Effective Date: January 2020
This notice reflects our good faith understanding of the law and our data practices as of the date posted above, but the CCPA's implementing regulations are not yet final and there remain differing interpretations of the law. Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.
Capitalized terms used but not defined in this California Consumer Privacy Act Notice ("Notice") shall, unless otherwise noted, have the meanings given to them in the Cleveland Browns Privacy Policy (the "Privacy Policy"). To the extent the California Consumer Privacy Act ("CCPA") applies to the Cleveland Browns (referred to hereinafter as "the Browns," "we," "us," and "our"), this Notice provides additional information to California residents whose personal information ("PI") is collected, used, and disclosed by the Browns pursuant to the CCPA. If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy for more information.
PI We Collect and Disclose:
During the preceding 12 months, we have collected the following categories of personal information that are processed pursuant to the CCPA, each of which may have been collected directly from you, our service providers, our vendors/suppliers, our Affiliates and/or other individuals and business: (1) identifiers, such as your real name, alias, postal address, email address, unique personal identifier, Internet Protocol address, and account name; (2) personal records, such as physical characteristics or description, signature, telephone number, education, employment, payment card numbers, and other financial information; (3) personal characteristics or traits, such as sex, marital status, familial status, veteran status, disability, gender identity, etc., (4) consumer accounts details and commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (5) internet usage information, such as browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement; (6) geolocation data; (7) voice messages and similar audio recordings; (8) professional, employment or education-related information; and (9) inferences from the personal information collected, such as creating a profile regarding your preferences, characteristics, predispositions, behavior and attitudes. Please see Section 1 of the Privacy Policy (Information We Collect) for more specifics regarding the PI we collect. We may use the PI for the business and commercial purposes described in Section 2 of our Privacy Policy (How We Use the Information We Obtain), including but not limited to, to deliver and improve our products and services, to send you marketing or transactional communications, to manage our benefits programs, for analytics, and for security and fraud prevention. In addition, we may collect, use and disclose your PI as required or permitted by applicable law.
Sharing of PI:
We do not believe that we "sell" PI as defined under the CCPA. However, there is not yet a consensus on what the term "sell" means under the CCPA and we may revisit this conclusion as the law evolves. As explained below and in the Privacy Policy, we may disclose PI to certain third-parties for their own purposes, however we do not get paid to share PI and do not exchange PI for money. Accordingly, we do not currently consider these disclosures a sale of PI as defined by the CCPA.
While there is not yet a consensus, and although we think otherwise, data practices of third party cookies and tracking devices associated with our websites and mobile apps may potentially be determined to constitute a "sale" as defined by the CCPA. We currently do not believe that collection of data by third parties related to our online services is a "sale" of PI by us to them. However, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices. See Section 11 of the Privacy Policy (Choices: Tracking and Communications Options) to learn more about your choices regarding certain kinds of online interest-based advertising.
As set forth in our Privacy Policy, we may share PI with our service providers and other qualified vendors, for the same business purposes for which we collect the PI, including without limitation, for purposes of advertising, marketing, and other services performed on our behalf, to protect against fraud and malicious activity, as well as other business purposes described in our Privacy Policy (see Section 3 ("Information We Share With Third Parties")). In addition, your PI may be accessible to third parties with whom you interact or direct us to share your PI through the Service (including in connection with Co-Branded Areas).
We do not knowingly sell PI of minors under the age of 16.
CCPA Rights:
If you are a California resident and this Notice applies to you, you can request from us:
- Categories: Up to twice in a twelve-month period, information regarding our practices with respect to your PI in the twelve months immediately prior to your request, including (i) the categories of PI collected, (ii) the categories of sources from which we collected the PI, (iii) the purposes for any collection or disclosure of the PI, (iv) the categories of third parties to whom we shared the PI, (v) a list of the categories of PI disclosed for a business purpose in the prior 12 months and the categories of recipients (or that no disclosure occurred); and (vi) confirmation that we have not sold PI as we understand the definition of sale under the CCPA;
- Specific pieces: Up to twice in a twelve-month period, access, via a transportable and (if technically feasible) readily usable form, to the PI maintained by us and collected about you in the 12 months immediately prior to your request; and
- That we delete your PI, which we will do unless there is a legal or other basis for which we must retain the PI under the CCPA (e.g., to complete transactions and services requested or reasonably anticipated, for security purposes, for legitimate internal business purposes and to maintain business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement). Note that we are not required to delete PI that we did not collect directly from you.
Please note that, in order to protect our customer's information, we will not disclose or delete information until we've confirmed the requester's identity as required by the CCPA.
Non-Discrimination and Financial Incentive Programs: We will not discriminate against you in a manner prohibited by applicable law for exercising your CCPA rights and choices.
Requests and Inquiries: Please submit requests and inquiries by calling 1-888-842-1115 or by emailing privacy@clevelandbrowns.com. Please indicate in the request which right(s) you are exercising and provide us with an e-mail address or mailing address to which we can direct our response to your inquiry. Please note that, in order to protect our customer's information, requests will not be processed until the requester's identity is confirmed, and once we receive a request, we will verify it by requesting information sufficient to confirm the requester's 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 the requester's identity cannot be verified.