Miami Dolphins, LTD. Privacy Policy

Effective Date: September 1, 2015

Updated as of June 21, 2022

Miami Dolphins, Ltd., South Florida Stadium LLC and their affiliated organizations (collectively, "we," "our," "us") respects your privacy and values your trust and confidence. This privacy policy (the "Privacy Policy") applies to our websites ("site" or "sites") and online services that link to or post this Privacy Policy including but not limited to MiamiDolphins.com, www.hardrockstadium.com; and our Official Miami Dolphins mobile application (collectively, the "Services"), and explains how we collect, use, and disclose information through the Services. By using the Services, you agree to the terms of this Privacy Policy. Please note that this Privacy Policy does not apply to any information that is collected or obtained through sites or services that do not link to this Privacy Policy (including the Team Shop at shop.miamidolphins.com) or information collected by the National Football League ("NFL") or the other NFL member clubs (the "Member Clubs").

Index

1. Information Collection
2. Use of Information
3. Sharing of Information
4. Mobile Applications
5. Advertising
6. Social Networking Services
7. Links to Other Websites
8. Security
9. Children's Privacy
10. Changes to Privacy Policy
11. Access/Choice
12. Certain Other Rights
13. Data Retention
14. California Privacy Rights; California Consumer Privacy Act Notice
15. International Users
16. Contact Us

1. Information Collection

For purposes of this Privacy Notice, "personal information" refers to information that relates directly or indirectly to an identified or identifiable individual ("you"). The personal information that we collect about you varies depending on your interactions and touchpoints with us, as follows:

Information We Receive From You

We may ask you for some or all of the following types of information when you register or create an account with our Services, sign up for contests or sweepstakes, use a send-to-a-friend feature, participate in surveys, access various content or features, submit comments or content, or directly contact us with questions or feedback:

• Contact information, such as name, e-mail address, postal address, and telephone number;
• Unique identifiers, such as a user name or password;
• Demographic information, such as gender;
• Financial information, such as credit card or other payment information;
• Geolocation information;
• Communications preferences;
• Search queries;
• Comments and other information posted in our interactive online forums;
• Correspondence and other information that you send to us; and
• Additional information as otherwise described to you at the point of collection or pursuant to your consent.

If you decide not to provide this information, it may limit our ability to provide some of the above content.

Information We Collection From You Automatically

We also may collect certain information automatically when you visit the Services, including:

o  Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;

• Your device type or mobile carrier;
• Other unique identifiers, including mobile device identification numbers;
• Your browser type and operating system;
• Sites you visited before and after visiting the Services;
• Pages you view and links you click on within the Services;
• Information collected through cookies, web beacons, HTML5, scripts, ETags, local shared objects, and other technologies;
• Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded;
• Geolocation Information; and
• Standard Server Log Information.

We and our partners, affiliates, and analytics or service providers may use technologies such as cookies, pixel tags, ETags, scripts, local storage (HTML5) and similar technologies to automatically collect this information. Cookies are small bits of code that are stored by your computer's web browser and that may automatically identify your browser to the Services whenever your computer is used to visit the Services. Pixel tags are very small images or small pieces of data embedded in images, also known as "web beacons" or "clear GIFs," that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

By using the Services, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies and similar technologies, you may not be able to use certain online products, services or features on the Services.

Information We Collect from Other Sources

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:

·     Address information about you from third party sources, such as the U.S. Postal Service, to verify your address so we can properly ship your order to you and to prevent fraud; and/or

·     Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

2. Use of Information

We may use information that we collect through the Services for a variety of purposes, including to:

• Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
• Contact you via email and otherwise about your account, products, services, contests, and events that we think might be of interest to you;
• Send you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties;
• Conduct analysis on fan behavior in order to better serve you with offers and content that is of interest to you;
• With your separate consent, contact you via email and otherwise about products, services, contests, and events that we think might be of interest to you, and otherwise send you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties;
• Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
• Publish stories, comments, photos, and other information posted in our interactive online features;
• Send you push notifications from time-to-time in order to update you about any events or promotions that we may be running;
• Process employment applications and inquiries;
• Customize and personalize your use of the Services; and
• As otherwise described to you at the point of collection or pursuant to your consent.

3. Sharing of Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. At times, as described below, we may share your personal information with others for the purposes described in this Privacy Policy:

• Service Providers: We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases; perform analyses, process credit card payments, provide customer service, or send communications for us).
• Social Networking Services: We may share information with third-parties, such as social networking platforms, so that they may send tailored communications on our behalf via their platforms. These companies are authorized to use your personal information only as necessary to provide these services to us. Our site may also include social media features, such as the Facebook Like button and widgets, such as the 'Share This' button, or interactive mini programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. In some instances, such as within our mobile application and certain parts of our site, if you leave a comment within the community forum on our site, you must login to your Facebook account to do so. Your interactions with these features are governed by the privacy policy of the company providing it.
• Subsidiaries and Affiliates: We may share your information with our subsidiaries and affiliates, including but not limited to South Florida Sports Foundation, Inc. and Dolphins Cycling Challenge, Inc. In addition, we share personal information with members of the NFL family for use in accordance with their own privacy notices, including, without limitation, NFL Properties LLC, NFL International LLC, NFL Enterprises LLC, NFL Ventures, L.P., NFL Ventures, Inc., NFL Productions LLC and the NFL member clubs for analytics and marketing purposes.
• Select Business Partners: With your prior permission, we may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, you may be presented with an opportunity to have certain information shared with our third party business partners when you enter a contest or sweepstakes or elect to receive marketing offers or other information. If you do not elect to have your information shared, it will not be shared with such third parties. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.
• Contests and Sweepstakes: In some cases, a third party may operate or host a contest or sweepstakes on the Services, and collect your information. In those cases, we urge you to review the third party's privacy policy for that contest or sweepstakes before participating. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of these business partners, which may use your information for their own purposes. Please read their respective privacy policies for more information.
• Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction.
• Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of our organization, our corporate affiliates, subsidiaries, business partners, and the users of our Services; enforce our Terms of Use (available at https://www.miamidolphins.com/libraries/footer/terms-conditions); respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
• Interactive Features: We may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.
• Other Parties With Your Consent: We may share information with third parties when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.
• Aggregate Information: We may share aggregate information, such as demographic and usage statistics, with advertisers, sponsors or other organizations.
• Geolocation Information: We may share your geolocation information with service providers that perform certain functions or services on our behalf. These companies are authorized to use precise geolocation information only as necessary to provide these services to us. We also may share your geolocation information with third parties so that they may provide you with geographically relevant advertising. If you wish to stop the further collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology, please opt-out using your device settings.

4. Mobile Applications

When you download and use our mobile app, we automatically collect information on the type of device you use and operating system version. Certain features within the app, such as playing a game, may require you to log into a separate account (e.g., Ticketmaster) to use them. Your interactions with these features are governed by the privacy policy of the company providing it.

We may send you push notifications from time to time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level.

We collect your location based information for the purpose of providing relevant information (e.g., locating a place you may be searching for) and/or data, information, features and/or services that are accessible only from certain locations (e.g., game broadcasts that are available only in our home marketing area, mobile wallet, mobile ticketing, etc.). We will only share this information with services providers for the purpose of providing you with these services. We may share your geolocation data with third parties for the purpose of them serving you ads for places (such as restaurants) in your area. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at compliance@hardrockstadium.com. You may opt-out of location based services at any time by editing the setting at the device level.

We may work in conjunction with third party partners who may use technologies such as geofencing and beacons to identify fans attending a game, and contact fans via an in-app feature in order to provide services such as navigation assistance and push notifications. Any personal information collected by your use of our mobile applications will be governed by the terms of this privacy policy. To opt-out of geofencing, you may disable the app's location permissions on your device.

We use mobile analytics software to allow us to better understand the functionality of our mobile applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

5. Advertising

We partner with third party advertisers, such as Google Analytics, to serve and display advertising on the Services. These partners may use cookies or similar technologies to collect information about your activities across different website and services to provide you with relevant advertising. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note you will continue to receive generic ads.

Third-Party Ad Serving and Audience and Traffic Measurement Services: We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users' online activities over time and across different websites. To manage your preferences you may opt out here https://optout.networkadvertising.org/. The Services may feature Nielsen proprietary measurement software, which will allow users to contribute to market research, such as Nielsen TV Ratings. Nielsen believes that you should have a choice about whether to contribute to our research and insights. To opt out of Nielsen measurement, you need only to activate the "Limit Ad Tracking" (for iOS devices) or "Opt out of Ads Personalization" (for Android devices) option in your devices settings. For web, please visit: http://www.nielsen.com/digitalprivacy to learn more about the Nielsen digital measurement products and your choices in regard to them.

6. Social Networking Services

We have worked with certain third-party social media providers to offer you their social networking services through our Services. For example, you can use third-party social networking services, including but not limited to Facebook, Instagram, Twitter and others to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

You also may be able to link an account from a social networking service to an account through our Services. This may allow you to use your credentials from the other site or service to sign in to certain features on our Services. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Privacy Policy.

7. Links To Other Websites

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by us such as the "Miami Dolphins Shop" at shop.miamidolphins.com operated and maintained by a third party service provider (currently operated and maintained by Fanatics). Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

8. Security

The security and confidentiality of your personal information is very important to us. We have implemented commercially reasonable technical and organizational safeguards to appropriately protect your personal information against accidental, unauthorized, or unlawful access, use, loss, destruction or damage. The measures that we utilize are administrative, technical, and physical. Still, no system can be guaranteed to be 100% secure. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described below.

Please note that limited members of the NFL Fan Marketing and IT departments, as well as the third party vendor that processes fan data on behalf of the Miami Dolphins, Ltd. may access and otherwise process personal information in connection with their job responsibilities or contractual obligations.

9. Children's Privacy

The Services do not knowingly collect, use, or disclose personal information from children under the age of 13, except as permitted by the Children's Online Privacy Protection Act ("COPPA").  If we are made aware that we have collected personal information from a child under 13 years old in a manner that is inconsistent with COPPA, we will delete this information as soon as possible.

The website is a general audience website. However, we do collect information about children under 13 from parents so they may sign their child up for our Junior Dolphins kids program. The information we collect is the child's name, date of birth and the address provided by a parent/guardian. We use this information to allow you to sign your child up for the Junior Dolphins and for you to receive our merchandise as a part of the Junior Dolphins program, for your child. If you no longer wish to allow your child to be part of the Junior Dolphins or wish to delete all information collected about your child, please contact us at compliance@hardrockstadium.com.

We will not share your child's personal information with any third party for any reason. If you feel we have collected personal information from your child directly, please contact us at compliance@hardrockstadium.com to request immediate deletion of that information.

10. Changes To This Privacy Policy

We may amend this Privacy Policy at any time. Your continued use of the Services after any modification to the Privacy Policy will constitute your acceptance of the new terms. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

11. Access/Choice

Upon request, we will provide you with information about whether we hold any of your personal information. If your information changes; if you would like to change your preferences for receiving commercial emails from us; if you no longer would like us to share your information with our marketing partners; or if you no longer desire to use the Services, you may request that we update or remove certain information or settings by signing into your account and making the required changes, by emailing our Customer Support at compliance@hardrockstadium.com, or by contacting us by telephone or postal mail at the contact information listed below. We will try to respond to your request within 30 days.

You may choose to receive promotional emails, newsletters, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or "unsubscribe" link included in the commercial e-mails you receive. You may opt out of receiving push notifications by turning off push notifications at the device level. Please note that opt-out requests may take up to ten (10) business days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.

12. Certain Other Rights

You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. For purposes of this Privacy Policy, "Personal Data" shall mean any information (i.e. name, identification number, location data, etc.) that can be used to identify a person, whether through direct or indirect means. Requests should be submitted by contacting us by emailing compliance@hardrockstadium.com.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

13. Data Retention

We will retain your information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our website and receipt of our Services.

14. Your California Privacy Rights; California Consumer Privacy Act Notice

California Civil Code Section 1798.83 permits California residents to opt-out of the disclosure of their personal information our disclosure of personal information to third parties for their direct marketing purposes.

To make such a request, please send an email to compliance@hardrockstadium.com or write us at 347 Don Shula Drive, Miami Gardens, FL 33056, Attn: Legal Department. In some cases, third parties may be able to collect information about a user's online activities over time and across different websites when he or she uses our Services. Some web browsers may transmit "do-not-track" 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. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

This California Consumer Privacy Act Notice ("Notice") provides additional information to California residents whose personal information is processed by us pursuant to the California Consumer Privacy Act ("CCPA"). If you are not a California resident, this Notice does not apply to you.

Categories of Personal Information Collected and Disclosed

During the preceding 12 months, we have collected the following categories of personal information that are processed pursuant to the CCPA: (1) identifiers, such as your contact information and online account information; (2) Internet and electronic network activity information, such as information about your interactions with our websites, mobile applications, and social media pages; (3) audio, electronic, or visual information; (4) professional information; (5) education information; (6) inferences about you, including about your preferences; (7) financial information and other information as described above that may be considered personal information under Cal. Civ. Code Section 1798.80; (8) protected classifications under California or federal law; (9) commercial information including records or products or services purchased; (10) biometric information; and/or (11) geolocation data.

We do not, and will not without your consent, "sell" personal information for purposes of the CCPA. As set forth in this Privacy Policy, we disclose personal information to third parties for business purposes, including without limitation, for purposes of advertising, marketing, and other services performed on our behalf, to protect against fraud and malicious activity, and for other business purposes described in the Privacy Policy. During the preceding 12 months, we have disclosed each of the above-listed categories of personal information for such business purposes. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our services.

CCPA Rights

The CCPA allows California residents to request that a business that collects consumers' personal information give consumers access, upon a verifiable consumer request, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of personal information under certain circumstances, although there may be legal or other reasons that we must retain your information consistent with California law. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you. Any differences in the services are related to the value provided.

Please submit your request by sending an email to compliance@hardrockstadium.com, calling (888) 346-7287 or submitting the web tool, which is accessible via the following hyperlink: Web Tool. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

15. International Users

Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Policy.

16. Contact Us

If you have any questions about this Privacy Policy or the privacy practices of the Services, please contact us by email at compliance@hardrockstadium.com or by regular mail at:

Miami Dolphins, Ltd.

Attn: Legal Department

347 Don Shula Drive

Miami Gardens, FL 33056