PRIVACY POLICY

CollegeSports Company (“CSC”) is committed to processing your personal information in a fair and lawful manner, while you interact with our Connect program. We have developed this Privacy Statement to inform you about how we handle personal information and about our privacy practices including for our website and any other CSC websites that direct you to this Privacy Statement (the “Covered Sites”).

I. GENERAL USES OF DATA

A. WHAT INFORMATION WE GATHER AND FROM WHOM

We may collect, use, store and transfer different kinds of personal information about you. We collect personal information directly from you and indirectly about you as described below. We may collect the following types of personal information from or about you, which we have grouped into categories as follows:

 includes first name, maiden name, last name, username or similar identifier, marital status, title, job title, company name, date of birth, and gender. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, job title, company name, date of birth, and gender.

includes billing address, delivery address, email address, and telephone numbers. Contact Data includes billing address, delivery address, email address, and telephone numbers.

·Financial Data includes bank account and payment card details.

includes details about payments to and from you and other details of services you have purchased from us. Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

includes internet protocol (“IP”) address, cookies, javascript, web beacons, clear gifs, HTTP headers, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Covered Sites. Technical Data includes internet protocol (“IP”) address, cookies, javascript, web beacons, clear gifs, HTTP headers, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Covered Sites.

includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, and any unsolicited personal information not otherwise covered by this Privacy Statement that you choose to submit in an inquiry or webchat, on a blog forum or otherwise on our Covered Sites or in person to a CSC representative at an event. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, and any unsolicited personal information not otherwise covered by this Privacy Statement that you choose to submit in an inquiry or webchat, on a blog forum or otherwise on our Covered Sites or in person to a CSC representative at an event.

includes information about how you use the Covered Sites, and/or our products and services. Usage Data includes information about how you use the Covered Sites, and/or our products and services.

includes your communication preferences in receiving marketing from us and third parties. Marketing and Communications Data includes your communication preferences in receiving marketing from us and third parties.

Sensitive Personal Information. Occasionally we may collect sensitive personal information that relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. For example, we may collect certain information made available through Social Media Applications. This information may contain sensitive personal information if you have made that information available on your Social Media profile. In addition, the information that you submit in blog forums (or otherwise) on our Covered Sites or when interacting with our products and services may include sensitive personal information.

We may collect the categories of personal information described above either directly or indirectly from different sources, including the following:

  • Our business partners.
  • Our customers.
  • You, when you interact with us through the Covered Sites.
  • Internet cookies, analytics programs, pixels, web beacons, and other technologies that help our Covered Sites operate effectively and efficiently.
  • Third-party social media applications such as Facebook, Instagram, or Twitter (each, a“Social Media Application”).

Please note that our Covered Sites may contain links to other unaffiliated third-party websites. CSC is not responsible for the privacy practices, privacy statements,or content contained in or regarding these other unaffiliated third-party websites that do not include this Privacy Statement. You should consult theprivacy statements associated with these unaffiliated third-party websites should you decide to visit them.

If you respond in a blog forum on our Covered Sites, you should be aware that anypersonal information you submit there will be stored on our servers and can beread, collected, or used by other users of these blog forums, and could be usedto send you unsolicited messages. CSC is not responsible for the actions thatother users of the blog forums take in relation to personal information youchoose to submit in the forums. You are also responsible for using these forumsin a manner consistent with our Terms of Service or other terms and conditions set forth on the relevant forum website.

B. HOW WE USE PERSONAL INFORMATION

We will only use your personal information in a manner that is consistent with applicable laws. Most commonly, we will use the categories of personal information identified above for the following business purposes:

  • For the provision of our products and services or the operation of our business or a third party’s business. Personal information may be made available to CSC businesses around the world for the provision of our products and services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.
  •  Where we need to perform a contract that we have entered into with you, or in order to take steps at your request prior to entering into a contract.
  • Where we need to protect your interests (or someone else's interests).
  • Where it is needed in the public interest or for official purposes.
  • In connection with the sale, merger, acquisition, or other reorganization of our business. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is CSC's practice to seek appropriate protection for information in these types of transactions.
  • For compliance with legal obligations and protection of CSC and others. Specifically, we may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, and as we otherwise believe to be necessary or appropriate: (i) under applicable law, which may include laws outside your country of residence; (ii) to respond torequests from courts, law enforcement agencies, regulatory agencies, and otherpublic and government authorities, which may include such authorities outsideyour country of residence; (iii) to enforce or apply our contractual rights;and (iv) to otherwise protect our rights, privacy, safety, or property, orthose of other persons.
  • For marketing purposes. Specifically, we may use your personal information (including cookies – for more information on how we use cookies, pleasesee this Section D below)to form a view on what we think you may want or need, or what may be ofinterest to you. This is how we decide which products, services, and offers maybe relevant for you (we call this marketing). You may receive marketing communications from us if you have purchased products or services from us, wehave identified similar products or services that may be relevant for you and,in each case, you have not opted out of receiving that marketing. We will getyour express opt-in consent before we market products or services to you thatare not similar to products or services you have purchased from us before, orif we share your personal information with any company outside the CSC group of companies for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time. If you receive a marketing communication from us, the communication will contain an option to opt-out offurther communications. If you receive a marketing communication from one ofour business partners, or from social media providers, you should opt out withthat entity directly. You can also contact us atany time to opt out using the details given at the end of this Privacy Statement.

We will only use your personal information for the purposes for which we collect edit, including where we reasonably consider that we need to use it for a reason that is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you as required by law.

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

C. WHEN, WHY, AND WITH WHOM WE SHARE PERSONAL INFORMATION

We may disclose the following categories of personal information to entities otherthan CSC for any the business purposes set out in above. When we disclose personal information, we do so in accordance with our data privacy and security requirements.

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, job title, company name, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or our business partners.

D. USE OF COOKIES, OTHER TRACKING TECHNOLOGIES AND GATHERING OF STATISTICAL DATA

Technical Data includes internet protocol (“IP”) address, cookies, javascript, web beacons, clear gifs, HTTP headers, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Covered Sites.

In addition to the personal information identified above, we use"cookies" and other statistical and tracking technologies asdescribed in this Section in connection with the operation of our CoveredSites. A cookie is a piece of information that our Covered Sites send to yourbrowser, which then stores the cookie information on your system. Other statistical and tracking technologies, such as web beacons, clear gifs, HTTPheaders, also work in ways that collect information about your visit and use ofour Covered Sites. We may use both temporary and persistent cookies based onthe cookie’s purpose. Some cookies are deleted when you close down yourbrowser. These are known as session cookies. Others remain on your device untilthey expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor toour Covered Sites.

includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, and any unsolicited personal information not otherwise covered by this Privacy Statement that you choose to submit in an enquiry or webchat, on a blog forum or otherwise on our Covered Sites or in person to a CSC representative at an event. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, and any unsolicited personal information not otherwise covered by this Privacy Statement that you choose to submit in an enquiry or webchat, on a blog forum or otherwise on our Covered Sites or in person to a CSC representative at an event.

We use these technologies in four ways:

Usage Data includes information about how you use the Covered Sites, and/or our products and services.

To provide a product or service: When you enable their use, a cookie may be used to provide you with a specific product or service. For instance, if you request our Covered Sites to remember your login password or remember your profile in a response to a blog post, we deposit a cookie on your computer to facilitate that request. If you are logging into an access-controlled section of our Covered Sites, we set a temporary session cookie to establish that you have been authenticated. The information containedin these cookies consists of random data that is used by our server to authenticate the browser requests to the server for that particular session. These cookies do not include any type of personal information. This bit ofinformation is erased when you close your current browser window. If you choosenot to accept a temporary cookie, you will not be able to navigate in theseonline applications. We also use a cookie when you visit our Covered Sites andrequest documentation or a response from us. When you are filling out a form,you may be given the option of having our Covered Sites deliver a cookie toyour local hard drive. You might choose to receive this type of cookie in orderto save time in filling out forms and/or revisiting our Covered Sites. We onlysend this type of cookie to your browser when you have enabled cookies andclicked on the box labeled "Please remember my information" oranother box with an equivalent content when submitting information or communicating with us.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

To facilitate website use: If you enable functional cookies, our Covered Sites will be able to remember information about your preferences and movement either until you exit your current browserwindow (if the cookie is temporary) or until you disable or delete the cookie. For instance, we may deposit a cookie to remember which of CSC’s regional Covered Sites you have selected to access or to save your password if youcreate an account. Many users prefer to use cookies in order to help themnavigate a website as seamlessly as possible. If you are accessing our services through one of our online applications, our web server may automatically sendyour browser a temporary cookie, which is used to help your browser navigateour Covered Sites. The information contained in these temporary cookies is adirection value that lets our software determine which page to display when youhit the back button in your browser. This bit of information is erased when youclose your current browser window.

Social Media Application Data includes, without limitation, your public profile, socialmedia relationships, listed work and education history, listed hometown andcurrent city, profile photos, personal description, and “likes.”[THA5] 

Sensitive Personal Information. Occasionally we may collect sensitive personal information that relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person's sex life or sexual orientation. For example, we may collect certain information made available through Social Media Applications. This information may contain sensitive personal information if you have made that information available on your Social Media profile. In addition, the information that you submit in blog forums (or otherwise) on our Covered Sites or when interacting with our products and services may include sensitive personal information.

To understand our visitors: When you visit our Covered Sites, if you have enabled analytics cookies our systems may automatically collect statistics in aggregate about visitor behavior. We maymonitor statistics and other data, such as how many people visit our site, theuser's IP address, which pages people visit, how users interact with pagecontent and functionality, from which domains our visitors come, which browsers people use and how they move about our Covered Sites. We use this data aboutyour visit for aggregation purposes only. These statistics are used to help usto understand our visitors’ interests and improve the content and performanceof our Covered Sites. If you come to our site from one of our business partners, our web server may also send your browser a temporary cookie thatreflects an origination code for that business partner. We use this information for statistical and marketing purposes.

Analytic cookies also allow us to track traffic patterns on our Covered Sites. Analysis of the collected information by our tracking technologies allows us toimprove our Covered Sites and the user experience. If you choose not to accepta persistent cookie, you will still be able to use our Covered Sites. Even ifyou choose to receive this type of cookie, you can always set your browser tonotify you when you receive any cookie, giving you the chance to decide whetherto accept it in each situation in which one is sent. We may supplement this unidentified user data with other data to better understand our users. Forinstance, we may relate a user’s IP address to the company to which it relatesto better understand our visitors’ interests.

Below are the categories of entities to whom we may disclose personal information and why.

To advertise: If you enable targeting cookies, this allows us to allowour ad partners to tailor the advertisements you receive on our Covered Sitesbased on the unidentified user data and related information. These cookiesallow us to receive information on unidentified users’ movements on otherwebsites to tailor advertisements to them on our Covered Sites and, likewise, provide unidentified user information to service providers, such as an adagency, who places our advertisements on other websites to market to these usersthat visit them. Even if you do not opt in to this cookie, you may still see CSC advertisements on other websites you visit, but these ads are not user specificand are not placed because of your past visits to our Covered Sites.

Business partners. We may provide your personal information to a CSC business partner. Please be assured that these CSC business partners have agreed toensure the privacy and security of any transferred information and may only usethe shared information to send you information about products or services aboutwhich you asked, or for sending updates or providing services on our behalf.

Do Not Track

We do not respond to Do Not Track signals.

Service providers. We partner with, and are supported by, service providers around the world. Personal information will be made available to these partiesonly when necessary to fulfill the services they provide to us, such assoftware, system, and platform support; direct marketing services; cloudhosting services; advertising; data analytics; order fulfillment and delivery;and services to assist us in managing and responding to consumer privacy and other requests. Our service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.

E. OUR SECURITY PROCEDURES

Third parties for legal reasons. We will sharepersonal information where we believe it is required: (i) in order to complywith our legal and contractual obligations; (ii) to protect CSC and others; and(iii) in the context of a business transition, such as a merger or acquisition.

We consider the protection of all personal information we receive offline andonline from our Covered Sites’ visitors and subscribers as critical to ourcorporate mission. We have security measures in place to protect against theloss, misuse, and alteration of any personal information we receive from you. As with any transmission over the internet, however, there is always someelement of risk involved in sending personal information.

Research entities. We will share personal information for research activities.

F. CHANGES TO THIS PRIVACY STATEMENT

 

Government entities. We will share personal information for information sharing and other security purposes.

Wecurrently do not sell personal information to third parties.

Itis important that you check back often for updates to this Privacy Statement. If a material change is made to this Privacy Statement and/or the way we useour customers' personal information, we will post a prominent notice on theCovered Sites and/or by means of other methods of contact such as email.

G. CONTACT CSC

If you have questions about this Privacy Statement or to lodge a complaint, youmay contact us in the following ways:

  • You may email us at: media@collegesportsco.com. Please specify"Privacy Statement" in the subject line of your email.
  • You may call us at: TBC
  •  You may write to us at: 169 Madison Ave STE 15027 New York, NY 10016

II. THE GENERAL DATA PROTECTION REGULATION (GDPR) PRACTICES

Where we collect, process, use or disclose personal information that is subject tothe General Data Protection Regulation (GDPR), we are committed to processing your personal information in a fair and lawful manner. This section describesour privacy practices specific to personal information covered by the GDPR and your rights in relation to your personal information.

A. THE INFORMATION WE GATHER

The information that we collect and process is described in Section I.A above. Pursuant to GDPR, we will explain the legal basis which allows us to do so.

We will only collect or process sensitive personal information on the basis that:(i) it has manifestly been made public by you; or (ii) the processing isnecessary: (a) in relation to legal claims; (b) for reasons of substantial public interest; or (c) where we need to carry out certain legal obligations and/or exercise certain rights relating either to or you. We do not collect any information about criminal convictions and offenses.

B. PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL INFORMATION

An explanation of how we may use your personal information is described in SectionI.B above. If you are located in the EU, you have the right to know what legalbasis we rely upon to process your personal information. The chart below describes all the ways in which we plan to use your personal information andthe legal bases we rely on to do so. We have also identified what ourlegitimate interests are where appropriate.

Purposes for which we will process the information

Legal Basis for the processing

To deliver services and features desired by you.

It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us.

To improve our services to you.

It is necessary for us to process your personal data in order to improve our services to you according to the applicable contract between us.

To personalize content and offers and serve you advertising that may be of interest to you.

We will personalize content and offers to you and serve you advertising based on your interests and online activities if you have consented to this processing.

To respond to your inquiries.

It is necessary for us to process your personal data in this manner to respond to your inquiries according to the applicable contract between us.

To fulfill your request for products or services.

It is necessary for us to process your personal data to fulfill your request for products or services according to the applicable contract between us.

To use your login user ID and password to register you on your behalf and to give you access to our affiliate websites and services as part of a “single sign-on” feature.

It is necessary for us to process your personal data to use carry out these activities according to the applicable contract between us.

To provide you with updates and other information regarding the Services.

It is necessary for us to process your personal data to provide you with updates and other information regarding the Services according to the applicable contract between us.

To share your information with the company that employed you, engaged you, or authorized you to access and use the Services.

It is in the legitimate interests of the company that employed you, engaged you, or authorized you to access and use the Services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To analyze statistically site usage and to customize our site's content, layout and services.

It is in our legitimate interests to process your personal data to analyze our site usage and to customize our site's content, layout and services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To enable our family of companies and affiliates and with trusted business partners that we do business with who may have content and offers of interest to you.

It is in our legitimate interests to process your personal data to enable our family of companies and affiliates who may have content of interest to you. We process your personal data to enable our family of companies and affiliates and trusted business partners to send you offers and market to you only if you have consented to these activities.

To enable our agents and service providers to perform certain activities on our behalf.

It is necessary for us to process your personal data in this manner in order to deliver the services and process transactions according to the applicable contract between us. It is also in our legitimate interest to enable our service providers to perform certain activities on our behalf. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To offer you the opportunity to use our invitation service and application so that you can tell your friends about the Services.

We process your data for these activities only if you have given your consent to do so.

 

To administer our Website including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

To improve our Website to ensure that consent is presented in the most effective manner for you and your computer, device or other item of hardware through which you access the Website.

For all these categories, it is in our legitimate interest to continually monitor and improve our services and your experience of the Website and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

 

To keep our Website safe and secure and to prevent detect fraud and abuse; and

To comply with our legal obligations, policies, and procedures.

We may process your personal data to respond:

  • To governmental requests or legal process (for example, a court order, search warrant or subpoena);
  • To other circumstances in which we have a good faith belief that a crime has been or is being committed by a user;
  • To an emergency that poses a threat to the safety of you or another person;
  • When necessary to protect our property;
  • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.

We conduct this processing to comply with our legal obligations and to protect the public interest.

 

To process otherwise for internal administrative and analytics purposes.

It is in our legitimate interest to process your personal data for internal administrative or analytics purposes. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

 

Note that we may process your personal information for more than one lawful purpose depending on the specific business purpose for which we are using your information. Please contact us (using the contact details above) if you need details about the specific legal ground we arerelying on to process your personal information.

C. HOW LONG WE KEEP PERSONAL INFORMATION

We will only retain your personal information in identifiable form for as long asneeded for the purposes for which it is gathered and processed. In determining retention periods, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use ordisclosure of your personal information, the purposes for which we process yourpersonal information and whether we can achieve those purposes through othermeans, and the applicable legal requirements. When we no longer need personal information, we either anonymize, securely delete, or destroy it expeditiously (within 45 days) once CSC determines the personal information is no longer needed.

D. YOUR GDPR RIGHTS

We respect the rights that you have in relation to your personal information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

Access to personal information. We will give you access to your personal information upon written request, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing information to you, we will ask for proof of identity and sufficient information about your interaction with us so that wecan locate any relevant data. Except where it is not permissible under applicable law, we may also charge you a fee for providing you with a copy of your data.

Correction and deletion. .You have the right to correct or amend your personal information if it is inaccurate or requires updating. You have the right to request deletion of yourpersonal information; however, this is not always possible due to legal requirements and other obligations and factors. We will do our best to respond promptly and in any event within one month of the following:

  • Our receipt of your written request; or
  • Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever happens to be later.

The information you supply in this form will only be used for the purposes of identifying the personal data you are requesting that we erase and responding to your request. You are not obliged to complete this form to make a request, but doing so will make it easier for us to process your request quickly.

If you would like to see such a request for erasure,please fill out this form: https://gdpr.eu/wp-content/uploads/2019/01/RIGHT-TO-ERASURE-REQUEST-FORM.pdf.

Data portability. You may have the right to (i) obtain personal information concerning you, which you have provided to CSC, and (ii)transmit such information to another data controller. The information may be transmitted directly from CSC to the other data controller where feasible.

Direct marketing. We may send you marketing communications as set out above. Where your personal information is processed for direct marketing purposes, you have the right to object at any time to such processing, which includes profiling to the extent that it is related to such direct marketing. All of CSC’sdirect marketing communications include an “unsubscribe” link to enable you to easily opt-out of future communications.

Withdrawal of consent. Where CSC is processing your personal information on the basis that you have consented to such processing, you have the right to withdraw that consent at any time. Once we have received written notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Objection to and/or restriction of processing of personal information. .You have the right to: (i) restrict the processing of your personal information in certain circumstances (e.g., where you contest the accuracy of your personal information); and (ii) object to certain types of processing of personal information.

Lodging a complaint. If you are not satisfied with how CSC manages your personal information, you have the right to lodge a complaint to a dataprotection regulator. A list of National Data Protection Authorities (“DPA”)can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Before filing a complaint with a DPA, we ask that you contact us toprovide us with an opportunity to resolve your complaint.

E. COOKIES

If you are in the EU, you may opt-out of certain third-party cookies that we and other websites may use for targeting through http://www.youronlinechoices.eu or www.aboutads.info. Opting out of one or more ad networks only means that those particular members no longer will deliver targeted content or ads to you. It does not mean you will stop receiving any targeted content or ads on our Covered Sites or other third-party websites. If your browser is configured to reject cookies when you visit one of the above referenced opt-out pages, and you later erase your cookies, use a different computer or change web browsers,youhr preference may no longer be active. Since all of these cookies are managed by third parties, you should refer to the third parties' own website privacy notifications and policies for further information.

Can I withdraw my consent?

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings, and disable cookies. Please note that disabling cookies will affect the functionality of our Covered Sites, and may prevent you from being able to access certain features on our Covered Sites.

F. DATA TRANSFER

CSC has a global network, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Statement and the requirements of applicable law wherever the data is located.

CSC has networks, databases, servers, systems, support, help desks, and offices located around the world, including outside the EU.

We use service providers located around the world, including outside the EU to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to discloseor transfer your personal information within CSC or to third parties in areas outside of your home country (including areas outside the EU).

We may transfer the personal information we collect about you to recipients incountries other than the country in which the information originally wascollected. Those countries may not have the same data protection laws as thecountry in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we willprotect that information as described in this Privacy Statement and will complywith applicable legal requirements providing adequate protection for thetransfer of personal information to recipients in countries other than the onein which you provided the information.