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Mobile App Privacy Policy

Example Table

Last modified: March 1, 2024

Introduction

Revolutionary Racing Kentucky, LLC d/b/a Sandy’s Racing | Gaming (“Company” or “We“) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you may provide when you download, install, register with, access, or use the Sandy’s Racing|Gaming mobile application (the “App“).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App, and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this App.
  • You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Legal Gaming Age

This App is not intended for use by persons younger than the legal wagering or gaming age in the applicable jurisdiction (usually 18 or 21 years of age depending on the jurisdiction).  Persons younger than this legal age are not allowed to use this App, and we do not knowingly collect information from such persons for gaming related offers.  We reserve the right to verify age at any time for any reason and may decline to provide products, services, or access rights to any person who does not have valid age identification.

Children Under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at info@sandysgaming.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

  • Directly from you when you provide it to us.
  • Automatically when you use the App.
 

Information You Provide to Us

When you download, register with, or use this App, we may ask you provide information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, social security number, bank account and routing information, payment card information, and/or loyalty or rewards program account number (“personal information“).

This information includes:

  • Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through the App and of the fulfillment of your wagers. You will be required to provide financial information before placing a wager through the App.

 

Automatic Information Collection and Tracking  

When you download, access, and use the App, it may use technology to automatically collect:

  • Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Location Information. This App collects real-time information about the location of your device to enable certain features of the App. 

If you do not want us to collect this information do not download the App or delete it from your device. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.  Note, however, that opting out of the App’s collection of location information will disable its location-based features.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
  • Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

 

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the App and its contents, and any other information, products, or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our App according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the App.

We use location information we collect for use with beacons, geofencing, and analytics purposes.  We do not share location data with any other applications or third parties.  Location information we collect is always encrypted.

We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please do not download the App or delete it from your device.  For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
  • Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.

Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

You may also send us an email at info@sandysgaming.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

·      California:  If you are a resident of California, please see the Supplemental Privacy Policy for California Residents.

·      Colorado, Connecticut, Utah, and Virginia:

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please email us at info@sandysgaming.com.

·      Nevada: Under Nevada law, Nevada residents may opt out of the “sale” of their personal information, where the information is exchanged for monetary consideration.  We do not engage in such activity; however, if you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by emailing us at info@sandysgaming.com.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using a combination of HTTPS and TLS technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated, and notify you by email and/or text message to the email address and/or phone number specified in your account.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Webmaster
Revolutionary Racing Kentucky, LLC
10775 U.S. Rt. 60
Ashland, KY 41102
Email: info@sandysgaming.com

 

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

Last Updated:  March 1, 2024

This Supplemental Privacy Notice for California Residents (this “Supplemental Notice”) supplements the Company’s Privacy Policy and applies to you if you reside in California. This Supplemental Notice is adopted to comply with the California Consumer Privacy Act of 2018 (the “CCPA”). It also addresses requirements of certain other California laws. Capitalized terms used without definition shall have the meanings ascribed to them in the Privacy Policy and other undefined terms shall have the meanings ascribed to them in the CCPA.

  1. Information We Collect. The App collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to a consumer or personal device. For purposes of this Supplemental Notice, such information constitutes personal information.
    (a) Personal Information Collected. Below are categories of personal information recognized by the CCPA (“Personal Information”), along with examples (provided by the CCPA) of types of personal information in each category:
  1. Identifiers. Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers
  2. CA Customer Records Statute categories. Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
  3. Protected Class Characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
  4. Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  5. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
  6. Internet/network activity. Browsing history, search history, information on a consumer’s interaction with a webApp, application, or advertisement
  7. Geolocation data. Physical location or movements
  8. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information
  9. Professional/employment-related information. Current or past job history or performance evaluations
  10. Non-public education information. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
  11. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes


Exclusions
. Personal Information does not include publicly available information from government records, deidentified or aggregated consumer information, and information excluded from the CCPA’s scope (such has HIPAA–protected information and information protected by the Gramm-Leach Bliley Act). Personal Information collected as part of a communication or transaction between the Company and a representative of a government agency or other business, where the transaction is made for providing or receiving a good or service to or from such government agency or other business or conducting due diligence in connection with the foregoing is also excluded from the scope of this Supplemental Notice except with respect to Section 4(c) (non-discrimination).

Sources. We obtain Personal Information from you, including from you directly when you provide the Company with the information, from you indirectly when you interact with the App, and from you when you make electronic communications to the Company.

  1. Use of Personal Information. The Company uses the Personal Information it collects in the ways described in Section 3 of the Privacy Policy. The Company may use the Personal Information for commercial purposes as well as business purposes.

Disclosure of Personal Information.

Disclosure. The Company has shared or disclosed Personal Information within the past twelve months as described below.  The following chart identifies the categories of Personal Information recognized by the CCPA and collected by the Company, provides examples of the types of Personal Information within each category collected by the Company, indicates whether the Company has collected such categories of Personal Information during the past twelve months, the source of such Personal Information, how the Company uses such Personal Information, and to whom the Company has disclosed such Personal Information within the past twelve months:

 

Category of Personal Information

Source

Business Purpose

To Whom Disclosed (categories)

Identifiers

-you

-technologically gathered from you

-service providers

-business partners

-facilitate transactions

-marketing/ communications

-fulfill requests

-provide support

-provide goods/services

-fulfill contractual obligations

-service providers

-business partners

CA Customer Records Statute categories

-you

-service providers

-business partners

-facilitate transactions

-marketing/ communications

-fulfill requests

-provide support

-provide goods/services

-fulfill contractual obligations

-respond to inquiries

-service providers

-business partners

Protected Class Characteristics

n/a

n/a

n/a

 

Commercial Information

-you

-service providers

-business partners

-facilitate transactions

-provide goods and services to customers

– improve goods and services

-fulfill contractual obligations

-respond to inquiries

-service providers

-business partners

Biometric Information

n/a

n/a

n/a

Internet/network activity

-you/your device

-analytics and advertising partners

-improve App

-personalize App

-improve App experience

-service providers

-analytics and advertising partners

-business partners

Geolocation data

-you/your device

-analytics and advertising partners

-improve App

-personalize App

-improve App experience

-improve customer experience

-analytics and advertising partners

-business partners

Sensory data

n/a

n/a

n/a

Professional/employment-related information

n/a

n/a

n/a

Non-public education information

n/a

n/a

n/a

Inferences drawn from other personal information

-analytics and advertising partners

-business partners

-service providers

-provide goods and services

-marketing and remarketing

-improve customer experience

-improve product and service offerings

-you

-analytics and advertising partners

-business partners

 

Sale. The Company does not sell Personal Information.

  1. California Rights. The CCPA provides you with specific rights as a California resident. This section identifies those rights and how to exercise them.

    (a) Access and Data Portability. Subject to certain exceptions, you have the right to request certain information about the Company’s collection, use, and/or disclosure of your personal information over the past 12 months. After receipt of a verifiable consumer request from you, the Company will disclose to you the categories of personal information collected, categories of sources for the categories of personal information collected, business or commercial purpose for collecting such personal information, categories of third parties with whom the Company shared such personal information, and specific pieces of personal information collected about you.

    (b) Deletion. Subject to certain exceptions necessary to the functionality of the App, you may request that the Company delete Personal Information about you that it has collected and retained.

    (c) Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under the CCPA.

    (d) Opt-Out. The Company does not sell Personal Information.


California Request Process
.

Instructions. If you reside in California, only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. Such a request must provide sufficient information to allow the Company to reasonably verify that you are (or are an authorized representative of) the person about whom the Company collected the Personal Information, and describe your request with sufficient detail to allow the Company to properly understand, evaluate, and respond to it.  Please note that the Company cannot respond to your request or provide you with information if the Company 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 the Company. The Company will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. If you reside in California, you may exercise your Personal Information rights by submitting verifiable consumer requests in one or more of the following manners:

Emailing us at info@sandysgaming.com with the subject line “Consumer Rights Request” and sufficient information in the content of the message to identify you in our records.

If you prefer to submit your verifiable request to exercise your Personal Information rights by phone, you may contact the Company by phone toll free at 844-SANDYS1 (844-726-3971).

Verifying Requests. The Company will confirm receipt of your request within the time period prescribed by the CCPA and/or its regulations, let you know how the Company will process the request, and let you know the Company’s verification process and anticipated timeframe for response. The Company may try to verify your request by asking you to provide certain information and matching it to the information Company maintains about you. The Company will request at least two data points about you. Depending on the nature of your request, the Company may require more data points to match and/or may require you to sign a declaration confirming under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Authorized Agent. If you are a California resident, you may designate an authorized agent to make requests on your behalf to exercise your Personal Information rights. The authorized agent must be registered with California’s Secretary of State. The authorized agent making any request on your behalf to know or delete certain Personal Information about you must submit a copy of the written permission you granted them to act as authorized agent or a copy of the document showing you granted them a power of attorney for this purpose. If the authorized agent does not have a power of attorney in compliance with California’s probate law, you must also directly verify your identity with the Company. If adequate proof is not presented, the Company may deny the request.

Response Timing and Format. The Company will try to respond to a verified consumer request within forty five (45) days of receipt, but if the Company requires more time to respond, it will let you know how long and why in writing. The Company will respond to you by mail or electronically at your option. Any disclosures the Company provides in response to your request will pertain only to the 12-month period immediately preceding receipt of the verifiable consumer request. If the Company is unable to respond to the request, the Company will explain why, if applicable. If the Company is unable to verify your identity in connection with a request for specific pieces of information about you, the Company will let you know (but will not disclose the specific pieces of information) and will evaluate the request as though it were a request for categories of Personal Information disclosed to third parties during the past 12 months. If the Company denies a request due to conflict with federal or state law or an exception to the CCPA, Company will explain the basis for the denial. If the Company cannot verify your identity in connection with a request to disclose categories of information disclosed to third parties, the Company will let you know and will provide you information about its general business practices regarding collection, maintenance, and sale of Personal Information (as described herein). If the Company cannot verify the identity of an individual requesting deletion of Personal Information, the Company will deny your request. The Company has no obligation to provide you with specific Personal Information if such disclosure creates a substantial, articulable, and unreasonable risk to security. For any data portability requests, the Company will provide your Personal Information in the following format: by pdf. Unless your request is excessive, repetitive, or manifestly unfounded, the Company will not charge a fee to process or respond to your request. If the Company determines that a fee is warranted, the Company will explain why it reached that decision and provide you with a cost estimate before responding.

  1. Changes to Privacy Policy. Changes to the Supplemental Notice will be posted on this page. If the Company makes material changes to the way it treats users’ Personal Information, it may choose to notify you by email or through a notice in addition to posting. The date the Supplemental Notice was last revised appears at the top of the Supplemental Notice. You are responsible for ensuring that the Company has a current email address for you and for periodically visiting the App and the Supplemental Notice to check for any changes.
  2. Third Party Marketing. California Civil Code Section 1798.83 permits users of the App who are 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, please contact the Company at the contact information set forth in Section 8 below.
  3. Contact. If you have any questions or comments about this Supplemental Notice and Company’s privacy practices, or if you wish to exercise your rights as a California resident, please contact Company at:

    10775 U.S. Rt. 60
    Ashland, KY 41102
    info@sandysgaming.com