ONEIDA INDIAN NATION ATHLETIC COMMISSION PRIVACY POLICY

(Revised December 21, 2022)

The Oneida Indian Nation and Oneida Indian Nation Athletic Commission (referred to in this Privacy Policy as “OINAC,” “us,” “we,” and/or “our”) may collect certain information from or about you in connection with your use of the OINAC Website. We are providing this Privacy Policy to explain our practices and policies for collecting, using and sharing information collected from or about you when you visit, access, or use, or provide information to us in connection with the OINAC Website. By visiting, accessing, or using, or providing information to us in connection with, the OINAC Website, you expressly consent to our collection, storage, use and sharing of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with the OINAC Website.

This Privacy Policy does not create a contractual obligation between you and OINAC, and it is subject to our Terms of Use located at https://portal.oinac.com/terms-of-use. If you have questions about this Privacy Policy, please contact us at oinac@oneidagc.com.

1. DEFINED TERMS
As used in this Privacy Policy:

(a) “OINAC Websites” refers to websites owned or operated by the Oneida Indian Nation or OINAC that display this Privacy Policy, including, but not limited to, oinac.com,

(b) “Personal information” refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, social security number, driver license number, passport number, license plate number, geolocation information, date of birth, , biometric information, medical records, medical information, and other similar information.

(c) “Non-personal information” refers to information by which you cannot be personally identified.

2. INFORMATION WE MAY COLLECT.
We collect and use information we believe is necessary to regulate, administer and oversee the conduct of professional and amateur athletic events held on Oneida Indian Nation lands, including professional amateur boxing, mixed martial arts and wrestling for the purpose of promoting the health, safety and welfare of all person engaged in such activities and that of members of the Oneida Indian Nation and its guests. We may collect and maintain both personal information and non-personal information needed for these purposes. Your personal information and/or non-personal information will be referred as your “information” in this Privacy Policy.

As part of our obligation to regulate athletic events at the Oneida Indian Nation, we may collect certain Personal information, medical records, and medical information. Any medical records or medical information collected will be collected by Oneida Indian Nation or OINAC employees, will be kept confidential and will not be disclosed in any way that identifies you unless we are otherwise required to disclose the medical information based upon applicable law. While we understand the sensitive nature of this Personal information and medical information, refusal to provide such information may result in our denial of licenses or approvals for you to participate in any athletic event and/or other restrictions being placed upon you.

3. HOW WE COLLECT YOUR INFORMATION.
(a) Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through OINAC Website, in connection with licensing and weigh-in, are videotaped or photographed in connection with a security incident or for other surveillance purposes, sign up to receive email or text messages from us, sign up to access Wi-Fi at an Oneida Indian Nation, park at an Oneida Indian Nation Property, request information from us, or scan your ID.

(b) Information Automatically Collected Through the ONE Websites.

(i) Traffic Data. We automatically track and collect general log information when you visit the OINAC Website, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on the OINAC Website (collectively “Traffic Data“). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on the OINAC Website. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of the OINAC Website. It enables us:

  • to estimate our audience size and usage pattern;
  • to learn what information is of most and least interest;
  • to speed up your searches; and
  • to learn of any possible OINAC Website performance problems.

We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs.

(ii) Data Collected Using Cookies and Other Technologies. We also automatically collect information from you using cookies and other technologies on the OINAC Website. We may use cookies and similar technologies to identify who you are and may use them when you visit the OINAC Website, or open our emails. Cookies also enable us to remember your user preferences for the OINAC Website. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, and protecting against fraud and theft. You can block or remove cookies using your Internet browser’s settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on the OINAC Website may be affected.

(iii) Information Collected by Third Parties through Third Party Links and Content. The OINAC Website may include links to other websites and other content from third party businesses. These third party businesses may use cookies, web beacons or other similar technology to collect information about you. OINAC does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third party website. You are encouraged to review the privacy policies of the different websites you visit.

(iv) Information Collected by Third Party Analytics Services. We may work with third party analytics services to help us understand how the OINAC Website is being used, such as tracking the frequency and duration of use of the OINAC Website. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting the OINAC Website, and your system information and geographic information. The information generated by these technologies about your use of the OINAC Website will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the OINAC Website.

(v) Information You Share on Third Party Websites or through Social Media. The OINAC Website may include links to third party websites and social media where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media may result in the collection or sharing of information about you by these third party websites and social media. We encourage you to review the privacy policies and settings on the third party websites and social media with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media. We may also monitor sentiments regarding OINAC that you publicly post on social media. We may reach out to you regarding these postings to address issues.

(vi) Information You Post on the OINAC Websites. If you post information on any public areas of the OINAC Website, that information may be collected and used by OINAC, other users of the OINAC Website, and the public generally.

(c) Information Obtained from Other Sources, including from Service Providers, and Third Party Services. We may obtain information about you from other sources, including service providers, third party services, publicly available sources, or government agencies, and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

(d) Information We Automatically Collect When You Use Our Wi-Fi Services. If you use Wi-Fi services that we make available at any Oneida Indian Nation Property, we might collect information about your use of our Wi-Fi services, including your IP address, Wi-Fi information (such as SSID), mobile carrier, the websites you visit, the type of device and browser you are using, your device identification number, bandwidth used and session time

(e) Information We Automatically Collect from Mobile Devices on Oneida Indian Nation Properties. If you have a mobile device, are located on an Oneida Indian Nation Property and have your Wi-Fi or Bluetooth functionality enabled, we may collect information concerning your mobile device, including the type of device, device ID, and the precise physical location of your device within and around the Properties (including geolocation and beacon-based location), for analytics and non-marketing related purposes, including general traffic patterns. If you do not want information concerning your precise location to be collected on Oneida Indian Nation Properties, you may adjust your mobile device location sharing settings and disable the Wi-Fi and Bluetooth functionality in your mobile device settings.

4. HOW WE MAY USE YOUR INFORMATION.
We will use the information you provide to us for the specific purposes for which you provided the information, as stated at the time of collection, and as otherwise described in the Privacy Policy or permitted by law. The following are some other ways in which we may use your information;

  • to evaluate and issue requested licenses or permits;
  • to issue credentials;
  • to improve the services we provide you;
  • to improve the OINAC Website;
  • to track your use of the OINAC Website for our internal market research and analytics;
  • to contact you in response to your inquiries, comments and suggestions;
  • to provide a healthy, secure, and safe environment for participants, regulators and employees;
  • to protect and defend our rights or property or enforce our agreements with you;
  • to perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks or any inquiries into your personal or medical history:
  • comply with our internal records management policy and retention rules;
  • to contact you otherwise when necessary; and
  • otherwise with your consent or as permitted or required by applicable law.

5. HOW WE SHARE YOUR INFORMATION WITH OUR AFFILIATES.

We may share certain information we receive from you, with our affiliates, including our casinos, hotels, convenience stores, marinas, online and web based businesses, and other instrumentalities, corporate entities or affiliates.

6. HOW WE SHARE YOUR INFORMATION WITH NON-AFFILIATED THIRD PARTIES.
As permitted by law, we may share the information we collect from and about you with non-affiliated third parties as follows:

(a) Third Party Service Providers. Your information may be shared with or collected by third party service providers who provide us with services, including but not limited to data hosting or processing, credit card processing, medical or background checks. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.

(b) Response to Lawful Requests for Information or Court Orders or to Protect Rights and to Comply with Our Policies and Applicable Law. To the extent permitted by law, we will disclose your information to government authorities or third parties: (i) if required to do so by applicable law, or in response to request for information that would otherwise be the subject of a lawful subpoena or court order if not for the Oneida Indian Nation’s sovereign immunity, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities having authority or jurisdiction, including but not limited to gaming regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, (iv) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or (v) we believe that you have abused a OINAC Website by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

7. TRACKING.
Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on the ONE Websites in response to any “do not track” requests that we receive from your browser.

8. SECURITY.
We maintain physical, electronic and organizational safeguards that reasonably and appropriately protect against the loss, misuse and alteration of the information under our control. With regard to information that you transfer to us through the OINAC Website, please be aware that no data transmission over the Internet or a wireless network can be guaranteed to be 100% secure. As a result, OINAC cannot guarantee or warrant the security of any information you transmit on or through the OINAC Website and you do so at your own risk.

9. CHANGES TO OUR PRIVACY POLICY.
Over time, it may be necessary to modify or supplement our Privacy Policy. When we make changes, we will post the changes to the OINAC Website and change the effective date at the top of the Privacy Policy. We encourage you to visit the OINAC Website from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of the OINAC Website following the posting of changes to the Privacy Policy means that you accept the changes and our use of your personal information in accordance with the revised Privacy Policy. If you have provided us with your email address, we will also notify you of material changes to this Privacy Policy by sending an email at least thirty (30) days before the effective date of the changes to the email address you most recently provided to us. We encourage you to keep the email address you provide to us current, and to promptly notify us of any changes to your email address, so that you may receive any notices we send to you regarding material changes to this Privacy Policy. If you do not agree to the changes, you should discontinue your use of the OINAC Website prior to the time the modified Privacy Policy takes effect.

10. VIDEO SURVEILLANCE AND FACIAL RECOGNITION TECHNOLOGIES.
We use surveillance systems to monitor all gaming areas and other public or sensitive areas of the Oneida Indian Nation properties. Video surveillance cameras may be used for security and health purposes and to protect us, our customers and employees against potential violations of criminal or civil laws as well as threats to our guests’, customers’ and employees’ health. Some video surveillance systems may incorporate facial recognition technologies that can be used, in the discretion of our employees, for additional surveillance and screening of individuals at Oneida Indian Nation properties. In addition, cameras and facial recognition technologies may also be used at Oneida Indian Nation properties to enhance your customer experience and provide services to you. Surveillance camera output is monitored by our employees and may be viewed by law enforcement and regulatory authorities.

11. NON-U.S. RESIDENTS.
Unless otherwise specified, the OINAC Website and material provided on or through the OINAC Website are solely intended for users located in the United States and for promoting products, programs, and business operations within the United States. If you do not reside in the United States and you choose to access or use the OINAC Website and provide your personal information to us, it may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should not use the OINAC Website.

12. CONTACT INFORMATION.
Should you have additional questions, comments or concerns regarding this Privacy Policy or how we collect and use your information, you may send an email or contact us by writing to:


Oneida Indian Nation Athletic Commission
5218 Patrick Road
Verona, NY 134785

oinac@oneidagc.com

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