient if you share that with us. We do not use the names or email addresses submitted in these circumstances for any purpose other than sending an email on your behalf, unless we obtain your consent or the recipient’s consent, as appropriate. If you provide us with the name or email address of a friend or person other than yourself, you must first make sure you have their consent to do so and by providing it to us, you represent and warrant that you have such consent.
- Log and analytics information.This is information we automatically collect and store when you use our Services. It may include, for example:
- Information about your interactions with our Services, including the content you view, the products or Services you view, bid on, or purchase, the amount of time spent on our Services, the date and time at which you accessed our Services, and information in cookies and similar technologies.
- Information about how you access our Services, including your browser or operating system, your Internet Protocol (“IP”) address, and the websites you visit before and after visiting our Services.
- Device information.This is information we collect and store concerning the device you use when you access our Services. (Note that by “device,” we mean anything you use to access our online or digital Services). Device information may include, for example:
- The type of device you are using (e.g. your particular brand of phone, computer or tablet);
- Browser type;
- Certain device identifiers which may be unique to your device;
- Your Internet service provider; and
- Content you have stored on your device, if you have granted us permission to do so in the “Permissions” or “Privacy” setting of your device.
- Location information. This information may include specific location information drawn from tickets and seating data, your device’s GPS, Bluetooth, or WiFi signals, including information about nearby WiFi networks, location beacons and cell towers. We receive this information when you use location-enabled services that we offer, and also when you use certain location-based informational, marketing, or public service applications that we or other parties offer. We may also obtain location information from our video surveillance system or from our telephone records (e.g. area code).
- Personal Information from third-party sources. We may receive additional information about you from third parties and our business partners, as well as receive information about you that is publicly or commercially available, and we may combine that with the information we have collected or received about you in other ways. Also, we receive information about you when you choose to connect with social networking services while using our Services.
- To protect you, ourselves and others. We may collect or receive your personal information to protect you, ourselves and others by enhancing our ability to detect, prevent, or otherwise address fraud, illegal activities, security or technical issues, or to protect against harm to the rights, property or safety of MLSE, its customers, users or the public, or otherwise enforce our rights.
We also may collect or receive your information for other purposes that may be described to you at the point of collection or for which you provide your consent, or as permitted or required by applicable law.
4) How We Use the Information We Collect or Receive.
We use the information we collect and receive for the following purposes:
- To provide our Services. We use the information we collect or receive to provide you with the Services and operate our business. For example, we use this information to:
- Create accounts;
- Process transactions;
- Provide technical support and respond to user inquiries;
- Managing invoicing, accounting and information security services related to our transactions with you;
- Internal management purposes, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation and reporting;
- Administer your participation in our events, contests, sweepstakes, games, or promotions; and
- Notify you about updates to our Services or send other communications that are relevant to your use of our Services.
- To improve our operation and Services. We also use the information we collect or receive to provide content you may find relevant and interesting and to maintain and upgrade our operations and our Services. For example, we may use this information to: Solicit input and feedback about our Services;
- Identify and address technical issues on our Services; and
- Customize your experiences based on location information or your online activities, including the content you view, the products you bid on or purchase, other Services of ours you use, and other information we collect or receive.
- To provide effective advertising and marketing. We also use the information we collect and receive to provide ads for our Services and certain third-party services and to send you promotional communications. For example, we may use this information:
- To show you ads (on and off our digital and mobile Services, including on third-party social media services) based on location information or your online activities, including the content you view, the products you bid on or purchase, the other Services of ours that you use, and other information we collect or receive.
- To help our business and advertising partners understand the effectiveness of their advertising and marketing campaigns and to compare the performance of those campaigns to ads displayed on other websites and apps.
- To send you electronic and other marketing messages about MLSE, the Leagues, our venues, team sponsors, our community and charitable endeavors, or other third-party business partners that may be tailored to your preferences and interests – for example, content related to your favorite team or musical performer. (Please see below the Your Choices section in connection with promotional messages).
- To anonymize.Anonymization means rendering your personal information in a form that does not identify you and where you can’t reasonably be re-identified through the use of that information or in combination with other information. We may take your personal information and anonymize it, after which we may use it for our analytics services (for instance, to find out the types of people who use certain Services). Please note that once your information is anonymized, it is no longer covered by privacy laws and can be freely used by us or others to gain insights.
- To protect you, ourselves and others. We may use your personal information to protect you, ourselves and others by enhancing our ability to detect, prevent, or otherwise address fraud, illegal activities, security or technical issues, or to protect against harm to the rights, property or safety of MLSE, its customers, users, business partners, or the public, or otherwise enforce our rights.
We also may use the information we collect and receive for other purposes that may be described to you at the point of collection or for which you provide your consent, or as permitted or required by applicable law.
5) How We Share the Information We Collect or Receive.
We may share information that we collect or receive with third parties as described below:
- Our affiliates. We may share information with current and future “affiliates”, a term that includes our parent and subsidiary companies, joint venture partners, registered charities operated by us or other companies we control, are controlled by, or with which we are under common control.
- Our service providers. We may provide information about you to service providers that perform certain functions or services on our behalf (for example, hosting our Services, storing our data, fulfilling orders, providing products and services, managing databases, performing analyses, administering our contests and sweepstakes, collecting location data, providing location-based services, processing credit card payments, providing customer service, or sending communications for us). These companies are obligated to protect your information in a manner that is comparable to the way we protect your information, and are only allowed to use it for the purpose it was collected (e.g. they are not permitted to sell it).
- Operational partners. We partner with third parties to operate certain of our Services. From time to time, we may provide information about you to these operational partners. For example, we partner with Ticketmaster and concert promoters to operate certain Services and live events conducted in our venues, and we therefore may share information about you with such third parties, their service providers, their successors and permitted assigns, and their affiliates in connection with the operation and delivery of our Services. While these operational partners may use information about you to operate the Services, you should presume that these operational partners may use your information for their own purposes in accordance with their respective privacy policies.
- Business partners. With your consent, we may share information about you with other select business partners that are not service providers, such as our sponsors, other retailers, and broadcast partners, so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. We may also share information about your use of our websites, social media sites and apps with our social media, advertising and analytics partners. These other business partners are expected to protect the confidentiality, integrity, and security of any information we share with them. However, when you agree to share your information in this way, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.
- Leagues. We may share information about you with our Leagues (including your contact information, demographic information, and information about your interactions with MLSE), and the Leagues may use this information for purposes including: providing you with special offers, promotional materials, and other information that may be relevant to you, improving their products and services, and performing internal analysis. Where required by applicable law, we will seek your consent before sharing your information with the Leagues for promotional purposes. Please note that League websites and services are not controlled by MLSE and are subject to their own individual privacy policies. We are not responsible for the privacy practices of Leagues.
- Fraud, security, or technical protection partners. We may share your personal information internally or with service providers, business partners, to detect, prevent, or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of MLSE, its customers, users, business partners, or the public.
- Other parties in response to legal process or when necessary to protect us or our Services. We or the other recipients of your personal information described above may disclose that information — including the contents of your communications — to other parties when required or permitted by applicable law, such as when we have reasonable grounds to believe that:
- Doing so is necessary to respond to lawful governmental requests or legal process (for example, a court order, search warrant, or subpoena);
- The information is relevant to a crime that has been or is being committed;
- An emergency exists that poses a threat to your safety or the safety of another person or persons; or
- Doing so is necessary to protect or give notice of our rights or property, the rights or property of another person or persons, or to enforce our Terms of Service.
- Interactive features. We may share information with third parties when you post information to a public user profile or a public area of our Services. If you post information to these interactive features, it may 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 and do not post sensitive personal information.
- Games and contests. We may share information with third parties in connection with the administration or marketing of games or promotional contests connected to our Services. This might include, for example, names of the winners of a contest or in connection with a game leaderboard.
- Aggregated or anonymized information. We also may share other information with third parties in a manner that does not identify particular users.
We also may share the information we collect and receive for other purposes that may be described to you at the point of collection or for which you provide your consent. We may also share the information we collect and receive as permitted or required by applicable law.
6) Third Parties That Provide Content, Advertising, or Functionality on Our Services.
Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. Such third parties include, for example:
- Content providers, which may operate contests, sweepstakes, games, or public forums on our Services;
- Retail and other companies(such as those that operate our mobile applications, our online retail store or our online auction service or those that operate other Services), which may process transactions, provide customer service, and perform other functions;
- Advertising providers, which help us and our advertisers provide ads (on our Services or elsewhere online) that are tailored to users’ interests and understand users’ response to those ads;
- Audience-measurement companies, which help us measure the overall usage of our Services and compare that usage to other online services;
- Social networking services(such as Facebook, Twitter, and Google+), which enable you to log in to certain of our Services, to comment on content available on our Services, and to share things you find on our Services with your social network;
- Customer service providers, who (among other things) offer “bots” that help us provide answers to frequently asked questions about our Services, including by collecting and analyzing questions asked by visitors to our websites, apps and other online services to improve the quality of answers provided, as well as to better understand the preferences of individual customers; and
- Mobile location analytics providers, which use location-specific data to facilitate the transmission of informational, marketing, and public service communications to you.
7) Your Choices.
You have a number of choices about how we handle information we collect or receive about you.
- You may opt out of receiving future promotional email communications from us by clicking the “Unsubscribe” link in the footer of promotional email communications and updating your preferences. You may also identify specific email publications about our teams and services which you would like to receive by visiting the applicable team’s website. Please note that we may continue to send you transactional or service-related emails regarding your account.
- SMS and MMS. You may opt out of receiving promotional SMS and MMS messages (e.g., text messages) from us by replying “STOP” to any message, which is free of charge. Please note that we may respond to your opt-out request with a message confirming that you have successfully opted out.
- Access, Update, or Correct Information. In accordance with applicable law, you may have the right to access, update, or correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. If you would like to access, review, or update your information, please contact us at email@example.com or by mail using the information listed below under Contact Us. Please include your first name, last name, user name and email address in the body of the email. You may also contact us as set out in the Contact Us section below.
- You can opt out of receiving certain cookies by adjusting your browser settings to refuse certain cookies or to alert you when a cookie is placed. Your browser settings may not permit you to block the use of certain non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.
- Mobile Advertising Identifiers. These are unique strings provided by your mobile device’s operating system. They facilitate the delivery of targeted advertisements to your mobile device. For information on how to reset your advertising identifier and/or limit advertising tracking, please refer to the instructions for your mobile device’s operating system.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent for us to use your personal information at any time by contacting our privacy officer at firstname.lastname@example.org. Such withdrawal may affect your ability to use our Services, and could, in certain cases, prevent you from using one or more Services altogether.
We have adopted physical, technical, and administrative safeguards to help protect against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification of the information we collect and receive. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected. However, please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot and do not guarantee or warrant the security of any information you disclose or transmit to our Services and cannot be responsible for the theft, loss, destruction, or inadvertent disclosure of your information, or any other disclosures out of our control.
Your online access to some of your information may be protected with a password that you select. You should not disclose your password to anyone, choose an easily guessed password, or reuse passwords that you have used for other accounts. Taking steps like avoiding dictionary words or proper names, and adding extra character and punctuation marks can also help protect you. If you believe your password has been compromised, you should change it immediately. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages).
9) Children’s Privacy.
We take our responsibilities with respect to our younger users of our Services seriously. In addition to the steps that we take to safeguard the privacy and integrity of personal information submitted by adults, we adhere to the following principles and practices regarding personal information requested from or provided by children under 13 years old:
- We will not knowingly collect personal information from children under 13 (such as full name, home address, e-mail address, phone number, etc.). We may use age screening mechanisms to help us determine if a user is under the age of 13. If we determine that the user is under the age of 13, they will be directed to content that does not involve the submission of personal information.
- From time to time, we may post information on our Services about other promotions, contests or games that are open to children under 13 but that require personal information to participate. For these contests, children will be required to provide proof of consent from their parent or legal guardian. Children are not permitted to provide personal information on any MLSE Site or to enter these contests online absent the consent of their parent or legal guardian.
- If, at any time, a parent or legal guardian becomes aware that their child has provided us with information without their consent, or wishes to withdraw their consent to our use or maintenance of personal information collected from their child, the parent or guardian should contact us at email@example.com and we will promptly remove such information from our database(s). Please note that we may request proof of identity and relationship to the child before doing so.
- If you have any comments or questions on policies related to children’s data or about our commitment to protecting your and your children’s privacy, please contact us at firstname.lastname@example.org or by mail at the address below.
10) Third Party Links.
11) International Transfers of Personal Information.
MLSE’s offices are located in Canada, and regardless of where you use our Services or otherwise provide information to us, your information may be transferred to, maintained, and processed by MLSE, its affiliates, and our operational partners and service providers in Canada and the United States. Please note that Canadian and United States privacy laws, regulations, and standards may not be equivalent to the laws in your place of residence and such information may be subject to lawful access by the courts of the applicable jurisdiction, law enforcement, and governmental authorities. By using our Services or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to, in, and out of Canada and the United States.
12) Contact Us.
MLSE Privacy Office
c/o Legal Department
50 Bay Street, Suite 500
13) Cookies, Pixels, Beacons, and Other Online Recognition and Authentication Technologies.
Our Services may use online technologies called “cookies”, “pixels” and “beacons,” as well as other local storage technologies. This section explains what these technologies are and how they may be used.
- Cookies are stored on your device or in “local storage.” We may also use other types of local storage technologies, such as Local Shared Objects (sometimes called “Flash cookies”), in connection with our Services. These technologies are similar to cookies in that they are stored on your device and can be used to maintain information about your activities and preferences.
- to help authenticate you when you use our Services;
- to remember your preferences and registration information;
- to enable a shopping cart;
- to present and help measure and research the effectiveness of our Service, advertisements, and email communications (by determining which emails you open and act upon); and
- to customize the content and advertisements provided to you through our Services and on other websites and services you visit.
Beacons. Beacons are small pieces of code placed on Web pages, videos, and in emails that can communicate information about your browser and device to a server. Beacons can be used, among other things, to count the users who visit a Web page or read an email, or to deliver a cookie to the browser of a user viewing a Web page or email. These “beacons” should not be confused with “location beacons”, which are small devices in our venues or retail locations that enable alerts (such as a time-sensitive special offer) to be sent to your mobile phone or tablet.