THIS PRIVACY POLICY (“PRIVACY POLICY”) SETS OUT THE POLICY REGARDING THE COLLECTION, USE, DISCLOSURE AND TRANSFER OF YOUR INFORMATION BY AMERICAN CRICKET ENTERPRISES INC., ALONG WITH ITS SUBSIDIARIES AND AFFILIATES (“WASHINGTON FREEDOM”, “WE”, “OUR” OR “US”).

This Privacy Policy is applicable to persons (each a “User”) who browse, access or use our various websites, including sub-sites, platforms and applications (collectively referred to as “Services”). By using or visiting the Services or otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend you review this Privacy Policy periodically as it may be updated from time-to-time. For the purpose of this Privacy Policy, wherever the context so requires, “you” or “your” shall mean User.

Washington Freedom is committed to protecting the privacy of those who entrust us with their personal information. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses, contact details and any similar information provided to us in the course of our business operations. Personal information that is de-identified or anonymized is not considered personal information. This Privacy Policy details our commitment to your privacy.

INFORMATION RECEIVED, COLLECTED AND STORED

PERSONAL INFORMATION

CATEGORIES

Washington Freedom may collect or receive the following type of personal information from Users:

• Contact information – such as name, address, email address, date of birth and phone number
• Unique identifiers – such as username or password
• Information provided in public forums – such as public posts, videos and other information
• Demographic information – such as race, gender or immigration status
• Financial information – such as credit card or other payment information
• Geolocation information – including your current location
• Forms of Identification – such as driver’s license or passport
• Player Information – such as a player’s skills, statistics, type of player

SOURCE

This information is usually provided by Users or a cricket player’s league or club representative.

PURPOSE

Washington Freedom receives, collects and stores the above type of information to allow our Users to access various aspects of our Services, to communicate with us and other Users, and respond to our Users about our Services, including validation of identity, to run background checks, or to meet legal obligations, and provide you with the products, promotions, services, newsletters, and information you request. We may also collect the above information through our online platforms or portals for the purpose of conducting player drafts, team / squad selections or youth coaching programs.

RECIPIENTS

We may share this information with our affiliates, select commercial or marketing partners (for commercial purposes) or other service providers and partners that perform services for us (such as hosting the Services, fulfilling orders, performing analyses, processing credit card payments or providing other customer service functions). We may share certain player information with other Users, affiliated team or club owners, affiliated academies, investors or other third parties.

BROWSING INFORMATION

Washington Freedom may also receive, collect and store your browsing information such as your IP address, MAC address or other device identifier, your device type or mobile carrier, standard server log information, the kind of browser or computer you use, pages and content that you visit on our Services, what you click on, the state and country from which you access the Services, date and time of your visit, and web pages you linked to our Services from. This type of information is usually collected from our Services and your interactions with the Services, including through the use of cookies and other tracking technologies (see below). Washington Freedom may use this information to evaluate the usage of the Services and improve performance, to protect the security and integrity of the Services and our business, such as preventing fraud, hacking and other criminal activity to meet our legal obligations. We may share this information with our service providers who help us with fraud protection and service analytics.

PROTECTING INFORMATION

Washington Freedom takes reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. Any information which Washington Freedom holds is stored (in electronic form) on secure servers that are protected in controlled facilities. Where applicable, we use industry-standard technology in connection with the Services to help protect personal information from loss, misuse and unauthorized access, disclosure, modification or disclosure. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. And, of course, any information you include in a posting to the discussion areas is available to anyone with Internet access. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your personal information secure.

In addition, Washington Freedom employees, contractors and service providers who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

COOKIES

Cookies allow web applications to respond to you as an individual. A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic and tracks when you visit a particular site. We may use traffic log cookies to monitor which pages on our web site are being used. This helps us analyze data about web page traffic and improve our web site in order to tailor it to customer needs. We only use this information for statistical analysis purposes before removing the data from the system. Overall, cookies help us provide you with a better web site experience by enabling us to monitor which pages you find useful and those you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You may choose to accept or decline cookies in most web browser settings. This may prevent you from taking full advantage of the web site.

USE OF INFORMATION

GENERALLY

Washington Freedom will only use personal information for the purposes identified in this Privacy Policy. We may use service providers to provide some of our Services. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by Washington Freedom, including requirements that such information be maintained in a confidential and secure manner. Washington Freedom does not sell, trade, distribute, lease or transfer User information to third parties unless we have your permission or are required by law.

BUSINESS TRANSFERS

In the event that a subsidiary, division, service, or all of Washington Freedom is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.

TO COMPLY WITH LAWS

Washington Freedom may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose personal information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our directors, officers, employees, licensees, affiliated team or club owners, affiliated academies or others, in accordance with or as authorized by law.

RETENTION OF INFORMATION

Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise authorized or required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified. Because of the way we maintain certain services, after your information is deleted, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

ACCESSING AND UPDATING PERSONAL INFORMATION

We will take reasonable steps to accurately record the personal information that you provide to us and any subsequent updates, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes.

UPDATING OR CORRECTING INFORMATION

We encourage you to review, update, and correct the personal information that we maintain about you, and you may request that we delete personal information about you that is inaccurate, incomplete, or irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirement. If you would like to review, change or delete personal information we have collected from you, please contact us at media@washingtonfreedom.com.

We ask Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Your right to review, update, correct, and delete your personal information may be limited, subject to the law of your jurisdiction:

• if your requests are unreasonably excessive or repetitive;
• where the rights or safety of another person or persons would be jeopardized; or
• if the information or material you request relates to existing or anticipated legal proceedings between you and us or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity.

Your right to review, update, correct, and delete your information is subject to our records retention policies and applicable law, including any statutory retention requirements.

OPTING-OUT

You may also exercise choices regarding communications from Washington Freedom as follows:

• Marketing or Quality Control Communications: You may decide that you prefer Washington Freedom not to use your personal information to promote new and/or additional products and/or services which may be of interest to you or request that we do not contact you by mail or telephone for marketing purpose or for quality control purposes. If this is the case, you can contact us at media@washingtonfreedom.com.
• Email Communications: You can also limit the communications that Washington Freedom sends to you by email. To opt-out of commercial emails, simply click the “unsubscribe” or “opt-out” link at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to provide you with important information about your account.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRY

The information we collect about you, in certain cases is transferred to the servers hosted in third countries, by the third parties engaged by us. You understand and expressly agree that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.

CALIFORNIA PRIVACY RIGHTS

California law permits our customers who are California residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. Washington Freedom does not meet the requirements for compliance with the California Consumer Privacy Act. However, we are happy to answer questions that California residents may have about our privacy practices by emailing media@washingtonfreedom.com.

LINKS TO THIRD PARTY SITES / AD-SERVERS

The Services may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the application or website you are visiting. That privacy policy may differ from ours. We are not responsible for the protection and privacy of any information that you provide while visiting such websites and such websites are not governed by this Privacy Policy.

UPDATES / CHANGES

We may alter our Privacy Policy from time to time to incorporate necessary changes in technology, applicable law, security standards or any other reason. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Services. Your use of the Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the Services to ensure that you are aware of the latest version.