ATHLETE ONE, LLC PRIVACY POLICY
Effective Date: September 27, 2024
Last Updated: September 27, 2024
I. INTRODUCTION
Thank you for visiting Athlete One, LLC’s Online and Mobile Resources (defined below), and for viewing this
Privacy Policy. This Policy applies to any Online and Mobile Resource that links to this Policy, including
www.athleteone.com; www.totalglobalsports.com; and www.scoutingzone.com (collectively referred to as
“websites” herein). Our full Privacy Policy, contained in the pages that follow, serves to give notice to data
subjects, about the types of Personal Data (defined below) we collect as a controller, how we use it, who we
disclose it to and why, your rights with respect to your Personal Data, and what we do to try to protect it. This
Policy does not apply to our current or former workforce members or job applicants.
By interacting with our Online and Mobile Resources, you agree that your Personal Data will be handled as
described in this Policy. Further, by using our Online and Mobile Resources, you are signifying to us
that you have read and understand this Privacy Policy.
This Policy does not apply to websites, products and services of third parties which are subject to their own
privacy policies. Please read this Policy carefully to understand our procedures and practices regarding your
information and how we will treat it. If you do not agree with our Policy, procedures and practices, your
choice is not to use our Online and Mobile Resources. This Policy may change from time to time. Your
continued use of our Online and Mobile Resources after we make changes is deemed to be acceptance of
those changes, so please check the Policy periodically for updates.
This Privacy Policy is an important document that explains how we address some of our legal obligations,
and your related legal rights, involving Personal Data. The section immediately below will let you know how
we use certain words in this Policy:
When we reference "this Policy", "this Privacy Policy", “the Policy”, and "our Policy", we
mean the Privacy Policy you are reading now.
Wherever we say "we", "us", "our", or "Athlete One", we mean Athlete One, LLC or its affiliates, as
applicable.
When we talk about our "Online and Mobile Resources", we mean all websites, applications, portals,
or other features Athlete One operates, that link to this Policy.
1When we refer to "Personal Data" we mean information that identifies or can be used to reasonably
identify you, or that is otherwise treated as personal information or Personal Data under applicable laws (for
example, IP address, cookie IDs, device IDs). Where information does not qualify as Personal Data under
applicable law (e.g., information that has been anonymized, sufficiently de-identified or aggregated), we will
not treat it as such.
II. WHO DOES THIS POLICY APPLY TO?
This Policy describes our Personal Data practices regarding the following groups of data subjects:
• athletes or other individuals associated with the athletes that visit, use, access, or interact with our
Online and Mobile Resources, including youth players and their parents ("Players and
Parents");
• contact persons and representatives of sporting clubs and organizations putting on events, for
example to manage and operate youth soccer leagues or tournaments ("Clubs and
Organizations"); and
• coaches or representatives of the coaches or their organizations, including recruiters, scouts, and
athletes from universities and colleges (“Coaches”)
• contact persons and representatives of our third-party vendors and business partners ("Vendor
and Business Partner Personnel").
The categories of data we collect from each of these groups, and the ways in which we use it, differs.
a. Players and Parents
This Privacy Policy applies to Players and Parents using our Online and Mobile Resources, including any
interactions within our Online and Mobile Resources Players and Parents may have with Clubs and
Organizations and Coaches and any marketing content we may send out.
b. Clubs and Organizations
Clubs and Organizations enter into contracts with us. That contract is separate from this Policy and may
have its own terms and conditions for processing of Personal Data on their behalf and governing our overall
confidentiality, data privacy and data security obligations. As such, those terms, as opposed to this Policy,
may apply to the Personal Data that we process on behalf of Clubs and Organizations. However, we may
independently collect and process for ourselves Personal Data of Players and Parents, and Coaches, and
this Policy covers that.
c. Coaches
We collect and retain information about Coaches that interact with our Online and Mobile Resources,
including to connect with Players and Parents for recruiting or coaching services.
2d. Our Vendors and Business Partners
Like all corporate enterprises, we buy goods and services, lease equipment and office space, enter into
strategic collaborations, and participate industry events. In doing so, we interact with personnel of existing
and potential Vendors from whom we necessarily collect certain Personal Data. We describe our use of
Vendor and Business Partner Personnel Personal Data that we control generally in this Policy; provided,
however, that our confidential contracts with those parties may address other Personal Data processing
relating to those parties.
III. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE
USE IT?
We collect the Personal Data we control in three ways: (i) Personal Data you voluntarily provide to us; (ii)
Personal Data we collect through automated/technical means; and (iii) Personal Data that we collect from
publicly available sources or obtain from third parties. We may also infer other Personal Data from the
Personal Data that we collect and control. We describe our Personal Data processing practices regarding
each of those collection methods in the tables below. Additional detail is provided in the Your Rights and Our
Obligations Under U.S. Privacy Lawssection that provide notices to residents of certain U.S. states.
We provide more detailed descriptions of our Personal Data practices by source in the charts below.
However, regardless of source, Athlete One may use your Personal Data for any purposes not inconsistent
with our statements under this Privacy Policy, or otherwise made by us in writing at the point of collection,
and not prohibited by applicable law, including, without limitation, to:
• allow you to participate in the features we offer on our Online and Mobile Resources;
• facilitate, manage, personalize, and improve your user experience;
• process your registration in tournaments or club events with Clubs and Organizations;
• manage and personalize your account;
• when you allow it, upload user-generated content, including content related to athlete training
sessions, exercise data, daily moods, or overall physical fitness to track athletic progress;
• facilitate or manage connections with college recruiters, scouts, or coaches;
• transact with you, provide services or information you request, respond to your comments, questions
and requests, serve you content and/or advertising, and send you notices;
• market to you and other promotional purposes;
• improve our products and service and for other internal business purposes;
• tailor our content, advertisements, and offers;
• fulfill other purposes disclosed at the time you provide your Personal Data or otherwise where we
are legally permitted or required to do so;
• determine your location and manage digital content (e.g., territory restrictions or customization); and
• prevent and address fraud, breach of policies or terms, and threats of harm, enforce rights and/or
comply with law and legal process.
3Without limiting the generality of the forgoing, please see the following sections below regarding distinctions
between Voluntarily Submitted Data, Automatically Collected Data, and Data Collected from Other Sources.
a. Voluntarily Submitted Data
If you choose to participate in or make use of certain activities and features available via our Online and
Mobile Resources, you will need to provide us with data about yourself. The types of Personal Data you will
be submitting to us in those situations will include basic identifiers such as your name, email address,
mailing address, and phone number. It may also include more sensitive information, such as your height,
weight, exercise data, daily mood reporting, birth certificates or passports for age verification to ensure
eligibility to participate in certain competitions. Below are some of the ways you voluntarily give us your
Personal Data and information on how and why we use it:
Data we collect voluntarily provided by you when Players and Parents
register an account on our site, connect with recruiters or Coaches, fill out a
form, interact with Online and Mobile Resources, upload images or content,
e-mail us or subscribe to one of our email lists. This data is directly provided
by you.
Categories of
Personal Data we
collect voluntarily
from you include:
• If you register an account, we collect personal identifiers such as your full
name, personal email address, and online identifiers.
• We may also collect characteristics about you that may be protected
under law, such as your height, weight, gender, and age.
• We may collect sensitive information such as your birth certificate or
passport, biometric information such as exercise data, and information
related to a Player’s/athlete’s daily mood reports.
• We may also ask you to provide information related to non-public
education information, including GPA and testing scores.
• You may provide Personal Data when registering to participate in a
tournament or competition, such as payment details and billing data.
• We may collect other identifying information like your photograph or
sports-related descriptions of athletes.
• We may collect what coaching or recruiting activities you are interested in
(e.g., training sessions with coaches or interest in particular schools,
recruiters or scouts).
• You may also provide Personal Data when you communicate with us
including your full name, contact details and email address, phone
number and details of any such communications.
4Data we collect voluntarily provided by you when Players and Parents
register an account on our site, connect with recruiters or Coaches, fill out a
form, interact with Online and Mobile Resources, upload images or content,
e-mail us or subscribe to one of our email lists. This data is directly provided
by you.
We use this Personal
Data in connection
with our business,
including:
• To facilitate your participation in and communication with tournaments and
other sporting events.
• To fulfill your requests, for example, to connect you with coaches,
recruiters, and scouts.
• To facilitate and maximize coaching and training efforts.
• To manage your account profile.
• To facilitate coaching services.
• To verify eligibility to participate in tournaments or other sporting events.
• To send you emails and communications relating to services or coaching
and recruiting connections, announcements related to tournaments or
events you are participating in, account related messages, event related
updates, and subscribed newsletters.
• To send you marketing information and offers regarding related services.
• To notify you about special offers available from us, our affiliates or
partners, which may be of interest to you.
• To provide our services, manage our Online and Mobile Resources,
respond to your questions, investigate any complaints or abuses, and
provide customer service.
• Customize your experience.
• Resolve disputes.
• For internal analysis and research purposes to help us to measure
interest in and improve our services;
• To prevent prohibited or illegal activities or harm to us or others.
• Enforce our policies or terms;
• To otherwise operate our business subject to the limitation of applicable
law; and
• As required by law or legal process.
5Data we collect voluntarily provided by you when Players and Parents
register an account on our site, connect with recruiters or Coaches, fill out a
form, interact with Online and Mobile Resources, upload images or content,
e-mail us or subscribe to one of our email lists. This data is directly provided
by you.
We use this Personal
Data because:
• It is necessary to comply with applicable laws or regulations; and/or
• To operate our business, including to:
o Manage and promote our business and brand;
o Provide and improve our services;
o Operate our business;
o Improve the performance and user experience of our Online and
Mobile Resources;
o Monitor, investigate and report any attempts to breach the security of
our Online and Mobile Resources; and
o Resolve any concerns or disputes you may have.
b. Automatically Collected Data
When you visit or use our Online and Mobile Resources, basic data about your internet/electronic activity is
automatically collected through your browser via tracking technologies, such as “cookies.” Cookies are small
text files downloaded onto your computer or mobile device. Cookies allow us to collect your IP address and
other usage data, recognize your computer or mobile device, and store some data about your preferences
for using our Online and Mobile Resources or past actions, such as described in the table below:
Data we collect about your use of our Online and Mobile
Resources(Automatically Collected).
Categories of
Personal Data we
collect
automatically about
you include:
• Internet and network activity data recorded in our logs, including URL, IP
address, browser and OS data, timestamp, referring site, geolocation, and
other standard browser data;
• Behavioral data (such as data on the behavior or presumed interests of
individuals which are linked to those individuals and may be used to create
a user profile) pages viewed, images viewed, documents downloaded and
links to other sites followed; and
• Data captured by our cookies https://s3.amazonaws.com/
images.totalglobalsports.com/privacy/DRAFT+-+Athlete+One+-
+Cookie+policy+-+6-17-24(8304035.1).pdf.
6Data we collect about your use of our Online and Mobile
Resources(Automatically Collected).
We use this
Personal Data in
connection with our
business,
including:
• To personalize your experience on our Online and Mobile Resources;
• Operating our Online and Mobile Resources, and developing and improving
our products and services;
• Analytical, statistical, and trend analysis to improve the user experience
and performance of our Online and Mobile Resources;
• To facilitate your access to and use of our Online and Mobile Resources;
• In connection with leads and ads, and subject to applicable law, to disclose
it with our customers and third-party advertising partners for their own
marketing purposes;
• Resolving disputes and troubleshooting problems;
• To otherwise operate our business subject to the limitations of applicable
law; and
• As required by law or legal process.
We use this
Personal Data
because:
• It is necessary to comply with applicable laws or regulations; and/or
• We use it to operate our business, including to:
o Monitor, investigate, and report any attempts to breach the security of
our Online and Mobile Resources;
o Improve the performance and user experience of our Online and Mobile
Resources;
o Develop our product and service offerings for service users and our
customers;
o You consented (where required under applicable law) to the use of your
data for marketing. Where we rely on your consent, you have the right to
withdraw this consent by contacting us via the information below or
unsubscribing via the opt-out functionality provided in our marketing
communications to you; and
o Resolve any concerns or disputes you may have.
c. Data Collected from Other Sources
We collect Personal Data from publicly available sources and from third parties (such as Clubs and
Organizations), which we may combine with Personal Data you have provided to us or that we have
collected automatically.
7Data that we collect from other sources
Categories of
Personal Data we
collect about you
include:
• Identifiers, such as name, email address, mailing address, and phone
number.
• Player data, such as age, height, weight, and gender.
• Uniquely identifiable mobile device data;
• Geolocation data when you register for tournaments and events;
• Data collected by third-party tracking technologies, including:
o URL, IP address, browser and OS data, timestamp, referring site, and
other standard browser data;
o Behavioral data, such as data on the behavior or presumed interests of
individuals which are linked to those individuals and may be used to
create a user profile; and
o Behavioral data from interactions with third-party sites and applications.
• Data collected from third-party mail services (as described below).
8Data that we collect from other sources
We use this
Personal Data in
connection with
our business,
including:
• Determining player eligibility and registering players for tournaments and
other sporting events.
• Matching players with coaches, recruiters, or scouts.
• Managing relationships with Clubs and Organizations.
• Managing relationships with Players and Parents.
• Managing your profile and account.
• Sending you service emails (e.g., announcements and messages relating to
your account, tournaments, events, coaching opportunities, recruiting
efforts).
• Notifying you about special offers available from us and our affiliates or
partners, which may be of interest to you.
• Sending marketing to you regarding our services and products or our
affiliated companies’ services and products which may be of interest and to
promote our business and brand.
• Administering our services and Online and Mobile Resources.
• Responding to your questions and requests and otherwise customizing your
experience.
• For internal analysis and research to help us to measure interest in and
improve our services.
• Preventing prohibited or illegal activities.
• Enforcing our policies or terms.
• To otherwise operate our business subject to the limitation of applicable law.
• As required by law or legal process.
9Data that we collect from other sources
We use this
Personal Data
because:
• It is necessary to comply with applicable laws or regulations.
• We have a legitimate business interest to:
o Manage and promote our business and brand;
o Provide and improve our services;
o Operate our business;
o Obtain payment for our services;
o Improve the performance and user experience of our Online and Mobile
Resources;
o Monitor, investigate, and report any attempts to breach the security of our
Online and Mobile Resources; and
o Resolve any concerns or disputes you may have.
• You consented (where required under applicable law) to the use of your
data. Where we rely upon your consent, you have the right to withdraw this
consent via the contact details below or unsubscribing via the opt-out
functionality provided in our marketing communications to you.
Additional data about cookies and tracking technologies is available https://s3.amazonaws.com/
images.totalglobalsports.com/privacy/DRAFT+-+Athlete+One+-+Cookie+policy+-+6-17-24(8304035.1).pdf
If you access our Online and Mobile Resources from a phone or other mobile device, the mobile provider
may transmit certain data to us such as uniquely identifiable mobile device data. We may be able to collect
additional information through your mobile phone that allows us to identify you, including by collecting your
mobile phone number. You can control some of the information disclosed to us through your device settings.
When you use our Online and Mobile Resources, we may allow third party providers, including third party
advertising partners, to place their own cookies or similar technologies to engage in the same types of
collection we describe above.
d. External Sites, Apps, Links, and Social Media
We maintain a presence on one or more external social media platforms, including but not limited to X,
Facebook, Instagram, and LinkedIn. We may further allow the community features of our Online and Mobile
Resources to connect with, or be viewable from, that external social media presence. Similarly, our Online
and Mobile Resources may contain links to other websites or apps controlled by third parties. If you interact
with our Online and Mobile Resources using plug-ins for any social networks, including Facebook, X, or
YouTube, your activity may be available for review by those network operators and other users of such
social networks.
10We are not responsible for the content on, or the privacy practices of, social media platforms, or any third-
party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore
have their own privacy policies and terms of use. To be clear: neither this Policy nor the terms of
use appearing on or in any of our Online and Mobile Resources apply to our social
media presence or any third-party sites or apps to which we may link. That means even if
you take an action related to our specific social media profile, and identifiers about you are automatically
collected and given to us as a result, that collection and transfer is governed by the privacy policies and
other terms of the applicable social media platform. If you have questions about how those apps, sites and
platforms collect, use and disclose Personal Data, you should carefully read their privacy policies and
contact them using the contact information they provide.
IV. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain your Personal Data for a period of time consistent with the purpose of collection and processing,
fulfilling our legal obligations and enforcing our agreements and defending our legitimate interests. The
retention period for Personal Data is determined by us based on the amount, nature, and sensitivity of the
Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the
Personal Data, whether we can achieve the purposes of the processing through other means, and any
applicable legal requirements. For example, we will retain certain identifiers for as long as it is necessary to
continue maintaining your account and providing you our products and services, to comply with our tax,
accounting, and recordkeeping obligations, and for research, development, and safety purposes, as well as
an additional period as necessary to protect, defend, or establish our rights, defend against potential claims,
and to comply with our legal obligations.
V. WHEN AND TO WHOM DO WE DISCLOSE PERSONAL DATA?
We may disclose your Personal Data as described below, subject to the requirements of the U.S. Privacy
Laws, such as opt outs under U.S. Privacy Laws.
a. Clubs and Organizations
Subject to applicable law, we may disclose Personal Data to Clubs and Organizations who will use data
according to their own policies. Certain types of Personal Data, e.g., sensitive data like your daily moods,
will only be shared with your permission. Please check with the Clubs and Organizations for more
information on their data privacy practices.
b. Coaches
Subject to applicable law, we may disclose Personal Data to Coaches, recruiters and scouts who will use
data according to their own policies. Certain types of Personal Data, e.g., sensitive data like your daily
11moods, will only be shared with your permission. Please check with the Coaches and their affiliated
organizations for more information on their data privacy practices.
c. Affiliates
Subject to applicable law, we may disclose Personal Data to other corporate affiliates who will use such data
in the same way as we can under this Policy.
d. Legal Requirements
We may disclose Personal Data to government authorities, and to other third parties, as required or
permitted by law, including responding to court orders and subpoenas.
e. To Prevent Harm
We also may disclose Personal Data when we have reason to believe that someone is causing injury to or
interference with our rights or property or harming or potentially harming other persons or property.
f. Business Transactions
If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests or securities,
or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization,
divestiture, consolidation, or liquidation, Personal Data may be one of the transferred assets. Such
disclosures may include pre-transaction disclosures such as during due diligence.
g. Vendors and Business Partners
We also disclose Personal Data to service providers, contractors, or processors, and business partners
(our "Vendors") who need it to perform services for us under the contracts we have with them, including
third party advertising partners (e.g., operators of cookies and tracking technologies associated with our
Online and Mobile Resources).
VI.HOW DO WE PROTECT COLLECTED PERSONAL DATA?
We have adopted, implemented, and maintain an enterprise-wide corporate data security and privacy
program that includes technical, organizational, administrative, and other security measures designed to
protect, as required by applicable law, against reasonably anticipated or actual threats to the security of your
Personal Data (the "Security Program"). We have reason to believe our Security Program is reasonable
and appropriate for our business and the nature of foreseeable risks to the Personal Data we collect and
process. Nonetheless, we cannot guarantee that your Personal Data, whether during transmission or while
stored on our systems, otherwise in our care, or the care of our Vendors, will be free from unauthorized
access or that loss or accidental destruction will never occur. Except for our duty under applicable law to
maintain the Security Program, we disclaim, to the maximum extent the law allows, any liability for any theft
12or loss of, unauthorized access or damage to, or interception of any data or communications including
Personal Data.
VII.YOUR GENERAL RIGHTS AND OPTIONS
If we are using your Personal Data to send you marketing materials, such as newsletters or product alerts
via email, you may opt out / withdraw your consent by following the instructions linked or otherwise provided
in the applicable email or other communication. In addition, residents of certain jurisdictions have additional
rights as set forth in the U.S. State Privacy Rights section below. When we receive your request, we will take
reasonable steps to remove your name from our distribution lists, but it may take time to do so. You may still
receive materials for a period of time after you opt out.
Some information about your use of our Online and Mobile Resources and certain third-party services may
be collected using tracking technologies across time and services and used by Athlete One and third parties
for purposes such as to understand you better as an athlete, to associate different devices you use, and
deliver relevant and retargeted ads and/or other content to you on the service and certain third-party
services.
Some browsers have a do not track (“DNT”) feature that lets you tell websites that you do not want to have
your online activities tracked. We do not support DNT because there is no industry consensus on how they
should be treated. We do, however, support Global Privacy Control (“GPC”) where we are required to do so.
The GPC signal communicates a Do Not Sell / Share / Target request from a global privacy control if
enabled for that browser or device, or the data subject, if they can be identified. For more information
regarding GPC, see the U.S. Privacy Laws section below.
VIII.CHILDREN'S PRIVACY
U.S. Federal law imposes special restrictions and obligations on commercial website operators who direct
their operations toward and collect and use Personal Data from children under the age of 13. Certain
Comprehensive Privacy Laws also regulate Personal Data processing practices involving children and other
minors. We take those age-related requirements very seriously, and, consistent with them, our information
practices comply with the Children’s Online Privacy Protection Act (“COPPA”). COPPA requires that we
inform you of our practices with regards to our collection, use, or disclosure of Personal Data from children
under the age of 13, and to obtain verifiable parental consent prior to collecting, using, or disclosing any
such information.
If we discover we have collected information from a child in a manner inconsistent with COPPA’s
requirements, we will either seek the parent’s consent for that collection or delete the information. We will
13not require a child to disclose more information than is reasonably necessary to participate in the Online and
Mobile Resources.
a. Verifiable Parental Consent
In order for a minor, including a child under the age of 13 to access our Online and Mobile Resources, either
(a) a parent or legal guardian (“Parent”) must provide verifiable parental consent; or (b) a coach or other
authorized team administrator must provide consent on behalf of the Parent.
Athlete One generally obtains verifiable parental consent prior to collecting, using, or disclosing any
Personal Data from children. There are limited instances where we may collect information without parental
consent in compliance with COPPA, including: (a) to protect the security or integrity of our Online and Mobile
Resources; or (b) we may collect contact information in order to respond to a specific request from a Club or
Organization on a one-time basis.
IX.YOUR RIGHTS AND OUR OBLIGATIONS UNDER U.S. PRIVACY LAWS
a. Categories of Data Collected
We collected and processed the following categories of Personal Data within the 12 months prior to the
effective date of this Privacy Policy:
• identifiers such as name, address, email address, IP address, and other similar identifiers
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data analytics providers, data processors,
payment processors, and marketing companies), other members of our corporate group,
and/or other parties (e.g., litigants and government entities).
o Sale/Share: Third party advertising partners.
• Personal Data under the Customer Records provision of the California Civil Code such as a
name, address, telephone number, credit card number, physical characteristics or description of an
athlete
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data processors, and payment
processors), other members of our corporate group, and/or other parties (e.g., litigants and
government entities).
o Sale/Share: Third party advertising partners.
• Protected Classifications under the Law such as height, weight, gender, and age
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data processors, and payment
processors), other members of our corporate group, and/or other parties (e.g., litigants and
government entities).
14o Sale/Share: N/A
• Internet/network activity such as browsing history and search history
o Recipients: Service Providers (e.g., general IT, cloud computing, software, and other
business vendors, data analytics providers, data processors, and marketing companies),
other members of our corporate group, and/or other parties (e.g., litigants and government
entities).
o Sale/Share: Third party advertising partners.
• Geolocation data including geographic coordinates/physical location/travel plans when participating
in tournaments or other sporting events
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data analytics providers, data processors,
and marketing companies), other members of our corporate group, and/or other parties (e.g.,
litigants and government entities).
o Sale/Share: N/A
• Biometric data including exercise data, metrics related to on-field performance, and daily mood
reports
o Recipients: Coaches, Service Providers (e.g., general IT, cloud computing, software, and
other business vendors, premises security vendors, and call center providers), other
members of our corporate group, and/or other parties (e.g., litigants and government
entities).
o Sale/Share: N/A.
• Professional or employment related data related to Coaches
o Recipients: Players and Parents, Service Providers (e.g., general IT, cloud computing,
software, and other business vendors, and data processors), other members of our
corporate group, and/or other parties (e.g., litigants and government entities).
o Sale/Share: N/A.
• Non-public education information of athletes such as GPA and testing scores
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data processors, and payment
processors), other members of our corporate group, and/or other parties (e.g., litigants and
government entities).
o Sale/Share: N/A.
• Inferences drawn from the foregoing to create a profile about a consumer reflecting the athlete’s
preferences, predispositions, behavior, and attitudes.
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, data analytics providers, data processors,
15and marketing companies), other members of our corporate group, and/or other parties (e.g.,
litigants and government entities).
o Sale/Share: N/A.
• Sensitive Personal Information, including:
o to create a profile about a consumer reflecting the an individual's commercial preferences,
predispositions, behavior, and attitudes.
o Birth certificate or passport for age verification and eligibility determinations.
o log-in information (e.g., username and password to online account with Athlete One)
o Recipients: Clubs and Organizations, Coaches, Service Providers (e.g., general IT, cloud
computing, software, and other business vendors, and data processors), other members of
our corporate group, and/or other parties (e.g., litigants and government entities).
o Sale/Share: N/A.
Because there are numerous types of Personal Data in each category, and various uses for each Personal
Data type, actual retention periods vary. We retain specific Personal Data pieces based on how long we
have a legitimate purpose for the retention. Generally, we process your Personal Data to provide you
services and as otherwise related to the operation of our business, including for one or more of the following
business purposes: performing services; registering athletes for tournaments and other sporting events;
coordinating coaching and training sessions; managing interactions and transactions; security; debugging;
advertising and marketing; quality assurance; processing interactions and transactions; and research and
development. We may also use Personal Data for other business purposes in a context that is not a sale or
share under applicable U.S. Privacy Laws, such as disclosing it to our service providers, contractors, or
processors that perform services for us (“Service Providers”), to you or to other parties at your direction or
through your action; for the additional purposes explained at the time of collection (such as in the applicable
privacy policy or notice); as required or permitted by applicable law; to the government or private parties to
comply with law or legal process or protect or enforce legal rights or obligations or prevent harm; and to
assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes
control over all or part of our business (“Additional Business Purposes”). Subject to restrictions and
obligations under applicable U.S. Privacy Laws, our Service Providers may also use your Personal Data for
Business Purposes and Additional Business Purposes, and may engage subcontractors to enable them to
perform services for us.
b. Your U.S. State Privacy Rights
As described more below, subject to meeting the requirements for a Verifiable Consumer Request (defined
below) and limitations permitted by applicable U.S. Privacy Law, we provide individuals the privacy rights
described in this section, as may be required by applicable U.S. Privacy Law. If you exercise these rights,
we will not discriminate against you by treating you differently from other individuals who use our Online and
Mobile Resources or purchase our services but did not exercise their rights.
16• Know – You may have the right to request that we disclose to you, specifically beyond the general
statement immediately above, the categories of Personal Data collected including the source of the
data, our use of it and, if the data was disclosed or sold to third parties, the categories so disclosed
or sold as well as the categories of third parties who received or purchased it. You may also have a
right to request that we provide a list of third parties to which we have disclosed Personal Data.
• Access – You may have the right to receive a copy of the categories and specific elements of
Personal Data we collected about you.
• Correct – You may have the right to request the correction of inaccurate information collected. You
can also make changes to your online account in the account settings section of the account. That
will not, however, change your information that exists in other places.
• Delete – You may have the right to request the deletion of Personal Data we collected about you
held by us, our Service Providers and any other third party to which we have disclosed your Personal
Data.
• Opt Out –You may have the right to opt out of any sale or sharing for targeted advertising of
Personal Data (as defined in applicable laws) if such sale / sharing / targeted advertising occurs.
• Transfer/Data Portability –You may have the right to request the transfer of specific pieces of
Personal Data we have collected about you to another entity.
• Sensitive Personal Information –With regard to Personal Data that qualifies as sensitive
Personal Data under applicable U.S. Privacy Law, if you elect to provide us with that sensitive
Personal Data you will have consented to such processing. We do not process sensitive personal
information that is subject to the right to limitation under applicable law. Note, you can terminate your
account with us at any time.
• Automated Decision Making / Profiling – We do not engage in Automated Decision Making
or Profiling as defined by U.S. Privacy Laws.
• Appeal – You may have a right to appeal a refusal to take action on a request by contacting us by
email at privacy@athleteone.com.
Exercising Your Rights
To submit a request to exercise your consumer privacy rights, or to submit a request as an authorized agent,
contact us at privacy@athleteone.com or via U.S. post to Athlete One, Inc., 202 Fashion Lane, Suite 101
Tustin, California 92780, Attn: Data Privacy Officer. We have the ability to charge a reasonable fee for
administrative costs of providing the Personal Data to you in situations where the request is unfounded or
excessive (e.g., due to its repeated nature), or in the alternative, we may refuse to act on the request in
those situations. We will notify you in such cases.
17Opt Out of Sale / Sharing / Targeted Advertising:
If you want to limit our processing of your cookie-related Personal Data for targeted advertising, or opt-out of
the Sale/Sharing of such Personal Data, you may utilize our cookie management tool which enables you to
exercise such an opt-out request and enable certain cookie preferences on your device. You must exercise
your preferences on each of our Online and Mobile Resources you visit, from each browser you use, and on
each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block
cookies, your preferences will no longer be effective, and you will need to enable them again via our cookie
management tool. Beware that if you use ad blocking software, our cookie banner may not appear when you
visit our services, and you may have to use the link above (the Do Not Sell or Share My Personal
Information link at the bottom of our Online and Mobile Resources) to access the tool.
Opt-Out Preference Signals: You may also opt out of cookie-related sales / sharing / targeted
advertising by using an opt-out preference signal or Global Privacy Control (“GPC”). To use a GPC, you can
download an internet browser or a plugin to use on your current internet browser and follow the settings to
enable the GPC. We have configured the settings of our consent management platform to receive and
process GPC signals on our Online and Mobile Resources. If you opt-out using the GPC functionality
available in some browsers while you are logged in to one of our Online and Mobile Resources, we will use
that signal to opt you out of all online and offline marketing and sharing. If your browser functionality
supports GPC but you are not logged into one of our Online and Mobile Resources we will use that signal to
opt you out of online tracking only. If your browser does not support GPC you can click on the [LINK] at the
bottom of our Online and Mobile Resources to activate our cookie manager where you can select your opt
out choices for browser activity.
We do not knowingly sell or share the Personal Data of consumers under 16. If you think we may have
unknowingly collected Personal Data of a consumer under 16 years old, please email us at
privacy@athleteone.com.
As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be a Verifiable
Consumer Request, meaning when you make a request, we may ask you to provide verifying information,
such as your name, e-mail, phone number and/or account information. We will review the information
provided and may request additional information (e.g., transaction history) via e-mail or other means to
ensure we are interacting with the correct individual. We will not fulfill your Right to Know, Right to Delete, or
Right to Correction request unless you have provided sufficient information for us to reasonably verify you
are the consumer about whom we collected Personal Data. To protect individuals’ privacy, if we are unable
to verify you sufficiently, we will be unable to honor your request.
18We will use Personal Data provided in a Verifiable Consumer Request only to verify your identity or authority
to make the request and to track and document request responses, unless you also gave it to us for another
purpose.
You may use an authorized agent to make a request for you, subject to our verification of the agent, the
agent’s authority to submit requests on your behalf, and of you. To designate an authorized agent to make a
request on your behalf, please provide us with a power of attorney or other legally binding written document
signed by you and identifying your agent. Once your agent’s authority is confirmed, they may exercise rights
on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.
You are not required to create a password-protected account with us to make a Verifiable Consumer
Request, but you may use your password-protected account to do so. If we suspect fraudulent or malicious
activity on or from the password-protected account, we may decline a request or request that you provide
further verifying information.
c. Shine the Light
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California
residents to request certain information regarding our disclosure of personal information to third parties for
their direct marketing purposes. To make such a request, please send an email to privacy@athleteone.com.
X. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change or update this Policy from time to time. Please check our Online and Mobile
Resources periodically for such changes since all data collected is subject to the Policy in place at the time
of collection. We will indicate the effective/amendment date at the beginning of this Policy.
XI.HOW TO CONTACT US
If you have any questions about our privacy and data security policies, procedures, and practices, including
anything we say in this Policy, please contact us at:
• Address: Athlete One, LLC,
Attn: Data Privacy Officer
202 Fashion Lane, Suite 101
Tustin, California 92780
• Portals:
• Email: privacy@athleteone.com
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