TOURNEY PRO PRIVACY POLICY
Please read the Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it. Please pay particular attention to the sections entitled “International Transfer” and “Your Rights.” Capitalized terms used and not defined herein shall have the meanings given to such terms in the Tourney Pro Terms of Use.
This Privacy Policy governs your access and use of the Platform and Services Tourney Pro provides. By continuing to browse, access and use (a) our proprietary website tourneypro.com, clubcentral.com, and/or application software commonly known as “Tourney Pro”; (the “Program”) and (b) any proprietary website using the subdomain name subdomain.clubcentral.com and created using the Program (each a “Subdomain” and, collectively, the “Subdomains”; the Program and the Subdomains are collectively referred to herein as the “Platform”), including any and all enhancements, modifications, and updates and related products and services for the Platform (the “Services”), you acknowledge and accept the privacy policy set out below. If you do not accept, you must cease access to and use of the Platform and Services immediately.
WHO WE ARE
For the purpose of applicable data protection legislation, the data controller of your information is Tourney Pro, LLC, 2500 W Higgins Road, Suite 1105, Hoffman Estates, Illinois 60169. Our data protection officer may be contacted by emailing info@tourneypro.com.
DATA COLLECTION AND CONSENT
We need certain personal data in order to deliver the Services and provide access to the Platform to you. By registering with us or submitting personal data through the Platform, you expressly consent to the collection, use and disclosure of your personal data in accordance with this Privacy Policy. We will process your personal data in accordance with applicable data protection and privacy laws. When you register with us, you are required to consent to our Privacy Policy. This consent provides us with a legal basis under applicable law to process your personal data. You maintain the right to withdraw such consent at any time.
We will collect the following information through your use of the Platform:
- Information you provide us
- Information about how you use the site
- Information about your device or network
- Payment Information
- Information from third parties
INFORMATION YOU PROVIDE US
For an individual user, the minimum amount of information we collect is your email address, a password, and your age. In most cases your name is required as well. If you register as a coach, we also collect country location, time zone, team name, sport type, and contact information of the members of your team. This information about your team will be associated with your information.
We may receive your information from third parties that provide services for us in connection with the Platform and the Services, and Tourney Pro may connect this information to your information that we already have.
Beyond the minimum information required to use the Platform and access the Services, we store data that you provide us for the Platform and Services. Examples include:
1. Contact information (e.g., phone number, physical address, date of birth, etc.)
2. Sports specific information (e.g., position, sports statistics, etc.)
3. Schedule information (e.g., whether you plan to attend an upcoming event)
4. Location information (e.g., your physical location at a given time)
5. Device and software information (e.g., the type of mobile device and associated hardware and software information, the browser used to access our web service, etc.)
Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience of the Platform and the Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits the Platform or accesses the Services; and (2) third party cookies, which are served by service providers on the Platform, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Our Service uses the following types of cookies for the purposes set out below:
ESSENTIAL COOKIES
The Platform and the services require these cookies for access to the Platform and to enable you fully access and use all aspects of the Platform and the Services. For example, these cookies facilitate the quick loading of content on the Platform. Tourney Pro cannot provide access to the Platform or the Services without these cookies and only uses these cookies for such purpose.
FUNCTIONALITY COOKIES
These cookies allow the Platform to remember choices you make when you use the Platform, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of the Platform which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you access the Platform.
ANALYTICS AND PERFORMANCE COOKIES
These cookies are used to collect information about traffic to the Platform and how users use the Platform, though this collected information excludes personally identifiable information about any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to the Platform, the websites that referred them to the Platform, the pages they visited on the Platform, what time of day they accessed the Platform, whether they have accessed the Platform before, and other similar information. Tourney Pro uses this information to operate the Platform and to gather demographic information about the Platform’s users and activity on the Platform. We may use third-party providers for this purpose that use their own cookies. Tourney Pro will only use these cookies to improve the Platform’s performance and delivery of the Services. You may opt out of cookies associated with these analytics services by turning off third party cookies for our site in your browser. Additional information about the specific cookies and third party providers is available on request.
TARGETED AND ADVERTISING COOKIES
These cookies track your browsing habits to enable Tourney Pro to show higher interest advertising to you by using your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.
SOCIAL MEDIA COOKIES
These cookies are used when you share information using a social media sharing button or “like” button on the Platform or you link your account or engage with our content on or through a social networking website. The applicable social network will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of the Platform. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you access the Platform.
INFORMATION ABOUT HOW YOU USE THE PLATFORM
We track how users use the Platform and Services including what pages a user visits and what actions the user takes.
INFORMATION ABOUT YOUR DEVICE OR NETWORK
We track what types of devices you use to access to the Platform and the Services. We collect device attributes like operating system, screen size, browser, etc.
We also track what networks you come from including your mobile operator, ISP, and location.
For security purposes we also track device specific information such as your IP address and device specific identifiers.
PAYMENT INFORMATION
If you choose to purchase any of our paid services, you will need to pay using a payment card (e.g., credit or debit card). We use third party payment card processing companies to process payments in connection with the Platform and Services. Tourney Pro has contracted with these entities so that these entities must process your payment card information in a secure fashion and in compliance with all applicable laws, including, but not limited to, any laws concerning the collection and transference of personally identifiable information. These third parties store and process your payment information and do not provide any such payment information to Tourney Pro.
If you are a team manager or league commissioner, you also may use Tourney Pro to collect funds from other users. Tourney Pro reserves the right to collect a servicing fee in connection with the collection of funds, provided, however, that Tourney Pro will outline any such fee to you in advance of collection. In addition, Tourney Pro will not use any payment information you provide for any reason other than effectuating the fund transfers. The fund transfers do not flow through Tourney Pro and are accomplished using one or more third party payment systems, and the use of these third party systems is subject to separate terms with that third party (as discussed further in “How We Share Your Information,” below).
INFORMATION FROM THIRD PARTIES
We receive data from third parties that are associated with Tourney Pro. These third parties provide us with data that you are using their service. In addition, these third parties may provide us with information about services in which you may have an interest (e.g., the sport or coaching type with which you are associated).
HOW WE USE YOUR INFORMATION
Tourney Pro will use any information collected from you pursuant to and in accordance with this Privacy Policy to:
- Provide, measure the use of, and improve your access to the Platform and the Services
- Deliver notices and other communications to you
- Show, track, and measure the efficacy of advertisements on the Platform
- Manage the security of the Platform and Services
PROVIDE, MEASURE, AND IMPROVE THE PLATFORM AND SERVICES
Our primary use of your information is to facilitate and improve our delivery of the Platform and Services to you. In doing so, Tourney Pro will use the data collected pursuant to this Privacy Policy data in anonymous and aggregate form to determine things like how many users in total are using a given feature on the Platform.
We also access information from third parties that provide analytical data to improve the effectiveness of Tourney Pro and make the Platform easier to use. We analyze the data in the aggregate, rolling up the data across many users to better understand how our users use Tourney Pro at a high level. Access to the privacy policies and opt out rights from these third party providers is available upon request.
During the process of developing, troubleshooting and administering the Platform and the Services, Tourney Pro may need to access your information, offer you additional information, opportunities and functionality, respond to requests that you make, resolve a problem or dispute, investigate potential security issues, or verify your compliance with the Terms of Use. The Tourney Pro customer support representatives may also need to review your information to assist you with any complaints or requests. Finally, Tourney Pro may need to review your information for accuracy and verify it with third parties or to comply with applicable law or legal process.
Third parties (such as coaches, managers, commissioners, and organizers in each club or league) can upload your information to the Platform and your information, in whole and in part, with other teams or club/league members through team and club/league settings or with the public. It is up to you as to whether you share this optional information, which is not required, though you may need to work with your coach or team managers and/or club/league owner/commissioner/manager to limit any information sharing or to remove or update any information submitted on your behalf. We may also share your information with a coach or manager, or if you have signed up to a team that participates in our clubs or leagues products, a club/league owner, commissioner or manager, or their designated contacts, in each case as shown on our records, if we believe you or another user that has interacted with you through our services may have violated the Terms of Use, as we consider necessary to help address the situation. The team coach or manager is defined as the person who is listed in Tourney Pro as the billing contact for the team. The club/league owner is the person who executed the contract with Tourney Pro to purchase access to the Platform and the Services.
COMMUNICATE WITH YOU
We use your information to send you marketing communications, communicate with you about the Platform and Services and to update you with any changes to or implementation of the Terms of Use, License Agreement, and Privacy Policy. We also use your information to respond to you when you contact us.
ADVERTISEMENTS
We use the information we have to improve our advertising and measurement systems so we can show you relevant ads on and off the Platform and measure the effectiveness and reach of ads and services.
MANAGE THE SECURITY OF THE PLATFORM AND SERVICES
We monitor the data to ensure that users are complying with the Terms of Use and to investigate suspicious behavior on the Platform and/or in connection with the delivery of the Services.
HOW IS MY INFORMATION SHARED?
- Data you share through the Platform and Services
- Vendors and service providers
- Third Party Apps and Sites
- Data sharing and advertising
- New owner
- Legal compliance
DATA YOU SHARE THROUGH THE PLATFORM AND SERVICES
The Platform and Services offer a number of ways to share content with members of your team, your sports organization or even publicly. You make the determination what data you want to share and how you want to share it. Coaches can enable the ability for the team to share certain information to social media sites and sports organization owners can determine if they want a website that is publicly accessible. In all cases the data shared is driven by the users.
VENDORS AND SERVICE PROVIDERS
Tourney Pro employs various third parties to run its service, as further described below. These third parties operate components of the Tourney Pro architecture. Tourney Pro relies on these third parties to maintain the safety and security of your information.
We may share your information with third-party service providers to: provide you with the Platform and Services that we offer you, to conduct quality assurance testing; to facilitate creation of accounts, to provide technical support, and/or to provide other services to Tourney Pro or to you.
THIRD PARTY APPS AND SITES
Tourney Pro works with various third parties to bring you additional goods and services through our Platform and the Services. We may share your information and transaction data (excluding payment card numbers and other non-anonymized information associated with the transaction) with such third parties if you, your team manager or your league/club commissioner has indicated interest in such third parties’ goods or services. Such third parties may also collect your information from you if you decide to interact with them. If we redirect you to a third-party site, we may send you to a URL on the third-party site which indicates some category data about you. We do not pass personal information to such third-party sites without your permission. However, that third party may add that category data (e.g., the fact that you are involved with a particular type of team or sport) to the data it stores about you. Please review that third party’s privacy policy to understand how it uses such data.
Information shared with or collected by such third parties is subject to their privacy policy. We do not control the privacy policies of these third parties, and you should review their privacy policies to understand how such third parties may use the information such third parties collect from you.
ADVERTISING
We use third parties to help measure our content and advertising effectiveness and to serve more relevant ads on our behalf and on behalf of other third parties. These ads are in some cases targeted to you based on your information collected across various channels including, offline and online, and are shown on our website and on third-party websites. We may share some anonymous information, including aggregated demographic information, for such purposes. Our partners may also place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device identifiers. Third parties may collect hashed information through a variety of technologies (including cookies, web beacons, and device identifiers) on our websites, our apps, or emails we send you. While this information is anonymous, our partners may collect information directly from you through linking the hashed or obfuscated personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Third parties may be able to add such information to the information it already stores about you, such as using this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for their own use such as advertising, analytics, attribution, and reporting purposes. Tourney Pro may share your email address with such third parties, solely in a hashed form that does not, in itself, identify you. Third parties may send personalized marketing emails to you based on the fact that you visited a particular website. Please review that third party’s privacy policy to understand how it uses such data. To opt-out of the use of your mobile device ID for targeted advertising, please see www.aboutads.info/appchoices. To learn more about internet-based advertising in general and to opt-out of these data provider cookies, please visit www.aboutads.info/choices, www.networkadvertising.org/choices.
Advertisers may assume that people who interact with, view, or click on targeted ads meet the targeting criteria. By interacting with or viewing an ad you are consenting to the possibility that the advertiser will assume that you meet the targeting criteria used to display the ad. Additionally information about these third party advertisers and partners is available upon request.
We also access your information from third parties to improve the Platform and Services. For example, we access information about your location, determined from your IP address or mobile device location information, to personalize your experience. We may use this information to provide you with weather or other information that pertains to your location.
NEW OWNER
We may share some or all of your information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset. If another company acquires our shares, business, or assets, that company will possess your information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy. Additionally, you hereby agree that we may share some or all of your information with any subsidiaries, joint ventures, or other companies under common control with us (collectively, “Affiliates”). We will require our Affiliates to comply with this Privacy Policy.
LEGAL COMPLIANCE:
Regardless of any choices you make regarding your information, we may disclose your information (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants or other legal process served on us; (c) to protect or defend the rights or property of Tourney Pro or users of the Platform and Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use. In response to any such reporting requests or obligations, Tourney Pro will provide only the data requested necessary for legal compliance.
MANAGING AND DELETING YOUR INFORMATION:
- Managing, deleting and accessing your information
- Questions about your information
MANAGING YOUR INFORMATION:
If you are a registered user, you may review, update, correct or delete your information by logging into Tourney Pro via the Platform or at www.tourneypro.com or www.clubcentral.com. If you are unclear about how to do this or have concerns, contact us at info@tourneypro.com. Registered users who are California residents can find additional information about your rights below.
If you wish to exercise any of these rights, please contact us using the details below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the Platform and the Services. Please note that your use of some of the Platform and/or Services may be ineffective upon opt-out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to the Terms of Use or Privacy Policy.
Access. You may access the information we hold about you at any time via your account, where applicable, or by contacting us directly through our support site on the Platform or via www.tourneypro.com or www.clubcentral.com.
Amend. You can also contact us to update or correct any inaccuracies in your information.
Move. Your personal data is portable, meaning you to have the flexibility to move your information to other service providers as you wish and upon written request to Tourney Pro.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your information, by contacting our support site on the Platform or via www.tourneypro.com or www.clubcentral.com. We retain the right to retain your information for up to 60 days after we process your deletion request.
Photos, team schedules and other information may be maintained by the team or group managers. If you have concerns about that information, contact your team or group manager or drop us a line at info@tourneypro.com.
We may communicate with you at various times, with administrative emails or phone calls, about transactions and service announcements, customer service responses and promotional emails like special offers, newsletters and updates. You can choose to stop receiving promotional emails at any time simply by changing your preferences, unsubscribing through the applicable Sites and Services, or using an email's unsubscribe function. You may not opt out of receiving administrative messages or customer service responses unless you delete your Tourney Pro account. If you have agreed to receive marketing communications through interactions with our partners, you must change your communication preferences with them directly.
If you choose to invite others to use Tourney Pro, we ask you for your friend’s email and possibly their name. We will automatically send your friend a copy of the email. Tourney Pro or our service providers store this information for the sole purpose of sending this one-time email. Your friend may contact us at info@tourneypro.com to request that we remove this information from our database.
QUESTIONS ABOUT YOUR INFORMATION
If you have any questions about this Privacy Policy, just send an email to Ray Glassmann at info@tourneypro.com. Or if for some reason you want to send us a letter (do people still do that?), just address it to:
Tourney Pro
Tourney Pro, LLC
2500 W Higgins Road, Suite 1105
Hoffman Estates, Illinois 60169
EU-US AND SWISS-US PRIVACY SHIELD NOTICE
- Compliance and certification
- Personal data
- Submitting complaints
OTHER IMPORTANT INFORMATION
- Data retention and security
- Children's privacy
- Changes
- Do not track settings
- Information for California residents
DATA RETENTION AND SECURITY
The security of your information is important to us. We store your information in the Tourney Pro systems, and we use industry standard security precautions to protect it.
No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee the security of your information or other information. If you have any questions or concerns about security, drop us a line at info@tourneypro.com and we will do our best to respond to them.
We retain information as long as it is necessary and relevant for our operations, typically until it is deleted by the user or team/group owner/manager so that it may be accessed for that team or group on an ongoing basis (for example in the next sports season). In addition, we may retain your information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use and take other actions permitted by law.
CHILDREN’S PRIVACY
Tourney Pro does not knowingly collect information from children under the age of 13. Furthermore, we do not target our service to children under these ages nor do we knowingly communicate with children under 13. When we work with teams and groups with children under 13, the parents/guardians of the children must enter and manage their children’s information. Any submission of information by any children under the age of 13 is an explicit violation of the Terms of Use and this Privacy Policy, and Tourney Pro may terminate or suspend the right to access the Platform or the Services of any user found permitting or facilitating the submission of any information to the Platformy by any children under the age of 13.
INTERNATIONAL TRANSFER
This Services are hosted in the United States of America and subject to applicable U.S. federal and state laws, rules and regulations. Your personal data, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your country. By using the Platform, you consent and agree to this transfer, storing, processing and use of your personal data in accordance with this Privacy Policy.
SENSITIVE INFORMATION
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive information (e.g., government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics or trade union membership) on or through the Platform or otherwise to us. Note that teams or sports organizations using the Platform may request certain health information from you to help ensure the safety of players. We do not use that health data in any of our marketing or advertising activities. Please consult your team or sports organization to understand how they use, disclose, and process such data.
COMPLAINTS
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal data, please contact us at: info@tourneypro.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
CHANGES
If we decide to change this Privacy Policy, we will post the changes on the Platform and at www.tourneypro.com or www.clubcentral.com. and if there is a material change to this Privacy Policy for any reason, we will notify you promptly by sending an email to an email address we have on file for you.
DO NOT TRACK
We do not currently respond to “do not track” signals from web browsers.
INFORMATION FOR CALIFORNIA RESIDENTS
Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at info@tourneypro.com. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
California S.B. 568, titled “Privacy Rights for California Minors in the Digital World” allows California minors a right to delete content that they posted to a website, social media profile, or online service while under the age of 18. To request removal of any such content, please contact us at info@tourneypro.com.
In addition to your rights stated in this Privacy Policy, if you are a California resident, you have the following rights:
Information. To request that we disclose the following information about our collection and use of your personal data during the past 12 months:
- The categories of personal data that we have collected about you;
- The categories of sources from which personal data is collected;
- The business or commercial purpose for collecting or selling personal data;
- The categories of third parties with whom we share your personal data;
- Whether we have disclosed your personal data for a business purpose, and if so, the categories of personal data received by each category of recipient; and
- Whether we have sold your personal data, and, if so, the categories of personal data received by each category of recipient.
Access. To request a copy of the personal data that we have collected about you during the past 12 months.
Deletion. To request that we delete personal data about you that we have collected from you.
Nondiscrimination. To exercise your rights described above free from discrimination, such as denial of goods or services; price/rate increases for goods or services (including through grants of discounts/benefits or imposing penalties); decreases in service quality; or suggesting that such discriminatory acts may occur if you exercise your rights. However, a difference in price or service quality is not discriminatory if reasonably related to the value to our business of the personal information we are unable to use due to the exercise of your rights, and we may offer you certain financial incentives that can result in different prices, rates or service quality.
Financial Incentive Program Disclosures. To receive a clear description of the material terms of any program involving financial incentives for the collection, sale or deletion of your personal information, and decide if you want to consent to be entered in it (you can revoke this consent at any time).
How To Exercise Your Rights. You may exercise the rights described above as follows:
Right To Information, Access, Deletion, and Opt-Out Of Sales. You may exercise the information, access, deletion, and opt-out of sales rights described above by submitting a verifiable request as follows:
- Opt-out by visiting our website or accessing the Platform and clicking the ‘Do Not Sell My Data’ button at the bottom of the page.
- Emailing info@tourneypro.com for remaining questions or concerns.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child under 13.
The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are a California resident about whom we collected personal information or their authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
These rights are not absolute, are subject to exceptions, and we may be required or permitted by law to decline your request.
PERSONAL INFORMATION THAT WE COLLECT, USE AND SHARE
The chart below provides information that we are required to give you under California law about the categories of personal information that we have collected, used and shared in the prior 12 months. See below for a description of the sources of the personal information we collect, as well as the business and commercial purposes for which we collect, use and share this information.
* For a description of these categories, see the definition of Personal Information in Section 1798.140(o)(1) of the California Consumer Privacy Act.
** See the section of this Privacy Policy titled “How is My Information Shared?” for a description of the business purposes for which we disclose your personal information and the categories of third parties to which we disclose it.
*** Our use of your personal data in a manner that constitutes a “sale” under California law is for analytics, marketing and advertising purposes.