Privacy Policy

OVERVIEW

This Privacy Policy relates to Personal Information collected through customer interactions with our services and applies to all of the websites and products owned and/or operated by 3STEP Sports, its subsidiaries, and affiliates (“3STEP”) unless noted otherwise. Interaction with any 3STEP website, application, owned or controlled registration or waiver form, and/or any of our products, constitutes an acknowledgement of the practices and policies outlined in this Privacy Policy.

3STEP collects and uses Personal Information as outlined in this Privacy Policy to better understand our audience, improve products and experiences, and provide resources for advertising and marketing. This Privacy Policy covers Personally Identifiable Information (PII) we collect and store, in addition to other types of Personal Information. Where applicable, we also use de-identified data, through obfuscation or other means for the aforementioned purposes. This anonymized data is not subject to this Privacy Policy.

II. COLLECTION

Customer data is collected in a variety of ways including when:

1. customers register for 3STEP programming, including club teams and events. This includes online registration through third party tools such as LeagueApps, EZFacility and SportsEngine. We refer to this collected information as “Registration Information.”
   1. LeagueApps: leagueapps.com/terms
   2. EZFacility: ezfacility.com/privacy-policy
   3. SportsEngine: nbcuniversal.com/privacy
2. customers communicate with us or sign up for promotional messaging.
3. customers connect with us on social media platforms such as Facebook, Twitter, and Instagram, including interactions with 100+ 3STEP brands.
4. customers engage with our websites and applications in which cookies, device IDs and tracking technologies are employed. We automatically collect certain information about devices, including information about web browsers, IP addresses, time zones, and some of the cookies that are installed on devices. We collect information about the individual web pages or products viewed, what websites or search terms referred customers to a site, and information about interactions with a site. We refer to this automatically-collected information as “Device Information.”
5. we collect data from third parties or publicly available sources.
6. customers interact with our communities, advertisements and/or sponsor and partner activations, both digitally and on-site at events.

III. DISCLOSURE

The authorized disclosure of Personal Information may be occur for the following entities and purposes:

1. Affiliates and Subsidiaries : We share data with brands and organizations owned partially or wholly by 3STEP, as well as internally to 3STEP departments and teams. This disclosure informs decision making, improves services, and drives marketing and advertising.
2. Service Providers, Partners, and Vendors : We disclose data to external providers, vendors, and partners to the extent required to deliver customer-facing goods and services that directly contribute to the 3STEP experience.
3. Advertising and Marketing : We disclose data to partners to create and implement marketing and advertising campaigns on behalf of 3STEP Sports to the extent required to create and manage these campaigns. We further use customer data to construct targeted advertisements and marketing communication we believe may be of interest. In many cases, as Personal Information is never sold or shared directly with external organizations, we distribute targeted advertising to our customers on behalf of partners and sponsors.
4. Compliance and Law Enforcement : We may share data to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

IV. GOOGLE ANALYTICS

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our sites and applications. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Customers can opt-out of having their activity on the site or application available to Google Analytics by installing the Google Analytics opt-out browser add-on.

V. EMAIL MARKETING

We may use Personal Information to contact customers with newsletters, marketing or promotional materials and other information that may be of interest. Customers may opt-out of receiving any, or all, of these communications from 3STEP by following the unsubscribe link or instructions provided in any email or by contacting us using the information provided in this Privacy Policy.

In many cases, we may use Email Marketing Service Providers to manage and send emails to customers, including:

1. Mailchimp : Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: mailchimp.com/legal/privacy
2. Constant Contact : Constant Contact is an email marketing sending service provided by Constant Contact, Inc. For more information on the privacy practices of Constant Contact, please visit their Privacy policy: constantcontact.com/forward/privacy-center

VI. DO NOT SELL MY PERSONAL INFORMATION

We do not sell Personal Information. However, the Service Providers we partner with may use technology to create targeted marketing campaigns and messages using Personal Information as defined by the CCPA law.

To opt out of the use of Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA law, follow the instructions in the opt-out section of this Privacy Policy. Please note that any opt-out is specific to the browser used and may need to be performed on all applicable browsers.

VII. CONSENT, OPT-OUT, CHILDREN

Consent and opt-out are respected at all steps during and after a customer’s interaction with 3STEP.

• Consent: in some cases, we ask directly for consent to process customer data. In most cases, consent is indicated through acknowledgement and acceptance of our terms and this Privacy Policy on forms pre, during, and post 3STEP experiences and brand interactions. Legal requirements for consent differ by region and requests for consent vary accordingly.
• Opt-Out: Customers can opt out of targeted advertising and marketing communication at any time using links provided in targeted communications including in emails. Additionally, customers can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: optout.aboutads.info. See the Email Marketing section in this Privacy Policy for more information on platform-based opt-out procedures.
• Do Not Track: Please note that we do not alter our data collection mechanisms on sites and applications or our data use practices when we see a Do Not Track signal from a web browser. Our “Do Not Track” policy is in place as required by the California Online Privacy Protection Act (CalOPPA).
• Children (under 13 years old): We may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent for the purpose of supporting our internal operations. We may collect and store other Personal Information about children if this information is submitted by a child with prior parental consent or by the parent or guardian of the child. 3STEP may collect and store the following types of Personal Information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:
  • First and/or last name
  • Date of birth
  • Gender
  • Grade level
  • Email address
  • Telephone number
  • Social media handle
  • Parent’s or guardian’s name
  • Parent’s or guardian’s email address

• Parental Access: A parent who has already given 3STEP the permission to collect and use his or her child’s Personal Information can, at any time:
  • Review, correct or delete the child’s personal information, and/or
  • Discontinue further collection or use of the child’s personal information

Such requests can be made by contacting us using the contact information provided in this Privacy Policy

VIII. CALIFORNIA PRIVACY RIGHTS FOR MINOR USERS (CALIFORNIA BUSINESS AND PROFESSIONS CODE SECTION 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. For California residents to request removal of such data, contact us using the contact information provided in this Privacy Policy, and include the email address associated with the account.

Be aware that a request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

IX. CUSTOMER RIGHTS

Our policies and safeguards are designed to promote and protect the privacy and rights of our customers and their families. We acknowledge and conform to legal regulations wherever applicable.

• California: Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. For California residents to request more information under the California Shine the Light law, contact us using the contact information provided in this Privacy Policy.
• Europe: European residents have the right to access Personal Information we hold about them and to ask that this Personal Information be corrected, updated, or deleted. To exercise this right, please contact us through the contact information provided in this Privacy Policy. Additionally, for European residents, we note that we are processing Personal Information in order to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to the United States.

X. DATA RETENTION

We retain Personal Information to support the purposes outlined in this Privacy Policy including where required to comply with legal requirements and/or enforce contracts and agreements. When data is no longer required for legitimate business purposes or lawful compliance, it is securely deleted from our systems. Where possible, Personal Information can be deleted at a customer’s request. For questions about our data retention practices, please contact us through the contact information provided in this Privacy Policy. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our products. Usage Data refers to data collected automatically, either generated by the use of our sites and/or applications, or from touchpoints, sensors, and monitors on-site at 3STEP programs.

XI. SECURITY

We have put best practices in place to protect the confidentiality, integrity, and availability of data. Our technical and organizational safeguards and policies are designed in accordance with the guidelines and best practices outlined in cybersecurity documentation provided by NIST and found in HIPAA. Our sites and applications may contain links to other sites and applications that are not operated by 3STEP. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

XII. CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

XIII. CONTACT US

For more information about our privacy practices, and for questions or complaints, please contact us by e-mail at privacy@threestep.com or by mail using the details provided below:

3STEP SPORTS

200 BALLARDVALE STREET, BUILDING 2, FLOOR 3

WILMINGTON, MA, 01887, UNITED STATES