Privacy Policy
This policy describes how WSC Sports Technologies (together with its affiliated companies – “WSC”, “we”, “our” or “us”) collects, stores, uses and discloses personal data about the following categories of individuals:
(i) Customer Data: personal data submitted by, or made available to us by our business customers (“Customers”) through the use of:
a. Our cloud-based platform and application, including via video content and related metadata (“Platform” and “Video Content”, respectively)
b. any related products, integrations, add-ons and extensions services managed and operated by WSC including any cookie, tag, pixel, SDK (together with the Platform, the “Products”).
We process Customer Data on behalf of and under the instruction of the Customer, in accordance with our Data Processing Agreement with them. Accordingly, this policy – which describes WSC’s independent privacy and data processing practices as a “data controller” – does not apply to the processing of Customer Data (For more information, please refer to Section 10 below). If you have any questions or requests regarding Customer Data, please contact the relevant Customer or the applicable individual within Customer’s organization that is acting as an administrator of the Platform and Services (“Administrator”) directly.
(ii) User Data: personal data concerning individuals acting on behalf of our Customers in respect of their engagement with WSC, and users of the Platform and our mobile application on behalf of such Customers, e.g., the account administrator and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”); as well as the Customer’s business needs and preferences, as identified to us through our engagement with them.
(iii) Prospect Data: data relating to visitors of our website at www.wsc-sports.com, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, digital ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Products – the “Services”).
Specifically, this policy describes our practices regarding –
● Data Collection & Processing
● Cookies and Tracking Technologies
● Requirements under US State Privacy Laws
If you are a Customer, User, or Prospect, please read this policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers, please simply do not visit or interact with our Sites, nor use our Services.
You may also choose not to provide us with “optional” personal data (fields typically marked as “not required” on forms), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services.
Any capitalized but undefined term in this policy shall have the meaning given to it in our Website Terms of Use (“Terms”).
1. Data Collection & Processing
When we use the terms “personal data” or “personal information” in this policy, we mean information that may identify, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. We collect or generate the following types of personal data in relation to the Services:
● Usage, login credentials, and device information concerning Users and Prospects (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (e.g., type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Platform, the cookies and pixels installed or utilized on Users’ and Prospects’ devices, and inferred or presumed data generated from their use of the Services) (collectively, “Usage Data”);
● Information concerning our Customers, Users and Prospects, such as contact details (name, email, phone number, position, workplace and related business insights), our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedbacks received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement, to the extent they constitute personal data.
● Personal data contained in Customer Data which is provided by our Customers or processed on their behalf and under their instruction. This may include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Customer Data), in accordance with the Data Processing Addendum we and our Customers have in place.
2. Data Uses & Lawful Bases
We use personal data as necessary of the performance of and to provide our Products to our Customers (“Performance of Contract”); to comply with applicable legal obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Products; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).
Specifically, we use personal data for the following purposes and in reliance on the lawful bases for processing noted next to them, as appropriate:
Customer and User personal data
● To facilitate, operate, enhance, and provide our Products (Performance of Contract; Legitimate Interests).
● To provide assistance and support, to test and monitor the Products, or diagnose or fix bugs or other technical issues, and to train our Customers and Customer-facing staff (Performance of Contract; Legitimate Interests).
● To personalize the Products, including by recognizing an individual and remembering their information when they return to it, and to provide further localization and personalization capabilities to make our Products easier to use (Performance of Contract; Legitimate Interests).
● To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests).
Customer, User and Prospect personal data
● To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services.
● To provide certain features of the Services related to the Video content, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities (Performance of Contract; Legitimate Interests).
● To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent).
● To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation).
● To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests).
● To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners (Legitimate Interests; Consent).
● To enforce our Terms or the agreement between us and our Customers, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);
● To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
● For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing personal data as described in this policy (either in general, based on the types of personal data you expect or elect to process or have processed by us or via the Services, or due to the nature of such processing) (“Consent”), your acceptance of our Terms and of this policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [email protected].
3. Data Location
We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Europe, Israel and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by applicable law.
WSC Is headquartered in Israel, a jurisdiction which is considered by the European Commission, the United Kingdom Secretary of State, and the Swiss Federal Data Protection and Information Commissioner (FDPIC), to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the European Economic Area, the UK and Switzerland to Israel on this basis.
While privacy laws vary between jurisdictions, WSC, its affiliates and Service Providers are each committed to protect personal data in accordance with this policy, customary and reasonable industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. For data transfers from the EEA, the UK and Switzerland to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers enter into Standard Contractual Clauses as approved by the European Commission, UK Information Commissioner’s Office, and the FDPIC (as appropriate).
Notwithstanding the foregoing, where WSC processes personal data on behalf of a Customer, such personal data (which is included in their Customer Data) may only be processed in the locations as permitted in the Data Processing Agreement and other commercial agreements with such Customer (as further described in Section 10 below).
4. Data Retention
We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, please contact us by email at [email protected]
5. Data Disclosure
We may disclose personal data in the following instances:
Service Providers: We engage selected third-party companies and individuals as “Service Providers”, to perform services on our behalf or complementary to our own. These include providers of third party services, such as: hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, email and communication distribution and monitoring services, session or activity recording services, call recording, analytics and transcription services, event production and hosting services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, voicemails, video conferencing solutions, support and customer relation management systems, third-party customer support providers, and our legal, compliance and financial advisors and auditors.
Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services or other activities, and may only use the data as determined in our agreements with them.
Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our prospective and existing Customers and Users. In such instances, we may share relevant contact, business and usage details with the respective partner, to allow them to engage with those Customers and Users for such purposes. If you directly engage with any of our Partners, please note that any aspect of that engagement which is not directly related to the Services and directed by WSC is beyond the scope of WSC’s Terms and Privacy Policy and may therefore be governed by the partner’s terms and privacy policy.
Event Sponsors: If you register to any event that we host, organize or sponsor, then with your permission we may share your registration details with others, including the hosts, organizers, speakers, service providers and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfill any promotions related to the event.
Customers and other Users: Your personal data may be shared with the Customer owning the subscription pursuant to which you are acting as a User of our Services (including data and communications concerning your User profile), as well as other Users of that account. Your personal data and activity within the Services may also be monitored, processed and analyzed by your Administrator.
If you register or access the Services using an email address at a domain that is owned by your employer or organization (our Customer), and another team within such Customer’s organization wishes to establish an account on the Services, certain information about you including your name, contact info and your general use of the Platform will become accessible to the Administrator.
Services integrations: You or your Administrator may choose to integrate your use of the Services with third-party services (provided that such integration is supported by our Services). The provider of this integrated third-party service may receive certain relevant data about you from the Services or share certain relevant data from your account on the third-party services with our Services, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them). If you do not wish your data to be shared with such third-party service(s), please contact your Administrator.
Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Website and Services. If you wish to remove your public review, please contact us at [email protected].
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.
Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or safety of WSC, any of our Users or Customers, or any members of the general public.
WSC Affiliated Companies: We share personal data internally within our group of companies, for the purposes described in this policy. In addition, should WSC or any of its subsidiaries undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such a change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via email or prominent notice on our Services.
For the avoidance of doubt, WSC may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
6. Cookies and Tracking Technologies
Our Sites and Services (including some of our Service Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide and monitor the use of our Services and Sites, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, as indicated by a Prospect or User. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy. You may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable. If you choose to opt-out of certain cookies, this will typically generate a new cookie which will preserve your choice and indicate it to our Services in your next visits so that the cookies you opted-out of will not be utilized. You can also manage your cookies preferences, and accept, remove or entirely block cookies, through your browser settings.
Certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates. However, due to differences in how web browsers interpret this feature and send those signals, and lack of standardization, we do not change our practices in response to such “Do Not Track” signals. However, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
When you visit our website, other parties, such as Google, may collect personal data about your online activities over time and across different websites. Please be advised that we are not responsible for any personal data collected and processed by Google, or any other third party, and it is recommended that you review such third parties’ privacy practices. To review the Google Privacy Policy you may click the link or go to: https://policies.google.com/privacy .
Please note that our customers may connect their YouTube accounts to our Platform in order to publish their Video Content. We will use the YouTube API Services to provide such functionality, in case you choose to do so. By enabling such connection, you agree to comply with and be bound by YouTube’s Terms of Service and Google’s Privacy Policy .
Our customers can revoke our Platform’s access to their data by visiting the Google security settings page. Customers can request the deletion of stored data associated with the Platform in accordance with the terms of the applicable agreement between the parties, by contacting [email protected] or follow the data deletion process outlined in their account settings.
7. Communications
We engage in Services and promotional communications, through email, phone, SMS and notifications.
Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Our Customers, and other Users of the account of a Customer, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify WSC at any time by sending an email to [email protected] or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.
8. Data Security
In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 5 above.
9. Data Subject Rights
If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR, the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), or the Colorado Privacy Act (CPA)). Such rights may include – to the extent applicable to you – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with WSC, or to restrict or object to such personal data’s processing (including the right to direct us not to “sell” or “share” your personal data to third parties now or in the future), or to obtain a copy or port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) – please contact us by email at [email protected]. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may instruct you on how to fulfill your request independently through a dedicated form; refer you to your Administrator; or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). If your request relates to personal data that may be processed on our Customer’s behalf, as their “data processor” or “service provider” (as further explained in Section 10 below), note that such Customer exclusively determines how such data is processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, and that such data is processed on behalf of any of our Customers, so that we may forward it to such Customer for their further handling. Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with Section 4 above.
We may redact from the data which we make available to you any personal or confidential data related to others.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the EU and UK GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
WSC is the “data controller” of User Data and Prospect Data. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this policy.
WSC is the “data processor” of Customer Data. We process such data on behalf of the Customer (who is the “data controller”); and our Service Providers who process such Customer Data on our behalf, are the “sub-processors” of such data.
Accordingly, WSC processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
If you would like to make any requests or queries regarding personal data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact your Administrator directly.
11. Requirements under US State Privacy Laws
This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 3) and deletion (Section 9) practices. We also included information about how we may process your information (in Sections 1 through 8), which includes “business purposes” under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and similar state laws, as applicable. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 5, if those third parties are our Customers (in respect of Customer Data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate our Services with third parties’ services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. We will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law.
If you have any questions or would like to exercise your rights under any applicable US State privacy laws, you can contact [email protected].
12. Additional Notices
Updates and Amendments: We may update and amend this policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. When we make material changes to this policy, wewill give notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Services or by sending an email. Your continued use of the Services after the changes have been implemented will constitute your acceptance of the changes.
Third Party Websites and Services: Our Services includes links to third party websites and services, and integrations with third party services. Such websites, services and third-party services, and any information you process, submit, transmit or otherwise use with or to such websites, services and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this policy. We encourage you to carefully read the terms and privacy policies of such websites, services and third-party services.
Our Services are not directed to children under the age of 13: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by email at [email protected].
EU Representative: WSC Sports Technologies Limited at 37 Broadhurst Gardens, London, England, NW6 3QT.
UK Representative: WSC Sports Technologies Limited at 37 Broadhurst Gardens, London, England, NW6 3QT.
Questions, concerns or complaints: If you have any comments or questions regarding our privacy policy or practices, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by WSC, please contact us be email at [email protected].
Last updated: April 1, 2024.