Colorado Buffaloes Buffs Premier

Buffs Premier

Privacy Policy

Last Updated: July 15, 2025 This privacy policy (“Privacy Policy”) describes the data privacy practices of Two Circles (including current and future affiliates and subsidiaries, “Two Circles”, “we”, “our”, or “us”) with respect to: (i) our providing services to you in relation to the Buffs Premier Fan Loyalty Program (the “Program”); (ii) any person accessing (“you” or “your”) our website in connection to the Buffs Premier Fan Loyalty Program (https://buffspremier.cubuffs.com) and/or any related mobile Site, applications, or features; and/or (iii) any other personal information collected when you call, email, or otherwise interact with Two Circles (collectively, the “Site”). We are committed to protecting the privacy of those who entrust us with their Personal Information. By becoming a member of the Program, visiting the Site or otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time. If you do not agree to the policy, please do not use the Site and your continued use of our Site and/or membership in the Buffs Premier Fan Loyalty Program shall be deemed to be acceptance of those changes. As stated in the Buffs Premier Terms and Conditions (https://buffspremier.cubuffs.com/terms-and-conditions), all account information and personal information of participants that is collected, used, disclosed or otherwise processed during any program related activity is subject to this Privacy Policy.

Information Collection Overview

Data Collected We may collect any information, such as your first and last name, email address, mailing address, and telephone number that you provide when you interact with us. Some examples are when you:

Sign up to become a member of the Program;
Sign up to receive email communications from us;
Register or create an account on the Site;
Correspond or communicate with us by phone, e-mail or otherwise;
Use our Site to interact with us; or
Use social media to interact with us, or to share something from our Site with others, we will receive information about what you share and other details that may be based on your social media privacy settings.

We also collect statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific features of the Site and/or Program. Each time you visit the Site, we may automatically collect certain types of information. Some examples of automatic information we may collect are as follows:

Your IP address, MAC address, browser type, operating system, device-identifying information, type of computer, and type of Web browser software, the specific webpages visited during your connection, and the domain name from which you accessed the Site.
Information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data.
We may use “cookies” of different types to recognize your computer. A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Site or other sites.

We may use web beacons, match scripts, pixel tags, clear GIFs or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, or links in the email utilized. In some instances, these technologies may allow us to match activities with particular users. We may combine the information we collect through cookies, web beacons, or other technology tools with other information we have collected from you or information from other sources. Use of Personal Data Collected We use information about you for purposes described in this privacy policy or disclosed to you on the Site. For example, we may use information about you:

For providing services to you as a member of the Program;
For editorial and feedback purposes;
For marketing and promotional purposes;
To develop new programs and outreach opportunities;
For content improvement and research;
To customize the content and layout of the Site;
To notify you about updates to the Site;
To Respond to your inquiries; or
To take other actions in response to your inquiries or other website activities.

We also may aggregate personal information use such information to analyze the effectiveness of our Services, improve our Services, conduct research and for other related purposes. Two Circles will only use Personal Information in accordance with this privacy policy. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in this Privacy Policy. In all cases, any service providers will be contractually limited in the way they may use Personal Information maintained by Two Circles, including requirements that such information be maintained in a confidential and secure manner in accordance with applicable laws.

In Connection with Buffs Premier Fan Loyalty Program: Two Circles may disclose Personal Information collected in the usual course of business from users of the Site and members of the Buffs Premier Fan Loyalty Program to University of Colorado Athletics. In Connection with Business Transfers: In the event that a division, a product or all of Two Circles is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law. To Comply with Laws: Two Circles may also disclose specific Personal Information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, employees or others, in accordance with or as authorized by law. We may also disclose Personal Information that we collect or you provided as described in this privacy policy:

To our subsidiaries and affiliates; and
To contractors, service providers, and other third parties we use to support our organization in connection with the Program and/or the Site.

2. Cookies

Like many websites, we analyze how visitors use our Site through what is known as “cookie” or similar tracking technology. A cookie is a small text file that is placed on your computer when you access the Site and allows us to recognize you each time you visit the Site. We may use cookies to: (1) allow you to use the Site without having to re-enter your user name and password; (2) enhance or personalize your Site usage; (3) monitor the Site usage; (4) manage the Site; and (5) improve the Site and our products and Site, including providing you with interest-based ads. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness. We may also use web beacons or pixels on the Site, in our emails, and in our advertisements on other website. These are tiny graphic images that are used to collect information about your visit to the Site, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to the Site. These tools help us analyze our Site visitors’ behavior and measure the effectiveness of the Site and our advertising. We may work with service providers that help us track, collect and analyze this information. Two Circles may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ Site or apps” located at www.google.com/policies/privacy/partners. We may combine the information we collect through cookies and web beacons with other information we have collected from you or information from other sources.

3. Retention of Personal Information

Personal Information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Two Circles or as required or authorized by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.

4. Opt-Out of Communications

At any time while accessing our Site, any user while online may decline participation in any activity that asks for information (e.g., survey email). Your choice not to participate will in no way affect your ability to use any other feature on the Site. If you do not wish to receive communications from us, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the Program and/or Site we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications.

5. Security

Two Circles has implemented a number of security features throughout the Site and our organization to prevent the unauthorized release of or access to Personal Information. For example, database information is kept separate from live servers and is firewall protected. Please be advised, however, that although Two Circles has endeavored to create a secure and reliable Site for you, the confidentiality of any communication or material transmitted to or from Two Circles via the Site or e-mail cannot be guaranteed. When disclosing any Personal Information, you should remain mindful of the fact that it is potentially accessible to the public and consequently, may be collected and used by others without your consent. Two Circles has no responsibility or liability for the security of information transmitted via the Internet.

6. Third Party Websites

The Site may contain links to third-party websites, including to University of Colorado Athletics as well as social media sites like LinkedIn, Facebook, X, Instagram, TikTok and others which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any Personal Information. Please contact those websites directly if you have any questions about their privacy policies.

7. Children

The Site is not directed to children, nor do we knowingly collect any Personal Information from children under the age of 18 years old online without verifiable parental consent. Persons under 18 years old are not eligible to be members of the Buffs Premier Fan Loyalty Program. If you believe that a child has provided Personal Information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

8. Your Privacy Rights

The law in many jurisdictions provides you with the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected, used, disclosed, and sold about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information Two Circles has collected about you.
The right to obtain a copy of Personal Information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
The right to correct inaccurate Personal Information about you, taking into account the nature of the Personal Information and the purposes of the processing.
The right to request that we delete any Personal Information we have about you.
If we deny your request, the right to appeal our decision. If you are not satisfied with our response, you can contact the applicable privacy regulator, see Right to Lodge Complaints.

In addition, and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have shared with third parties for their own direct advertising purposes. We have not engaged in this activity, but please contact us if you have any questions. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any Personal Information about our users. We do not use or disclose sensitive Personal Information, as defined in applicable laws, for any purposes other than those stated herein and permitted by applicable law. Submitting Requests If you are a resident of the relevant jurisdictions, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Information we have collected about you by contacting us at via the contact specified at https://help.buffspremier.com/ or via email at dpo@twocircles.com. We will respond to your request in compliance with the requirements of your state’s applicable laws. Verification of Your Identity When you exercise these rights and submit a request to us, we will need to verify your identity and may ask for your email address or other information needed for verification. We may also use a third-party verification provider to verify your identity. We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under applicable privacy law. Appeal You have the right to appeal a decision we have made regarding their requests by contacting us via the contact specified at https://help.buffspremier.com/ or via email at dpo@twocircles.com. Non-Discrimination If you make a request under your state privacy law, we will not discriminate against you in any way. For example, we will not deny you discounts or other benefits or impose penalties on you, or provide you with or suggest that you will receive a different level or quality of benefits or services.

Authorized Agents You may permit an authorized agent to submit a request to know or to delete your Personal Information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Information. Automated Decision-Making We generally do not use automated decision-making technology, as that term is defined by applicable privacy laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

9. Visitors from Outside the United States—Cross-Border Transfer

The Site is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing Personal Information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

10. Right to Lodge Complaints

We are transparent about the ways in which we collect and use Personal Information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your Personal Information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

11. Changes to This Privacy Policy

We may change this Privacy Policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will let you know by appropriate means such as by posting the revised statement on this page with a new “Last Updated” date. Changes to this Privacy Policy will become effective when posted, unless indicated otherwise.

12. How to Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our users or to request a copy of this Privacy Notice in another format, you can contact us via the contact specified at https://help.buffspremier.com/ or via email at dpo@twocircles.com.. If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.

Buffs Premier Loyalty Program Privacy Policy