WTA Privacy Notice

Last updated on December 17, 2018

The WTA knows that your privacy is important to you, and we want you to know that it is important to us too. This Privacy Notice explains how we collect, use, and disclose Personal Data that we receive when you visit our websites (including the mobile optimized versions and mobile applications on which it is posted) (collectively, the “Site”), participate in our services, or communicate with us, both on the Site and offline. This Privacy Notice also describes how we protect this data once it is collected, and how you can exercise your rights regarding your data. This Privacy Notice should be read in conjunction with the Terms of Use for the Site.

Contents:

1. Who we are
2. Contact Us
3. How We Collect and Use Your Data
4. Disclosure of Personal Data and Site Usage Information to Third Parties
5. Your Rights
6. Exercising your Rights
7. Cookies and Third-Party Ad Servers and Networks
8. Do Not Track Disclosures
9. Security
10.Social Networking
11.Links to Third Party Websites
12.International transfers
13.How long do we keep your Personal Data?
14.Children's Privacy
15.Complaints
16.Changes to this Privacy Notice
17. WTA Players

1. Who We Are

This Privacy Notice is issued on behalf of WTA Tour, Inc. and its corporate affiliates (referred to collectively in this Privacy Notice as “WTA” and “we,” “us,” “our” and other similar pronouns). When we process your Personal Data, we do so as a ‘data controller’ under the General Data Protection Regulation (in the European Union), meaning that we are responsible for deciding how and why we hold and use your Personal Data.

2. Contact Us

If you have any questions or comments regarding our privacy practices, or to exercise any of your rights as described in this Privacy Notice or under data protection laws, you may contact us using the contact details below. If you are located in the European Economic Area (“EEA”), you may contact our appointed representative in the EEA about any data protection queries.

WTA Tour, Inc.
100 Second Avenue South, Suite 1100-S
St. Petersburg, FL 33701 USA
Email: Legal@wtatennis.com
Phone: +1.727.895.5000#

In the EEA

WTA Tour, Inc.
Palliser House
Palliser Road
London W14 9EB
Email: Legal@wtatennis.com

Phone: +44.20.7386.4100

3. How We Collect and Use Your Data

a) Data you provide to us:

Personal Data” is information that can be used to identify you as an individual, such as your name, age, and contact information. Whether or not you provide us with your Personal Data is your choice; however, in many instances your Personal Data is required to participate in certain services or activities we offer or gain access to certain content on the Site. For example, we collect Personal Data when you create an account on our Site; sign up for our newsletters; enter sweepstakes and contests; or submit a comment or question to us using a “contact us” or similar feature on the Site; or communicate with us offline. If you do not provide your Personal Data, this may make it impossible for us to provide you with the requested service or content.

We may ask you to provide all or some of the following categories of Personal Data, for the purposes set out in the table below, which also explains our legal basis for doing so:

Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights, and freedoms do not override our legitimate interests. If you want further information on the balancing test we have carried out, you can request this from us using the contact details set out above.

 

Data We Collect 

How We Use Your Data

Legal Basis

1. Data you provide when you register for any account with us directly (where this functionality is available on the Site), including your:


  • Full name;
  • Email address;
  • Account password;
  • Gender;
  • Age range;
  • Country; and
  • Favorite content on our site

We may collect additional data about you if you register for an account via a social media platform, including your:

  • Social media account ID; and 
  • Address (if you choose to provide this)

We use this data to:


  • Provide our services to you;
  • Provide you with more relevant content;
  • Communicate with you regarding your account and our services;
  • Manage and administer the Site; and
  • Make improvements to the Site and our content and services.
  • It is necessary for us to process your data in this way in order to enter into and perform our contract with you;
  • It is in our legitimate interests to monitor and make improvements to the Site and our content and services.

2.


Data you provide when you sign up to receive our newsletters or enter to participate in a sweepstake or contest, including your:


  • Name; and
  • Email address

We use this data to:


  • Send you our newsletters where requested;
  • To make suggestions and recommendation to you about content, goods, or services that may interest you;
  • To enable you to participate in sweepstakes or contests which we may run from time to time;
  • To contact you to tell you whether you have won a prize or award.
  • It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you;
  • We will ask for your consent before sending you unsolicited direct marketing (i.e., direct marketing communications sent by email to individuals who we have not previously engaged with). You can always opt-out of receiving direct marketing-related email communications or text messages by following the unsubscribe link or contacting us as described herein.

3.


Data you provide when we communicate with each other whether through the Site or via email, through social media, or offline, including:


  • Your contact details;
  • The details of your communications with us and the content you provide; and
  • Our messages to you.

We use this data to:


  • Respond to your requests or answer your issues or concerns;
  • Monitor customer communications for quality purposes;
  • Improve our services based on the data and feedback you and other customers provide;
  • To notify you of changes to the Site.
  • It is in our legitimate Interests to:


Understand your concerns and respond appropriately


Ensure quality 


Protect our rights; and


Improve the Site and our content and services


  • It is necessary for us to process your data in this way in order to enter into and perform our contract with you.

 

Generally, we do not rely on consent as a legal basis for processing your Personal Data, although we may need your consent before sending direct unsolicited marketing communications to you via email or text message. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent by contacting us using the contact details set out above.

b) Data collected from third parties: The Site contains links to web sites that are not operated by WTA. These third parties may collect data from you and share some of that data with us, as follows:

  • Perform Media Group, from which we collect the following categories of Personal Data: name, email, country, and address;

WTA is careful when choosing its partners, sponsors, and affiliates, but WTA is not responsible for any misuse of Personal Data by such third parties. We recommend that you view the privacy notice posted on each website that you use to confirm that the site's privacy practices are acceptable to you.

c) Site Usage Information: Our servers automatically collect your IP address when you visit our Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, Web browser, and operating system and their settings, the referring page that linked you to the Site, the pages, content, or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.

Among other things, this information enables us to: improve and develop our services and content; understand the behavior of our users, and how users interact with the Site; analyze site traffic and understand customer needs and trends; identify issues with the Site. We have a legitimate interest in collecting and using this information, 1) so that we may understand how our customers use our content, services, and the Site, 2) so that we may make improvements to our content, services, and Sites, and 3) so that we can provide you with advertisements that are more relevant to you. See Section 7 below for more details.

At times, we may match information collected from you through different means or at different times, including both Personal Data and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails, and our other messaging campaigns both on an individual basis and in the aggregate.

4. Disclosure of Personal Data and Site Usage Information to Third Parties

 

We share the Personal Data we collect on the Site and offline with others for a variety of reasons, as described in this Privacy Notice. In addition to the kinds of information sharing you might expect, such as sharing with employees, contractors, and third party service providers (such as analytic companies, email newsletter distributers, cloud services providers, and prize providers) who process your Personal Data in order to provide services to us, and sharing what you voluntarily post to public areas on the Site with other Site users, we may share your information:

  • with our co-sponsor(s) in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties;
  • with the Tennis Integrity Unit for the purpose of assisting with their anti-corruption investigations. You can read the Tennis Integrity Unit’s privacy policy here: http://www.tennisintegrityunit.com/privacy-policy;
  • when we believe in good faith that disclosure is necessary to protect or enforce our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial, or other legal request, or to otherwise comply with the law;
  • in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, or wind down of business;
  • with our professional advisers including lawyers, auditors, and insurers.

In addition, we may share anonymous Site Usage Information (including aggregate data) with others, for their own use, because in such circumstances the data does not identify you and will cease to be Personal Data.

5. Your Rights

To the extent that the GDPR applies to you, you have certain rights in relation to your Personal Data. The availability of these rights and the ways in which you can use them are set out below in more detail. Some of these rights will only apply in certain circumstances.

  • Access: You may ask us if we are processing your Personal Data and, if we are, you can request access to that data.
  • Correction: You may ask us to correct or remove Personal Data you think is inaccurate.
  • Erasure: You may ask us to delete or remove your Personal Data in certain circumstances.
  • Restriction: You may ask us to restrict or suspend the processing of your Personal Data in certain circumstances.
  • Transfer: You may request the transfer of certain of your Personal Data to another party. This right to data portability only applies where your Personal Data is processed by us with your consent or for the performance of a contract, and when processing is carried out by automated means.
  • Objection: You have the right to object at any time to our processing of your Personal Data for direct marketing purposes. Where we process your data based on our legitimate interests (or those of a third party), you also have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data which is based on our legitimate interests. However we may be entitled to continue processing your data if our legitimate interests outweigh your interests, rights, and freedoms, or where the data is relevant to legal claims.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. We may refuse a request for erasure, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise, or defense of legal claims. We may refuse to comply with an access or correction request if the request is manifestly unfounded or excessive or repetitive in nature.

6. Exercising Your Rights 

You can exercise any of your rights as described in this Privacy Notice and under data protection laws by contacting us as provided in the Contact Us section above. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Save as described in this Privacy Notice or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (taking into account the administrative costs of providing the information or taking the action requested); or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

As described above, you can opt-out of receiving direct marketing (i.e., our newsletters and promotional emails) from us at any time. You can do so by clicking on the unsubscribe link within the e-mail you receive, or by contacting us as provided in the Contact Us section above.

7. Cookies and Third-Party Ad Servers and Networks

When you visit our Site, we collect certain information by automated means, using tracking technologies such as cookies, local storage, web beacons, and pixel tags. Cookies are small data files that websites send to your computer or device to uniquely identify your browser or to store information or settings in your browser. This enables us to recognize you as the same user who was at our Site in the past and relate your use of the Site to other information about you, such as your Site usage information and Personal Data.

Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily, and keeping you logged into the Site after you have provided your password) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.

Our Sites may use the following types of cookies/tracking technologies:

  • Local shared objects, otherwise known as “Flash cookies” are stored on your computer or device using a media player or other software installed on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you
  • HTML5 (the language some websites are coded in) are used to store information on your computer or device about your Site usage activities. This information can be retrieved by us to determine how our Site is being used by our visitors, how it can be improved, and to customize it for our users.
  • Cache cookies, such as eTags, are used to identify your computer or device as the same computer or device that visited our Site or another website in the past.
  • Browser history sniffing which enables us to detect whether you have visited a webpage of ours or of someone else’s in the past by determining whether its URL is located in the list of URLs stored in your Web browser’s history file.
  • Browser fingerprinting which enables us to recognize your computer or device as the same one that has been used to visit our Site in the past based on various detectable information from your computer or device that, together, can be used as a “fingerprint” of your computer or device.
  • Pixel tags (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.
  • Cookies that collect and manage social media identities and data or provide login, registration, social media functionality on the Site.
    These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. 

Third party advertising

We use third-party advertising companies to serve ads when you visit our Site. These companies may use information about your visits to this and other websites, the region of the country or world where your IP address indicates you are located, and other information about you in order to provide advertisements about goods and services of interest to you. These advertisements may appear on this Site and on other websites. These companies may employ cookies, clear GIFs, and other tracking technologies to cause relevant ads to be displayed to you. This Privacy Notice does not apply to, and we cannot control the activities of, such advertisers, ad servers, or ad networks. You should consult the respective privacy policies of any advertisers on our Site to see your options for opting out of their use of such devices. We encourage you to read these businesses’ privacy policies to learn about how they treat your information. In addition, some of the ad servers and ad networks may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads on our Site from ad servers and ad networks, you will continue to receive advertising and promotional messages after you opt-out, but they will not be customized or personalized to you based on your use of our Site and/or third party websites. For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices/ or Aboutads.info at http://www.aboutads.info/choices/.

8. Do Not Track Disclosures

Some Web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates. Because of differences in how Web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “Site Usage Information” above) in response to DNT settings in your web browser.

Our third-party partners, such as Google Analytics, Quantcast, Mixpanel, and third-party ad networks, collect information about your online activities over time and across our Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your Web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our Web analytics and you can opt out of your Site usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout. 

9. Security

While we endeavor to protect the security and integrity of your Personal Data collected via this Site, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you create an account on our Site, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security as soon as possible.

If at any time during or after our relationship we believe that the security of your Personal Data in our care may have been compromised, we may seek to notify you of that development, as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can change that e-mail address anytime in your account profile. To receive these notices, you must check your e-mail account. You consent to our use of e-mail as a means of such notification. 

10. Social Networking

We maintain a presence on several social networking platforms, such as Facebook, Instagram, and Twitter, and we also incorporate some third-party social networking features onto our Site. Through these platforms and features, we receive some Personal Data and some Site Usage Information about you as described above, and this Privacy Notice applies to that information as well. In addition, third-party social networking platforms have their own privacy policies that explain how the third parties that provide them will use and protect your information. In accordance with those policies (and your privacy settings within your social networking accounts), information about your activities on our Site (such as “Mary Jane “likes” the WTA” or “John Smith read our article about the WTA Finals”) may be published to your social network.

11. Links to Third Party Websites

The Site may contain links, banners, widgets, or advertisements that lead

to other websites. We are not responsible for these other sites, and so their posted privacy policies (not this Privacy Notice) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each website visited after leaving the Site to learn about how your information is treated by others.

12. International Transfers 

Because WTA operates our Site and our services from the US, your Personal Data may be transferred to, and stored, in the Unites States and other locations outside of the EEA, for the purposes of

processing by us and by third party service providers that work for WTA.

Where Personal Data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for Personal Data, we take steps to provide appropriate safeguards to protect your Personal Data, including:

  • entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your Personal Data;
  • under the EU-U.S. Privacy Shield Framework (where we transfer Personal Data to the U.S.), which enables U.S. businesses to self-certify as a means of complying with EU data protection laws.

In the absence of an adequacy decision or of appropriate safeguards as referenced above, we will only transfer Personal Data to a location outside of the EEA where one of the following applies:

  • the transfer is necessary for the performance of our contractual engagement with you;
  • the transfer is necessary for the establishment, exercise, or defense of legal claims; or
  • you have provided explicit consent to the transfer.

13. How long do we keep your Personal Data?

Your Personal Data will not be kept for longer than is necessary for the purposes for which it was collected and processed.

The criteria we use for retaining different types of Personal Data, will depend on the following:

  • if you have registered for any account on the Site, we will retain your information for as long as you hold such account with us;
  • guidance from applicable regulatory authorities and industry best practice recommendations;
  • legal and regulatory requirements – we may need to retain Personal Data for up seven (7) years after we cease providing services to you where necessary to comply with our legal obligations, resolve disputes, or enforce our terms and conditions.

 

14. Children’s Privacy

This is a general audience website. We do not knowingly collect data from individuals who are under 16 years old. If you are under 16 years old, you should only view the Site and/or submit Personal Data to us with your parent or guardian’s permission.

15. Complaints

If you have a complaint regarding our Privacy Notice or practices, please contact us in the first instance as provided in “Contact Us” above.

If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/).

16. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. When we do, we will

let you know by posting the changed Privacy Notice on this page with a new last updated date. In some cases, we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes. We encourage you to review this Privacy Notice periodically, especially before you provide Personal Data directly to us through the Site. Your continued use of the Site after we implement any changes to this Privacy Notice constitutes your acceptance of the revised Privacy Notice.

17. WTA Players

 For clarity, this Privacy Notice does not apply to WTA players. If you are a WTA player please contact us for more information about how we collect and process your Personal Data.