House v. NCAA Settlement: What it means for you

PRIVACY POLICY

Effective Date: June 9, 2025


IMG Academy Parent, LLC and its affiliates and subsidiaries (collectively, “IMG Academy,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access this website and our mobile applications (collectively, “Site”) and any of our online and, where required, offline services (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage with a new “last updated” date. If we make material changes, we may provide you with additional notice, such as adding a statement on the homepage of our Site or distributing a notification. We encourage you to review this Privacy Policy periodically.

This Privacy Policy covers the following topics:

  1. Personal Data We Collect
  2. How We Use Your Personal Data
  3. How We Share Your Personal Data
  4. Universal Opt-Out Mechanisms
  5. Security
  6. Data Retention
  7. Third Party Links
  8. Children’s Privacy
  9. Your State Privacy Rights and Additional Disclosures
  10. Notice to California Residents
  11. Your Personal Data and Your Rights – Europe and the United Kingdom Only
  12. Your Choices and Rights – Canada and Rest of the World
  13. Accessibility
  14. How to Contact Us

1. Personal Data We Collect

We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual.

Depending on how you interact with our Site and Services, we may collect the following personal data that you voluntarily provide us for the following purposes:

  • If you purchase our products or Services. Depending on the product you choose to engage with, you will provide us with the first and last name, email address, phone number, and postal address of the student-athlete, parent or guardian, or coach, as well as the date of birth. Further, if you choose to create an account using our Services, you may also provide additional information such as height, weight, video footage, social media handles, references, a personal statement, and scholastic information. To pay for the products or Services, you will provide us with payment information. We use third parties to process payment information and those third parties will collect, record, and store your payment information.
  • If you inquire about our products or Services. If you request a consultation, assessment, or schedule a campus visit, you will provide us with the student-athlete’s first and last name, email address, phone number, gender, postal address, date of birth, and academic information. You will also provide us with a parent or guardian’s first and last name, email address, phone number, postal address, and relationship to the candidate.
  • If you apply to or enroll in our Services. Depending on the Service(s) you enroll in, you may provide us with the first and last name, email address, phone number, postal address, date of birth, academic information, country of birth, country of residency, race, citizenship information, including a copy of a passport or birth certificate, and native language of the student-athlete. You may also provide us with financial information, certain medical information, and government-issued identification numbers such as your Social Security number, driver’s license number, or passport number. You will also provide us with certain parent or guardian information, including first and last name, email address, phone number, date of birth, postal address, relationship to applicant, and you may provide us with employment, education, familial status, and custodial information. When you enroll in our Services and create an account, you will have the option to make your account public through our Site to other members and coaches. You may also choose to message with other members through our Site.
  • If you seek customer support. If you engage our support Services, you may provide information including your first and last name, email address, phone number, device information, and any additional information you choose to provide.
  • If you apply for a position with one of our companies. Depending on the position you apply for, you will provide us with your first and last name, email address, phone number, postal address, work experience, scholastic information, social media URLs, government-issued identification numbers such as your Social Security number, driver’s license number, or passport number and reference information, including first and last name, position, email address, and phone number.
  • If you utilize our equipment or facilities. If you choose to access or utilize our grounds, training equipment, or other facilities we may collect your first and last name, email address, phone number, date of birth, and information related to your activities and performance, including video footage or photographs, usage information, and performance metrics such as speed, accuracy, and additional measurements.

Personal Data as You Navigate Our Site

We automatically collect certain personal data through your use of our Site and our use of cookies and other tracking technologies, such as the following:

  • Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
  • Device Information. For example, hardware model, operating system, application version number, and browser.
  • Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
  • Location Information. Location information from Site visitors on a city-regional basis.

To learn more about how we use cookies and to manage your cookie settings, please see our Cookie Policy.

Personal Data We Collect About You from Other Sources

In some cases, we may receive personal data about you from other sources. This includes from customer support service providers, fraud and cybersecurity companies, event registration companies and venue providers, event partners and sponsors, medical services providers, marketing, media and digital content partners, performance technology platforms, ticketing providers, promotions companies, reservation booking platforms, advertising networks, internet service providers, data analytics providers, payment providers and processing companies, e-commerce platforms, academic institutions, sports/athletics leagues and event operators, colleges and universities, conferences, and governing bodies, recruiting service providers, lead generation partners, government entities, operating systems and platforms, social networks, certified testing centers, data brokers, and affiliates.

2. How We Use Your Personal Data

In addition to the purposes stated above, we may use all the personal data we collect in accordance with applicable law such as to:

  • Maintain, improve, and protect the security and integrity of our Site and Services
  • Market our products or services that we think may interest you;
  • Provide measurement, analytics, and other business services;
  • Provide our products and Services;
  • Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Service and to otherwise fulfill our legal obligations;
  • Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
  • Defend our legal rights and the rights of others and comply with applicable law;
  • Fulfill any other purposes for which you provide it;
  • For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data, as disclosed to you.

3. How We Share Your Personal Data

We may share the personal data that we collect about you in the following ways:

  • Affiliates and subsidiaries. For purposes consistent with this Privacy Policy, including to provide Services to you, enhance our offerings, conduct analytics, manage business operations, and offer you products and services that may be of interest to you. Our affiliates and subsidiaries are required to handle your personal information in a manner consistent with our privacy commitments;
  • Technology and infrastructure vendors. To perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
  • Customer service and communications partners. To assist with user inquiries and support;
  • Analytics providers. To help us understand how users interact with our Site and Services;
  • Advertising and marketing partners. To assist us to prepare, deploy, and analyze advertising content;
  • Payment processors. To process payment information and provide fraud prevention, credit risk reduction, and other financial related services;
  • Performance analysis providers. To measure and track performance;
  • Law enforcement or to meet our legal obligations, including:
    • To the extent that we are required to do so by law or in connection with any legal proceedings;
    • To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
    • With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
  • Business Transfers. With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events and such person or entity may use your personal data for their own purposes;
  • With your consent. With any other person or entity where you consent to the disclosure;
  • For the disclosed purpose. For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

For more information on how we sell personal data with third parties, see our “YOUR STATE PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES” section below.

4. Universal Opt-Out Mechanisms

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

5. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control when operated by third parties. We accept no responsibility or liability for third party websites.

8. Children’s Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.

9. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. For example, California, Colorado, Connecticut, Delaware, Oregon, and other states have passed state-specific privacy laws. If you are a California resident, please see our “NOTICE TO CALIFORNIA RESIDENTS” section below. For other state residents, your privacy rights may include (if applicable):

  • The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
  • The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
  • The right to obtain a list of specific third parties, to which we have disclosed personal data;
  • The right to obtain a list of categories of third parties to which we have disclosed your personal data;
  • The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
  • The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
  • The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • If your personal data is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you, you have the right to question the result of the profiling, to be informed of the reason that the profiling resulted in the decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision (and the actions that you might take to secure a different decision in the future). If applicable, you also have the right to review the personal data used in the profiling and, if the decision is determined to have been based upon inaccurate personal data, the right to have the data corrected and the profiling decision reevaluated based upon the corrected data;
  • If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
  • The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we may sell personal data (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us at 1-866-996-6272. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting an opt-out request on behalf of another individual, please use the same contact methods described above. We will process authorized agent requests in accordance with applicable law. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 1-866-996-6272. If you would like to opt out of targeted advertising, you may alter your cookie preferences here.

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”

Notice at Collection of Personal Information

We may currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information

  • Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number)
  • Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
  • Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, medical information, or health insurance information as well as the categories listed in “Identifiers” category above)
  • Characteristics of protected classifications under California or federal law (race, color, sex/gender, age (40 and older), religion (including religious dress and grooming practices), national origin, disability (mental and physical), citizenship status, genetic information, medical condition (genetic characteristics, cancer or a record or history of cancer), military or veteran status)
  • Commercial information (products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies)
  • Biometric information (imagery of iris, imagery of retina, fingerprint, imagery of face, imagery of hand, imagery of palm, vein patterns, voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information)
  • Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information (including employment history)
  • Education information
  • Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We collect Personal Information directly from California residents and from the sources listed in the “Personal Data We Collect About You from Other Sources” section above. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “HOW WE USE YOUR PERSONAL DATA” we may currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Debugging to identify and repair errors that impair existing intended functionality
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
  • Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Category of Personal Information Categories of Third Parties
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) Advertising and marketing partners; business partners; third-party platforms or integrations
Identifiers (name, email address, alias, postal address, online identifier) Advertising and marketing partners; analytics providers; business partners; third-party platforms or integrations
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number) Advertising and marketing partners; analytics providers; business partners; third-party platforms or integrations
Characteristics of protected classifications under California or federal law (race, age, sex/gender) Advertising and marketing partners; analytics providers; business partners; third-party platforms or integrations
Audio, electronic, visual, thermal, olfactory, or similar information Advertising and marketing partners; analytics providers; business partners; third-party platforms or integrations
Commercial information (products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies) Advertisers and marketing partners; analytics providers
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement) Advertising and marketing partners; analytics providers
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (physical characteristics or description; medical information) Third-party platforms or integrations
Biometric information (sleep, health or exercise data that contain identifying information) Advertising and marketing partners; analytics providers; third-party platforms or integrations
Education information Advertising and marketing partners; analytics providers; business partners; third-party platforms or integrations
Geolocation data Advertising and marketing partners; analytics providers
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Advertisers and marketing partners

We sold or shared Personal Information to third parties for the following business or commercial purposes:

  • Advancing our commercial or economic interests
  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
  • Providing advertising and marketing services
  • Undertaking internal research for technological development and demonstration

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

Category of Personal Information Categories of Recipients
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (bank account number, credit card number, debit card number) E-commerce vendors; payment providers; fraud and cybersecurity companies
Identifiers (name, email address, alias, online identifier) Customer support partners; marketing sponsors and partners; ad networks; e-commerce vendors; analytics services; technology service providers; leagues, conferences, colleges and universities, and governing bodies; recruiters; affiliates or subsidiaries; other accountholders or platform users
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number) Customer support partners; marketing sponsors and partners; ad networks; e-commerce vendors; analytics services; technology service providers; leagues, conferences, colleges and universities, and governing bodies; recruiters; other accountholders or platform users
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) Customer support partners; marketing sponsors and partners; ad networks; e-commerce vendors; analytics services; technology service providers; leagues, conferences, colleges and universities, and governing bodies; recruiters; affiliates or subsidiaries; other accountholders or platform users
Identifiers (driver’s license number, passport number) Directly managed hotel bookings; directly managed travel
Characteristics of protected classifications under California or federal law (race, age, sex/gender) Analytics services; ad networks; technology service providers; marketing sponsors and partners; leagues, colleges and universities, conferences, and governing bodies; recruiters; affiliates or subsidiaries; other accountholders or platform users
Education information Technology service providers; leagues, colleges and universities, conferences and governing bodies; recruiters; analytics services; ad networks; marketing sponsors and partners; affiliates or subsidiaries; other accountholders or platform users
Audio, electronic, visual, thermal, olfactory, or similar information Analytics services; ad networks; technology service providers; marketing sponsors and partners; leagues, colleges and universities, conferences and governing bodies; recruiters; affiliates or subsidiaries; other accountholders or platform users
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement) Technology service providers; analytics services; ad networks; affiliates or subsidiaries
Geolocation data Ad networks; technology service providers; marketing sponsors and partners; leagues, colleges and universities, conferences and governing bodies; recruiters; affiliates or subsidiaries
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Ad networks; marketing sponsors and partners; technology service providers; analytics companies; leagues, colleges and universities, conferences and governing bodies; recruiters
Commercial information (products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies) Analytics services; technology service providers; e-commerce vendors; leagues, colleges and universities, conferences and governing bodies; affiliates or subsidiaries
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (physical characteristics or description; medical information) Technology service providers; marketing sponsors and partners; leagues, colleges and universities, conferences and governing bodies; recruiters; analytics services; other accountholders or platform users; medical services providers
Biometric information (sleep, health or exercise data that contain identifying information) Technology service providers; marketing sponsors and partners; leagues, colleges and universities, conferences and governing bodies; analytics services; medical services providers

We disclosed Personal Information for all of the business and commercial purposes listed above.

We collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information as described in the “Data Retention” section above.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

  1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
  2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
  3. The right to correct inaccurate Personal Information that we maintain about you;
  4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
  5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure;
  6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive webform available here or by emailing us at [email protected].

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information. You may submit a request to opt out of sales or sharing by clicking here or by calling us at 1-866-996-6272. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “UNIVERSAL OPT-OUT MECHANISMS SIGNALS” section above for more information.

Special Rules Regarding Minors

If you are 13-16 years old, you may opt in to the sale of personal information, including by submitting a request to [email protected].

Shine the Light Law

If you are a California resident and have an established business relationship with us, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to [email protected] with the subject line “Shine the Light Request.”

Erasure Law

If you are a California resident under the age of 18 and a registered user of the Services, California Business & Professions Code § 22581 permits you to request and obtain removal of content or information posted on the Services by you. If you wish to make a request, please contact us at [email protected]. Please be aware that removal does not ensure complete or comprehensive removal of the content or information posted on the Services by you and there may be legal reasons for denying your request.

11. Your Personal Data and Your Rights – Europe and the United Kingdom Only

If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the following explanation of the legal bases we rely on to process your Personal Data and a description of your privacy rights.

Legal Bases for Processing Your Personal Data

The legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

Consent

We may process your Personal Data based on your consent such as when you create an account or when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Our Legitimate Interests

We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services and the content and functionality of our Site.

To Perform a Contract

We may process your Personal Data to administer and fulfill contractual obligations to you.

To Enable Us to Comply with a Legal Obligation

We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims

If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data for any specific processing activity, please contact us using the “HOW TO CONTACT US” section below.

Your Rights

Access Your Personal Data

You have the right to obtain from us confirmation as to whether or not we are processing Personal Data about you and, if so, the right to be provided with the information contained in this Privacy Policy. You also have the right to receive a copy of the Personal Data undergoing processing.

Rectify Your Personal Data

You have the right to ask us to rectify any inaccurate Personal Data about you and to have incomplete Personal Data completed.

Restrict Our Use of Your Personal Data

You have the right to ask us to place a restriction on our use of your Personal Data if one of the following applies to you:

  • You contest the accuracy of the information that we hold about you, while we verify its accuracy;
  • We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
  • We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
  • You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

Object to Our Use of Your Personal Data

You have the right to object to our use of your Personal Data where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Delete Your Personal Data

You can ask us to delete your Personal Data if:

  • We no longer need it for the purposes for which we collected it;
  • We have been using it with no valid legal basis;
  • We are obligated to erase it to comply with a legal obligation to which we are subject;
  • We need your consent to use the information and you withdraw consent;
  • You object to us processing your Personal Data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Data Kept” section below.

If you do exercise a valid right to have your Personal Data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Transfer Your Personal Data to Another Service Provider

You may request that we transfer some of the Personal Data you have provided to you or another service provider in electronic copy. This applies to Personal Data we are processing to service a contract with you and to Personal Data we are processing based on your consent.

To exercise any of these rights, please contact us as described in the “HOW TO CONTACT US” section below.

Make a Complaint

If you have any concerns or complaints regarding our processing of your Personal Data, please contact us as described in the “HOW TO CONTACT US” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority:

EU Data Protection Authorities (DPAs)

Swiss Federal Data Protection and Information Commissioner (FDPIC)

Information Commissioner’s Office (United Kingdom)

How Long Is Your Personal Data Kept?

We will retain your Personal Data for as long as necessary to fulfill the purposes for which we collect it and as set out in this Privacy Policy and for the purpose of satisfying any legal, accounting, or reporting requirements that apply to us.

12. Your Choices and Rights – Canada and Rest of the World

Depending on the jurisdiction in which you are located, you may have certain rights with respect to your personal data. For example, you may have the following rights:

  • Right to access your personal data
  • Right to correct or amend your personal data
  • Right to delete your personal data
  • Right to withdraw consent
  • Right to file a complaint

If you would like to exercise your legal rights, please contact us at [email protected]. We will process your request in accordance with any applicable legal requirements. If you remain unsatisfied with our response and you are a resident of Canada, you may file a complaint with the Office of the Privacy Commissioner of Canada.

For a description of the legal bases for which we collect your personal data, please see the section “YOUR PERSONAL DATA AND YOUR RIGHTS –EUROPE AND THE UNITED KINGDOM ONLY - Legal Bases for Processing Your Personal Data” above.

13. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

14. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices, please contact us at [email protected].