Effective date: 01 May 2022

Welcome to the ufubo LLC website (the “Site“, “App“), (“ufubo“, “we”, “us” and/or “our”).

We at ufubo LLC (“ufubo,” “we,” and “us”) believe you should always know what data we collect from you and how we use it. This privacy notice provides information on how we collect and process your personal data when you use our products or services (collectively the “Services”) or visit our website www.ufubo.com; app.ufubo.com (the “Site”), contact us, or have a relationship with us.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE TO THE PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS AND USE THE SERVICES.

By using the Site and the Services, and in particular, when you fill out an account, you agree to the terms of this Privacy Policy and the collection, storage, use, processing, and disclosure by ufubo and its services providers of the Personal Information that you enter into the Services. If you don’t agree with this Privacy Policy, Cookies Policy, or the Terms of Service, please do not use the Services.

1. Information We Collect

When you use our Services, we collect the following types of information (collectively “Personal Information”).

Account Information

Some general and basic information is required to create an account with UFUBO and while signing up for our Services, such as your name, email address, phone number, password, and in some cases your date of birth and gender, language preferences, etc.

Other Information

Your private, sensitive, personal information other than the basic information to form an account that you voluntarily submit through the Services, including your stored documents, other passwords, and financial and legal information (“Secure Information”). Our systems will indicate whether you have submitted certain information if it is provided under certain functions of our Services but we do not access this information for the purpose of operating our Services other than storing the information until it is released and shared as per your instructions.

Health Information

If the situation calls for it, you may voluntarily provide us with your health and medical information which may be considered “Protected Health Information” or “PHI,” as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Our systems will indicate whether you have submitted certain information if it is provided under certain functions of our Services but we do not access this information for the purpose of operating our Services other than storing the information until it is released and shared as per your instructions.

Additional Information

To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information such as a profile photo, biography, nationality, location, and profession.

Data From Third Party Services

If you choose to connect your account on our Services to your account on another third-party service, such as financial advisors, legal advisors, or other third-party service providers, we may receive information from mentioned third parties as well.

We may also partner with third parties, such as funeral providers, employers, and insurance companies, that offer ufubo’s Services to their customers, employees, clients, and consumers. In such cases, those organizations may provide us with your name, email address, or similar information, including personal health information, so that we can provide the Services to these third parties.

For the Services to fully function, it may therefore be necessary for you to authorize one or more third-party providers to provide us with the information needed for performing the Services. This will only be done with your express permission, which will be collected upon the creation of your account with the third-party service providers that we have an agreement with and who you have given the permission to share the information with us.

Payment and Card Information

If you purchase a service or product from us, your credit card number, type, expiration date, name, and billing address (collectively, “Payment Information”) is collected, stored, used, and processed by Stripe Inc. (“Stripe”), our third-party payment processing company, and not by us. Accordingly, the collection, storage, use, and processing of your Payment Information is governed by Stripe’s applicable terms of service available at https://stripe.com/us/terms and privacy policy available at https://stripe.com/us/privacy. From time to time, we may request and receive some of your Payment Information from Stripe in order to complete certain transactions you initiated through the Services, to enroll you in a discount or other rebate program you elected to participate in, to protect against or identify potentially fraudulent transactions, or otherwise as necessary to manage our business. Accordingly, sometimes we may obtain Payment Information pertaining to you as a result of your use of the Services but we will only use any such Payment Information we obtain in furtherance of the Services.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your internet protocol (“IP”) address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services.

2. How We Use Your Personal Information

We use the information we collect for the following purposes:

Registration

When you register for the Service, or when a third party registers you for the Service on your behalf, we collect your Personal Information as part of the registration process, including but not limited to your name, address, phone number, and email address.

Service Delivery

We collect information to provide you with our Services and to manage your relationship with us, including sending you technical notices, updates, offers, promotions, rewards, events, news, security alerts, support, and administrative messages.

Improve, Personalize, and Develop the Services

We use the information we collect to improve and personalize the Services and develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys, and develop new features and Services.
Promote Safety and Security

We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

Legal Obligation

We collect information to enforce or defend any legal obligation or rights or to comply with any legal obligation.

Aggregate Insights

We use your data to produce and share aggregated insights that do not identify you for statistical purposes and to improve the Services. For example, we may use your data to generate statistics about our users, their profession, or nationality, to publish cognitive demographic insights.

3. How Information Is Shared

Subject to applicable state and federal law, including but not limited to our obligations under HIPAA and HITECH, we may share aggregated, de-identified or identified versions of your Personal Information with our subsidiaries, affiliates, partners, investors, and contractors for the purposes below.

Ufubo personnel may access Personal Information in order to provide Services and customer support to our users. We have developed internal processes to govern the way our personnel accesses user data. Internal access to this data is supervised to ensure user privacy.

We use third parties to process some of your Personal Information. When we allow them access to your data, we do not permit them to use it for their own purposes. We have a contract with each processor that requires them only to process the data on our instructions and take proper care in using it. They are not permitted to keep the data after our relationship with them has ended unless required by law.

If you connect or communicate with us using social media, for example, Instagram, Twitter, or Facebook, your personal information will be shared with us and the social media platform. We may be able to communicate with you using that platform but we are not otherwise responsible for the ways in which these platforms might use your personal information. Please look at the privacy notices and preference centers available on these platforms to understand how your personal information is used and what options you might have in respect of it.

We use service providers for the following:

Cloud Hosting Services – to provide hosting services;

Storage Services – to provide physical storage services;

Forwarding/Shipping Services – to provide shipping services;

Drop Off Points Services – to provide physical data reception services;

Analytic Tools – to provide data analytics on how the website is used;

Authorized contractors and third-party companies involved in the development, build, operation, and optimization of our Services and websites;

Authorized third-party companies involved in the processing of the information generated by the use of the Services and in managing our communications;

Authorized service providers to provide maintenance and support, including customer support;

Other service providers may be used from time to time.

We will update this page with details of any major service providers (or categories of service providers) who may have access to personal information.

Law and the Public Interest

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

Non-Personal Information

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports, to partners under agreement with us, or as part of the community benchmarking information we provide to users of our subscription services.

Anonymous or Aggregated Data

We may share de-identified versions of your Personal Information and other data in aggregated or non-aggregated forms with partners, investors, contractors or prospective advertisers, and research partners for any purposes related to our business practices.

Successor Businesses

We may share your Personal Information during a corporate transaction like a merger or sale of our assets or as part of the due diligence for such contemplated transactions. If a corporate transaction occurs, we will provide notification of any changes to control of your personal information, as well as choices you may have at that time.

Storage of Personal Data

We may store your Personal Data in data centers in the United States, EU-UK, cloud storage solutions, or on our premises, including corporate offices, partners, and warehouses. You may be entitled to review our data sharing and Processing agreements if you contact us per the contact details provided at the end of this Data Privacy Policy.

Sharing with Authorized Persons

As part of your use of the Services, you may designate specific persons who may access your information given certain conditions met. We may share your Personal Information with your designated specific persons and only pursuant to and in accordance with your explicit instruction, including the permissions you set that give any particular Deputy access to designated portions of the Services.

We may share your information with third-party providers to perform tasks on our behalf. These companies include (for example) logistics companies (e.g. USPS, FedEx, DHL), our payment processing providers (e.g. Stripe), website analytics companies (e.g. Google Analytics), and our insurance providers (e.g. Hiscox). Other tasks such as data analysis, surveys and customer service are completed in-house by our staff and do not require the sharing of your Personal Data with other parties. In instances where your Personal Data is shared with third-party providers, the providers will be contractually required to protect Personal Data from additional Processing (including for marketing purposes) and transfer.

Your Personal Data may be transferred to another country outside of the EEA, other than the United States, in order to fulfill the services requested, for example, where the ship-to address for data delivery is in another country. In this case, the country where Personal Data is transferred may not provide a similar or adequate level of protection to that provided by the EEA.

Under certain data protection laws, including the GDPR, Ufubo LLC, is liable if a third-party provider that we have engaged to Process Personal Data fails to fulfill its data protection obligations.

We may access and disclose your personal data to regulatory bodies if we have a good-faith belief that doing so is required under regulation. This may include screening against the Consolidated Screening List, for which the United States Government maintains restrictions on certain exports, re-exports, or transfers of items. This may also include submitting personal data required by local customs authorities and tax authorities. Additionally, we may disclose your personal data and other information as required by law, including in response to lawful requests by public authorities or to meet national security or law enforcement requirements. We may also disclose your personal data to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the resource, of any individual, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations.

Sharing with Financial Advisors or Partner Providers

We may share your Personal Information with third-party service providers for the case where you signed up for the Services using an invitation received from external advisors and third-party service providers such as financial advisors, funeral providers, or any other third-party provider.

4. Your Rights to Access and Control Your Personal Information

We give you account settings and tools to access and control your Personal Information. If you live in certain jurisdictions, you may have legal rights with respect to your information, which your account settings and tools may allow you to exercise.

Accessing and Exporting Data

By logging into your account, you can access much of your personal information, including your account settings. You can also download information in a commonly used file format, including data about your activities and results.

Editing and Deleting Data

By logging into your account and using your account settings, you can change and delete your personal information.

If you choose to delete your account, please note that all data, scores, and information will be permanently deleted, except as noted below.

We retain your Personal Information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others may remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other users copied out of our Services.

Note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like data stored in our backup systems.

5. How Long do We Keep the Data?

We maintain information about you for as long as we provide services to you, and as long it is required for us to perform any related business activities. After your information is no longer necessary for our business purposes, we will destroy the information unless we have agreed with you that we should keep the information, or a court or administrative order is made to preserve the information, or if it is otherwise stipulated by law.

6. Our Policies for Children

The Services are not directed to children under 18 years of age. Unless otherwise disclosed during collection and with parent or guardian consent, ufubo does not knowingly collect Personal Information from children under 18 years of age. Should it come to our knowledge that we have collected Personal Information of a person under 18 years of age without verified consent from a parent or guardian, we will take action to remove the information from our systems.

7. Information Security

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other service providers who have a business need to know and they are contractually obliged to keep this information confidential.

We also endeavor to take reasonable steps to protect Personal Information from external threats, for example, hacking or malicious software. Please be aware that there are always risks in sending Personal Information over public networks and that we cannot guarantee the security of data sent to us using these networks.

We have procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator when it is appropriate for us to do so.

If you have a security-related concern, please contact customer support at privacy@ufubo.com.

8. Our International Operations and Data Transfers

We currently operate in the United States, but we also have offices in the EU, and your Personal Information may be transferred to and from the EU for the purposes described in this Privacy Policy. For GDPR panel access, please visit this link.

We share your personal data within our company. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are also based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see EUROPEAN COMMISSION: ADEQUACY OF THE PROTECTION OF PERSONAL DATA IN NON-EU COUNTRIES.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see EUROPEAN COMMISSION: MODEL CONTRACTS FOR THE TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see EUROPEAN COMMISSION: EU-US PRIVACY SHIELD.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. California Privacy Disclosures

If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act of 2018 (“CCPA”).

How to Exercise your Legal Rights

You have the right to understand how we collect, use, and disclose your PHI, to access your information, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights.

You may exercise these rights using your account settings and tools as described in the Your Rights to Access and Control Your PHI section, for example:

By logging into your account and using your account settings, you may exercise your right to access your PHI and to understand how we collect, use, and disclose it.

Your account settings also let you exercise your right to delete PHI.

If you need further assistance regarding your rights, please contact our privacy support at privacy@ufubo.com and we will consider your request in accordance with applicable laws.

California residents also have the right, at any time, to direct us not to sell your Personal Information to third parties. We are not in the business of selling consumer information to third parties, we only use and share your Personal Information as described in this Privacy Policy. You may still send a “Do Not Sell My Info” request to us at any time by clicking the email link below to make your request, or mail your request to our address listed under “CONTACT DETAILS” below.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Categories of Information We Collect, Use, and Disclose for Business Purposes

We collect the categories of Personal Information listed below. We receive this information from you, your device, your use of the Services, third parties and as otherwise described in this policy. We use and disclose these categories of information for the business purposes described above. The categories are:

Identifiers like your name or username, email address, mailing address, phone number, IP address, account ID, cookie ID, and other similar identifiers.

Demographic information, such as your gender, age, health information, or description, may be protected by law.

Commercial information, including your payment information or records of the Services you purchased, obtained or considered (for example, if you added them to your shopping cart on the ufubo platforms but did not purchase them).

Internet or other electronic network activity information, such as the usage data we receive when you access or use our Services. This includes information about your interactions with the Services and about the devices and computers you use to access the Services.

Geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs, if you have granted us access to that information.

Electronic, visual, or similar information, such as your profile photo or other photos.

Professional, educational or employment-related information, including any information (like your name, email address, or similar information) that your employers, insurance companies, etc. provides to us so that we can invite you to participate in or determine your eligibility for ufubo’s Services that they offer to their customers, employees, clients, and consumers.

Other information that you provide, including account information such as your biography or country; ‘messages on the Services; and information recorded by your device which may vary depending on the device you use.

We never sell the personal information of our users.

10. Changes to This Policy

We may update this Privacy Policy from time to time, without notice, by posting a new version online. You should check this page occasionally to review any changes. If we make material changes affecting you we will notify you by posting the revised Privacy Policy on our websites and, if you are a registered user of our platform, by providing notice by email. This helps you always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Modifications will be effective immediately. Your continued use of the Service and/or continued provision of Personal Information to us will be deemed as an acceptance of such modifications to this Privacy Policy.

11. How to Contact Us

If you have questions about this policy or need help exercising your privacy rights, please contact us at privacy@ufubo.com, ufubo LLC, 300 Delaware Ave, Ste 210, #490, Wilmington, DE 19801, United States.