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BRAND 27 SPORTS – PRIVACY STATEMENT

We are Brand 27 Sports LLC (“Brand 27”, “we”, “us” and “our”). We provide youth hockey scouting and recruiting services (the “Services”) that we provide through our www.prospectivehc.com website (the “Site”), “Prospective Hockey Central” mobile application, electronic mail, texts, and other electronic communications.

Each person or entity who uses our Services is referred to as a “user” or “you” or “your”. If you subscribe to any of our Services, we will refer to you as a “registered user”. If you don’t register with us, we will refer to you as an “unregistered user”. This Privacy Statement and our Terms of Service (“Terms”) apply to each user.

This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, personal health information, personal financial information, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Information”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Information.

Any Content that is not Personal Information is referred to as “Non-Personal Information.” Non-Personal Information includes information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).

Among other services, Brand 27 and the Prospective Hockey Central platform connect users with other companies in the industry (collectively, “Partners”). This Privacy Statement does not apply to any Partners or to any other websites, mobile applications, or businesses. This Privacy Statement does not apply to any Personal Information or other Content collected via any means other than the Services.

By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Information, as described in this Privacy Statement.

1. Information We Collect

As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Information that we use to contact you and our Partners, and which may be necessary to provide the Services, now and in the future. Other Content we collect from you includes behavioral data and other Non-Personal Information that we aggregate, share, and use to improve our Services, the services of our Partners, and others in the industry.

We collect many different types of information from you, both directly and indirectly.

Information you provide us directly

Information we gather from your use of our Services

2. How We Store Your Information

3. How We Use Your Information

We share and use your Personal Information in the following circumstances:

4. Your Right to Review, Request Changes, and Disclose Personal Information

Subject to applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Information as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by Brand 27, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Information you provide to us remains completely under your control. If you believe the Personal Information we have is incorrect or incomplete, you may in writing request an amendment to your Personal Information. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Information. We will also make a reasonable effort to notify people to whom the Personal Information was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.

Any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Information or your User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Information or your User Content with other people, or otherwise made it public, that Personal Information and your User Content may be re-shared by others.

5. Children

Our Services are not directed to persons under age 13. If you are the parent or guardian of a person under 13, and you become aware that your young person has provided us with Personal Information or User Content without your express consent, please contact us at info@prospectivehc.com and we will remove the information or User Content, and we will terminate the young person’s account.

6. Changes to this Privacy Statement

We may modify our Privacy Statement from time to time on prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective no less than ten (10) calendar days after posting on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us.

7. Different Locations, Different Laws

The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including: Several of the Laws that concern unregistered users, registered users, and Brand 27 are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.

7.1 United States Federal Laws

Several of the federal Laws in the United States may apply to the Personal Information collected by us.

Currently, all Personal Information of users resident in the United States is stored on servers and other machines physically located within the United States.

7.1.1 Health Insurance Portability and Accountability Act (“HIPAA”)

Currently, HIPAA does not apply to the Services as we are neither a covered entity nor a business associate (as those terms are used in HIPAA).

7.1.2 Children’s Online Privacy Protection Act (“COPPA”)

Currently, COPPA does not apply to the Services. Each registered user and other user must be 13 years of age or older. As noted in this Privacy Statement, if we learn of any registered user or user is under the age of 13, or if any parent or guardian contacts us, we will close that person’s account and remove all information provided by the individual from our Services.

7.2 State Laws in the United States

Individual states in the United States have passed and enforce information privacy and security laws.

7.2.1 Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to info@prospectivehc.com, or send us postal mail at:

Attn: Privacy, Brand 27 Sports LLC, 788 N 26th St., Philadelphia, PA 19130

Pursuant to California Civil Code Section 1798.83(c)(2), we do not share users’ Personal Information with affiliate companies or others outside Brand 27 for those parties’ direct marketing use, unless a user elects that we do so.

If you are a California resident under the age of 18, and a subscriber of any site where this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@prospectivehc.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.

By submitting any Personal Information or other User Content to us, or placing any order with us, you consent to the storage, processing, use and onward transfer of your Personal Information and User Content to us in the United States.

8. Use of Email Addresses and Other Contact Information

We collect the email addresses of those who voluntarily provide them to us, including unregistered users and registered users. You may receive subscription, editorial and other messages from the Services or from us. If you do not want to receive email from us in the future, please let us know at info@prospectivehc.com.

9. Contact Us

If you have questions or concerns about this Privacy Statement, please contact us online at info@prospectivehc.com, or by postal mail addressed to:

Attn: Privacy, Brand 27 Sports LLC, 788 N 26th St., Philadelphia, PA 19130

10. Revision Date and History

These Terms were last revised: August 1, 2017.

Prior versions of this Privacy Statement are listed below: