Privacy Policy

This Privacy Policy explains the information that Empire Combat Pass collects when you use its products and services, how that information is used, with whom it may be shared, and your privacy choices.

1. Introduction

This Privacy Policy covers Empire Combat Pass (“Empire Combat Pass” “we” “us” or “our”). We provide online video hosting, sharing and related services through our owned-and-operated websites, including https://empirecombatpass.tv, our branded applications for mobile and connected devices, and our embeddable video players (collectively, the “services”).
By registering for or using our website and/or services, you accept this Privacy Policy. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at https://empirecombatpass.tv/privacy-policy. If we change the Privacy Policy in a way that materially lessens our commitments to you, we will provide notice to registered users by email or other methods.

2. Children’s Privacy

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian’s account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to Empire Combat Pass without your consent, you may ask us to delete such information by contacting us at help@sprintty.com.

3. Data We Collect About You

We collect the following information about you when you use our services:

Account Information
To create an account, you must provide a valid email address required for your authentication. If you choose to sign-up and/or authenticate using a third-party account (e.g., Facebook, Google), you authorize us to obtain account information from the third-party platform. Each account may have several users. We also collect the following data provided by you in your account:

Name
Phone number
Company name
Credit card or bank account details
Transaction history
To make financial transactions with us, you need to provide a valid payment method (e.g., credit card or PayPal account). Your payment information will be collected and processed by our authorized payment vendors.
Your profile may display information about you and your activities. This information may be accessed by others. Your information may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, descriptions, tags, etc.) are viewable by others. Your interactions with other users (e.g., comments, «likes,» private messages) may be seen by others. You may choose to limit the availability of your profile.
You may refuse to provide these data or delete your account any time provided that the services associated with the account will not be available. Upon deletion of the account this data will be processed only for the purposes of accounting, fraud protection and defense of legal claims.

Other Information You May Submit
You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.

Automatically-Collected Information
We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies.
Information Collected by Third Parties
Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).
We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.
Content Interaction Data
In case if you interact with our video player (including our embedded video player) we will collect data on the content you watched and watching habits. We may provide this data to content owners and advertisers who may combine this data with the data they already have on you to provide personalized content and advertising.

4. How We Use Your Data

We may use your data for the following purposes:

Identification and authentication: We use your data to verify you when you access your account.
Operating our services: We use your data to provide our services, process and fulfill orders, provide customer support, and to otherwise comply with our contractual obligations to you. We (and/or our third-party vendors) use your financial information to process financial transactions.
Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
Improving our services: We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
Customizing your experience: We use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying videos that you might enjoy, based upon your viewing choices.
Marketing and advertising: We use your data to show you ads on third-party sites. We may also use your data in delivering third-party advertisements to you. This may include «targeted ads» based upon your activities.
Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.
Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.
We may use algorithms and other automated means to implement any of the above.
Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:
Performance of a contract;
Legitimate commercial interest;
Compliance with a legal obligation; or
Consent

5. With Whom We Share Your Data

We share data with third parties as follows:

As you instruct: We may make your profile available to others as you instruct in using our services. We may share your data with persons to whom you have granted account-level access.
With your consent: We may share your data with third parties where we have obtained your express consent to do so.
Authorized vendors: We may share your data with third-party vendors that help us operate our services, process orders, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors, and shipment vendors.
Advertising and content personalization: We may share your data with advertising companies and content owners to display relevant content and ads to you.
Analytics: We may share your data with analytics providers which help us understand how customers are using our services.
Affiliates and advisors: We may share your data with our affiliate companies, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. We may share your data with our affiliates to the extent necessary to provide you with the services ordered.
Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction as discussed in Section 6.
Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.
We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

6. Legal and Safety-Related Disclosures

We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) («requests») that we receive from government authorities or parties to legal proceedings.
We handle U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.
We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

7. Data Retention

We retain your data for as long as you have an account. When you close an account, we will delete its content. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
We have no control over search engines; however, we will, upon request, send a request for deletion to major search engines.
If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

8. Your Privacy Choices

We enable you to make numerous choices about your data:

You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
You may change your account and video privacy settings. See Section 9 for more details.
You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
You may opt out of receiving commercial emails from us. See Section 10 for more details.
You may limit the use of cookies.
You may close your account.

9. Account Privacy Settings

Team Members
Some of our subscription plans enable you to grant account-level access rights to others. Persons with such access («Team Members») may be able to see and potentially alter your data. You may revoke or downgrade Team Member access at any time.

10. Communications from Empire Combat Pass

Emails
If you create an account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

11. Protecting Your Information

We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to not share it with others the password for your email account. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

12. Your Responsibilities

You may receive other people’s data in using our service. If you receive information from other users, you must comply with all laws, including those concerning privacy, data security, and online marketing.

13. Third-Party Services

We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. For example, if you click on an advertisement, you may be taken to the advertiser’s website. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.
You may use our service through third-party sites and to send you offers. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps and video players, but does not cover any third-party site or any third-party video player.

14. International Data Transfers and Certain User Rights

14.1 Location of Data
Empire Combat Pass is based in the United States. We provide services globally using computer systems, servers, and databases located in the US, Netherlands and other countries. Your information may be transferred from country to country to be processed in a better way. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth in Sections 14.2 and 14.3 below.

14.2 GDPR (EEA Users)
This Section 14.2 applies only to natural persons residing in the European Economic Area (for the purpose of this section only, «you» or «your» shall be limited accordingly). It is Empire Combat Pass policy to comply with the EEA’s General Data Protection Regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:

Legitimate business interests: We could not provide our services or comply with our legal obligations without transferring your personal information to the U.S.
Our use of Standard Contractual Clauses (also known as «Model Clauses») where appropriate.
Our certification and adherence to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, as described further below.
You have the right to: opt out of non-essential cookies; access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users to change their information, download their videos, and close their accounts. We also fulfill our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person’s rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact us at the address listed in Section 15. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

14.3 California Users
Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure.
Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:
Right to Know. You have the right to request information about the categories and sources of personal information we collect, our purposes for collecting the information, and the types of third parties that receive that information. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12-month period.
Right to Delete. You have the right to request that we delete some or all of the personal information that we have about you. Deleting all data will typically require the deletion of your account, along with all content, including your videos. Notwithstanding the foregoing, we may retain information to provide services you have ordered, complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights.
Do Not Sell. You have the right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. Empire Combat Pass does not sell personal information, and we have not done so in the last year. If we begin to do so, we will update this notice and provide a mechanism to opt out of any such sale.
Non-Discrimination. We won’t discriminate against you because you exercise any rights herein.
To exercise your rights to know and delete, we must be able to verify your identity as the owner of the Empire Combat Pass account you are inquiring about. We may not be able to fulfill your request until we can do so. In general, we verify identity by confirming that you are the owner of the email address associated with the account. An authorized agent submitting a request on your behalf must also have access to the email address associated with the account, along with sufficient evidence that you have authorized that person to submit the request on your behalf. Although you need not have a Empire Combat Pass account to submit a request, we may not be able to locate certain information to process your request if you don’t have one.

15. California Right to Know Information

The table below describes the categories of personal information we receive when you use our services or visit our websites, our purposes for collecting that information, and the third parties we share it with.
Account Information
What it includes
Account information means information that forms part of your account profile. This includes your name or username, contact information (including email address and location), Empire Combat Pass account ID, and any personal characteristics you might choose to add to your profile (like your pronoun preferences).
We may, in certain cases, enrich the information you’ve provided with data we receive from third parties. Some enriched data may include inferences about your use of other platforms.
Sources
We collect most account information directly from you. For example, to register, you must provide an email address and a screen name. We may provide other opportunities to directly provide personal information, such as in your user profile.
We may receive certain account information, like your email address, from a third-party platform if you choose to authenticate your account using third-party log-ins. We may also receive enriched data from third-party platforms where we advertise and third-party analytics vendors.
Purposes
We use account information to:

Provide our services, manage interactions on our services, fulfill orders, implement your preferences, and provide customer support;
Improve our services, provide quality assurance, and correct errors;
Implement security measures and prevent fraud and other abuse; and
Provide updates and offers that you may be interested in.
Third-Party Disclosures
We share account information with third parties for numerous business objectives:
We store your information on third-party cloud infrastructure providers. These providers are not permitted to use your data for any purpose other than providing services to us.
We share your account information with our customer support partners and vendors who provide customer relations management (CRM) tools, which allow us to provide support, send you emails, and provide other services.
If you purchase a physical product, we will share your shipping information with our fulfilment and delivery partners.
When you authenticate with a third-party account, we will provide information to that platform indicating that you have logged onto our platform with the credentials stored on the third-party platform.
Payment Information
What it includes
Payment information means payment card information, bank accounts, PayPal information, and other payment-related information.
Sources
You provide payment information to our authorized payment processing vendors when you make a funds withdrawal. We may obtain certain payment information from those vendors for certain limited purposes, such as investigating fraud.
If you use one of our monetization products, you must provide a bank account or other financial account to receive monies, and you may need to provide us with your tax information, which could include your taxpayer identification number.
Purposes
We use payment information to fulfill orders, pay amounts owed to you, prevent fraud and other abuse, handle chargebacks and refunds, and provide support.
Third-Party Disclosures
Your payment information is collected directly by our payment processing vendors; we do not directly collect such information in the first instance. This information will be disclosed to other parties in the financial payments system solely for the purpose of processing your transactions and complying with PCI (payment card industry) and legal requirements. We may also disclose certain financial information to our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance.
Purposes
We use automatically collected information to: provide services to you, manage interactions on our services, fulfill orders, complete transactions, manage preferences, implement security measures, provide customer support, quality assurance, and debugging, prevent fraud and other abuse, and improve our services.
Third-Party Disclosures
We share automatically collected information with authorized vendors, including:
Cloud storage and delivery providers, so that we can optimize the delivery of our services, taking into account your location and device capabilities;
CRM providers, so that we can understand how to best address any issues you might write to us about;
Vendors who help us detect fraud, spam, and other abuse;
Analytics providers, so that we can understand how our services are being used and improve them; and
Advertising partners, so that we can show you ads on third-party sites and understand how our advertising money is being spent.
Content Interaction Data
What it includes
Automatically collected information about your interaction with our video player (including our embedded video player). We will analyze the content you prefer and your watching habits.
Sources
We collect this information directly when you use our websites and apps. We also collect it through third parties who may include cookies, pixels, and similar technologies on our services. We may also receive this information from our authorized vendors and business partners.
Purposes
We use this information to provide personalized content and ads.
Third-Party Disclosures
We share this information with advertising companies and content owners.

16. How to Contact Empire Combat Pass

For any questions, inquiries, or complaints relating to your privacy, please contact us at: help@sprintty.com.

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