Smith Entertainment Group – Website PRIVACY POLICY
Last Updated and Effective: 05.21.2024
1. Welcome!
2. Scope & Acknowledgment
This Policy applies to our “Services,” which include, the website located at www.reimaginedowntownslc.com and any other website where we post or link to this Policy (our “Websites”) or other services we operate where we post or link to this Policy.
This Policy does not apply to Personal Information processed by third parties, for example, when you visit a third-party website or interact with third-party sites, except to the extent those parties collect or process information on our behalf. Please review any relevant third party’s privacy policy for information regarding their privacy practices.
Your use of our Services indicates your acknowledgement of the notices provided in this Policy.
3. Who We are
SEG, its affiliates, subsidiaries and related companies under the SEG brands described below (collectively, “SEG Companies,”) own and operate various sports and live entertainment properties and professional sports teams (collectively, “SEG Properties”). References to SEG Companies include (without limitation):
- SEG-owned and/or operated facilities and venues (such as the Vivint Arena)
- SEG-owned sports teams (such as the Utah Jazz and Salt Lake City Stars)
- Other current and future SEG affiliates and subsidiaries
4. Controllers; Contact Us
The controller of your Personal Information under this Policy is Smith Entertainment Group, LLC. You may contact our Data Privacy Team at privacy@smithentertainmentgroup.com.
5. Categories and Sources of Personal Information
Categories of Personal Information We Process
In order to provide our Services, we may collect and process information that relates to identified or identifiable individuals (“Personal Information”). We collect and process the following categories of Personal Information (note, specific Personal Information elements are examples and may change):
Contact Data – Identity Data used to contact an individual, e.g. email address, physical address, or phone number.
Device/Network Data – Personal Information relating to your device, browser, or application e.g. device identifiers, identifiers from cookies, session history and Website navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
General Location Data – Non-precise lwocation data, e.g. location information derived from IP addresses.
Identity Data – Personal Information about you and your identity, such as your name or IP address.
Inference Data – Personal Information we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or your interests.
User Content – Personal Information included in content provided by users of the Website in any free-form or unstructured format, such as in a “contact us” box, free text field, in a file or document, or messages to us.
Sources of Personal Information
We collect Personal Information from various sources based on the context in which the Personal Information will be processed:
You – We collect Personal Information from you directly, for example, when you book a service, input information into an online form, or contact us directly.
Automatic Collection – We may collect certain Personal Information automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Website, access our Website, or when you open our marketing communications.
Service Providers – We receive Personal Information from service providers performing services on our behalf.
Data we create or infer – We, certain partners, and third parties operating on our behalf create and infer Personal Information such as Inference Data based on our observations or analysis of other Personal Information processed under this Privacy Policy, and we may correlate this data with other data we process about you.
Social Media Companies – We receive Personal Information from social media companies, such as Facebook or Instagram when you interact with us on that social media company’s platform (e.g. our company page or account) on or in connection with our Services.
6. Data Processing Contexts / Notice at Collection
Newsletters and Marketing Communications
We and the SEG Companies may process Identity Data, Device/Network Data, Inference Data, and Contact Data in connection with email newsletters or other promotional communications that we send in relation to our Services, SEG Properties, and the business of the SEG Companies (“Marketing Communications”). For example, we send Marketing Communications to you if you subscribe to a newsletter through our Services, or express an interest in or request to learn more about SEG Companies, SEG Properties, or our other products, services, or initiatives.
You may receive Marketing Communications if you contact us, choose to receive them, or interact with us in way that allows us to send you those Marketing Communications. We may also automatically collect Device/Network Data when you open or interact with those Marketing Communications so that we can better understand whether users read or engage with our Marketing Communications.
We generally use this Personal Information as necessary to send and manage our promotional communications. We may also process this Personal Information for our Business Purposes. You can opt out of promotional communications at any time as specified in the “Your Choices” section below.
Social Media Posts
We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media or communications platform (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Information to engage with you on the social media platform, and for our Business Purposes.
Please note: Content you provide may be publicly available when you post it on our Service, or in some cases, if you reference, engage, or tag our official social media accounts or communications platform.
Contact Us
We process Identity Data, Device/Network Data, as well as any Personal Information contained within any User Content when you contact us via a contact us, email, or other support channel to request in relation to SEG Companies, SEG Properties, our products, services, or initiatives, or to ask for support. We use Identity Data, Contact Data, User Content, and Audio Data as necessary to communicate with you about the subject matter of your request. If related to your request, we may send you Marketing Communications. We also process this Personal Information for our Business Purposes.
Website
Generally
When you use our Website, we automatically collect and process Identity Data, Inference Data, General Location Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Website, such as operating our Website, delivering webpages, or logging activities for security purposes. We may also process this Personal Information for our Business Purposes (as defined below).
Cookies and Similar Tracking Technologies
We process Identity Data, Device/Network Data, Contact Data, Inference Data, and General Location Data in connection with our use of cookies and similar technologies on our Website. We may collect this data automatically. We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:
- for “essential” purposes necessary for our Website to operate (such as maintaining user sessions, content delivery, and the like);
- for “functional” purposes, such as to enable certain features of our Website (for example, to allow you to store your preferences, such as language or content settings); and
- for “analytics” purposes, such as to analyze the traffic to and on our Website. For example, we can count how many people have looked at a specific page, or see how visitors move around the Website when they use it, to distinguish unique visits/visitors to our Website, and what website they visited prior to visiting our Website, in order to understand user behaviors and interests related to our Website and improve the design and functionality of the Website.
We also process this Personal Information for our Business Purposes. See the your “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.
Please note, in some cases, third parties may view, edit, or set their own cookies or place web beacons on our Website. We, or third party providers, may be able to use these technologies to identify you across websites, devices, sites, and services. Third parties have their own privacy policies and their processing is not subject to this Policy.
Feedback and surveys
We process Identity Data, Contact Data, Preference Data, and User Content collected in connection with surveys or questionnaires. We process this Personal Data as necessary to respond to guest/visitor requests and concerns, for our Business Purposes, and other business interests, such as analyzing interest in or satisfaction with SEG Companies, SEG Properties, our products, services, or initiatives, or to improve your experience with our products and services.
7. Purposes of Processing
Business Purposes
In addition to the processing described above, we generally process Personal Information for several common purposes in connection with our business. Please see below for more information regarding the purposes for which we process your Personal Information.
Operate our Services and Fulfill Obligations
We process any Personal Information as is necessary to provide our Services, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.
Internal Processes and Service Improvement
We may use any Personal Information we process through our Services as necessary in connection with our improvement of the design of our Services, understanding how the Services are used or function, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to use of our Services, and for ensuring the security and stability of the Services. Additionally, we may use Personal Information to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our users.
Security and Incident Detection
We may process Personal information in connection with our legitimate interest in ensuring that our Services is secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals, and ensure the safety of our guests. Similarly, we process Personal information as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal information in connection with our information security operations and related.
Aggregate Analytics
We process Personal Information as necessary in connection with our creation of aggregate analytics relating to how our Services is used, the pages and content users view, and to create other reports regarding the use and performance of our Services, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified.
Compliance, Safety & Public Interest
Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Information subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Information in extraordinary circumstances.
Corporate Events
Your Personal Information may be processed as part of routine corporate operations, as part of corporate reorganizations, or any business transition, such as a merger, acquisition, liquidation, or sale of assets.
8. Data Sharing
Personal Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, described below.
SEG Companies
In order to streamline certain business operations and develop products and Services that better meet the interests and needs of our visitors and guests, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies. For example, we share Personal Information with other SEG Companies in support of our Business Purposes, and in connection with our Marketing Communications.
Service Providers
In connection with our general business operations, product improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Information with service providers or subprocessors who provide certain services to us, or process data on our behalf. For example, we may use third party hosting providers to host our sites or content, and we may disclose information as part of our own internal operations, such as security operations, internal research, etc.
Social Media Companies
We may share certain Personal Information with social media companies when you interact with SEG on social media. We may allow these third parties to operate through our Service, such as through a social media icon link on our homepage.
Corporate Events
Your Personal Information may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Legal Disclosures
In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.
9. Your Rights & Choices
Your Rights
Applicable law may grant you rights in your Personal Information. These rights vary based on your location, state/country of residence, and may be limited by or subject to our own rights in your Personal Information. You may submit requests to exercise rights you may have by contacting us at privacy@smithentertainmentgroup.com.
Note: We are able to fulfill rights requests regarding Personal Information that we control or process. We may not have access to or control over Personal Information controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.
Verification of Rights Requests
We verify all rights requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Information. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
Your Choices
You may have the following choices regarding the Personal Information we process, to the extent required under applicable law:
Consent
If we rely on your consent to our processing of Personal Information, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services. You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email (for email), by responding with “OPT-OUT”, “STOP”, or other supported unsubscribe message (for SMS), by adjusting the push message settings for our mobile apps using your device operating system (for push notifications), or for other communications, by contacting us using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.
Email Marketing
You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in our communications.
Cookies & Similar Technologies
If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies and certain similar technologies using your browser’s settings menu. You must opt out of the use of some third party Services directly via the third party. To learn more about Google Analytics, please click here. To opt-out of Google’s analytic services, you may use the Google Analytics Opt-Out, or use your device’s settings.
Do Not Track
Our Services does not respond to your browser’s do not track signal.
10. Security
We implement and maintain reasonable security measures to safeguard the Personal Information you provide us. However, we sometimes share Personal Information with third parties as noted above, and though we may take certain measures to help ensure the security of your Personal Information, we do not control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.
11. Data Retention
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
12. International transfers
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be processed in the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in foreign countries. Contact us for more information regarding transfers of data to the U.S.
13. Children
Our Services are neither directed at nor intended for use by persons under the age of 13 in the US. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Information if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.
14. Changes to Our Policy
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.
15. REGIONAL SUPPLEMENTS
US States
Scope
This section applies to individuals located in the United States.
US State Privacy Rights
Under Utah and other state privacy laws, residents of Utah and certain other US states may have the following rights, subject to applicable law, as well as applicable requirements, exceptions, and limitations under the law applicable to you:
Confirm – Right to confirm whether we process your Personal Data.
Access – Right to request any of following: (1) the categories of Personal Data we have collected, sold/shared, or disclosed for a commercial purpose (if any); (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/shared your Personal Data (if any); (4) the categories of third parties to whom we have sold/shared your Personal Data, or disclosed it for a business purpose (if any); and (5) certain specific Personal Data we have collected about you.
Portability – Right to request that we provide certain Personal Data in a common, portable format.
Deletion – Right to delete certain Personal Data that we hold about you.
Correction – Right to correct certain Personal Data that we hold about you.
Opt-Out (Sales, Sharing, Targeted Advertising, Profiling) – Right to opt-out of the following:
- If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
- If we engage in targeted advertising, you may opt-out of such processing.
- If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt-out of such processing.
You may submit requests as follows, subject to identity verification where required by law (please review our verification requirements section above). If you have any questions or wish to appeal any refusal to take action in response to a rights request, including any denial of the request or failure to verify your identity, contact us at privacy@smithegentertainmentgroup.com. We will respond to any request to appeal within the period required by law. We may charge a fee for excessive, repetitive, or technically infeasible requests, or if you submit multiple requests within a 12-month period.