Privacy Notice for California Residents
Effective Date: March 28, 2023
This Privacy Notice for California Residents (this "Notice") is provided by Association of Surfing Professionals LLC d/b/a World Surf League and its affiliates (collectively, “WSL”, "we", "our" and similar pronouns). Please note the following:
- We adopt this Notice to comply with the California Consumer Privacy Act of 2018, as amended, and the regulations promulgated thereunder (“CCPA”) and any terms defined in the CCPA (such as “personal information” or “share”) have the same meaning when used in this Notice.
- This Notice applies solely to California residents who visit or use the WSL Digital Sites, who register for, attend or participate in our events, who apply for or undertake employment, contractor or similar opportunities with us or who otherwise provide personal information to us (such California residents, "consumers" or "you").
- If you are an athlete or other individual with an agreement with WSL, this Notice applies to that relationship except to the extent our practices may differ from this Notice as explained in any other agreements, policies or consents applicable to information about you.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
- Information that is “publicly available” under the CCPA.
- Lawfully obtained, truthful information that is a matter of public concern.
- Deidentified or aggregate consumer information.
- Information excluded from the CCPA’s scope.
In particular, we collect the following categories of personal information from consumers:
- Identifiers, such as name, postal address, email address, account name, Social Security number, unique personal identifier, social media handles, online identifier, Internet Protocol address, device identifiers or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number, signature, Social Security number, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Protected classification characteristics under California or federal law, such as national origin, citizenship, medical condition, or sex (including gender identity).
- Commercial information, such as purchasing or consuming histories or tendencies.
- Internet or other electronic network activity, such as browsing history, search history or information on a consumer’s interaction with a website, email, application, or advertisement.
- Geolocation data.
- Audio, electronic, visual or similar information, such as photographs, video recordings and voice recordings of our participants and other consumers.
- Professional or employment-related information, such as current or past job history.
- Non-public education information, such as education records, degrees and vocational certifications obtained and transcripts.
- Inferences drawn from other personal information to create a profile, such as a profile reflecting the consumer’s preferences, characteristics, behavior, attitudes, abilities, or aptitudes.
- Sensitive personal information, including personal information that reveals:
- A consumer’s account log-in in combination with a required security or access code, password, or credentials allowing access to an account on our systems or WSL Digital Sites.
- A consumer’s precise geolocation if relevant for features on the WSL Digital Sites.
- Health information, such as health-related information collected in connection with participation in our events or administering benefits to employees and certain independent contractors.
- Personal information collected and analyzed concerning a participant’s sexual orientation if you provide that information with us.
Categories of Sources
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from transactions you request (such as registering to compete in an event or purchasing a ticket for events), subscriptions, applications, surveys or other forms you complete or in connection with your communications or relationship with us.
- Indirectly from you. For example, from observing your actions on the WSL Digital Sites.
- Created about you by us in the course of job-related or engagement-related activities throughout the period of your engagement with us (for example, your performance appraisals and opinions about your competencies).
- From other sources. For example, information from social media services, analytics providers, advertising networks, internet service providers, commercially available sources, government entities, employment agencies, data processors to which we outsource tasks (such as membership and event registration), our affiliates and our business partners (such as WSL sponsors or event licensees).
Use and Disclosure of Personal Information for Business or Commercial Purposes
We do not use or disclose “sensitive personal information” for purposes other than those specified in section 7027, subsection (m) of the CCPA regulations.
Disclosures of Personal Information for a Business or Commercial Purpose
We have disclosed in the preceding twelve (12) months, and may in the future disclose, the following categories of personal information to third parties for a business or commercial purpose:
- California Customer Records personal information categories.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Internet or other electronic network activity.
- Geolocation data.
- Audio, electronic, visual or similar information
- Professional or employment-related information.
- Inferences drawn from other personal information.
- Sensitive personal information. In the preceding 12 months, we have disclosed the categories of personal information listed above for business or commercial purposes with our service providers and business partners who we work with in providing our services or operating our business, such as sponsors, streaming platforms, social media platforms, advertising networks, internet service providers, analytics providers, operating systems and platforms, content providers, payment providers and other business partners. You can find more detail about our practices for disclosing personal information to third parties (including the purposes for such disclosures) in our https://www.worldsurfleague.com/pages/privacy-policy.
“Sales” and “Sharing” of Personal Information
Retention of Personal Information
We will retain your personal information for as long as necessary to fulfil the purposes for which we collected it (as described above), including for the purposes of satisfying any legal, tax, accounting, or reporting requirements or, if you participate in our events, for purposes of maintaining records (including statistics and rankings) in relation to our events. To determine the appropriate retention period, we consider the nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize or deidentify your personal information so that it can no longer be associated with you, in which case we may retain and use such data without further notice to you to the extent permitted by law.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. The sections below describe your CCPA rights and explains how to exercise those rights, which are subject to our records retention policies and applicable law (which has certain exceptions to these rights).
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose the following information to you with respect to the preceding 12 months or a longer period as applicable under the CCPA:
- The categories of personal information we collected about you.
- The categories of sources from which that personal information is collected.
- The business or commercial purposes for collecting, selling or sharing that personal information.
- The categories of third parties with which we disclose personal information.
- The categories of your personal information which we disclosed for a business purpose and the categories of third parties to which we disclosed such personal information.
- The categories of your personal information we have "sold" or “shared” and the categories of third parties to which we sold or shared such personal information.
- The specific pieces of personal information we collected about you (also called a "data portability" request).
Correction Request Rights
You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and purpose for which it is processed. Once we receive and confirm the validity of your request, we will work to correct the requested personal information within our records as required by the CCPA.
Deletion Request Rights
You have the right to request that we delete the personal information we collected about you, subject to certain exceptions provided by the CCPA. Once we receive and confirm the validity of your request, we will delete the requested personal information from our records or deidentify the information, unless an exception provided by the CCPA applies. For example, we may retain personal information as required or permitted by law, and may maintain a copy of your deletion request.
Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a valid consumer request to us by either:
- Calling us toll-free at 1-866 – 980 -1358
- Emailing us at firstname.lastname@example.org
- Filling out the Web Form here. Only you, or someone legally authorized to act on your behalf, may make a valid consumer request related to your personal information. You may also make a valid consumer request on behalf of your minor child. Depending on the nature of your request (for example, for requests to know, delete or correct personal information), you may be sent an email to verify and confirm your identity before we can comply with your request.
A valid consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. To verify your request, we work to match the personal information about you provided with the request with personal information in our records to determine whether and what personal information we hold about you that falls in scope of a valid CCPA request of that nature. We cannot carry out your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may only make a valid consumer request for access or data portability twice within a 12-month period. Please describe your request with sufficient detail for us to properly understand, evaluate and respond to it.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to opt out of our future "sale" or “sharing” of your personal information. To do so, you may submit a "Do Not Sell or Share My Personal Information" request by: Following the instructions available here. Calling us at 1-866 - 980 - 1358
You do not need to create an account with us to exercise your opt-out rights.
Please be aware, if you do not log in to your account (or do not have an account with us) and instead opt out of certain future “sales” or "sharing" of your personal information to our ad partners by setting a cookie-based "Do Not Sell or Share My Personal Information" preference that is specific to the WSL Digital Site that you are visiting, such setting is also specific to the device and browser you are using. It will only work if your browser is set to accept cookies, and you will need to opt out on each device and each browser you use to visit a WSL Digital Site. Once the "Do Not Sell or Share My Personal Information" cookie setting expires, or if you clear your browser cookies, you will need to reset the setting if you wish to opt out again. For our mobile apps, the local setting should remain until you specifically change it or clear the mobile app’s data on your device; however, you should check the setting regularly to ensure it reflects your current preferences.
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from the consumer who is at least 13, but not yet 16, years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to personal information sales may opt out of future sales at any time.
Requests from Authorized Agents
If you would like an authorized agent to submit a CCPA request on your behalf or if you are an authorized agent of a consumer and registered with the Secretary of State to conduct business in California, please submit the request using one of the methods offered as described in this Notice and provide, as part of the request, evidence that you have authority to act on the consumer’s behalf in this manner in the form of a written letter of authority or power of attorney.
Right of Non-Discrimination
You have a right under the CCPA not to receive discriminatory treatment by us because you exercised any of your CCPA rights. Except when permitted by the CCPA, examples of discriminatory treatment include denying goods or services; charging different prices or rates for goods or services; providing a different level or quality of goods or services; suggesting any of the foregoing; and retaliating against an employee, applicant for employment, or independent contractor. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.
Financial Incentives Program
We offer various financial incentives. In order to participate in some of these financial incentives, you may be asked to provide personal information or allow us to sell or share that personal information with a third party. For example, you may have the opportunity to receive free or discounted tickets to events, merchandise, shipping or other products or services in exchange for our collection of your Identifiers, Personal information categories listed in the California Customer Records statute, Protected classification characteristics under California or federal law, Commercial information, and Internet or other electronic network activity, signing up to receive our marketing communications or agreeing to sign up for an account with WSL or a third party with whom we have a relationship (such as Club Rip Curl).
Your participation in a financial incentive program is voluntary and you may withdraw from the program at any time. To withdraw and forgo any ongoing incentive, you may unsubscribe from our emails (for email-based incentives only) or, for other incentives, submit a request to opt-out by emailing us at email@example.com with the subject line “Financial Incentive Opt-Out” and include the name of the applicable program(s) or promotion(s) you wish to discontinue as well as the email address and other information you submitted when signing up for the program. To withdraw from a financial incentive program that involved sharing your personal information with a third party or creating an account with that third party (such as a referral program), you will need to directly contact any third party that already received your information directly and request to opt out and/or close your account with them, as relevant.
For each CCPA-permitted financial incentive we offer, we have determined that the value of the financial incentive you would receive reasonably relates to your personal information’s value. To assess this, we estimate the value of consumers’ personal information by considering the expenses incurred by us related to the collection, storage and retention of consumers’ personal information in the context of the financial incentive program and the expenses related to the provision of the financial incentive. From time to time, we may provide additional terms that apply to a particular financial incentive, which will be presented to you at the time you sign up for the financial incentive.
Reasonable Access for Consumers with Disabilities
Persons with disabilities may obtain this Notice in an alternative format upon request by contacting us at firstname.lastname@example.org or calling 1-866 – 980 -1358.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the WSL Digital Sites and update the notice’s effective date. Your continued use of the WSL Digital Sites following the posting of changes constitutes your acceptance of such changes.
If you have any questions about this Notice, the ways in which we collect and use your information described here, or your choices and rights regarding such use, please do not hesitate to contact us at: Phone: 1-866 – 980 -1358 Email: email@example.com Postal Address: Association of Surfing Professionals LLC dba World Surf League 149 Bay St, Santa Monica, CA, 90405 USA