Robn Privacy Policy

Green Onions LLC operates Robnsports.com, including all of its written and videographic media, podcast media and social media pages (“Robn”).

Robn is the sponsoring brand (the “Brand”) for all of Robn Sports Prediction Tournaments (“Tournament” or "Tournaments"). 

Actiplay LLC (hereafter “we,” “our” or “us”) operates our own technology as well as external technologies (“Technology Providers”) that comprise the Tournament platform (collectively, the “Platform”) and conduct and manage interactions with Tournament entrants (hereafter “Contestants,” “they,” “their” or “them”).

This Privacy Policy (“Policy”) is effective as of August 1, 2024, and explains the types of data and information (the “Information”) we collect, how that Information is used, how the Information may be shared with other parties, and what controls Contestants have regarding their Information.

For purposes of this Policy, neither us, the Platform or the Brand shall be considered third-party businesses (“Third Parties”). Any updates or modifications to this Policy will be posted on the Platform.

By participating in a Tournament, Contestants signify that they have read, understand and agree to be bound by this Policy.

INFORMATION WE COLLECT AND HOW WE USE IT

We may collect the following types of Information through our Platform:

1. “Personal Data” such as Contestants’ name, e-mail address, physical address, phone number, birthdate, geolocation data and other information that can be used to directly identify them;
2. “Device Information” such as Contestants’ device’s IP address, the type of browser and operating system they are using, the identity of their internet service provider, and their device and browser settings;
3. “Usage Data” such as the pages Contestants visit on the Platform, their actions within the Platform, the type of content they have accessed, seen, forwarded and/or clicked on, WiFi connections, general geolocation information, and the date and time stamps of prediction submissions.
4. “VMOE Data” such as the time, cost and physical or online location of purchase, action, free alternative method of entry, or other behavior the Contestant has engaged in order to constitute a valid method of entry (“VMOE”) into a Tournament

We collect Personal Data and only when Contestants provide it to us but may collect other types of Information whenever Contestants use the Platform through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).

PERSONAL DATA

In order to participate in Tournaments on our Platform, Contestants are required to register an account. This process requires Contestants to give us personal data (the “Personal Data”).

We use Personal Data to comply with laws and regulations, including verifying that Contestants are at least 18 years of age and guarding against potential fraud. We also use Personal Data to furnish services or features for Contestants associated with their Tournament submissions, and to communicate with them regarding the Platform and its functionality.

When Contestants submit Personal Data, whether by directly providing it to us upon request or voluntarily disclosing it, they are giving their consent to the collection, use and disclosure of their Personal Data as set forth in this Privacy Policy.‍

DEVICE INFORMATION & USAGE DATA

Any time Contestants visit the Platform, either we and/or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and also in aggregate form for internal business purposes, such as research, security, Platform optimization, statistical generation and developing marketing plans.

INFORMATION TO AND FROM TECHNOLOGY PROVIDERS

Contestants participating in a Tournament will utilize the Platform, which is in part powered by our technology and in part powered by Technology Providers, including but not limited to Google, Typeform SL and Stripe Inc. While we will never voluntarily disclose, rent, sell or share any Information with Technology Providers, we cannot guarantee that such use will not allow for the viewing, sharing or collection of Information by the Technology Providers. As such, Contestants are encouraged to check the privacy policy of each Technology Provider before entering a Tournament.

INFORMATION TO AND FROM SOCIAL NETWORKS

If Contestants choose to connect to our Platform through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”) or others, we may collect Personal Data from Contestants’ profile on such Social Network, such as their name, username, and e-mail address or other data, and we will use that Personal Data for the purposes set forth herein. In addition, our Platform may offer social sharing features which will allow them to “Share” or “Like” on a Social Network. If they decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network, so Contestants should check the privacy policy of each Social Network before using such features.

VMOE DATA

Contestants shall not gain entry to a Tournament prior to completing a VMOE.

A VMOE could include but is not limited to such actions as: making a qualifying purchase of the Brand’s good or service, posting certain content to social media in a way prescribed by the Brand, redeeming a specified Brand coupon (collectively, the “Brand Actions”). Contestants that gain entry to a Tournament by committing any “Brand Action” shall be considered Shared Contestants between us and the Brand, and we reserve the exclusive right to disclose, rent, sell or share VMOE Data to the Brand.

Contestats whose VMOE is an Alternative Free Method of Entry (“AMOE”) shall solely be considered Our Contestants. We will never voluntarily disclose, rent, sell or share Our Contestants VMOE Data to the Brand, a Technology Provider, or any Third Party.

SHARING OF INFORMATION

In no event will we voluntarily disclose, rent, sell or share any Personal Data to Third Parties for any purpose.

We or the Brand may publicly disclose a Contestant’s First and Last Name only, solely for purposes of:

1.    Displaying that Contestant’s ranking on a Tournament leaderboard

2.    Allowing Contestants to search on the Platform for their friends

3.    Creating and Publishing Organic Content

We may share other types of Information in the following instances:

• 1. In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; 
• 2. When performing legally required Know-Your-Customer verification to determine that a Contestant is 18 years of age or older and a legal U.S. resident (“KYC”);
• 3. When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements; or
• 4. In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or‍

AUTOMATED DATA COLLECTION / COOKIES

We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing Personal Data, collecting Device Information, Usage Data and VMOE Data, understanding Contestants’ use of the Platform, customizing the content offered to them on the Platform and delivering relevant advertising to them. Such technologies include:

1. Cookies. Cookies are text files placed in a computer’s browser to store a user’s preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the Platform and the content, offerings, or advertisements Contestants’ see on the Platform. For example, we may use cookies to personalize a Tournament experience on the Platform (e.g., to recognize once the Contestant has returned to the Platform that they have committed a VMOE), save their password in password-protected areas, and facilitate subscriptions or orders on the Platform. Most web browsers automatically accept cookies, but Contestants can usually configure their browser to prevent cookie acceptance. Not accepting cookies may make certain features of the Platform unavailable to Contestants.
2. Web Beacons. We may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor behavior of, and collect data about, the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
3. Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits (“SDKs”) that are incorporated into the Platform to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about a Contestant’s device or use of the Platform. A mobile SDK may act as the mobile version of a web beacon (see “Web Beacons” above) and we may use this technology to deliver or help the Brand deliver certain advertising through the Platform.

By visiting the Platform, Contestants acknowledge and agree that they are giving us their consent to track their activities and their use of the Platform through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to them.

ORGANIC CONTENT PRIVACY POLICY

From time to time, we or the Brand will communicate directly with Contestants in order to interview them about their Tournament participation. These interviews could result in the generation of content by us, the Brand, or the Contestant about the Contestant’s experience in a Tournament, their fellow Contestants, their VMOE, Prizes, etc. (collectively, "Organic Content")

Any Organic Content shall be wholly owned by the Contestant or Contestants to whom it pertains. However, the Contestant or Contestants to whom Organic Content pertains grant us and the Brand a worldwide, non-exclusive, royalty-free, sub-licensable, and transferable license to host, store, use, display, reproduce, modify, adapt, edit, publish and distribute the Organic Content solely for the purposes of promoting the Brand or the Platform.

For the sake of clarity, Organic Content shall not be generated based on any interactions with the Brand or the Platform regarding customer support, technical support, the communication of Personal Data to or from the Platform, or questions or concerns about this Policy, the Rules or the Terms of Service. Organic Content shall not include the disclosure of Personal Information other than a Contestant’s First and Last Name, unless the Contestant explicitly authorizes the creator of the Organic Content to disclose such other Personal Information.

PERSONAL DATA RETENTION

We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Platform or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

PRIVACY AND SECURITY

We take reasonable precautions to protect all Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, we cannot ensure or warrant the security of any Information that Contestants, the Brand or Technology Providers may purposefully or incidentally transmit to us or receive from us over the Internet, and Contestants therefore submit all Information to us at their own risk. Contestants hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and they hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner. If a Contestant believes their Information is being improperly used by us or any Third Party, they are encouraged to notify us immediately at support@playrobn.com.

MINORS UNDER 18

Each Tournament and the Platform are intended for and targeted to adults. We do not permit any Minors under the age of 18 (“Minors”) to participate in any Tournament or otherwise utilize the Platform, nor do we knowingly collect or solicit Personal Data directly from a Minor. We request that anyone under 18 years of age do not send their Personal Data to us, including their name, address, telephone number, or email address.

In the event that we learn that we have collected Personal Data from a Minor, we will delete that information as quickly as possible. If a parent or guardian of a Minor believes said Minor has provided us with Personal Data, that parent or guardian is encouraged to notify us immediately at support@playrobn.com.

OPTING OUT OF COMMUNICATIONS

Either we or the Brand may use the Personal Data to send Contestants newsletters, notifications, or general and promotional communications. If Contestants do not want to receive such communications, they can opt out (as applicable) by using the unsubscribe link at the bottom of such communications, unchecking the applicable box to opt out when prompted, or by simply not opting in when prompted.

Please note that even if Contestants unsubscribe from our communications, we or the Brand may still need to contact them with important information related to their account or their purchases.

DISALLOWING COOKIES AND LOCATION DATA COLLECTION

Contestants can opt out of the collection and use of certain information, which we collect about them by automated means, by changing the settings in the device they use to access the Platform. In addition, their browser may tell them how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies implemented, Contestants may not be able to use all of the features of the Platform.

When they access the Platform through a mobile device, Contestants may be asked to share their precise (GPS level) geo-location information so we can customize your experience and the content you receive. If they agree to such collection, in most cases, Contestants’ will be able to turn off such data collection at any time thereafter by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application, which will also cause them to lose the applicable feature for which such location data was collected, or, in certain instances, will cause them to lose the ability to participate in any Tournament.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such a policy will be re-posted on our Platform in the applicable location of a Tournament to which this Policy pertains. The date such modifications were made indicated on the top of the page. Therefore, Contestants are encouraged to review this Policy from time to time so that they are aware when any changes are made to this Policy.

YOUR AGREEMENTS

Contestants represent and warrant that any Personal Data they provide us is true and correct and relates to them and not to any other person.

If Contestants use the Platform, they are responsible for maintaining the confidentiality of their account and for restricting access to their computer or device.

Contestants agree to accept responsibility for all activities that occur under their account.

GENERAL

Please contact us via email at support@playrobn.com, and include the word “Privacy” in the email subject line, for answers additional information or queries related to this Policy.