Privacy Policy - December 7, 2019

Your privacy is important to Wise Gentlemen Sports Consulting, LLC and its affiliates, including HC Think Tank, LLC (the “WGS Group,” “we,” “us,” and “our”). This Privacy Policy (“Privacy Policy”) describes the information, data collection, and other privacy practices for the sites owned or operated by us, including, but not limited to, the Wise Gentlemen Sports website currently located at www.wisegentlemensports.com and the HC Think Tank, LLC (Sports Picks Marketplace) website currently located at www.sportspicksmarketplace.com (collectively, the “Site”), including, without limitation, what type of information is gathered and tracked, how the information is used, and with whom the information is shared. As described below, this Privacy Policy also applies to your other interactions with the WGS Group, such as when you purchase products or services, sign up for a newsletter or provide information to the WGS Group at a trade show or other event.

By visiting our Site or submitting your Personal Information (as defined below) to us by any means, you are giving your consent to our collection, use and disclosure of your Personal Information as described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please exit our Site and do not provide Personal Information to us.

What Information We Collect:

This Privacy Policy applies to all information collected by or submitted to the WGS Group and its affiliates (or carefully selected third parties acting on the WGS Group’s and its affiliates’ behalf), including Personal Information (as defined below). “Personal Information” is data that reasonably can be used to identify or describe an individual, such as your name, e-mail address, physical address, phone number(s), and credit card information. You do not need to provide us Personal Information to simply browse our Site. In addition, we use web analytics tools to gather anonymous, aggregated demographic information by tracking IP addresses and other types of Traffic Data (as defined below). We may use this anonymous, aggregated demographic information and share it with third parties to better understand users’ activity on our Site and provide services to our visitors. To learn more about our collection and use of Traffic Data, see the “Traffic Data” section below.

The WGS Group may collect Personal Information and Traffic Data when:

• you make purchases of products or services;
• you request support for the WGS Group’s products or services;
• you create a user account (e.g., login user name and password) on the Site;
• you register for webcasts, seminars or roundtables;
• you request information or materials (e.g., whitepapers or newsletters);
• you participate in surveys and evaluations;
• you participate in promotions, contests or giveaways, which we may offer from time to time;
• you apply for a job, or submit your resume to the WGS Group; or
• you submit questions or comments to us.

The WGS Group may also collect Personal Information from individuals (with their consent) at conventions, trade shows and expositions.

The types of Personal Information and Traffic Data collected may include (but are not limited to), as applicable:

• your first and last name;
• your title and your company’s name;
• your home, billing, or other physical address (including street name, name of a city or town, state/province, postal code);
• your e-mail address;
• your telephone number;
• (for job applicants submitting electronic information) your educational background, employment experience, and job interest;
• any other identifier that permits the WGS Group to make physical or online contact with you;
• any information that the WGS Group collects online from you and maintains in association with your account, such as: (a) your username, (b) your password, and/or (c) your credit card account information.

Use of Your Information:

Generally

The WGS Group collects and uses your Personal Information and Traffic Data to operate and improve its Site and deliver the services or carry out the transactions you have requested. These uses may include providing you with more effective customer service; making the Site or services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your Personal Information and Traffic Data to communicate with you. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. Some of the WGS Group’s services may send periodic member letters that are considered part of the service. We may also contact you to inform you of other products or services available from the WGS Group and its affiliates.

Personal Information collected on the Site and services may be stored and processed in the United States both on-premises and in the cloud, and by using the Site, product or service, you consent to any such transfer of information.

Sale or Acquisition of Assets

If we or substantially all of our assets are acquired, your Personal Information will be one of the transferred assets. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your Personal Information in the same manner required by our Privacy Policy in effect at that time. The provisions of this paragraph will apply also if we are sold as a part of bankruptcy proceedings.

If we purchase a business, the Personal Information received with that business will be treated in accordance with our Privacy Policy in effect at that time, so long as it is practicable and permissible to do so.

Use by Third Parties

From time to time, we may use your Personal Information and Traffic Data: (a) if we need to respond to valid legal process, including, but not limited to, a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law; or (b) if we deem it necessary to disclose Personal Information or Traffic Data, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, or to protect our rights or interests. We may also exchange Personal Information with other companies and organizations for credit fraud protection and risk reduction.

The WGS Group may share Personal Information and Traffic Data with companies working on our behalf and to our affiliated companies. In addition, some services of the WGS Group may be co-branded and offered in conjunction with another company. If you register for or use such services, both the WGS Group and the other company may receive information collected as part of the co-branded services.

In some cases the WGS Group uses contractors to collect, use, analyze and otherwise process information on its behalf. The WGS Group may also allow carefully selected partners to participate in limited marketing campaigns solely to promote the WGS Group’s products and services to you.

If you request something from the Site (for example, a product or service, a callback, or specific marketing materials), we will use the information you provide to fulfill your request. To help us do this, we may share information with others, such as the WGS Group’s business partners, financial institutions, shipping companies, and postal or government authorities (e.g., Customs authorities) involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes, which may require us to engage third-party service providers.

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, or performing statistical analysis of our services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain the confidentiality of the Personal Information and are prohibited from using it for any other purpose.

We do not endorse specific third parties or their goods or services, regardless of whether such third parties offer goods or services on the Site from time to time. Any relationship between you and such third parties will be governed exclusively by the terms offered by the third party and agreed to by you. If you provide these third parties with any Personal Information or other information, their use of such information will be subject to their privacy policies, if any, and will not be governed by this Privacy Policy. In addition, if you accept third-party goods or services advertised on the Site, a third party may be able to determine that you have a relationship with us (e.g., if the offer is made only through the Site).

Except as set forth herein, unless you have provided consent, the WGS Group will not (a) sell, rent or lease your Personal Information to third parties, and (b) disclose your Personal Information to third parties for their own marketing purposes.

Your Choices:

The WGS Group provides a number of ways for you to ‘opt-out’ of receiving additional information from us or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your information.

If you do not wish to continue receiving certain marketing materials (e.g., email messages), you can opt-out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, product safety warnings, software updates, or other administrative and transactional notices.

We may work with third parties that collect and use information about your website and mobile app usage over time and across our and non-affiliated websites and mobile apps including on different devices and browsers. These partners may use cookies, web beacons, pixels, and other similar technology to collect this information, and use it to infer your interests and deliver relevant advertising to your browser or device, and browsers or devices associated with it. This activity is called interest-based advertising. To learn more information about interest based advertising, and to opt out of interest-based advertising on your browser from companies that participate in industry self-regulation, US users can visit www.aboutads.info/choices and EU users can visit http://youronlinechoices.eu/. To opt out of interest-based advertising from participating companies for mobile apps, you can visit www.youradchoices.com/appchoices and download the appropriate version of App Choices for your device.

When you exercise choice through these tools, you will still receive advertising but that advertising may be less relevant to you. After you make your choices, data will no longer be collected from your browser or device for interest-based advertising on that browser or device, or associated browsers or devices. Additionally, data from those associated browsers and devices will not be used for interest-based advertising on the browser or device for which you made your choices. Data may still be collected for other purposes, such as analytics, reporting, and research. If you delete your cookies, reset your mobile identifier, or use multiple browsers or devices, you will need to register your opt-out choices again.

How to Update Your Information:

• Email Newsletters: Should your email address change, you may manage your subscription by unsubscribing to our newsletter and re-subscribing with your new email address.
• Specialized Areas: Specialized areas of our Site that require you to register may identify, at the point of collection, the ways available for you to update your information.
• Generally: At any time, you may update your information by e-mailing us at wisegentlemensports@gmail.com

Safeguarding Your Personal Information:

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of any information you transmit to the Site. Any transmission of information, including Personal Information, is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on this Site.

If a password is used to help protect your accounts and Personal Information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone, you should always log out before leaving a site or service to protect access to your information from subsequent users.

Enforcement:

The WGS Group regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or the WGS Group’s treatment of Personal Information by contacting us at the link or address indicated below.

wisegentlemensports@gmail.com

Traffic Data:

(a) Generally:

Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes and for improving your experience on this Site. When you visit our Site, we may automatically track and collect the following categories of information: (1) web beacons; (2) IP addresses; (3) log files; (4) domain servers; (5) types of computers accessing this Site; and (6) types of web browsers used to access this Site (collectively “Traffic Data”). We also use “cookies” to collect Traffic Data in order to customize content specific to your interests and make your navigation of our Site easier during subsequent visits.

(b) Cookies and Browser Information:

The WGS Group uses cookies for a variety of purposes. A cookie is a name for tokens of information that our Site may provide to your browser while you are at the Site. Cookies are stored on your device’s hard drive and, once placed there, the cookie will remain until you remove it. We use cookies to help us keep track of the items that you place in your shopping cart and to better understand our Site usage in the aggregate so that we know what areas of the Site users prefer. We also use cookies when you register for of our online groups to authenticate you and provide you access to those areas of the Site and to simplify your data entry for some of our online forms. We may also use temporary or “session” cookies to help you learn more about and/or order our services. If you simply want to browse, you do not have to accept cookies from the Site. Should you decide, however, that you would like to register and login to special areas of the Site and you have modified your browser settings not to accept cookies, you will need to re-set your browser to accept the cookies that we send it. Otherwise, you may not be able to participate in certain areas of the Site. Most browsers are defaulted to accept and maintain cookies. These cookies are not tied to your Personal Information.

Third party vendors, including Google, may use cookies to serve ads to you while you are using the Site based on your prior visits. We do not have access to or control over these cookies, and we disclaim liability for the actions of all third-party vendors. You may opt out of Google’s use of cookies by visiting Google’s Advertising Opt Out Page.

(c) Web Beacons:

Web beacons (also known as “web bugs”) are small strings of code that provide a method of delivering a graphic image on a web page or in an e-mail message for the purpose of transferring data. We may use web beacons (or clear GIFs) on our Site or include them in the e-mail messages we send you for many purposes, including site traffic reporting, unique visitor counts, advertising e-mail auditing and reporting, and personalization. Information gathered through web beacons may be linked to your Personal Information.

(d) IP Addresses and Log Files:

An Internet Protocol (“IP”) address is a number assigned to each computer on a network to identify your computer every time you log on to the Internet. We may keep track of IP addresses to troubleshoot technical concerns and to maintain the safety and security of our Site, such as by reviewing your IP address in combination with your Personal Information for credit fraud protection and risk reduction. In addition, we may use IP addresses to analyze trends, administer this Site, track traffic patterns, and gather demographic information for aggregate use.

Please be aware that, with or without cookies, our Site keeps track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring web site (if any), and other parameters in the URL (e.g., search criteria). We use this data to better understand our Site usage in the aggregate so that we know what areas of our Site users prefer (e.g., based on the number of visits to those areas). This information is stored in log files and is used for aggregated and statistical reporting. It is not attributed to you as an individual (i.e., log files are not associated with any particular user, computer, or browser).

(e) Do Not Track Signals:

At this time, our Site does not respond to “Do Not Track” signals received from our users’ web browsers.

(f) Google Analytics:

We may use Google Analytics to provide analytics services as described above. To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit https://support.google.com/analytics/answer/6004245. To opt out of Google Analytics you may visit https://tools.google.com/dlpage/gaoptout/.

Links to Other Sites:

The WGS Group’s Site often provides links to third-party websites, such as those of our business partners and online advertisers. You should review their privacy policies to learn more about what, why, and how they collect and use Personal Information and Traffic Data. Please be aware that these websites are not under our control, and we have no responsibility for the privacy practices of such other websites. This Privacy Policy applies solely to information collected by this Site. We make no guarantees about the accuracy, currency, content or quality of the information provided by such third-party sites, and we assume no responsibility for unintended, objectionable, inaccurate, misleading, or unlawful content that may reside on those sites.

For avoidance of doubt, if we provide links to social media platforms, such as Facebook or Twitter, and you choose to visit those websites through our links, please note that the information you post, transmit or otherwise make available on those websites may be viewed by the general public. We do not control user-posted content on social media homepages and are not responsible for any third-party use of your information that you have posted, transmitted or otherwise made available there.

Your California Privacy Rights:

California Civil Code Section § 1798.83 permits users of our Site that 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 send an email to wisegentlemensports@gmail.com.

For Questions or Concerns:

If you have questions or concerns regarding this Privacy Policy, you should first e-mail us at wisegentlemensports@gmail.com.

Changes to the Privacy Policy:

This Privacy Policy is incorporated into our Terms of Use which can be viewed using the link at the bottom of the Site. The WGS Group reserves the right to change this Privacy Policy from time to time, consistent with applicable law. If we do make material changes to this Privacy Policy, the revised Privacy Policy will be posted on this Site, and we will post a notification of such changes on the Site. Such changes, whether in the form of modifications, additions, or deletions, shall be effective when specified in the relevant notification or, if the change is immaterial, immediately upon appearing on this Site. Any use by you of this Site after such changes shall conclusively be deemed to be your acceptance of such revisions. We encourage you to review this Privacy Policy periodically to be informed of any such revisions.

To the extent there is a conflict between this Privacy Policy and our Terms of Use, the Terms of Use shall supersede and control.

NOTICE TO CHILDREN UNDER THE AGE OF 18 AND THEIR PARENTS OR LEGAL GUARDIANS:

THE SITE IS INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO THE WGS GROUP. IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION, PLEASE CONTACT US IMMEDIATELY AND WE WILL REMOVE THE INFORMATION. BY USING THIS SITE, YOU REPRESENT THAT YOU ARE AT LEAST 18 YEARS OF AGE.