PRIVACY POLICY

CALIFORNIA RESIDENTS

Relevent Sports, LLC and its parent company, subsidiaries, affiliatesand divisions (collectively referred toin this document as “we,” “us”, “Relevent”,or “Company”) are strongly committed to respecting andprotecting your privacy. We know that you care how information about you is shared and used. Weappreciate your trust that we handle your information sensibly and responsibly. Please carefully read thefollowing privacy policy (“Policy”). The purpose of this Policy is to explain the types of information thatthe Company collects and receives, what we do with that information, and with whom the Companyshares this information. This Policy applies to those individuals who browse and use our Site (“Visitors”)and those individuals whose information is collected otherwise and provided to us, either from us directlyor from third parties with whom we conduct business (“Partners”). Any Visitor or individual who providespersonally identifiable information (“Personal Information”) or any other information to the Company orto any Partners consents to the collection, use and disclosure of such information under the terms of thisPolicy

In order to ensure your privacy, information the Company collects from Visitors to its website(www.InternationalChampionsCup.com) and websites or applications (including mobile apps) hosted bytheCompany (all of such Internet locations collectively referred to as the “Site”) and/or our Partners,and/or otherwise is used only in the manner and for the purposes described in this Policy.

INFORMATION COLLECTED BY THE COMPANY AND/OROUR PARTNERS

The Company may collect any Personal Information, defined as any information that identifies you as an individual or relates to an identifiable individual or household that is provided to us by our Visitors or our Partners, or is collected through sweepstakes, in-person events, or social media platforms, such as Facebook. Examples of Personal information may include, without limitation, name, phone number, mailing address, zip-code, e-mail address, or any other Personal Information that is provided to us in connection with the Site or the other data collection points listed above. In addition, if a purchase is made on the Site and/or on one of our Partners’ websites, we may collect credit card, debit card or other payment account information and shipping and billing addresses for billing purposes and to fulfill your order.
If you register on the Site and create an account, you will be asked to create a user name and password, which you will need to access your account information. You are responsible for maintaining the confidentiality of your password. If you are located in the European Economic Area (EEA), you may be asked to consent to the collection and use of your information as described in this Policy.

A. Automatic Information

Examples of other information we collect automatically include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type, version, and time-zone setting, browser plug-in types and versions, operating system, and platform; and the full Uniform Resource Locator (URL). During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

B. Cookies

Like many websites, we use “cookies” and similar mechanisms to collect certain data from the computer or mobile device you use to access our website.
Cookies allow us to serve you better. They allow us to understand website and Internet usage and to improve or customize the content, offerings, or advertisements on our Site. For example, we may use cookies to personalize your experience at our Site (e.g., to recognize you by name when you return), or save your password in password-protected areas. We also may use cookies to help us offer you products, programs, or services that may be of interest to you and to deliver relevant advertising.
To learn more about the cookies we use see our cookie policy. You can also learn more about cookies at: AllAboutCookies: https://www.allaboutcookies.org/

C. Do Not Track Policy

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track your online activities over time and across different websites. Our services do not support Do Not Track requests at this time.

HOW THE COMPANY USES PERSONAL INFORMATION

The Company uses Personal Information obtained from Visitors to our Site, and/or from our Partners and/or otherwise: (i) to respond to questions, comments and other requests from Visitors, (ii) to send information about the Company and our events, (iii) to confirm and process orders, (iv) to keep you informed about your order status, (v) to protect the security of our Visitors, systems, and Site, (vi) to improve our products and services, (vii) to run analytics on purchaser data, and (viii) to share information about our Partners’ events and products. We use the payment account information you provide to us for billing purposes and to fulfill your order.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

The Company may share Personal Information, including Personal Information that you provide on our Site, to Partners on their websites, or otherwise to us, with third parties as described below.

A. Affiliated Entities

We may share any information, including Personal Information that you provide on the Site, on Partners’ websites, or that we collect in the disclosed manners provided herein, with our Partners, subsidiaries, and affiliates worldwide, for the purposes described herein (as modified from time to time).

B. Strategic and Media/Club Partners

From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with the Company to provide additional features on the Site. These special relationships may include Partners, sponsors, and co-branded sites (referred to here as “co-branded pages”). Any information, including Personal Information that you provide on one of these co-branded pages, may be shared with such Partners or sponsors. By participating in activities or providing your Personal Information on these co-branded pages (or by accessing these co-branded pages or the Site), you consent to our providing your Personal Information to such Partners or sponsors. As such Partners or sponsors will use your Personal Information in accordance with their own privacy practices, you should review their privacy policies. Our Partners include both strategic partners and the clubs that participate in Company events and we may share your Personal Information with such strategic and club partners so that they may communicate with you directly about their products and services.

C. Service Providers

We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending emails, fulfilling orders, selling tickets, and administering sweepstakes. We may share your Personal Information with such service providers for such limited purposes. For instance, if you participate in a sweepstakes, game, or loyalty program that results in a prize or award, we will share your Personal Information with our fulfillment and management agencies.

D. Advertising Networks

We may have relationships with third party service providers known as advertising networks to place and administer advertisements on our behalf across the Internet. Using cookies and pixel tags (also known as web beacons), advertising networks may collect anonymous information about your visits to the Site and other websites in order to deliver advertisements that may be of particular interest to you. This process does not involve the collection of any Personal Information. The advertising networks do not know your name, phone number, address, email address or any Personal Information. Nor do we share any Personal Information with such advertising networks. To find out more about how such advertising networks manage the privacy of Personal Information in conjunction with delivering advertisements online and how to opt-out of information collection by such advertising networks please go to: http://www.youradchoices.com or http://www.networkadvertising.org, or see our cookie policy. The cookie consent pop up that you see when you log on to our Site for the first time allows you to opt out of the use of third party cookies.

E. Other Disclosures

In addition to the third parties described above, Personal Information of any Visitor, or individual whose information is collected otherwise, may also be shared with parties outside of the Company: (i) as permitted by law, (ii) in the event of a transfer of ownership, assets or a bankruptcy of the Company, (iii) if we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process, or (iv) to protect the interests or safety of the Company or Visitors to the Site.

YOUR CHOICES WITH RESPECT TO PERSONAL INFORMATION

The Site gives Visitors who register on the Site the opportunity to stop receiving communications from the Company if requested. The Site also gives registered Visitors options for changing and modifying Personal Information previously provided. To remove or change Personal Information in our database, or to not receive future communications from the Company, please contact us at privacy@releventsports.com.

CHILDREN

The Company does not knowingly solicit or collect Personal Information from Visitors or individuals under the age of eighteen (18) (“Minors”), and we will not knowingly link to any third party website that solicits or collects Personal Information from Minors. If you believe that a Minor has disclosed Personal Information to us or that we have linked to such a third party website, please contact us at privacy@releventsports.com.

SECURITY AND PROTECTION OF PERSONAL INFORMATION COLLECTED BY US

The Site has security measures in place to protect the loss, misuse, and alteration of the Personal Information under our control. The Company has implemented various physical, electronic, and managerial measures, including education and training of our personnel, to provide Personal Information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. The Company has invested and deployed a wide variety of technology and security features to ensure the privacy of Personal Information that is collected by the Company. The Company will continue to revise policies and implement additional security features as new technologies become available. Unfortunately, despite our best efforts, no security measures are perfect and we cannot guarantee complete security.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Permitted transfers of information, including Personal Information, either to third parties or within the Company, include the transfer of information from one jurisdiction to another, such as transfers to and from the United States. Because privacy laws vary from one jurisdiction to another, Personal Information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the Personal Information originated. We will always handle your Personal Information as described in this Policy. To facilitate the secure transfer of your Personal Information from the EEA to the United States, we execute approved “standard contractual clauses” approved by the European Commission with entities that provide Personal Information to us.

ENFORCEMENT

The Company will cooperate with the appropriate data protection authorities to resolve any complaints and disputes arising in connection with this Policy. All necessary Company employees will be required to be familiar with and adhere to this Policy. The Company will investigate any reported complaints of violations of this Policy and will take prompt remedial action where violations are found. In order to inquire or complain about the Policy or anything related to the privacy of Personal Information handled by the Company, please contact us at: privacy@releventsports.com.

CALIFORNIA RESIDENTS

A. If you are a California resident, we are required to tell you certain things about your Personal Information and your rights regarding your Personal Information that we have collected in the last twelve (12) months. First, let us tell you more about how your Personal Information is collected, used, and shared. Please keep in mind that not all categories or personal information will apply to all California residents:

Categories of PI Collected in Last 12 months Category or Source from Which PI Collected Business or Commer-cial Purpose for Collection and Use of PI Sold or Shared to Third-Parties Category of Third-Party to Whom PI was Sold or Shared Purpose for Selling or Sharing PI to Third-Parties Disclosed for a Business Purpose Category of Third-Party to Whom PI Disclosed for a Business Purpose Specific Purpose for Disclosing PI How Long We Keep Your PI
Identifiers such as a real name, alias, postal address, online identifier, IP address, email address, account name, social security number, driver’s license number, background check information, job application information, health information, union data, passport number or other similar identifiers

Consumer

Computer operating systems

Providing services requested by Consumer

Marketing and promotions

Personalizing Website, products, and services

HR

Hiring

No None None Yes

Payment processor

Benefits administrator

Payroll company

Processing transactions

Performing contractual obligations

Handling information relating to sweepstakes

Assist with performing benefits administration and payroll processing

Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

Personal information collected by cookies is retained in accordance with the cookie policy.

Character-istics of protected classifications under California or federal law Consumer

HR

Hiring

No None None No None None Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

Commercial information

(such as for services or other contractual matters)

Consumer or consumer’s employer

Providing services requested by consumer

Marketing and promotions

No None None Yes Payment processor

Processing transactions

Performing contractual obligations

Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

Biometric information

(such as from players)

Consumer Analytics No None None Yes Analytics partners Measuring performance Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.
Internet or other electronic network activity information Consumer

Improving services

Personalizing Websites, products, and services

Advertising and amrketing

Yes Advertisers

Advertising

Analytics

Yes Analytics and advertising partners Providing advertisements for similar products and services

Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

Personal information collected by cookies is retained in accordance with the cookie policy.

Geolocation data Consumer

Improving services

Personalizing Websites, products, and services

No None None Yes Analytics Consumer analysis Personal information collected by cookies is retained in accordance with the cookie policy.
Education information

Consumer

Educational institutions

HR

Hiring

No None None No None None Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

Sensitive personal information

(including payment card numbers for sales and services)

Consumer

HR

Hiring

Processing transactions

No None None Yes. Payment processor

Sales

Processing transactions

Personal information is retained for: (i) the duration of time necessary for the purposes for which the personal information was received or collected; (ii) the period of time to respond to potential legal or regulatory proceedings; or (iii) the time required by applicable law.

B. Sensitive Information

Relevent does not use or disclose sensitive personal information except to perform the services for which the information is collected.

C. Third-Party Collection of Personal Information

We use third-party cookies to collect personal information about your interaction with our Website. These third-parties include:

  1. Google. For more information about Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners’ Sites or Apps.”
  2. Microsoft. For more information about Microsoft cookies please see “Delete and manage cookies – Microsoft Support”.
  3. Adobe. For more information about Adobe cookies or to opt-out, please see “Adobe Privacy Center”

You can also review our cookie policy for more information about the cookies we use.

D. Rights Regarding Your Personal Information

You have several rights regarding your personal information. We will explain those rights to you and how you may exercise them.

  1. The Right to Know: This means you have the right to know what personal information we have collected about you, the categories of this personal information, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third-parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
  2. The Right to Delete: You have the right to request that we delete personal information that we have collected from you. However, keep in mind, that this right is subject to certain exceptions.
  3. Right to Correct: You can request that we correct inaccurate personal information we maintain about you.
  4. Right Not to Receive Discriminatory Treatment: You have the right not to be discriminated against based on your personal information, and the right not to be retaliated against for the exercise of your rights under California law.

You may also request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@releventsports.com.

E. Exercising Your Rights

You may exercise any of the rights listed above by calling us at 1-888-969-9650 or sending an email to privacy@releventsports.com. If you exercise any of these rights, we may need to verify your identity. If we need to do so, we may ask you to provide certain information such as your driver’s license, or other form of identification. If we cannot verify your identity, we may deny your request. If that happens, we will let you know.

You can also have an authorized agent exercise your rights on your behalf. If you do so, we may also ask your authorized agent to provide proof that they are authorized to act on your behalf.

F. Right to Opt-Out of Selling or Sharing Your Personal Information

In addition to the rights mentioned above, you also have the right to opt-out of Relevent “selling” or “sharing” your personal information, as those terms are defined by the California Privacy Rights Act. If you choose to opt-out, personal information about your device and browser will no longer be accessed by third-parties. If you would like to exercise your right to opt-out, send us an email at privacy@releventsports.com or click the link below:

Do Not Sell or Share My Personal Information

PRIVACY PROVISIONS FOR VISITORS AND OTHER PERSONS WHOSE PERSONAL INFORMATION MAY BE COLLECTED IN OR FROM THE EEA

While Visitors who are located in the EEA are visiting our Site or the websites of our Partners or individuals located in the EEA are participating in sweepstakes, in-person events, or social media platforms that collect their Personal Information, we recognize and, to the extent applicable to us, adhere to relevant EEA data protection laws.

A. Lawful Grounds to Process and Obtain Consent

We process the Personal Information of individuals who are located in the EEA (“EEA Data Subjects”) for one or more of several lawful purposes, including:
With your consent:

To provide you with Company services, including customer service support;

To optimize and enhance Company services for all Visitors or for you specifically;

To comply with legal obligations:

To conduct identity verification and authentication checks (you authorize us to share your Personal Information with our third-party service providers, who may also conduct their own searches of publicly available Personal Information about you);
For our legitimate business purposes:

To monitor the usage of the Site, conduct automated and manual security checks of our services, protect our rights, and perform our lawful obligations.
EEA Data Subjects may withdraw consent at any time where consent is the lawful basis for processing their Personal Information. Should an EEA Data Subject withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, an EEA Data Subject may be unable to avail him or herself of the services we provide.

B. Automated Decision-Making

The Company does not engage in automated decision-making.

C. Contact Information for EEA Data Subjects
If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your Personal Information, you may contact us at: privacy@releventsports.com.
If, as person in the EEA, you believe that we have not adequately resolved any such issues, you have the right to contact an EEA Data Protection Authority.

D. Access to, Correction of, and Deletion of Your Personal Information

You have the right to the following with respect to your Personal Information: obtain a copy, ask for a correction if it is inaccurate, request restriction of processing, and request deletion. If you would like to exercise any of these rights, please contact us at privacy@releventsports.com. Please note, however, that before the Company is able to respond to any of these requests, we may ask you to verify your identity and to provide other details, including Personal Information, to help us to respond to your request. The Company affirms that it will correct, amend, or delete any erroneous information if instructed to do so by you and if required by law. We will not charge a fee for responding to any such request unless the request is repetitive or unduly burdensome.

AMENDMENTS

From time to time, the Company may update, modify or change this Policy. When this occurs, the new Policy will be posted on the Site. You should check the Site periodically to review the most recent Policy. Your use of the Site or provision of Personal Information to the Company or any of our Partners after any update, modification, or change to this Policy constitutes your acceptance of and agreement to such updates, modifications, or changes.

CONTACT US

If you have questions, comments, or complaints about Relevent’s data practices you can send an email to privacy@releventsports.com, or write us at 423 West 55th Street, Floor 11, New York, NY 10019.