Zweeler™
US Privacy Policy 1.0

The website located at www.Zweeler.com (the “Site”) and the fantasy sports gaming services offered through our platform (the “Services”) are owned and operated by Zweeler LLC.

Zweeler respects and protects the privacy of the users that use our Services. We maintain strict policies to ensure the privacy of those who use our Services or those who may just be visiting (together, “Users”). This policy (“Privacy Policy”) describes the types of information we may collect from you, as a User, and our practices for how we collect, use, maintain, protect, and disclose such information. The way that we collect and use your information depends on the way you access the Services (general browsing, account creation, entering contests, etc.). This Privacy Policy also includes a description of certain rights that you may have over information that we may collect from you.

By using the Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Services.

Table of Contents

1. Summary
2. How can you get in touch?
3. What types of Personal Information do we collect?
4. Why do we collect your Personal Data and on what basis?
5. Cookies and Similar Technologies
6. When do we share your personal information?
7. Controlling Your Information (California Data Rights)
8. How long will Zweeler keep my data?
9. Security of Your Data
10. Zweeler Employees
11. Do Not Track Settings
12. Complaints
13. Changes to Zweeler Privacy Notice

1 Summary

2 How can you get in touch?

There are various ways you can contact us.

For general queries do not hesitate to get in touch with our Customer Service team via email: support@Zweeler.com.

If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email: dataprotectionofficer@Zweeler.com.

3 What types of Personal Information do we collect?

We collect personal information when you interact with us and use our services. Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you.

Information you provide to us

At registration:
• Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
• Payment details; and
• Your account login details, such as your username and password.

Through your use of Zweeler services:
• Information about how you interact with our products;
• Information about your online browsing behavior on Zweeler’s websites, mobile apps, and other Zweeler content online – please see our Cookies Policy for more details; and
• Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier).

Other sources of personal data
• Data received from our business partners and from other organizations, such as specialist companies providing verification services, credit reference agencies, and fraud prevention agencies;
• Publicly available sources, like postcode lookup;
• Photographic identification and proof of address documents (to carry out due diligence). This is only mandatory when the cumulative refund amount exceeds the $2,000 USD; and
• Banking and financial details (to establish the source of funds where a transaction is involved). Only when you ask for a refund via bank transfer.

Information about third parties

If you give us personal information about someone else (for example via a Refer a Friend program) then you should not do so without their permission. Where information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this Privacy Notice. This list of personal data types collected by Zweeler is not exhaustive and further information may be requested from you when Zweeler considers it fair and necessary to do so.

Special categories of data

Personal data collected by Zweeler may include so called “special categories of data”, such as data revealing health (responsible gambling related).

We have in place additional measures to protect your sensitive personal data and its confidentiality.

4 Why do we collect your Personal Data and on what basis?

We recognize the trust and confidence our customers place in us as a service provider. In return, Zweeler is open about why we collect your data. First and foremost, collecting your information is essential for providing you the services and products you want. In addition, your data is used to personalize and improve your experience using our services, and to contact you from time to time with important information. In some cases, we need to collect and use your information to comply with the law. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities.

Under the contract – when it is necessary for the performance of a contract to which you are a party. Our T&Cs, which you have accepted at registration, set out the terms of one of the contracts and the services we will provide. In addition to other services, data collection under the T&C occurs when we provide the following services:
• to provide (skilled) gaming services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
• for "service administration purposes", such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or Terms of Use, to let you know if your Zweeler account has become dormant and to ask if you would like to use it again before we close it; and
• to process your transactions.

B) Under legitimate interests - It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine if we can process your data on this basis, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
To personalize your experience
• to offer a more relevant, tailored service; for instance, we could use your playing history to provide personalized recommendations and products;
• If you are signed-in or subscribed to our marketing offers, you will receive a personalized service. If you don’t want to receive these services you can unsubscribe from marketing offers, or disable personalization by contacting support@Zweeler.com or sending an email to dataprotectionofficer@Zweeler.com

To contact and interact with you
• Contact you about our services, for example by phone, email or post or social media;
• Manage promotions and competitions you choose to enter;
• Respond to your queries and complaints.

To make your game safer and more enjoyable
• to deter, prevent or detect the use of third party software;
• to deter, prevent, or detect any activities conducted in breach of the Zweeler T&Cs.

C) Under the legal obligation – when it is necessary in order to comply with mandatory legal obligations to which we are subject under local law; including, but not limited to:

• to determine where you are accessing the services from to redirect you to the correct country site, in accordance with our license conditions;
• to make sure we offer our services to eligible persons;
• crime detection, prevention, and prosecution;
• to verify your identity and establish the source of funding in any transaction;
• to carry out appropriate anti-fraud checks (by conducting online searches using a third party identity provider). Please note that this will not affect your credit rating; and
• to assess and manage any potential risks and prevent problem gambling.

D) Special categories of data

We will only process such data if:
• you have given us your explicit consent;
• it is necessary for the purposes of carrying out the obligations and exercising specific rights of Zweeler or of the data subject in the field of employment and social security and social protection law;
• it relates to personal data which you have made public;
• it is necessary for the establishment, exercise or defense of legal claims;
• is necessary for reasons of substantial public interest, on the basis of local law, or licensing requirements.

5 Cookies and Similar Technologies

Zweeler’s Services use cookies for various purposes. We use cookies for the following purposes:
1. to identify the User’s preferred language, so it can be automatically selected when the User returns to the Services;
2. to ensure that the User receives any bonuses for which they are eligible;
3. for analysis of the Site traffic, so as to allow Zweeler to make suitable improvements;
4. Google analytics; and
5. Google Adsense.

For more information about cookies and how they work, please visit: www.aboutcookies.org.

Manage your cookies

We recommend you don't change your cookie settings as it may limit your user experience and the performance of the site.

If you do want to change the cookies setting, you can do this through your browser. Different web browsers may use different way of controlling cookies, so you'll need to use your browser's help section to find out how to do this.

6 When do we share your personal information?

We do not share your personal information to third parties outside Zweeler.com for marketing purposes. However, there are circumstances when we share your personal data with third parties that provide services to you on our behalf, and with other third parties in the course of complying with our legal obligations. Other examples of when we share your personal information include when we enter any kind of merger or business sale. Even when it is shared, we ensure that your personal information will only be used for the purposes outlined in this policy.

With third parties

We may share personal data with third parties in the following circumstances:

• providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
• when ordered to do so by any regulatory body and/or in compliance with applicable laws;
• we may instruct and authorize the Financial Institution with which a User’s account is held to disclose any information as may be requested by a regulator in respect of an User account;
• in order to establish, exercise or defend our legal rights;
• for fraud detection and control purposes, we may transfer your personal data to third parties, including but not limited to so-called address verification system service providers, age verification services, payment service providers and financial institutions. Furthermore, we reserve the right to disclose the User’s personal data to relevant parties where Zweeler has reasonable grounds to suspect irregularities involving a Zweeler account;
• with service providers to enable us to provide our services, such as companies that help us with technology services, storing and combining data, and processing payments or providing relevant online advertising for our products and services;
• with external auditors who may carry out independent checks as part of our licenses to offer online fantasy sports;
• to an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organization receiving your personal data can use your personal data in the same way as us; or
• to any other successors in title to our business.

7 Controlling Your Information (California Data Rights)

If you would like to prevent us from collecting your information completely, you should cease use of our Services as our platform does not operate without collecting information. You can also control certain data via these other methods.

Under the California Consumer Privacy Act residents of the state of California have additional data rights. We provide the same control and rights over your data no matter where you choose to live in the United States. As a user of Zweeler, you have the following control over your data:

• Opt-out of non-essential electronic communications: You may opt out of receiving promotional notices, newsletters, and other non-essential messages by using the ‘unsubscribe' function included in all such messages. However, you will continue to receive notices and essential transactional emails.
• Optional information: You can always choose not to fill in non-mandatory fields when you submit any form linked to our services.

Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.

Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Data Portability
You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

Exercise Your Data Rights
We also recognize that you have the right to prohibit sale of your data, but we do not sell data.

You can exercise the rights described above, by making adjustments in your user account. Only you, or an agent authorized to make a request on your behalf, may make a request related to your personal information.

We cannot respond to your request if, (i) we cannot verify your identity; or (ii) your request lacks sufficient details to help us handle the request. We will make our best efforts to respond to your request withing 45 days of its receipt. If we cannot respond in 45 days, we will inform you, in writing, the reason for the delay and will respond to your request within 90 days. Any information we provide will only cover the 12-month period preceding the request's receipt.

We do not charge a fee to process or respond to your 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. We are not obligated to provide responses to your data requests more than twice in a 12-month period.

8 How long will Zweeler keep my data?

We will only retain your information for as long as is reasonably necessary to carry out the purposes outlined above and to satisfy our legal obligations. While you are a customer, we will usually need to retain your information to meet our legal and contractual requirements. However, when you cease using Zweeler services, we will normally still retain your personal information for a period of time.

Typically, we will store your personal information for a period of ten years after you cease being a customer of Zweeler, beginning at the date your account is closed. There are several reasons which we retain your information, these include:

• To comply with legal obligations (for example, anti-money laundering regulations, or licensing regulations);
• To establish or defend legal claims (for example negligence claims) which could be made against us.

9 Security of Your Data

Zweeler is committed to protecting the personal information you entrust to us. We take all reasonable steps to ensure that all information collected through our Sites is treated securely and in line with this Policy and strict data protection standards. Accordingly, we have adopted robust procedures and technologies to protect your data from unauthorized access and improper use.

After logging in all information sent to and from the Zweeler site is encrypted using 128- bit Secure Socket Layer (SSL) technology. The SSL certificate used is issued and verified by Go Daddy Secure Certificate Authority.

Zweeler has systems in place to detect and prevent suspicious activity, to ensure that the Zweeler website remains a secure playing-field. Any account involved in suspicious activity will be suspended and investigated to the fullest extent. Should you as user have any doubts about the activity on your account, such as unrecognized transactions in the transaction history or surprising changes in the balance, please contact us immediately.

10 Zweeler Employees

All Zweeler employees are required to comply with the terms of this Privacy Policy. This Privacy Policy provides that employees are obliged to keep Player information strictly confidential. This obligation continues once an employee is no longer employed with Zweeler.

11 Do Not Track Settings

We do not track our users over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (“DNT”) signals.

12 Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by emailing to: dataprotectionofficer@Zweeler.com

13 Changes to Zweeler Privacy Notice

This Privacy Notice may be updated from time to time to reflect changes in the way we work or the way our work is regulated - so you may wish to check it each time you submit personal information to us. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal information to Zweeler or use Zweeler services in any way. Otherwise, by continuing to do this, you will be deemed to have accepted the changes to the Privacy Notice. You can also delete your Zweeler account at any time. If significant changes are made to the Privacy Notice, for instance affecting how we would like to use your personal information, we will provide a more prominent notice (including, for certain services, notification of Privacy Notice changes by email).