Effective Date: [INSERT LAUNCH DATE]

What’s New?

• We’ve added more detail about what data we collect, how we use your data, and who we share it with.
• We’ve updated our policy to include new rights to opt out of the sale of your data under applicable laws.
• We’ve included additional information about rights of some customers under new California laws relating to data privacy.

IMG ACADEMY PARENT, LLC PRIVACY POLICY

This privacy policy (“Privacy Policy”) describes how we use the data (which may include personal information) we collect about you offline and through our digital properties (“Site(s)”) when: you create an account, make a reservation, request support, chat, send us a message, or otherwise communicate or interact with us via our websites or app, when you apply, register, inquire about or participate in our school, camps, training programs, competitions or events, and any additional products or services association with your participation, when you buy a ticket or other merchandise from us online or onsite, when you view or interact with content on our online channels, including online trainings and coaching, when you attend our events in person, when you book our facilities for corporate events, groups or otherwise, and when you otherwise interact with us, including our social media, performance platforms, marketing, contests, sweepstakes, and surveys (collectively our “Service(s)”). This Privacy Policy does not apply when we are a service provider, i.e., when we provide services to businesses and handle data (including personal information) on behalf of those businesses. OR

This Privacy Policy (together with our Terms of Use, Cookie Policy and any other documents referred to therein) provides information on the data we collect from you, or that you provide to us, through this website (“Website”) and how we process it. Please read this policy carefully before you provide us with your personal information. This Policy provides detailed information about when and why we collect your personal information, how we may use it, and how we keep it secure. This policy works in conjunction with the Cookie Policy and Terms of Use. It covers what we collect from you or your use of the Website, it does not apply to information that you provide or have provided to other websites or social media or that has come from public sources. This policy also provides information about your privacy rights and to how to request and enforce them.

Please read this Privacy Policy carefully to understand how we handle your information.

WHO WE ARE

We are IMG Academy Parent, LLC, which includes IMG Academy, LLC, IMG Performance, LLC, DC711SPA, LLC, (“we”, “us”, “our”). We are also part of Endeavor Operating Company, LLC and may share data (as described further below) with its affiliated entities (collectively, “Endeavor”).  If you would like a full list of relevant entities, please submit an information request to the Privacy Team [here.]

Like any company, we use a variety of third party businesses and partners to market and provide our Services to you. Some of those companies are part of Endeavor, and some are third parties that we partner with or support our operations so we can provide the best experience to you.

HOW WE COLLECT INFORMATION ABOUT YOU

Directly From You

You may provide us with personal information in a number of ways, namely when you:

• Access our Sites, applications, and other digital channels by signing up, creating accounts (including using social media login), filling out forms, using chat services, commenting, or otherwise engaging with our online Services;
• Communicate with us by e-mail or phone;
• Subscribe to e-mails, newsletters, or other features made available on our Sites or apps from time to time;
• Report a problem or request support for any of our Services;
• Apply to, register for, inquire about or participate in our school, camps, programs, competitions or events;
• Interact with our social media;
• Interact with performance technology or platforms we make available to you;
• Subscribe to or otherwise view our content online, including any of our online social media channels official videos, or participate in our online streaming events, such as academy, schools, or events; Attend any event using our Services (e.g. ticket scanning, CCTV, and other on location interactions you may have with us);

Information We Collect From Other Sources

We work closely with our affiliates that are part of Endeavor to provide our Services, market to you and to provide a seamless service across different businesses.

We work closely with third parties and may receive personal information about you from them, such as: technology, customer support service partners, and other service providers (to seamlessly provide our services to you), fraud and cybersecurity companies (that protect our Services and information from fraud or other cyber threats) event registration companies and venue providers (that enable you to register for our events, academies, camps, etc., and host events and provide various marketing, advertising, customer support, and security services related to events), cookies and similar tracking technologies (information that is automatically collected when you visit our Sites), , marketing, media and digital content partners (IP addresses and email addresses to market our products and services and create look alike audiences), partners and sponsors (who partner with us or sponsor our events), performance technology platforms (to enhance our service offering to you by providing performance statistics and analytics), ticketing providers (that provide services supporting our sale of tickets for our events), promotions companies (who assist in operating and managing promotions), reservation booking platforms (that enable you to book a reservation at our hotels or country club, and enable us to track your stay at our hotels, , advertising networks (such as Google/Bing), analytics providers, payment providers and processing companies (that process your purchases of our Services and fulfill your payments on our behalf, by providing us with your billing and purchase information), e-commerce platforms (that provide platforms enabling you to purchase our Services (e.g., merchandise, tickets to events, etc.) and fulfill your orders on our behalf) academic institutions, sports/athletics leagues, colleges and universities, conferences, and governing bodies (the institutions you may attend or are interested in attending, or that may be interested in recruiting you to attend their institution), recruiters (that seek your interest in our Services and provide your contact information to us),  lead generation partners, (which provide us with your information if you are interested in receiving our Services or communicating with us), directly managed hotels and travel bookings (that enable us to facilitate your travel to/from our events, academies, camps, and clubs), third party data providers (that provide us with information regarding individuals interested in our services or the services of our affiliates), and certified testing centers (for purposes of assisting with standardized and college placement testing).

We may also receive and display personal information and content which is or you make publicly available on your social media account when you use social media logins for our Services or interact with any of our content (such as contests or when you post using one of our promoted hashtags). For more information see the “SOCIAL MEDIA” section below.

INFORMATION WE COLLECT AND HOW WE USE IT

If you are located in California, Nevada, the European Economic Area, the United Kingdom, Brazil, Mexico, India, Japan, South Korea or China, please also refer to the specific section below that is relevant to you.

 

Categories of personal information  collected	Business or commercial purposes for collection, use, and sharing personal information	Affiliates/Categories of third parties with whom personal information is shared for a commercial or business purpose	Affiliates/Categories of third parties with whom personal information is sold for CCPA purposes
Personal and online identifiers (such as first and last name, email address, phone number, usernames, or unique online identifiers)	To provide and improve the Services Personalize the Services, including assisting individuals with admissions and helping  individuals get recruited Customer support partners Marketing and targeted advertising Security and fraud prevention Admissions and recruiting	Customer support partners Marketing sponsors and partners Ad networks E-Commerce vendors Endeavor Analytics services Technology service providers Leagues, Conferences, Colleges and Universities, and Governing Bodies Recruiters	Marketing partners Leagues, Conferences, Colleges and Universities, and Governing Bodies Recruiters Endeavor
Financial Account Information (such as credit card numbers, bank account information, Paypal account information)	To provide the Services To sell you merchandise and/or tickets	E-Commerce vendors Payment providers Fraud and cybersecurity companies Endeavor	Endeavor
Personal Information categories listed in the California Consumer Records statute (e.g., Government IDs, such as driver’s license or passport)	To provide travel related services, such as when you stay at our hotels, or attend our academies, camps, clubs, or events	Endeavor Directly managed hotel bookings Directly managed travel (such as charter flights)	Endeavor
Travel Information (such as loyalty cards, bookings, itineraries)	To provide travel-related services	Endeavor Directly managed hotel bookings Directly managed travel (such as charter flights)	Endeavor
Customer Profile Information (such as race, gender, age range, income range, ad demographics, academic information, sport information, photos, and videos)	To provide and improve the Services Personalization of the Services Direct marketing Targeted advertising Analytics Research and development Security and fraud prevention Admissions and recruiting	Endeavor Analytics services Ad networks Technology service providers Marketing sponsors and partners Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Endeavor
Commercial and Transactional Information	To provide and improve the Services Customer support partners Analytics Research and Development	Endeavor Analytics services Technology service providers E-Commerce Vendors Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Endeavor
Communications with you (such as customer support messages, emails, chatbots, social media posts)	To provide and improve the Services Customer support partners	Endeavor Analytics services Technology service Providers E-Commerce vendors Customer Service Partners	Endeavor
Internet Activity Information  (such as browsing history, search history, interactions with a website, email, application, or advertisement)	To provide and improve the Services Personalization of the Services Direct marketing Targeted advertising	Endeavor Technology service providers Analytics services Ad networks	Marketing partners Ad networks Endeavor
Performance Data (including movement output,  information about your wellbeing and sleep habits, heart rate information, height body composition, health assessment information, etc.)	To provide and improve the Services Personalization of the Services Enhancing event, competition and training experiences Research and Development Analytics Recruiting	Endeavor Technology Service Providers Marketing sponsors and partners Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters Analytics Services	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Endeavor
Education/Academic and learning information	Admissions and class placement To provide and improve the Services Personalization of the Services Research and development Class selection Recruiting	Endeavor Technology service Providers Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Leagues, Colleges and Universities, Conferences and Governing Bodies Endeavor
Non-Precise Geolocation information (such as zip or area code, state, country)	To provide and improve the Services to you Personalization of the Services Fraud and cybersecurity Direct marketing Targeted advertising	Endeavor Ad networks Technology service providers Marketing sponsors and partners Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters Endeavor
Precise Geolocation (such as full address or specific location while at an event)	To provide and improve the Services to you Personalization of the Services Direct Marketing Fraud and cybersecurity	Endeavor Ad Networks Technology service providers Marketing sponsors and partners Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Endeavor
Sensory information (such as audio, video, photos, electronic, visual, or similar information)	To provide and improve the Services, for example,  when you interact with certain apps at our school, camps, events or competitions, including, uploading of photos and videos Personalization of the services Marketing and promotion of the Services Enhancing live event experiences Research and development	Endeavor Technology service providers Marketing sponsors and partners Leagues,  Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Leagues, Colleges and Universities, Conferences and Governing Bodies Endeavor
Dietary Preferences	To provide and improve the Services Personalization of the Services	Endeavor	Endeavor
Medical Information (such as, COVID testing, an athlete’s medical history, or similar information)	To provide and improve the Services Personalization of the Services To enhance public safety To protect our customers	Endeavor Johns Hopkins All Children’s Hospital	Endeavor
Biometric Data	To provide and improve the Services	Endeavor Johns Hopkins All Children’s Hospital	Endeavor Medical services partners
Inferences drawn from the above information about your predicted characteristics and preferences	To provide and improve the Services Personalization of the Services Direct marketing Targeted advertising Analytics	Endeavor Ad networks Marketing sponsors and partners Technology service providers Analytics companies Leagues, Colleges and Universities, Conferences, and Governing Bodies Recruiters	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Third party data providers Recruiters Endeavor
Other information about you that is linked to the personal information above	To provide and improve the Services Personalization of the Services	Endeavor Ad networks Marketing sponsors and partners Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters	Marketing partners Ad networks Leagues, Colleges and Universities, Conferences and Governing Bodies Recruiters Endeavor

 

We may also use personal information we have about you

• as necessary if we believe there has been a breach of the registration materials, Terms of Use or the rights of any third party,
• as necessary to assist in the investigation of potential criminal activity or other activity that is in violation of our rules, regulations and policies, including, but not limited to, the IMG Academy Student Handbook;
• to comply with legal and regulatory requirements.

We combine personal information we receive from other sources with personal information you give to us and personal information we collect about you. We use this combined information for the purposes set out above. We may use data that has been anonymized or aggregated without limitation in a lawful manner.

DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information with Endeavor Group Companies and with selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in order to provide you with a product or service;
• except for EEA or countries that prohibit it, we may share your personal information with business partners, suppliers and sub-contractors to provide you with unsolicited direct marketing information about promotions and offers without asking for your consent;
• Non- personal, aggregated, anonymized or other data to advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We may also use aggregated information to help advertisers reach the kind of audience they want to target;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website.

In the event that we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets or transfer personal information held where it is one of the transferred assets;

• We may share your personal information if we are under a duty to disclose or share your data in order to comply with any legal obligation;
• in the event of an emergency;
• in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of Endeavor, our customers, clients or individuals; or
• if you consent to allow us to share your information.
• .

MARKETING AND

Targeted Advertising

We use personal information, with your consent where required, to tailor our marketing and advertising efforts. To do this, we provide personal information to third party advertising networks (such as Google Doubleclick) and social media companies (such as Facebook). When we provide personal information to agencies, ad networks, and other parties for targeted advertising, we do not provide them with your name, financial information, or any sensitive information (such as a government ID or date of birth, if we have collected that). We use online identifiers such as email, cookie addresses, and device identifiers to help us provide targeted advertising to you and others like you. We may also use aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected about you to enable us to display advertisements to target audiences.

To opt out of targeted advertising, you may use the following links provided by third parties that manage opt outs for some ad networks:

http://preferences-mgr.truste.com,
http://www.networkadvertising.org/managing/opt_out.asp
http://www.aboutads.info/
https://policies.google.com/privacy/partners

Email Marketing

• With your consent where required, we also add you to our mailing lists for email communications from us, our affiliates, and our partners when you sign up for our mailing lists, apply, register, inquire about or participate in our school, camps, programs, competitions or events, make a reservation at our hotel or country club, purchase a ticket or our merchandise, or subscribe to our content online. If you provide us with your email address in order to receive communications, you can opt out at any time by using the unsubscribe links at the bottom of our emails.

 

• ADVERTISING AND SOCIAL MEDIA
• We, and/or our Endeavor Group Companies, engage in on-line advertising that appears on third party websites to keep you aware of our brands, events, products and services. We do this using a variety of digital marketing networks and a variety of advertising technologies like pixels, ad tags, cookies and mobile identifiers as well as service providers such as Google and Facebook. The banners and ads you see will be based on information we hold about you, from what you’ve bought or responded to in the past or your customer journey on our websites. We encourage you to become familiar with our Cookie Policy. We are not responsible for the data and information treatment employed by other third party websites where our advertising is displayed (our Privacy Policy only refers to our websites), so please always read the privacy policy on third party websites.
• COOKIES

We and trusted third parties use cookies and similar technologies on the Site to collect and process personal information. For more information, please see our Cookie Notice by interacting with the cookie banner on our Site and selecting “Cookie Settings.”

DO NOT TRACK

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Like many websites, our Sites are not currently able to respond to these “do-not-track” signals. To learn more about “do-not-track” signals, you can visit http://www.allaboutdnt.com/.

To submit a Do Not Track request on mobile using an iOS device:

• launch the Settings app on your iPhone → Privacy → Advertising.
• toggle ON the switch next to Limit Ad Tracking.
• now that you have opted out of receiving ads targeted to your interests, based on your Apple ID on that device, you will be removed from the list of users receiving targeted ads.

To submit a Do Not Track request on mobile using an Android device

• open Google Settings,
• select AdsPrivacy.and toggle ON the switch next to Do Not Track to opt out of Ads Personalization. Do Not Track is now enabled on your Android device.
• Apps are then instructed not to use your advertising ID to build profiles or show you personalized ads.

Some devices may require a different procedure, so please check your instructions.

STORAGE AND TRANSFER OF INFORMATION

We operate the Services and store personal information about you in and from a number of different jurisdictions, including the United States, the United Kingdom (the “UK”) and European Economic Area (the “EEA”), but the Site is primarily operated from the United States. The personal information that we collect from you will be transferred to and stored at/processed in countries outside of your location. Personal information about you is processed by staff operating outside of your respective country who work for us or our third party service providers. Personal information about you may be disclosed in response to inquiries or requests from government authorities or to respond to legal process in the countries in which we operate and/or store personal information about you. We will take steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. For any transfers outside the UK or EEA, we transfer information to be able to perform our Services under our contract with you.  We also enter the European Commission’s model contracts for the transfer of personal information to third countries (i.e. the standard contractual clauses), or, for transfer out of the UK only, any similar model contracts approved by the UK Information Commissioner’s Office with entities we share your data with.

CALIFORNIA PRIVACY RIGHTS

In the past 12 months, we collected, use, shared, and sold (as defined within the California Consumer Privacy Act (“CCPA”)), the categories of personal information detailed in the chart above in the “INFORMATION WE COLLECT AND HOW WE USE IT” section. As also noted above, we sell personal information as that term is defined in the CCPA.

California residents have certain rights with respect to the personal information collected by businesses under the CCPA. If you are a California resident, you may exercise the following rights regarding personal information about you, subject to our ability to verify your request and certain other limitations:

• Information about You. You may ask for us to state what categories of personal information about you we have, and the categories of sources from which we collect personal information about you;
• Receive a Copy of Your Data. You may request the categories and specific pieces of information (if any) we have about you, the categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties with which we have shared personal information in the previous 12 months.
• Delete Your Data. You may request that we delete the personal information we have collected from you.
• Do-Not-Sell. You may opt out of our sale(s) of personal information about you, as “sale” is defined by California law. Please see above for more information.
• Non-Discrimination. California law prohibits discrimination against you for exercising your privacy rights.

 

In addition, California’s “Shine the Light” law permits users of our Services, who are California residents to request certain personal information regarding our disclosure of personal information to third parties for their direct marketing purposes.

 

How to Exercise Your Rights. To exercise any of the above rights, please follow the instructions below:

• By phone at 1-866-983-0571
• Online by using this webform [Link]

 

If you have any other request you wish to submit to the Privacy Team, you may submit a general request [here].

 

Verification Process and Required Information. All requests must be verified.  Some requests, including receiving a copy of personal information about you or requests made by an agent claiming to be acting on your behalf, are subject to heightened requirements.  If we cannot verify your identity based on the personal information provided, a request for a copy of personal information about you shall be treated as a request for information and if we cannot verify your identity, a request to delete personal information may be treated as a request to opt-out of the sale of personal information.

Authorized Agent. You may designate an authorized agent to make a request on your behalf. An Authorized Agent must have written documentation of their authority to act on your behalf, such as a Power of Attorney.

NEVADA

Under Nevada law, you may direct a business that operates an internet website not to sell certain personal information a business has collected or will collect about you. Nevada residents who wish to exercise their right to opt-out of a sale under Nevada Revised Statutes Chapter 603A may submit a request by submitting the webform or calling 1-866-983-0571.

OPTING IN TO/OPTING OUT OF THE SALE OF PERSONAL INFORMATION

We share personal information about you with sponsors, vendors, Endeavor, technology partners, and third party advertising networks (as discussed above in the “INFORMATION WE COLLECT AND HOW WE USE IT” section). These transfers, which are used to provide you with certain Services and/or to more effectively provide you with personalized Services (including advertising), can be deemed a sale under some data privacy laws, including the California Consumer Privacy Act and Nevada law.

You may opt out of the sale of personal information about you by clicking on the Do Not Sell My Personal Information link on the appropriate Site or calling 1-866-983-0571. You will be asked to provide certain information to us in order to exercise this option so we can verify your identity and locate your records with us.

If you are a 13-16 years old, you may opt in to the sale of personal information, including by submitting a request through this webform.

Please note if do not provide us with certain information, we are unable to provide you with certain corresponding Services.

CANADA, EEA AND UK

 

If you are in Canada, the EEA or UK, the disclosures set out below apply to you (as applicable) in addition to the disclosures set out in the general sections of this Privacy Policy.

We are a limited liability corporation established in Delaware with a registered office at 11 Madison Ave., 17^th Floor, New York, NY 10010  and for the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and the UK General Data Protection Regulation and/or the UK Data Protection Act 2018 (together, the “UK GDPR”), we are the data controller. Our UK affiliate, International Management Group (UK) Limited (Companies House Reg.: 00946580) is established in England & Wales with registered office at , United Kingdom, W4 5HR. Our EU data protection officer can be reached at imgperformanceprivacy@img.com.

 

We process personal information about you on the legal basis specified in the table.

Categories of personal information we collect	Why we collect this information	Legal basis we rely on to collect this information
Personal and online identifiers (such as first and last name, email address, phone number, usernames, or unique online identifiers)	Provide the Services Personalize the Services, including assisting  individuals with admissions and helping  individuals get recruited Customer support	Necessary to perform our contract with you and to provide the Service
	Marketing and targeted advertising	With your consent
	Security and fraud prevention Improve the Services	It is in our legitimate interests to ensure the security of our Service and improve our Services
Financial Account Information (such as credit card numbers, bank account information, Paypal account information)	Provide the Services, including selling merchandise and/or tickets	Necessary to perform our contract with you and to provide the Services
Personal Information categories listed in the California Consumer Records statute (e.g., Government IDs, such as driver’s license or passport)	Provide travel-related services	Necessary to perform our contract with you and to provide the Services
Travel Information (such as loyalty cards, bookings, itineraries)	Provide travel-related services	Necessary to perform our contract with you and to provide the Services
Customer Profile Information (such as gender, age range, income range, ad demographics, academic information, sport information photos, videos)	Provide the Services Personalize the Services	Necessary to perform our contract with you and to provide the Services
	Admissions and recruiting	Necessary to perform our contract with you and to provide the Services
	Direct marketing Targeted advertising	With your consent.
	Analytics	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs and improve the operation of our Services
	Research and development Security and fraud prevention Improve our Services	It is in our legitimate interests to ensure the security of our Service and improve our Services
Customer profile information – race	Improve our Services by conducting equal opportunities monitoring	With your consent. As your race is special category data, the additional legal basis for processing we rely on is: your explicit consent.
Commercial and Transactional Information	Provide our Services Customer support	Necessary to perform our contract with you and to provide the Service and customer support  and it is in our legitimate interests to improve our Services
	Analytics	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs and improve the operation of our Services
	Research and development Improve our Services	It is in our legitimate interests to improve our Services
Communications with you (such as customer support messages, emails, chatbots, social media posts)	Provide and improve the Services Customer support	Necessary to perform our contract with you and to provide the Service and customer support and it is in our legitimate interests to improve our Services.
Internet Activity Information  (such as browsing history, search history, interactions with a website, email, application, or advertisement)	Provide the Services Personalize the Services	Necessary to perform our contract with you and to provide the Service
	Direct marketing Targeted advertising	With your consent
	Improve our Services	It is in our legitimate interests to improve our Services
Performance Data (including movement output, information about your wellbeing and sleep habits, heart rate information, height body composition, health assessment information, etc.)	Provide the Services Personalize the Services	Necessary to perform our contract with you and to provide the Services
	Analytics	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs and improve the operation of our Services.
	Recruiting	It is in our legitimate interests to improve our Service Necessary for our legitimate interests to ensure the success of our recruitment practices.
	Research and Development Improve our Services, including enhancing events, competition and training experiences	It is in our legitimate interests to improve our Services
Academic and learning information	Admissions and class placement Provide and improve the Services Personalize of the Services Class selection	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Services.
	Research and Development	It is in our legitimate interests to improve our service
	Recruiting	Necessary for our legitimate interests to ensure the success of our recruitment practices.
Non-Precise Geolocation information (such as zip or area code, state, country)	To provide and improve the Services to you Personalization of the Services	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Services.
	Fraud and cybersecurity	It is in our legitimate interests to ensure the security of our Service and improve our Services.
	Direct marketing Targeted advertising	With your consent.
Precise Geolocation (such as full address or specific location while at an event)	To provide and improve the Services to you Personalization of the Services Fraud and cybersecurity	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Service.
	Direct Marketing	With your consent.
Photographs and Videos of you	To provide the Services, for example,  when you interact with certain apps at our school, camps, events or competitions, including, uploading of photos and videos Personalization of the services	Necessary to perform our contract with you and to provide the Service
	Enhancing live event experiences Research and development Marketing and promotion of the Services	It is in our legitimate interests to improve our Services
Dietary Preferences	To Provide the Services	Necessary to perform our contract with you and to provide the Service.   To the extent that your dietary preferences reveal information regarding your religion (e.g. Kosher), the additional legal basis for processing we rely on is: with your explicit consent.
Medical Information (such as, COVID testing, an athlete’s medical history, or similar information)	To Provide the Services, as we must ensure the health of  individuals To enhance public safety To protect our customers	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Service.   As health data is special category data, the additional legal basis for processing we rely on is with your explicit consent
Inferences drawn from the above information about your predicted characteristics and preferences	To Provide and improve the Services Personalization of the Services	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Service.
	Direct marketing Targeted advertising	With your consent.
	Analytics	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs and improve the operation of our Services
Other information about you that is linked to the personal information above	To Provide and Improve the Services Personalization of the Services	Necessary to perform our contract with you and to provide the Service and it is in our legitimate interests to improve our Service.

 

Automated Decision Making

We will make automated decisions regarding you and using your information.

We use automated decision making to segment and target product offers based on our customers’ demands and needs.

If you disagree with the decision you are entitled to contest this by contacting us here.

Depending on your location, certain laws apply to you and personal information about you, you have certain rights in relation to personal information about you:

 

• You have the right to access personal information we hold about you and ask us for other information such as purposes of processing, categories of personal information and recipients of the information.
• You have the right to request a copy of personal information about you and request that we transfer it to a third party (with certain exceptions).
• You may be entitled to request correction of any personal information about you which is incomplete or inaccurate.
• In certain circumstances, you have the right to request deletion or erasure of the personal information we hold about you.
• Restriction of processing to storage only. You have the right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances.
• Objection. Where we are processing personal information about you on the basis of legitimate interests, you have the right to object to our processing of personal information about you. You also have the right to object to marketing at any time by opting out at the bottom of our emails to you.
• Withdrawal of Consent: Where we rely on consent to process personal information about you, you have the right to withdraw this consent at any time by contacting us using the webform .

You may also have the right, in certain circumstances, to object to our processing personal information about you. However, we may be entitled to continue processing it in line with applicable law. Where we rely on consent to process personal information about you, you have the right to withdraw this consent at any time.

 

These rights apply under and subject to applicable law and in many cases are limited by applicable law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property or where there are overriding public interest reasons or where we are required by law to retain personal information about you. If you want to exercise any of these or other rights under applicable law, please contact us using the webform. We may require you to prove your identity with approved identification. We will respond to any requests to exercise your rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).

 

You may also have the right, where provided under applicable law, to ask us to stop processing personal information about you for direct marketing purposes. You can exercise this right by checking certain boxes on the forms we use to collect personal information about you or by clicking “unsubscribe” on the emails you receive.

We will retain personal information about you for as long as needed to provide you with services you have requested. We will retain and use personal information about you as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

 

If you have complaints about how we process personal information about you, please contact us using the webform and we will respond to your request as soon as possible. If you think we have infringed data protection laws, you can file a claim with (as applicable to where you are located) the Office of the Privacy Commissioner of Canada or provincial Privacy Commissioner, the UK Information Commissioner’s Office or the data protection supervisory authority in the European Union country in which you live or work.

 

BRAZIL

If you are in Brazil, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy.

If the Brazilian Data Protection Law (Law No. 13,709/2018 or “LGPD”) applies to you and personal information about you, you have certain rights in relation such personal information:

 

• Access. Right to obtain a confirmation if personal information related to you are being processed and, where that is the case, have access to them.
• Right to obtain the correction of inaccurate personal information about you;
• Erasure. Right to obtain the erasure of personal information about you.
• Restriction of processing. Right to obtain a restriction of processing in certain circumstances;
• Portability. Right to receive such personal information and transmit those data to another data controller.
• Object. Right to object to our processing of such personal information in certain circumstances.
• Withdrawal of consent. Where an instance of processing is based on consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on the consent prior to the withdrawal.
• Right to lodge a complaint with the supervisory authority. Right to lodge a complaint with the competent Brazilian supervisory authority.

 

We will respond to requests to exercise your access right without undue delay and within fifteen days, thought this may be extended as permitted in certain circumstances.

 

We will retain personal information about you for as long as needed to provide you with services you have requested. We will retain and use personal information about you as necessary to comply with our legal obligations and to resolve disputes.

 

If you want to exercise any of these or other rights under the LGPD, please contact us using the webform.

 

MEXICO

If you are in Mexico, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy.

Data Controller. The data controller of personal information about you is IMG Academy Parent, LLC  located at 11 Madison Ave., 17^th Floor, New York, NY

Sensitive Data. Some of the personal information that we collect from you may be considered sensitive data, including your medical/health information and, under certain circumstances, your biometric data.

 

Purposes of Processing. Some of the purposes of processing stated above are voluntary purposes, including marketing and targeted advertising. You may object to the processing of personal information about you for voluntary purposes as stated in the section “Your rights” below in this section.

 

Data Transfer Consent. We require your consent to transfer personal information about you to the entities mentioned in this Privacy Policy, except when the transfer is to companies within our corporate group, such as Endeavor, authorities to comply with legal/authority requirements or defend our rights, or to entities acting on our behalf (data processors).

 

By using the Site and providing us with personal information about you, or otherwise interacting with us, as well as by providing us your explicit written consent on the forms we use to collect personal information about you (where applicable) you agree to the data transfers detailed in this Privacy Policy that require your consent. You may exercise your rights in connection with personal information about you as stated in the section “Your rights” below.

 

Your Rights. You have the following rights in relation to personal information about you:

 

• Access. You have the right to access personal information we hold about you and ask us for other information such as purposes of processing, categories of personal information and recipients of such information.
• Correction. You may be entitled to request correction or update of any personal information about you which is incomplete or inaccurate.
• Erasure. In certain circumstances, you have the right to request deletion or erasure of the personal information we hold about you.
• Objection. You have the right to object to our processing of personal information about you for voluntary purposes or under other legitimate grounds.
• Withdrawal of Consent: Where we rely on consent to process personal information about you, you have the right to withdraw this consent at any time.
• Use and disclosure limitation. You have the right to request we limit the use and disclosure of personal information about you.

We may require you to prove your identity with approved identification to fulfill your request. We will respond to any request to exercise your rights within 20 days from the day we receive your request, and if your request is deemed valid, it will take effect within 15 days. These deadlines can be extended in extraordinary circumstances.

 

You can ask us to stop processing personal information about you for direct marketing purposes by checking certain boxes on the forms we use to collect personal information about you, by clicking “unsubscribe” on the emails you receive, and/or other mechanisms as described in this Privacy Policy or within the communication we send you.

 

To exercise your rights, know more about your rights, as well as the applicable means, procedures, and requirements to exercise any of them, please contact us using the webform.

 

INDIA

If you are in India, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy.

Age Restrictions. Children under the age of 18 may not use our Services, without providing parental/legal guardian consent.

 

Sensitive Personal Information. Under applicable law, Sensitive Personal Information is passwords, financial information such as bank account, credit card, debit card or other payment instrument details, biometric data, physical or mental health details, sex life or sexual orientation, and/or medical records or history, biometric, genetic and gender related information, caste or ethnicity, religious or political affiliations and similar information, excluding information available in the public domain, or accessible by exercise of statutory rights under Indian laws.

 

Withdrawal Of Consent. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities, and correct or update personal information about you by contacting our data protection officer at imgperformanceprivacy@img.com or using the webform. Where consent is required to process personal information about you, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Your request to withdraw your consent shall not (i) apply retrospectively, or (ii) require deletion of records required for statutory purposes.

 

JAPAN

If you are in Japan, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy.

Minimum Age. Parental/legal guardian consent is required for children under the age of 20, you must obtain your parent’s or legal guardian’s consent to use our Services.

Information we collect and how we use it. The table above in the “INFORMATION WE COLLECT AND HOW WE USE IT” section applies mutatis mutandis to our collection and handling of personal information about you by:

• replacing the names of columns “Business or commercial purposes for collection, use, and sharing personal information” and “Affiliates/Categories of third parties with whom personal information is shared for a commercial or business purpose” with “Purposes for collection, use, transfer and joint-use of personal information” and “Our group companies and the Joint-use Third Parties with whom personal information is jointly used“, respectively; and
• adding “transfer to third parties” as a purpose to each category in the “Purposes for collection, use, transfer and joint-use of personal information” column.

Joint-use Third Parties. We and third parties whose handling of personal information is reasonably regarded as equivalent to the handling of personal information by IMG Academy Parent, LLC (“Joint-use Third Parties“) may jointly use, share, or process personal information about you, within our group companies (i.e., Endeavor) and with our Joint-use Third Parties (if any). Consent to a Sale of Personal Information. You consent to the sale of personal information about you to third parties by us based on your consent to the transfer of personal information about you to third parties. You may request us to cease the sale of personal information about you at any time via the webform.

Collection of Special Care-required Personal Information. The categories of personal information specified in above table may include “special care-required personal information” (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

 

Your Rights. You may request us to notify you about the purposes of, use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of personal data about you which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at imgperformanceprivacy@img.com or using the webform.

 

SOUTH KOREA

If you are in South Korea, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy above.

Items of Personal Information Processed. Please refer to the table under “INFORMATION WE COLLECT AND HOW WE USE ITfor the items of personal information processed by us.

Period of Retention and Processing of Personal Information. In principle, when the purposes of collection and use of personal information are achieved, we will destroy the personal information without undue delay. However, if any personal information is required to be retained under applicable law, such information will be retained for the period and purpose as prescribed by law.

Examples of retention prescribed by law are as follows:

• Act on the Consumer Protection in Electronic Commerce (Article 6)
  • contract or records of rescinding of offer, etc. (5 years)
  • records of settlement or rendering of services (5 years)
  • records of consumer complaints or consumer disputes (3 years)
• Protection of Communications Secrets Act (Article 15-2)
  • Record of computer communication or Internet log, trace data of access point (3 months)

 

Process and Method of Destruction of Personal Information. Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be processed, will be destroyed in an irreversible way, unless we are required to retain them for a longer period under applicable laws. Personal information stored in electronic files will be deleted in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating. Furthermore, measures will be taken to store by segregating the personal information which is required to be retained even after the expiration of the retention period or whose purpose of collection and use is fulfilled under applicable laws from other personal information.

Delegation of Processing of Personal Information. We delegate the processing of personal information as described below, and the delegatees may process personal information according to the purpose of the delegation:

Delegatee	Description of Delegated Services
Atlas/Atlarge	Processes online orders for shopimg.com and sends order & customer data to CRM
Rarecrew	Processes all customer information in relations to CRM integrations, receives customer data to import as leads into CRM, etc.
Lamark Media	Receives customer information to build lookalike audiences for paid media marketing campaigns
Revoptimum

Data Transfers to Overseas Country and Provision of Personal Information to Third Parties. follows:

Recipient (Contact Information of Information Manager)	Country to which Personal Information is to be Transferred	Date and Method of Transfer	Items of Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
IMG Academy (please see “Contact” section below)	USA	Via online              network upon       collection	All collected          personal information	Please see “INFORMATION WE COLLECT AND HOW WE USE IT” section of this Privacy Policy	Please see “PERIOD OF RETENTION AND PROCESSING OF PERSONAL INFORMATION” section above
Endeavor Group Holdings (imgperformanceprivacy@img.com)	USA	Same as above	Same as above	Same as above	Same as above
IMG Academy Golf Club (imgperformanceprivacy@img.com )	USA	Same as above	Name, email and certain other information as necessary to provide the services	Same as above	Same as above
Johns Hopkins All Children’s Hospital (hipaa@jhmi.edu )	USA	Same as above	All collected          personal information	Same as above	Same as above
Kitman Labs (dpo@kitmanlabs.com )	USA	Same as above	All collected          personal information	Same as above	Same as above
Google	USA	Same as above	Name, email address and certain other information as appropriate	Same as above	Same as above
Facebook	USA	Same as above	Name, email address and certain other information as appropriate	Same as above	Same as above

 

Rights of Data Subjects and Methods to Exercise Such Rights. You may exercise rights related to the protection of personal information by requesting access to, correction, deletion or suspension of processing of personal information about you,  in writing or via email, fax, phone, etc. pursuant to applicable laws. You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise such rights. However, in this case, you must submit a power of attorney to us in accordance with applicable laws. Upon your request, we will take necessary measures without delay in accordance with applicable laws. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

In accordance with the Personal Information Protection Act (“PIPA”), we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc.  We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information.  Specific considerations are as follows:

 

• Whether the additional use/provision is related to the initial purpose of the collection;
• Whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
• Whether the additional use/provision unfairly infringe on the interests of the data subject; and
• Whether the necessary security measures such as pseudonymization or encryption were taken.

 

Contact. If you have any questions or comments about this Privacy Policy and/or this section, if you need to report a problem, or if you would like us to update, amend, or request deletion of the information we have about you, please contact our data protection officer or Privacy Team at:

• Data Protection Officer Name: Valerie Alou

Telephone Number: 1-866-983-0571

E-mail: imgperformanceprivacy@img.com

 

Domestic Privacy Representative

The information regarding the domestic agent is as follows:

 

• Steve Jeong
• 5th Floor Find Gangnam Building 21, Teheran-ro 8 gil Gangnam-gu, Seoul, Korea 06234
• imgperformanceprivacy@img.com
• 1-866-983-0571

CHINA

If you are in China, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy above.

Age Restrictions. Children under the age of 18 may not use our Services, without providing parental/legal.

 

Sensitive Personal Information. Under applicable law, “sensitive personal information” means personal information the divulgence, illegal provision or misuse of which may endanger the bodily or property safety or may probably result in damage to personal reputation or bodily or mental injury or discrimination, which may be composed of data concerning race, religion, political position, personal property, personal health and physiological information, personal identity and network identifier data. Your sensitive personal information such as bank account, credit card, debit card or other payment instrument details, government IDs, browsing history, search history, performance data (including movement output, information about your wellbeing and sleep habits, heart rate information, height body composition, health assessment information, etc.), precise geolocation, dietary preferences, medical information (such as, COVID testing, an athlete’s medical history, or similar information), biometric data, and similar information may be collected by us.

 

.

Permissions. In order to provide related services, we need your authorization to open the following related permissions to collect related information. If you refuse to enable relevant permissions, you may not be able to obtain related functions or services.

• Location services (location data is not stored)
• Camera access
• Microphone access
• Photos access
• Documents access

 

Consent storage of personal information outside of China.

Your Rights. You may exercise rights related to the protection of personal information about you:

• Access. You have the right to access personal information about you, except as provided by laws and regulations;
• Correction. When you find any error about personal information about you processed by us, you have the right to request us to make corrections; and
• Deletion. If our processing of personal information violates laws and regulations, or if we collect, use, or process personal information that is not covered in this letter and without your consent, you can request us to delete personal information about you;
• Withdraw Consent. You may have a right to withdraw your authorization and consent at any time;
• Account Deregistration. You may deregister your account in our online services at any time, and we will delete such account as soon as practicable. Please note that, the deregistration of the account will result in an irrevocable removal of all of personal information about you, including but not limited to your account information.

 

If you wish to exercise such rights, you may direct your request to us using the contact details set out below, and we will reply to you within 15 working days from receipt of such inquiry.

 

Contact. If you have any questions or comments about the Privacy Policy and/or this China Section, if you need to report a problem, or if you would like us to update, amend, or request deletion of the information we have about you, please contact us at imgperformanceprivacy@img.com or the webform.

SECURITY

We use a variety of administrative, physical, and technology solutions to protect your data from unauthorized access, loss, or misuse. Because there is always some risk in transmitting data over the internet and otherwise processing data, we cannot and do not guarantee or warrant the security of any data that you transmit on or through the Services or that we otherwise maintain.

LINKS TO THIRD PARTY WEBSITES

Our Services, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others, including our partner networks, retail partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

UPDATES

Any updates we may make to our Privacy Policy will be posted on this page, and we may also provide a website notice of any material changes for a reasonable period of time. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use the Services.

CONTACT

Questions or comments regarding this Privacy Policy should be submitted to us using the webform here or at imgperformanceprivacy@img.com.