PRIVACY POLICY

This Privacy Policy is effective as of 15th August 2018.

The Strive platform (including the Strive website and any companion application) (the Strive platform) is operated by STRIVE SCANDINAVIA LTD (company number 11508680 and registered office address

Building 6 Chiswick Park, 566 Chiswick High Road, London, United Kingdom, W4 5HR) (Strive, we, us and our)

We take our obligations under applicable law seriously. We respect your privacy and value the trust you place in us when you share your personal information with us. This Privacy Policy sets out how we, as data controller, collect, hold, use, process and disclose your personal information, why and with what legal reasoning we process it, with whom and with what purposes we share it, the rights to which you may be entitled and your choices about our use of your personal information.We are the data controller in relation to your personal information. This means that Strive collects, holds, uses and discloses your personal information in relation to the provision of the services to you in accordance with the Terms of Use, as well as for marketing and analytics, as set out below.This Privacy Policy covers our use of your personal information arising from use of the Strive platform as well as registering / subscribing / buying / using our products and services.If you have any questions or need any further clarity please get in touch.

Contact details are set out below.

Please click on the sections below to learn more about our Privacy Policy:


Data Collection And Usage
Why We Collect Your Information
Legal Requirements
How Long We Keep Your Information
Information We Share
Where Your Information Will Be Held
Your Privacy Rights
Cookies
Children
Security
Links To Third Party Websites
How To Contact Us
Changes To The Policy

DATA COLLECTION AND USAGE

We will collect and use your personal information to:
a) conduct our business;
b) allow you to access the Strive Pass platform;
c) allow you to register / subscribe / buy / use our products and services;
d) meet our legal obligations;
e) fulfil any purpose we make known to you when we collect your personal information; and
f)   fulfil other purposes set out in more detail in this section.

We will also use and disclose your personal information for any other purposes authorised by applicable law.

Your information will be shared with members of our group and some third parties as described below.

Some of the personal information we request is required to provide the services and if it is not provided, we may not be able to provide the relevant products and services to you or provide information you have requested from us. If the personal information is needed to participate in an activity on the Serie A Pass platform, you may not be able to do so if you do not provide that personal information to us.

In other cases, for example, when we request your personal data to send you marketing and promotional communications or to personalise your experience with our services, the lack of such information will mean it is impossible to send you these communications or to personalise your experience, but it will not have any consequence on the primary purpose of the data collection (to provide the services).

The table below indicate what we collect, how we use it, and whether such information is required to provide products and services to you.Any personal information you supply to us through the Serie A Pass platform must be complete and accurate. You also agree to allow us to contact you to verify your personal information, if we need to.

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We will also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the Strive/IMG Media group and combined with information collected on this Strive platform. We will also receive and display information and content which you make publically available on your social media accounts.  Please not that you have the right to object to such processing.  Please refer to the section titled “Your Privacy Rights” below for more information.

We also work closely with third parties (for example, business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers). We may receive information about you from Facebook Pixel and Google Tag Manager for the purposes of our marketing campaigns.

We use Stripe for payment, analytics and other business services. If you purchase anything from us via our third party payment provider Stripe, Stripe will collect your payment information. We do not collect or store this data, and you provide this information directly to Stripe. Stripe also collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe, purposes for which Stripe processes your personal information and read Stripe's privacy policy at https://stripe.com/gb/privacy. Stripe will request the following information for the payment processing service:

·    contact details, such as name, postal address, telephone number, email address;
·    financial and transaction data, such as credit or debit card number, and bank account information; and
·    other personal data, such as date of birth.

Please check Stripe’s privacy policy for updates. The information that you provide through the website and/or app in relation to payment, will not be forwarded or delivered by us and will be collected by Stripe for the purposes described above.

WHY WE COLLECT YOUR INFORMATION
We collect and use your information for a variety of reasons.  We need some information to enter into and perform our contract with you – for example your contact details and content selections you make.

Some information processing is required for our anti-fraud screening or to verify our customers' identities. In some jurisdictions, such screening and/or verification is not a legal requirement, whilst in others it is.

Some information is processed because you've given your consent to receive certain marketing communications, which can be withdrawn at any time by contacting us (e.g. to keep you informed about products and services and in your device settings or on the website).

We also collect and use your information to keep you informed by email about new products, services and content that we believe may be of interest to you. We may notify you of such new products, services and content provided we have your consent to such notices (where consent is required), and you will have the opportunity to withdraw your consent to such notices at any time.

LEGAL REQUIREMENTS
Your personal information will be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, to enforce or apply Strive's Terms of Use and other agreements, in an emergency, to protect the rights, property or safety of Strive/IMG's group companies, customers, clients and others or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows for it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.

HOW LONG WE KEEP YOUR INFORMATION
We will keep your information for as long as it is reasonably necessary, as set out in fourth column of the table above under the 'Data Usage'. The length of your contract with us will depend on factors such as whether you have a live subscription or an account with us or have interacted with recent offers. If you want to delete your information, please refer to the section "Your Privacy Rights".

Once the above retention period expires, we destroy your personal data pursuant to the following procedure and methods:

·        For electronic data files: permanently deleted in a way so that the personal data cannot be restored or reconstructed.
·        For hard-copies, print-outs, paper documents or any other recording media: shredding.  

INFORMATION WE SHARE
There are certain circumstances where we will transfer your personal data to employees, contractors and to other parties.

We will share information about you with other members of our group of companies so we can provide the best service across our group.

In relation to marketing, we respect your privacy and you can enable a 'Do Not Track' feature in your browser’s settings, if your browser supports that feature. When Do Not Track is turned on, your browser will send a Do Not Track request to the sites you visit. The Do Not Track request lets these sites know that you prefer not to have your browsing activity tracked. You can take similar steps in mobile.  To submit a Do Not Track request on mobile. In iOS, launch the Settings app on your iPhone → Privacy → Advertising. Toggle ON the switch next to Limit Ad Tracking. Now that you have opted out of receiving ads targeted to your interests, based on your Apple ID on that device, you will be removed from the list of users receiving targeted ads. If you have an Android device, in Google Settings, select AdsPrivacy. Toggle ON the switch next to Do Not TrackOpt out of Ads Personalization. Apps are then instructed not to use your advertising ID to build profiles or show you personalized ads. Do Not Track is now enabled on your Android device.  Some devices may require a different procedure, so please check your instructions.

We will:

·       share aggregated, anonymised or other de-identified data with advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience they want to target. We will make use of the personal information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to a target audience and to present our promotional messages to you including using Facebook Custom Audience. This means you will be presented with advertisements that are more relevant to you as a result of the personal information we hold about you.
·       share your personal data with and access information in anonymous form from analytics and search engine providers that assist us in the improvement and optimisation of the website and the app and for better personalisation of content and advertising.
·       share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists or email providers.

Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their functions for us. Under our contracts with them, they would be prohibited from using or disclosing the information for their own use.A list of parties we will outsource the processing of your personal data to and who we will transfer data to for their own purposes can be accessed here.Your personal information will be transferred to other third party organisations in certain scenarios if we are:

·    discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers and their advisors under appropriate terms as to confidentiality;
·    reorganised or sold - information may be transferred to a buyer who can continue to provide services to you;
·    required to by law, or under any regulatory code of practice we follow, or if we are asked by any public or regulatory authority – for example, Law Enforcement Authorities; or
·    defending a legal claim - your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

WHERE YOUR INFORMATION WILL BE HELD (TRANSFER TO THIRD COUNTRIES OUTSIDE OF THE EEA)
We may store your information, directly or indirectly on servers located around the world including in jurisdictions outside of  the EEA, which may not have equivalent data protection laws to those applicable in  the EEA. This means that your information may be stored outside of your jurisdiction and the EEA.We will only transfer data where the appropriate safeguards are in place. We are happy to provide you with copies of any relevant regulator-approved standard contractual clauses, which you can request from us by dataprivacy@img.comWhen we share your information, it may be held by the parties with whom we share it, whether in or transferred outside of your jurisdiction.

YOUR PRIVACY RIGHTS
Depending on applicable laws to which we are subject, you will have certain rights in relation to your personal information such as a right to access or to correct the personal information we hold on you. We have listed the rights you have over your personal information and how you can use them dependent on which country you are resident in below.PLEASE CLICK ON THE LINK TO THE COUNTRY YOU ARE RESIDENT IN BELOW, TO SEE A LIST OF YOUR PRIVACY RIGHTS, AND OTHER TERMS APPLICABLE TO YOU:·   

SWEDEN, DENMARK AND NORWAY
You will have the opportunity to receive certain communications from Strive. You can opt out at any time by using the unsubscribe links at the bottom of Strive’s emails or by contacting Strive via strivesport@inplayer.com  and requesting to unsubscribe.

COOKIES
We use cookies that identify your browser. They collect and store information when you visit our website about how you use it through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website and for analytics. The personal data we collect through these technologies will also be used to manage your session.For more information about cookies and how we use them, please see our: Cookie Policy.

CHILDREN
We do not knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you must not submit any personal information to us or subscribe for the services. If you believe we might have any personal information from or about a person under the age of 18, please contact us at dataprivacy@img.com

SECURITY
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through the Strive platform and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.

LINKS TO THIRD PARTY WEBSITES
The Strive platform, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including members of our groups, our partner networks or advertisers and/or social networks as offered to you and supported by your browser. The personal data that you provide through those other websites is not subject to this Privacy Policy and the treatment of your personal data by the operators of such websites is not our responsibility. If you follow a link to any of these websites, please note that the operators of those websites may have their own privacy policies which set out how your information is collected and processed by them. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of entities through which you choose to share.

HOW TO CONTACT US
If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.If you have any questions about this policy, please contact: IMG Media (company number 04459066) at dataprivacy@img.com  or +44 20 8233 5000, or by post at Building 6 Chiswick Park, 566 Chiswick High Road, London, United Kingdom, W4 5HR.

CHANGES TO THE POLICY
This Privacy Policy (inclusive of other policies referenced herein) represents the entire agreement among the parties on the subject matter hereof. Should any provision be held invalid by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.This Privacy Policy may be updated from time to time.If we wish to change anything in this Privacy Policy (e.g. the information we collect, how we use it or why) we will notify you through a pop-up which will be live for 30 days prior to the change and once the change has been made. You will receive the pop-up when you next access your user account after the pop-up has gone live. If you do not accept the changes to the Privacy Policy, we may not be able to provide the service to you. Hence, you have the right to terminate your Strive subscription due to the changes of this Privacy Policy in accordance with section 7.C.VIII in the Terms of Use, upon one month’s notice to us or at the latest when the changes enters into force.Once this Privacy Policy is posted on the Strive platform, it will automatically come into force. The latest version of this Privacy Policy will prevail over all previous versions and can be reviewed by visiting the Strive platform and clicking on the "Privacy Policy" link.Alternatively, you can email the Representative if you are in the EEA for previous versions.

ADDENDUM: SWEDEN, DENMARK AND NORWAY

YOUR PRIVACY RIGHTS
You have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at dataprivacy@img.com .

·    Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and certain other information about it.

·    Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.

·    Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we will refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.  

·    Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

·    Data Portability: under certain circumstances, you are entitled to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance from us, if technically feasible.                                                                         

·    Objection: where we are processing your personal information based on legitimate interests (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information if our legitimate interests are regarded to override your interests, rights and freedoms or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place. A list of supervisory authorities are set out below: