Privacy Policy

Updated and Posted June 1, 2024; Effective as of January 1, 2024

WHAT'S NEW?

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

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This privacy policy ("Privacy Policy") describes how we use the data (which may include personal information) we collect about you offline and through our digital properties ("Site(s)") when: you create an account, make a reservation, request support, chat, send us a message, or otherwise communicate or interact with us via our websites or app, when you apply, register, inquire about or participate in our school, camps, training programs, competitions or events, and any additional products or services association with your participation, when you buy a ticket or other merchandise from us online or onsite, when you view or interact with content on our online channels, including online trainings and coaching, when you attend our events in person, when you book our facilities for corporate events, groups or otherwise, and when you otherwise interact with us, including our social media, performance platforms, marketing, contests, sweepstakes, and surveys (collectively our "Service(s)").

This Privacy Policy also applies to mobile applications developed by Around The Dirt, LLC, which includes AroundTheDirt.com. This Privacy Policy does not apply when we are a service provider, i.e., when we provide services to businesses and handle data (including personal information) on behalf of those businesses. Please read this Privacy Policy carefully to understand how we handle your information.

WHO WE ARE

We are Around The Dirt, LLC, and their affiliated entities ("we", "us", "our"). We may share data (as described further below) with its affiliated entities (collectively, "Endeavor"). If you would like a full list of relevant entities, please submit an information request to the Privacy Team. Like any company, we use a variety of third party businesses and partners to market and provide our Services to you. Some of those companies are part of Endeavor, and some are third parties that we partner with or support our operations so we can provide the best experience to you.

HOW WE COLLECT INFORMATION ABOUT YOU

DIRECTLY FROM YOU

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

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

INFORMATION WE COLLECT FROM OTHER SOURCES

We work closely with our affiliates that are part of Endeavor to provide our Services, market to you and to provide a seamless service across different businesses. As such we receive from such affiliates, the following personal information such as name, email, phone number, address, sport or academic information (GPA, position, sport metrics, school/team affiliation), family information (parent /guardian), and coach.

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

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

Some of our key partners, who we receive data from (and may share some data with, see "DISCLOSURE OF PERSONAL INFORMATION" section below) include:

• Other technology companies, who we work with to analyze and track performance data
• Leagues, Colleges and Universities, Conferences, and Governing Bodies, who we work with around the world.
• E-commerce platforms and services, which provide merchandise.
• Recruiting service providers.
• Media and digital content partners.
• Partners and Sponsors.
• Venues which host events and provide various marketing, advertising, customer support, and security services related to events.

INFORMATION WE COLLECT AND HOW WE USE IT

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

We may also use personal information we have about you

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

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

DISCLOSURE OF PERSONAL INFORMATION

We do share personal information with Endeavor, third parties, and the other categories of partners as listed above. Some of these disclosures of personal information may be constitute a sale of personal information under some data privacy laws. Accordingly, we offer the option for you to opt out of the sale of personal information, as further set forth below.

We may also disclose personal information to third parties:

• if we evaluate or enter into negotiations to buy, sell, or merge with any business or assets, or if we enter into bankruptcy, reorganization, or receivership, or some similar proceeding in which case we may disclose personal information about you to the prospective or eventual seller or buyer of such business or assets;
• if we are under a duty to disclose or share personal information about you in order to comply with any legal obligation, or in the event of an emergency, or in order to enforce or apply our applicable Terms of Use, registration documents, and other agreements, or to protect the rights, property, or our safety or of, Endeavor, our customers, clients, or others; and to any other third party not covered in this policy with your prior consent.

MARKETING AND ADVERTISING

TARGETED ADVERTISING

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

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

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

EMAIL MARKETING

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

MOBILE NOTIFICATIONS AND TEXT MESSAGES

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

With your consent, where required, we may send informational, transactional, and other service-related text messages to your mobile phone number. [You can opt out of receiving text messages to your mobile phone number by texting "STOP". Please note that opting out of receiving text messages may impact your use of the Services.

SOCIAL MEDIA

You may be able to use social sharing features and other integrated tools on the Site such as the Facebook "Like" button. These features and tools may permit you to share actions you take on our Service with other media, and vice versa. Your use of such features enables the sharing of data with your friends or the public, depending on the settings you establish with the service that provides the social sharing feature. Please remember, though, that use of the data you share on social media sites will be governed by the privacy policies of the social media provider, and we are not responsible for how they treat the data.

You may also be able to use your account credentials on social media platforms like Facebook or Google to log-in to certain services we offer. If you link your account with us to your social media log-in, please be aware that this means information such as your username, password, and some account activity may be shared between us and the social media provider.

CHAT ROOMS, FORUMS, AND MESSAGE BOARDS

We may make chat rooms, forums, commenting and message boards available to you and other users using third party software. You are not required to provide any personal information when using these areas, but you may choose to do so. If you post personal information online, it will be publicly available, and you may receive unsolicited messages from other parties. By using the commenting features of the Site, you acknowledge that your username and location information will be disclosed. We cannot ensure the security of any data you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas. To request removal of personal information about you from any blog or community forum, please submit a request to delete personal information about you below with instructions regarding what you would like removed. In some cases, we may not be able to remove personal information about you, in which case we will let you know if we are unable to do so and why.

COOKIES

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

DO NOT TRACK

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

STORAGE AND TRANSFER OF INFORMATION

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

CALIFORNIA PRIVACY RIGHTS

California residents have certain rights with respect to the personal information collected by businesses under the California Consumer Privacy Act ("CCPA"). For more information on your rights as a California resident, including how to exercise your rights, see our California Privacy Rights page.

NEVADA

Under Nevada law, you may direct a business that operates an internet website not to sell certain personal information a business has collected or will collect about you. Nevada residents who wish to exercise their right to opt-out of a sale under Nevada Revised Statutes Chapter 603A may submit a request by submitting email to contact@aroundthedirt.com or calling 1-833-774-3387.

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

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

You may opt out of the sale of personal information about you by clicking on the Do Not Sell My Personal Information link on the appropriate Site or calling 1-833-774-3387. You will be asked to provide certain information to us in order to exercise this option so we can verify your identity and locate your records with us. If you are a 13-16 years old, you may opt in to the sale of personal information, including by submitting a request to contact@aroundthedirt.com. Please note if do not provide us with certain information, we are unable to provide you with certain corresponding Services.

CANADA, EEA AND UK

If you are in Canada, the EEA or UK, the disclosures set out below apply to you (as applicable) in addition to the disclosures set out in the general sections of this Privacy Policy. We are a limited liability corporation established in Delaware with a registered office at 2602 W Lone Cactus Dr, Phoenix, AZ 85027 and for the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR") and the UK General Data Protection Regulation and/or the UK Data Protection Act 2018 (together, the "UK GDPR"), we are the data controller. Our UK affiliate, International Management Group (UK) Limited (Companies House Reg.: 00946580) is established in England & Wales with registered office at Building 6 Chiswick Park, 566 Chiswick High Road, London, United Kingdom, W4 5HR. Our EU data protection officer can be reached at contact@AroundTheDirt.com.

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

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

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

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

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

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

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

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

BRAZIL

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

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

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

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

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

If you want to exercise any of these or other rights under the LGPD, please contact us at contact@aroundthedirt.com

MEXICO

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

Data Controller. The data controller of personal information about you is Around The Dirt, LLC located at 2602 W Lone Cactus Dr, Phoenix, AZ 85027.

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

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

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

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

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

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

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

You can ask us to stop processing personal information about you for direct marketing purposes by checking certain boxes on the forms we use to collect personal information about you, by clicking "unsubscribe" on the emails you receive, and/or other mechanisms as described in this Privacy Policy or within the communication we send you. To exercise your rights, know more about your rights, as well as the applicable means, procedures, and requirements to exercise any of them, please contact us.

INDIA

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

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

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

Withdrawal Of Consent. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities, and correct or update personal information about you by contacting our data protection officer at contact@AroundTheDirt.com. Where consent is required to process personal information about you, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Your request to withdraw your consent shall not:

1. apply retrospectively, or
2. require deletion of records required for statutory purposes.

JAPAN

If you are in Japan, the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy. Minimum Age. Parental/legal guardian consent is required for children under the age of 18, you must obtain your parent’s or legal guardian’s consent to use our Services. Information we collect and how we use it. The table above in the "INFORMATION WE COLLECT AND HOW WE USE IT" section applies mutatis mutandis to our collection and handling of personal information about you by:

1. replacing the names of columns "Business or commercial purposes for collection, use, and sharing personal information" and "Affiliates/Categories of third parties with whom personal information is shared for a commercial or business purpose" with "Purposes for collection, use, transfer and joint-use of personal information" and "Our group companies and the Joint-use Third Parties with whom personal information is jointly used", respectively; and
2. adding "transfer to third parties" as a purpose to each category in the "Purposes for collection, use, transfer and joint-use of personal information" column. Joint-use Third Parties. We and third parties whose handling of personal information is reasonably regarded as equivalent to the handling of personal information by Around The Dirt, LLC ("Joint-use Third Parties") may jointly use, share, or process personal information about you, within our group companies (i.e., Aroundthedirt.com) and with our Joint-use Third Parties (if any). Consent to a Sale of Personal Information. You consent to the sale of personal information about you to third parties by us based on your consent to the transfer of personal information about you to third parties. You may request us to cease the sale of personal information about you at any time at contact@aroundthedirt.com

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

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

SOUTH KOREA

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

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

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

Examples of retention prescribed by law are as follows:

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

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

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

Data Transfers to Overseas Country and Provision of Personal Information to Third Parties. We transfer Personal Information overseas to third parties as follows:

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

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

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

CONTACT

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

• Data Protection Contact
  Telephone Number: 1-833-774-3387
  E-mail: contact@AroundTheDirt.com

DOMESTIC PRIVACY REPRESENTATIVE

The information regarding the domestic agent is as follows:

• Administration
  contact@AroundTheDirt.com
  1-833-774-3387

CHINA

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

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

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

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

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

Consent storage of personal information outside of China. By clicking "accept", you consent that personal information about you will be stored in countries or regions outside of China where we have databases or affiliates and, including to the United States.

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

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

If you wish to exercise such rights, you may direct your request to us using the contact details set out below, and we will reply to you within 15 working days from receipt of such inquiry. Contact. If you have any questions or comments about the Privacy Policy and/or this China Section, if you need to report a problem, or if you would like us to update, amend, or request deletion of the information we have about you, please contact us at contact@AroundTheDirt.com

SECURITY

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

LINKS TO THIRD PARTY WEBSITES

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

UPDATES

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

CONTACT

Questions or comments regarding this Privacy Policy should be submitted to us at contact@AroundTheDirt.com.