Privacy Policy

PRIVACY POLICY

This Privacy Policy was last modified on September 20, 2024.

California Notice at Collection/State Law Privacy Rights: See the State law privacy rights section below for important information about your rights under applicable state privacy laws.

European Users: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Canadian Users: Please see the Notice to Canadian Users section below for additional information for individuals located in Canada.

Velasa Sports. Inc. (“Sparx Hockey,” “we,” “our,” or “us”), provides this privacy policy to describe how we collect, use, and share the information of individuals who visit our website at sparxhockey.com (the “Site”) or interact with us through the Sparx Hockey App or Sparx Commercial App (the “App” or “Apps”) and Sparx internet-connected devices, including BEAM and Sparx Sharpener (the “Device” or “Devices”) (collectively, the “Services”).

PERSONAL INFORMATION WE COLLECT

Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
Demographic data, such as your city, state (or province), country of residence, and postal code.
Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, preferences, and any other information that you add to your account profile.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Payment dataneeded to complete transactions, including payment card information or bank account number.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

When Using the Apps and Devices. We may also collect information about you relevant to your use of the Apps and Devices, such as your name, phone number, age range, gender, associated Devices, and any other information associated with your Sparx account. In addition, for each Skater Profile you set up, we may collect:

Skater information, such as name, picture, skater weight and height, age.
Team information, such as team name, level, and logo.
Position information, such as forward, defense, goalie, or figure skater.
Product preference, such as grinding ring type, radius of hollow size, or skate blade profile.
Brand preference, such as brand of skates, blades, or other related equipment.
Device information, such as serial number and type of Device or Sparx Grinding Ring used, the date and time of sharpening, and other diagnostic data associated with the Device. This information may be collected with or without respect to an individual Skater Profile.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Private sources, such as data providers, social media platforms and data licensors.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic Data Collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location datawhen you authorize the Service to access your device’s location.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and Similar Technologies. Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes.

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail).  If you wish to disable cookies, you may do so through your individual browser options. The Help feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use the information we collect for any lawful purpose, including the following:

to fulfill your orders;
to establish and maintain your user account on the Service;
to respond to your inquiries, including questions about order status;
to operate and improve our Services, including for analytics purposes;
to understand your needs and interests, and personalize your experience with the Services and our communications;
to provide App users with information about your preferences if you provide them access to your Skater Profile;
to provide our commercial customers insights about their operations;
provide support and you troubleshoot the Services, and respond to your requests, questions and feedback.
to communicate with you about the Services, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
to facilitate social features of the Services, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality;
to enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
to provide third parties with information about the operation of our Services;
for marketing and advertising purposes, including to send updates, promotions, and marketing materials that may be of interest to you;
with third parties, including Advertising Partners as described in the “Marketing and Advertising” section of this privacy policy;
to communicate with you about events or contests in which you participate;
to comply with the law and otherwise in relation to legal proceedings
to protect our Services and our operations, our rights and property, and the rights and property of others, including to maintain the security of our Services; or
with your consent, or as otherwise disclosed at the time information is collected.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. Third-party ad servers or ad networks use technology in their respective advertisements and links that appear on www.sparxhockey.com and which are sent directly to your browser. They automatically receive your IP address when this occurs. Other technologies (such as cookies, JavaScript, or Web Beacons) may also be used by our site’s third-party ad networks to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on the site. Velasa Sports, Inc. has no access to or control over these cookies that are used by third-party advertisers. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the Terms and Conditions of Service that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics).

Advertising partners. Third-party advertising companies for the Interest-Based Advertising Purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles, and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and Protection Purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Velasa Sports, Inc., financing of Velasa Sports, Inc., public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Velasa Sports, Inc. as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

YOUR CHOICES

In this section, we describe the rights and choices available to all users. Users who are located in California, Europe, and Canada can find additional information about their rights below in the State Privacy Rights, Notice to European Users, and Notice to Canadian Users sections respectively.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. For information about cookies employed by the Service and how to control them, see the Cookies and Similar Technologies section above.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals except where we expressly indicate otherwise. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFER

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe and Canada should read the important information provided below about transfer of personal information outside of Europe contained in the applicable Notice to European Users or Notice to Canadian Users sections below.

CHILDREN

The Service is not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

HOW TO CONTACT US

Email: privacy@sparxhockey.com

Mail
Velasa Sports, Inc.
Attn: Privacy Officer 
30 Sudbury Road
Acton, MA 01720
USA

STATE PRIVACY NOTICE RIGHTS

Except as otherwise provided, this section applies to residents of California and other states where they have privacy laws applicable to us that grant their residents the rights described below, including the California Consumer Privacy Act (“CCPA”).

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply with respect to the activities it describes instead of this section.

Your privacy rights. You may have some or all of the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Right to information/know.You can request the following information about how we have collected and used your personal information during the past 12 months:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting and/or selling personal information.
- The categories of third parties with which we share personal information.
- The categories of personal information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
Right to access. You can request a copy of the personal information that we have collected about you.
Right to appeal. You can appeal our denial of any request validly submitted.
Right to correction.You can ask us to correct inaccurate Personal Information that we have collected about you.
Right to deletion. You can ask us to delete the personal information that we have collected from you. Please note that once we process a deletion request, we will be unable to provide any online or digital services to you or support for past products or services that you may have purchased.
Right to opt-out.
- Opt-out of tracking for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising (also known as interest-based advertising) purposes. Your request to opt-out will apply only to the browser and the device from which you submit the request.
- Opt-out of other sales of personal data.You can opt-out of other sales of your personal information. Although our Service is not intended for children under 16 years of age, we are required to inform you that we do not have actual knowledge that we have sold or shared the personal information of children under 16.
You are entitled to exercise the rights described above free from discrimination as prohibited by the state privacy laws.

Exercising your right to information/know, access, appeal, correction, and deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion at Privacy Data Request Form, calling us toll free at 855-772-7947, or via email to privacy@sparxhockey.com.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

Exercising your right to opt-out of the “sale” or “sharing” of your personal information. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The state privacy laws may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes or other sales of personal information here: Privacy Data Request Form , or via email to privacy@sparxhockey.com or via phone by calling 855-772-7947.

Verification of Identity. We may need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, authentication into your Service account, personal identifiers we can match against information we may have collected from you previously, confirmation of your request using the email or telephone account stated in the request, a declaration under penalty of perjury, or other information, where permitted by law.

Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Personal Information (“PI”) we collect	CCPA statutory category	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” or “share” PI
Contact data	Identifiers (online) Identifiers (other) Commercial information California customer records	Affiliate Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Demographic data	Identifiers (online) Identifiers (other) California customer records	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Account data	Identifiers (online) Identifiers (other) Commercial information California customer records	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Communications data	Identifiers (online) Identifiers (other) Commercial information California consumer records Internet or Network Information	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Transactional data	Commercial information California consumer records Financial information	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Marketing data	Identifiers (online) Identifiers (other) Commercial information California customer records Internet or Network Information	Affiliates Payment processors Professional advisors Authorities and others Business transferees	Advertising partners (to facilitate online advertising) Business and marketing partners
Payment data	Commercial information Financial information California consumer records	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Device data	Identifiers (other) Internet or Network Information	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Online activity data	Identifiers (other) Commercial information Internet or Network Information	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Communication interaction data	Identifiers (online) Identifiers (other) Commercial information California consumer records Internet or Network Information	Affiliates Service providers Payment processors Advertising partners Third parties designated by you Professional advisors Authorities and others Business transferees Business and marketing partners Other users and the public	Advertising partners (to facilitate online advertising) Business and marketing partners
Data derived from the above	Inferences	Affiliates Service providers Advertising partners •Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Other Sensitive Personal Information We do not intentionally collect this information, but it may be revealed in identity data or other information we collect	Protected Classification Characteristics	N/A	None

Additional information for California residents

Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.

Deidentification. We do not to attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Notice of financial incentive. We offer various programs that may constitute a “financial incentive” under the CCPA, such as our Sparx Hockey Customer Loyalty program and our email marketing campaign. The details of these financial incentives are described in the chart below and are subject to change. You have the right to withdraw from these programs at any time and may do so by following the instructions in the “How to withdraw from the program” column. The value of each incentive is reasonably related to the value of your data, including as applicable: the benefit and insights that we realize and expect to realize from your participation in our programs (such as shopping preferences and habits); the quantity and quality of information that you provide to us through your participation; sales directly or indirectly generated from your participation in the relevant program; and any increased goodwill towards us.

Program and material terms

How to opt-in to the program

Incentive offered for your participation

Personal Information we may collect though the program (see “Personal information we collect”)

How to withdraw from the program

Sparx Hockey Customer Loyalty Program

By joining this program, you will receive exclusive perks, privileges, and offers.

See terms and conditions HERE.

By creating an account at sparxhockey.com or on the Sparx Hockey App

A discount off your purchase, exclusive perks, privileges, and offers, or other similar benefit.

Contact data
Account data
Transactional data
Device data
•Online activity data

By submitting a request HERE.

Email Marketing Campaign

By joining this program, you will receive marketing emails from us.

By providing your email address to join our email marketing list.

A discount off your first purchase or other similar benefit.

Contact data
Device data
Online activity data

By following the unsubscribe link in our marketing emails.

NOTICE TO EUROPEAN USERS

General

Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.

Controller. Velasa Sports, Inc. is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can contact them directly should you wish:

Our Representative in the EU.

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Sparx Hockey has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

By using EDPO’s online request form: https://edpo.com/gdpr-data-request/
By postal mail to: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Our Representative in the UK.

Pursuant to Article 27 of the UK GDPR, Sparx Hockey has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

By using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request
By postal mail to: EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Demographic data Account data Communications data Transactional data Marketing data Payment data Data from Third Party Services Device data	Delivery and operations  Contractual Necessity. Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service, our business and associated IT services, systems and networks. Personalization Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences. Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Research and development	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in taking steps to ensure that our Service and how we use Personal Information is as un-privacy intrusive as possible.
Direct marketing	Contact data Demographic data Marketing data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Interest-based advertising	Device data Online activity data Location dat	Consent
Service improvement and analytics	Contact data Demographic data Communications data Account data Device data Online activity data Communication interaction data	Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business. Consent, in respect of any optional cookies used for this purpose.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We provide our analysis to our business customers and our business customers make decisions that may affect you.

Your additional rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Update. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe 

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

NOTICE TO CANADIAN USERS

General

Where this Notice to Canadian users applies. The information provided in this ‘Notice to Canadian users’ section applies only to individuals located in Canada. This section is intended to provide you with additional information about how we handle your personal information and your privacy rights.

Personal information. References to “personal information” in this Privacy Policy should be understood to include “personal information” as defined in the Personal Information Protection and Electronic Documents Act “PIPEDA” or any successor laws (i.e., contemplated to be the Consumer Privacy Protection Act), as well as all provincial laws deemed substantially similar.

Consent

No obligation to provide personal information. You do not have to provide personal information to us. You are consenting to our collection and use of your personal information when you voluntarily provide your personal information for a particular purpose, for purposes that a reasonable person would expect in the circumstances, and for the purposes described in this Privacy Policy. If you do not consent to our processing and use of your personal information in accordance with this Privacy Policy, you must not submit personal information through our Service. You may withdraw your consent at any time, subject to instances where we need to process your personal information either to comply with applicable law or to deliver our Service to you. We encourage you to read this policy and visit the website to keep up to date of any changes.

Marketing Communications

We will respect your marketing communications choices. We will only send you marketing communications if you have expressly opted-in, or if an exception to consent applies, such as when you have an active account with us or have made a purchase in the past two years. If you do not wish to receive marketing communications, you may choose to opt-out by using the unsubscribe link (or texting STOP to any text message) in our communications to you.

Other information

Collection and Sharing with certain third parties. We will not collect your personal information from private sources or affiliate partners as described above, except from publicly available social media, without your consent. We will only share your personal information with business and marketing partners as described above with your consent.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Data Processing outside your home province

Adequate protection for data transfers. We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside of Canada.

Where we share your personal information with third parties in other jurisdictions, we take steps to consider and try to ensure an appropriate degree of protection is afforded to it. We may use specific appropriate safeguards, which are designed to give personal information effectively the same protection, such as contracts with our third parties.

Your additional rights

General. Canadian privacy laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Canada, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Update. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where reasonable to do so.
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent.You have the right to withdraw your consent subject to legal requirements.

Exercising These Rights. You may submit these requests by contacting us. You may submit requests to exercise your rights, such as for access, correction, or deletion to Privacy Data Request Form, calling us toll free at 855-772-7947, or via email to privacy@sparxhockey.com.

We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee for access to your personal information. We will respond to your requests within a reasonable time and any legal limitations. In the event your request is particularly complex or if you have made a number of requests, it may take longer to process. In this case, we will notify you and keep you updated.

Our Privacy Officer. We have appointed a Privacy Officer, who is responsible for our compliance with applicable Canadian privacy laws and the practices described in this Privacy Policy. If you want to contact our Privacy Officer directly, you can email: privacy@sparxhockey.com.

If you have questions or concerns about how we handle your personal information or how we have responded to your request, please contact our Privacy Officer.

Your Right to Lodge a Complaint. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the applicable privacy commission or commissioner in Canada or in your province: