1. INTRODUCTION

This Privacy Policy provides notice of our practices related to personal information collected, used, and disclosed by Detroit Red Wings, Inc. (“DRW,” “us,” “our,” or “we”), including personal information collected through nhl.com/redwings (the “Website”), our mobile application (the “App”) (the Website and Apps together are “Services”). 

Please note that the Website is maintained and facilitated by the National Hockey League (“NHL”). As such, while we collect personal information through the Website as described in this Privacy Policy, the NHL may also collect personal information through the Website and control certain portions, features, or technologies of the Website, including the use of cookies and similar technologies. Please refer to the NHL’s official websites and policies, such as the NHL’s privacy policy, for more information on the NHL’s collection and use of personal information, use of cookies and similar technologies, and privacy practices in relation to this Website.

We may provide you additional privacy notices at the point of collection of your personal information, which supplement this Privacy Policy. This Privacy Policy does not apply to other online services that we control and maintain, but do not link to this Privacy Policy.

We may change this Privacy Policy from time to time as indicated by the “Last Updated” date. If we make material changes, we may provide notice of such changes, subject to applicable law.

2. PERSONAL INFORMATION COLLECTED

We may collect personal information directly from you (such as when you register an online account, request customer service, or make a purchase), from our vendors and service providers, the NHL, joint marketing partners, affiliates and other entities within our corporate structure, and other business partners. The personal information we collect about you may vary depending on the nature of your interactions with us. 

You may provide us personal information of others; in which case you represent to us that you have the or obtained authorization from those individuals to provide us such personal information.

Below are the categories of personal information we collect:

• Identifiers and Personal Records. This includes first and last name, mailing address, phone number, email address, mobile phone number, or other similar identifiers.
  • For job applicants, this may include Social Security number, driver’s license, state identification card, or passport numbers.
• Account Credentials. This includes username and password.
• Payment Information. This includes payment information necessary to process a transaction, including billing and shipping address.
• Demographics Information. This includes military or veteran status and disability status such as for submissions for in-game accommodations or experiences.
  • For job applicants, this may also include demographic information you selfidentify and date of birth.
• Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with the Services.
• Geolocation Data. This includes approximate location, which may be based on your ZIP code or IP address.
  • This may include precise geolocation, such as where you enable permissions for our Apps.
• Audio, electronic, visual, or similar information. This includes audio recordings of customer service calls.
  • For job applicants, this may include portrait headshot, submitted video bios, and recordings of video interviews.
• Professional or Employment-Related Information. This includes your job title, employer, and other professional background information.
  • For job applicants, this may include: background information commonly used for onboarding and security screenings, criminal records information including results of background checks obtained through government agencies; citizenship, immigration, visa status, and work authorization information; and talent information (employment background, languages spoken, functional experience, leadership experience, honors or awards, education, training, professional certifications, evaluations, and career interests).
• Commercial Information. This includes products or services purchased (such as jersey size or number of tickets), or interests (such as favorite team or favorite player) and purchase history.
• External Service Information. We may obtain information about you from other parties (including those that do not process your personal information solely on our behalf), such as if you choose to use a feature integrated into our Services offered by an external party. For example, ticketing vendors may provide us information when you buy tickets, parking vendors may provide us information related to your vehicle, calendar scheduling vendors may provide us information on what events you are interested in, or co-marketing partners may provide us information you submit to them as part of a co-marketing promotion. The information that we receive from these external parties depends on your interaction with them, and is subject to their privacy policies, which we do not control.
• Inferences. We may draw inferences from the personal information described above to create a profile about you reflecting your preferences and interests.

3. APP PERMISSIONS

Certain features of the App may require access to certain information from your device. Depending on the App and your App permissions or device settings, the App may have access to various device features. For example, this includes access to your photos, media, files, and storage (i.e., allows the App to access the contents of files on your device), access to stored payment information (i.e., allows the App to access your stored credit cards on a wallet app), access to your calendar (i.e., allows the App to read calendar events, add or modify calendar events, send email to others about calendar events), or camera and microphone (i.e., allows the App to take pictures and videos). Refer to the App’s description on the app store from which you downloaded the App and your App or device settings for more information.

If you do not consent to our collection of App permissions then this may impact on our ability to provide products, services, or features to you and the functionality of the App.

4. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

We or our vendors may use personal information for the following reasons:

• Provide Services You Request, including when you apply for a job; operating and maintaining our online and offline goods and services; giving you information about our Services; processing your payments and orders, including donations made either to the Detroit Red Wings Foundation (such as for Autographs for a Cause) or a co-branded service (including for in-game experiences, such as intermission messages); communicating with you about our Services; providing inArena or in-game experiences, such as intermission messages and the Military Salute to Service; and responding to your requests and questions.
• Security and Integrity, including protecting our Services from cyber risks; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other liabilities; enforcing our policies and terms; protecting our rights; and generally providing you with a secure experience when using our Services.
• For job applicants, this may include conducting a background check. 
• Quality, Safety, and Internal Research, including evaluating how our Services perform; repairing or improving the quality of our Services; tracking and responding to quality and security issues; and developing new or enhanced products and service offerings.
• Advertising and Marketing, including providing personalized advertisements on and off our Services; sending you electronic and other marketing messages based on your preferences and interests; measuring the use of our Services and effectiveness of our advertising and marketing; uncovering insights to improve our Services and provide our users with enhanced features and functionalities, such as personalized experiences; and administer your participation in our contests, sweepstakes, or other promotions.

The personal information we collect about you may be disclosed to, and used by, our subsidiaries. We also disclose personal information to our vendors, including those who collect, manage, and analyze our customer information and perform services for us, such as sending promotional communications and improving the performance of our Services. 

We may also disclose personal information for the following purposes:

• Co-Branded Services. From time to time, we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features for our Services. These arrangements may include business partners, sponsors and co-branded online services (referred to here as “co-branded services”). Any information, including personal information, that you provide on one of these co-branded services may be shared with these partners. By participating in activities or providing your information on these co-branded services, you direct us to provide your information to those partners. Separate privacy policies may apply to these partners’ uses of your personal information. Some of our Services are co-branded with the NHL. To the extent that you see the NHL logo or references to the NHL while using our Services, then please note that we may disclose such personal information to the NHL, respectively.
• Business Transactions. In the event of a business transaction, we may disclose personal information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transactions involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
• Legal Compliance. We may also disclose personal information for legal compliance, and law enforcement or public safety purposes. For example, to law enforcement, government or regulatory bodies, or other authorized parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of other parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

We may combine your personal information with data we obtain from our Services, other users, or third parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law.

We may also share ticketing and other information about you with our partners at the NHL so that we and the NHL may customize and improve services, advertising, and communications based on a better understanding of you and your engagement across the League. For more information on how the NHL may use this information, refer to the NHL’s privacy policy.

5. OTHER ONLINE SERVICES

Our Services may contain links to, or features facilitated by, other online services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature to assist you with ticket purchases and for other customer service purposes. When you participate in the interactive chat with the virtual agent, the contents of the chat may be captured and kept as a transcript. Certain interactive features may allow you to share content to your social media profile.

This Privacy Policy does not apply to the practices of companies that we do not own or control. We provide these external links and interactive features for your convenience, and we have no control over, do not review, and are not responsible for external online services. When visiting another online service or submitting information through an interactive feature provided by a vendor, you are subject to that online service’s terms of use and privacy policy. You should review those privacy policies to understand how these parties may use or disclose your personal information.

6. YOUR CHOICES

You may update certain personal information by logging into your Red Wings account and accessing the Account Information tab.

If you prefer to no longer receive any marketing emails from us, you may opt out by clicking the “Unsubscribe” link at the bottom of any of our emails. Note that regardless of your email marketing preferences, we may still send you emails for administrative reasons, including transactional emails about your account or any services or products you have requested or received from us.

7. DATA RETENTION

We keep personal information for as long as is necessary for the purposes described in this Privacy Policy. This generally means holding the information for as long as one of the following apply: 

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information.
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected.
• We are otherwise required or permitted to keep your personal information by applicable laws or regulations.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.

8. DATA SECURITY

We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through the portions of our Services that we control and maintain. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the Services.

9. CALIFORNIA PRIVACY RIGHTS

California residents may have certain rights related to the personal information that we have collected about you. We will comply with your request as soon as reasonably practicable, subject to legal requirements. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. 

To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person that is the subject of the request. Following verification of your identity, we will process your request; if we are unable to fulfill your request, we will let you know why.

You may exercise your rights to your personal information by submitting your requests via calling 1-800-982-7111, or by email to [email protected].

We will not discriminate against you for choosing to exercise any of your privacy rights.

Right to Know: You have the right to know about your personal information. You also have the right to obtain a transportable copy of your personal information.  

Your right to know request may encapsulate the following: 

• The categories of personal information we have collected about you
• The categories of sources from which the personal information was collected.
• Our business or commercial purposes for collecting, selling, or sharing your personal information.
• The categories of third parties to which we disclosed your personal information.
• The categories of personal information we sold or shared about you and the categories of third parties to which each category of personal information was sold or shared.
• The categories of personal information we disclosed about you for a business purpose and the categories of persons to which it was disclosed.
• The specific pieces of personal information we have collected about you.

Right to Correct Personal Information: You may request that we correct personal information that we maintain about you if you believe such personal information is inaccurate. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct. 

Right to Request Deletion of Personal Information: You may request that we delete your personal information. Please note that we may retain certain personal information as permitted by applicable law. 

Right to Opt Out of Sale and Sharing of Personal Information: As described in Section 1 titled “Introduction,” the NHL controls certain portions, features, or technologies of the Website, including the use of cookies and similar technologies. For more information on whether the NHL’s use of these technologies includes the sale or sharing for crosscontext behavioral advertising, as well as for how to opt out of such technologies and uses, refer to the NHL’s privacy policy and NHL’s Cookie Policy. The NHL may enable cookie setting features on the Website that allows you to change your preferences in relation to cookies and similar technologies. Otherwise, you may request to opt out of the sale and sharing for cross-context behavioral advertising by contacting DRW as per the instructions at the top of this Section 9. 

Authorized Agents: You may have the right to designate an authorized agent to make privacy rights requests on your behalf. We will subject privacy rights requests we receive from agents to our verification process, which includes verifying the identity of the agent and their authorization to make the request.

California’s Shine the Light Law: California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to other parties, including affiliates, for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those other parties. California residents may make one such request per calendar year. To make a Shine the Light request, you may contact us by email or postal mail using the information provided in the “Contact Us” section. In your request, please state that you are a California resident and provide a current California mailing address for our response.

10. ADDITIONAL INFORMATION FOR THOSE LOCATED OUTSIDE THE UNITED STATES

If you are located outside the United States, you acknowledge that your personal information will be processed in the United States or in other jurisdictions, which may have data protection laws and regulations that are different from the laws in your country of residence.

11. CONTACT US

You may contact us by emailing [email protected]