Privacy Policy

GURU FANTASY REPORTS, INC. PRIVACY POLICY

Last updated: 10/07/22

Guru Fantasy Reports, Inc. and any of its subsidiaries or affiliates (collectively, “Guru Fantasy Reports,” “we,” “us,” or “our”) owns and operates its fantasy sports websites located at FantasyGuru.com, EliteFantasy.com, and EliteSportsBetting.com and related applications, content, products, tools, features, subscriptions, and services (collectively, the “Services”).  

This Privacy Policy (the “Policy”) describes the types of information we collect, use, process, and share about you when you visit or make a purchase from one of our websites, or when you otherwise contact or interact with us. When we use the terms “you” or “your” in this Policy, we are referring to individuals who access or use our Services in any way. If you are using the Services on behalf of a business, association, or other entity, “you” or “your” will also refer to such business, association, or other entity, unless the context clearly dictates otherwise.

PLEASE READ OUR TERMS OF SERVICE FOR DETAILED INFORMATION ABOUT OUR SERVICES AND YOUR LEGAL OBLIGATIONS. By using/continuing to use the Services, you acknowledge you have read and understand and agree to the collection, storage, use, and disclosure of your personal information as described in this Policy, and you agree to the Terms of Service which are incorporated by reference. If you choose to visit the Services, your visit and any dispute over privacy is subject to this Policy and our Terms of Service, including, but not limited to, limitations on damages and resolution of disputes. If you do not agree, please do not access or use the Services.

Eligibility to Use the Services

Our Services are available only to residents of the United States and Canada who are eighteen (18) years of age or older.  If you are located outside the United States or Canada, you are prohibited from registering for an account or accessing the Services in any way. You represent and warrant that you are, at least the age of eighteen (18) and a resident of the United States or Canada.

1. PERSONAL INFORMATION WE COLLECT

Generally, we collect four (4) types of information about you: (1) information and content you provide to us directly; (2) information we obtain automatically when you use our Services; (3) demographic information; and (4) information we get about you from other sources. When we talk about “Personal Information” in this Policy, we are talking about any information collected in accordance with this section. Please see below for more information on each category.  

1. Information and Content You Provide to Us Directly
   1. Personal Information. Personal information such as your e-mail address, name, phone number, address, username, password, and any other information you directly provide us on or through the Services. This includes information you provide when you register or create an account or submit a request for customer service.
   1. Email Correspondences. Records and copies of your email messages together with your email address and our responses, if you choose to correspond with us through email.
   1. Transaction Information. We or service providers working on our behalf may collect information and details about any purchase or transactions made on the Services. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping, and contact details. We do not collect or store payment card information ourselves; rather we rely on our payment processors to store this information as part of the Services. Please see our payment processor’s privacy policy regarding the use, storage, and protection of your credit card information before submitting any credit card information.

We make chat rooms, articles, and similar content areas available for public comments and discussions with other users. Your username and profile picture will be visible to other users and potentially the public when you use our chat rooms and content areas.  We cannot control the information that is shared by other users. Please remember that any information you voluntarily post in our chat rooms, content areas, comments, or any public area of the internet may be viewable by other members or the public at large. Please exercise caution when deciding to post your views and Personal Information via our Services. You will not be able to remove your content after you have posted it. 

• Information We Obtain Automatically When You Use Our Services
• Activity Information. Details of your visits to our Services, including the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; the time, frequency, and duration of your activities; and other information about your use of and actions on the Services.
• Equipment Information. Information such as your device’s IP address, browser type, browser version, unique device identifiers and other diagnostic data. When you access the Service by or through a mobile device, we may collect the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
• Location Information. Information about the location of your device, including GPS location, for purposes of enhancing or facilitating the Services. We may also use information about the location of the device you are using to help us understand how the Services and functionality are being used and to deliver more relevant advertising. If you do not want to share your location, you can disable location sharing in the settings on your device.
• Cookies, Pixel Tags/Web Beacons, and Other Technologies. Cookies, pixel tags, web beacons, clear GIFs or other similar technologies may be used by us, as well as third parties that provide the content, advertising, or other functionality on the Services to automatically collect information through your use of the Services. Please see Section E for more information on the technologies we may use for this automatic data collection.
• Demographic Information

We may collect demographic, statistical, or other aggregate information that is about you, but individually does not identify you. Some of this information may be derived from Personal Information, but it is not Personal Information and cannot be tied back to you. Examples of such aggregate information include gender, age, race, household income, and political affiliation.

• Information We Get About You from Other Sources

We may receive information about you from other sources and add it to our information, including from third-party services and organizations who have the right to provide us with such information. We protect this information according to the practices described in this Policy, plus any additional restrictions imposed by the source of the data. These sources may include: online and offline data providers, from which we obtain demographic, interest-based, and online advertising related data; publicly-available sources such as open government databases or social networks; and service providers who provide us with information, and updates to that information, based on their relationship with you. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product or service recommendations and special offers that are more likely to interest you.

• How We Use Your Personal Information
• We Use Your Personal Information to Provide Our Services

We may use your Personal Information to:

• Provide the Services and related content to you.
  • respond to comments, questions, and provide customer service.
  • communicate with you about an order, purchase, or account.
  • inform you about important changes to, or other news about, the Services or any related features or content.
  • fulfill any other purpose for which you provide Personal Information.
• We Use Your information for Administrative Purposes

We may use your Personal Information to:

(i)        operate, maintain, improve, personalize, and analyze the Services.

(ii)       monitor and analyze trends, usage, and activities for marketing or advertising purposes.

(iii)      detect, prevent, or investigate security breaches, fraud, and other unauthorized or illegal activity.

(iv)      carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

(v)       maintain appropriate records for internal administrative purposes.

(vi)      allow you to participate in interactive features on the Services.

• We Use Your Information to Market and Advertise Our Services and Products

We may use your Personal Information to:

(i)        send promotional communications, such as information about features, newsletters, offers, promotions, contests, and events.

(ii)       share information across Services and devices to provide a more tailored and consistent experience on all Guru Fantasy Reports products you use.

(iii)      develop, test, and improve new products or services, including by conducting surveys and research and testing and troubleshooting new products and features.

• HOW WE MAY SHARE OR DISCLOSE YOUR PERSONAL INFORMATION

We may share or disclose aggregated or anonymized information about our users to third parties for a variety of business purposes without any restrictions, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in additional detail the ways we may share or disclose your Personal Information that we collect or you provide under this Policy:

1. We Disclose Your Personal Information to Provide Our Services

(i)        Subsidiaries and Affiliates. We may share your Personal Information with our parent companies, subsidiaries, joint ventures, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes, consistent with this Policy.

(ii)       Service Providers. We may share your Personal Information with our third-party service providers, contractors, and any other similar third parties that help us provide our Services. This may include service providers that help us with reservations, analytics services, or support services, such as credit card processing, website hosting, email and postal delivery, location mapping, product, and service delivery. Some of our web pages utilize framing techniques to serve content to you from our third-party providers, while preserving the look and feel of the Services. In such cases, please note that the information you provide is being provided to the third party. Service providers are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

(iii)      Advertising/Marketing Service Providers. We may share your Personal Information with marketing service providers to assess, develop, and provide you with promotions and special offers that may interest you, administer contests, sweepstakes, events, or for other promotional purposes.

(iv)      Consent or to Fulfill the Purpose that Information was Provided. We may share your Personal Information to fulfill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information.

• We Disclose Your Personal Information to Protect Us or Others
• When Required by Law. We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
• To Enforce Our Rights. We may disclose your information when we believe it appropriate in order to investigate, prevent, or take action regarding possible illegal activities, or to enforce or apply this Policy, the Terms of Service and other agreements.
• To Protect Lawful Interests. We may share your Personal Information if we believe disclosure will help us protect the safety or rights of any person or legal entity. This may include exchanging information with other companies and organizations for fraud protection, and spam and malware prevention.         
• We May Disclose Your Personal Information in the Event of a Merger, Sale or Other Asset Transfer

As we continue to develop our business, we may sell, buy, or partner with other companies or businesses. In such event, we may transfer or assign the information we have collected as part of such financing due diligence, merger, acquisition, sale, or other change of control. In such transactions, your Personal Information may be among the transferred assets.

Also, in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used and your Personal Information may be included in the transferred assets.

• Your Privacy Choices and Rights

Participation in the Services is always completely voluntary. You have certain choices and rights with respect to your privacy. For example, you may be able to opt out of receiving marketing messages from us, make choices regarding cookies, and exercise other privacy rights under applicable law.

1. Privacy Rights Regarding Your Personal Information

In accordance with applicable law, you may have the right to:

• Access Personal Information. You may access personal information about you, including: (a) confirming whether we are processing your personal information; (b) obtaining access to or a copy of your personal information; and (c) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”).
• Request Correction of Personal Information. You may request correction of your personal information where it is inaccurate, incomplete or improperly possessed.
• Request Deletion of Personal Information. You may request deletion of your personal information collected from or concerning you, which is held by us. Please note: we cannot delete your personal information except by also deleting your account.
• Opt-out. You may request to opt-out of the processing of your personal information for the purpose(s) of: (a) targeted advertising; (b) sale of personal information; or (c) profiling to make decisions that have legal or other significant effects on you.

If you would like to exercise any of these rights, you may “contact us” (please see the “Contact Us” section below) to request the exercise of such rights. We will process such requests in accordance with applicable law.

The following are additional Consumer Privacy Rights:

• Non-Discrimination.  Residents have the right not to receive discriminatory treatment by covered businesses for the exercise of their rights conferred by the applicable privacy law.
• Authorized Agent.  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
• Verification.  To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
• Your Right to Appeal

If you are dissatisfied with the refusal of Guru Fantasy Reports to take action in accordance with the exercise of your rights in the “Privacy Rights Regarding Your Personal Information” section above, you may request reconsideration by Guru Fantasy Reports, by sending a written request for reconsideration to the mailing address found in the “Contact Us” section below. Within sixty (60) days of Guru Fantasy Reports’ receipt of such written request for reconsideration, Guru Fantasy Reports shall inform you in writing (at the address indicated in your initial written request) of any action taken or not taken in response to your request for reconsideration, including a written explanation of the reasons for the decision. In addition, if your request for reconsideration is denied, you have the right to appeal to the Attorney General in your state of residence.

• Mechanisms to Control Your Personal Information
• Communications. If you do not wish to have your contact information used by us to promote our own or third-party products or services, you can opt-out by: (a) informing us of your preference at the time you sign up for our newsletter, or complete any other form on or through the Services which we collect your data; (b) modifying your user preferences in your account profile by checking or unchecking the relevant boxes; (c) following the opt-out instructions at the bottom of the promotional emails we send you; or (d) sending us an email stating your request. Please note that we may also send you non-promotional communications, however you will not be able to opt-out of these communications (e.g., transactional communications, including emails about your account or purchases; communications regarding our Services; and communications about updates to this Policy and the Terms of Service).
• “Do Not Track”. “Do Not Track” (“DNT”) is a privacy preference you can set in certain web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Online Advertising Industry. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
• Additional State Privacy Rights
• California Privacy Rights. The California Consumer Privacy Act, as revised by the California Privacy Rights Act (collectively, “CCPA”) requires us to provide California consumers with the following information about how their ”personal information” (as defined in the CCPA) is processed and the rights available to them with respect to their personal information.
  • Categories of Personal Information that is Collected, Disclosed, and Shared. The CCPA provides California residents with the right to know what categories of personal information covered businesses have collected about them and whether such covered businesses have disclosed that personal information in the preceding 12 months for a business purpose. California residents can find this information below:

Category of Personal Information Collected	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers. A real name, postal address, Internet Protocol address, email address, or other similar identifiers.	Advertising partners Service providers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	Service providers
Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners Service providers
Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.	Advertising partners Service providers
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners Service providers
Professional or employment-related information Collect the employment information of Customers, to provide the appropriate level of service	Advertising partners Service providers
Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address.	Advertising partners Service providers

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the personal information was collected. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “What Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

We may share any of the information listed above with Service providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement.

• “Sales” of Personal Information under the CCPA. California residents have the right to opt out of the “sale or sharing” of their personal information. Under the CCPA, (a) “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money), and (b) “sharing” is defined as communicating personal information by a business to a third party for cross-context behavior advertising.

We may “sell” personal information. The categories of personal information we have “sold” and the categories of third parties we have “sold” personal information to in the preceding twelve months are listed below.

Category of Personal Information Sold by Guru Fantasy Reports	Category of Third Parties Personal Information is Sold to
Identifiers. A real name, postal address, telephone number, unique personal identifier, online identifier, email address, or other similar identifiers.	Advertising Partner
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number.	Advertising Partner

Our business and commercial purposes for “selling” personal information can be found in “How We Use Your Information” above. Guru Fantasy Reports does not have actual knowledge of any “sale” of personal information of minors under 16 years of age.

• Additional California Consumer Privacy Rights.
  • Opt-out of “Sales or Sharing”.  California residents may opt-out of the “sale or sharing” of their personal information by contacting us as set forth in “Contact Us” below.
  • California Shine the Light.  The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by clicking on this form.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” above. We will process such requests in accordance with applicable laws.

• Nevada Privacy Rights. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to sell or license that Personal Information, even if your Personal Information is not currently being sold. If you would like to exercise this right, please contact us via the information found in the “Contact Us” section above.
• E.    COOKIES AND OTHER TRACKING TECHNOLOGIES
• Description of the Technologies

We as well as third parties that provide the content, advertising, or other functionality on the Services may use cookies, web beacons, javascript, entity tags, HTML5 local storage, resettable device identifiers, and other technologies (collectively, the “Technologies”) to automatically collect information through your use of the Services. The following describes some of these Technologies we may use for this automatic data collection:

• Cookies. A cookie is a small data file stored on the hard drive of your computer either for (a) the duration of your visit on a website (“session cookies”) or (b) for a fixed period (“persistent cookies”). Cookies contain information that can later be read by a web server. We may use cookies to provide you with a more personal and interactive experience on the Services.
• Web Beacons. Web beacons are small files that are embedded in webpages, applications, and emails (also known as “clear gifs”, “pixel tags”, “web bugs”, and “single-pixel gifs”) that collect information about engagement on our Services. For example, web beacons allow us to track who has visited those webpages or opened an email, to test the effectiveness of our marketing, and for other related website statistics.
• JavaScripts. JavaScripts are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.
• Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed.
• HTML5 Local Storage. HTML5 local storage allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
• Resettable Device Identifiers. Resettable device identifiers (also known as “advertising identifiers”) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” or “IDFA” on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.
• Our Uses of the Technologies

We may also use these technologies for security purposes, to facilitate navigation, to display information more effectively, and to better serve you with more tailored information, as well as for site administration purposes, e.g., to gather statistical information about the usage of our websites in order to continually improve the design and functionality, to understand how users use our websites, and to assist us with resolving questions regarding use of the websites.

• Mechanisms to Control Cookies and Other Technologies

You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. Please note that you cannot remove Flash cookies simply by changing your browser settings. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or may not function properly.

• Third Party Technologies

This Notice covers the use of cookies by Guru Fantasy Reports and does not cover the use of tracking technologies by any third parties. The Services may contain links, content, advertising, or references to other websites or applications run by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Services, such as member recruitment vendors to using Web beacons and cookies on our registration pages for payment verification. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that we do not control these third parties’ tracking technologies or when and how they may be used. Therefore, Guru Fantasy Reports does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. We do not endorse, screen, or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly.

• HOW WE PROTECT YOUR DATA

We have implemented commercially reasonable technical, physical and administrative security measures and safeguards designed to reduce the risk of loss, misuse, unauthorized access, erroneous disclosure, and modification of your information.

The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

While we have employed security technologies and procedures to assist safeguarding your Personal Information, no website or internet transmission is completely secure and we cannot ensure or guarantee the security of any information you provide us. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. In the event that your Personal Information under our control is compromised as a result of a breach of security, we will notify those individuals whose information may have been compromised in accordance with any applicable laws and regulations.

• INTERNATIONAL TRANSFERS

We currently do not intentionally accept users from outside the United States or Canada, and we will take reasonable steps to delete any data we receive from outside those countries. If you provide Personal Information through the Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Guru Fantasy Reports and the other third parties referenced in this Policy located in the United States or other jurisdictions, which may have data protection laws that are different from the laws where you live. We use commercially reasonable efforts to safeguard your information consistent with the requirements of applicable laws.

• Personal Information Retention Period

We keep your information for the length of time needed to carry out the purpose outlined in this Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, strengthen the security of the Services, improve the functionality of the Services, and to comply with our legal obligations.

1. THIRD PARTY LINKS

Our Services may contain links to other websites, which may have privacy policies that differ from our own. We are also not responsible for any information or content contained on such sites. Your browsing, use, and interaction on any other websites, including websites which have a link to our Services, are subject to that third-party website’s own rules and policies. Please review the privacy policy posted on any website that you may access through, or which links to, our Services.

• CHILDREN

We are committed to protecting the privacy of children who visit our use our Services. Our Services are directed for a general audience and not intended for children under eighteen (18) years of age.  If you are a child under the age of eighteen (18), do not sign up with our Services or send us any information.  If we learn that we have inadvertently collected or received Personal Information from an individual under the age of thirteen (13) in violation of applicable law, we will use reasonable efforts to immediately remove such information, unless we have a legal obligation to keep it. If you are a parent or legal guardian and believe we have collected any information from your child under the age of thirteen (13) without your consent, please notify us immediately at [email protected].

• Changes to Our Privacy Policy

We reserve the right to update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. When we do update this Policy, we will post the updates and changes on our website(s). We may elect to notify you of material changes by mail, email, posting of modified Policy, or some other similar manner. However, it is your responsibility to check our website regularly for changes to this Policy. Your continued use of or access to the Services following the posting of any changes to this Policy constitutes acceptance of those changes.

• CONTACT US

If you have any questions regarding this information or our privacy practices, or if you wish to make a complaint, email us at [email protected]om

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