PRIVACY POLICY

Effective Date: December 3, 2020

IMG Academy (the “Academy”) is owned and operated by IMG Academy, LLC. This Privacy Policy (“Policy”) describes how information about you is collected, used, and disclosed by IMG Academy, LLC, and our parents, subsidiaries and affiliates (collectively, “IMG,” “we” or “us”) when you access or use Academy websites, mobile applications, or other online services that link to this Policy (collectively the “Sites”).

This Policy applies solely to your use of our Sites, or information we collect when you make an initial request for information. It does not apply to information we collect in connection with your attendance at the Academy or your participation in or presence at our events, programs, camps or other activities (other than forms and other information and communications submitted through the Sites), or if you otherwise interact with us.

INFORMATION COLLECTION

Information You Provide to Us

IMG collects a variety of information from you when you choose to provide it to us in connection with your use of our Sites. This may include when you request information from us, apply to the Academy, register for a camp, program or event, create an account, fill out or submit a form or questionnaire, request transportation, add a contact, sign up for our newsletters or email lists, make a purchase, create or deposit to a GET Account, participate in our contests, promotions, sweepstakes, surveys, or interviews, request support, chat with us, send us a message, or otherwise communicate or interact with us via the Sites. The information we collect may include your name, contact information (including your address, email address, and telephone number), applicant/registrant information (including academic and educational information and history, age, birthday, demographic information, family and ethnic information, medical information, athletic experience and positions, applicant essays and parent assessments), payment information, and any other information you choose to provide.

Information We Automatically Collect

Log Information: We log information about your use of the Sites, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Site.

Device Information: We collect information about the computer or mobile device you use to access our Sites, including the hardware model, operating system and version, unique device identifiers and mobile network information.

Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Sites and your experience, see which areas and features of our Sites are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Sites or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect from Other Sources

We may receive information about you from other sources and link or combine that with information we collect about you. For example, we may collect information about you from third parties, including mailing list providers and publicly available sources.

INFORMATION USE

IMG may use the information we collect from and about you to:

• Operate, maintain, and improve the Academy and our Sites;
• Evaluate your application for the Academy or an Academy program, camp, event or activity;
• Facilitate communication with the Academy and Academy staff
• Send you technical notices, updates, security alerts and support and administrative messages;
• Provide and deliver the products and services you request, process forms and transactions, and send you related information, including notifications, confirmations and invoices,
• Develop new Services and content;
• Provide you with information about the Academy and about Academy and third party events, programs, camps, activities, products, services, promotions and special offers that we think might be of interest to you;
• Personalize and improve the Sites and provide you with customized content, targeted offers, and advertising;
• Monitor and analyze trends, usage, and activities in connection with the Sites;
• Respond to your inquiries, requests, and comments and provide customer service;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries, prizes, and rewards;
• Send you information, newsletters, and promotional materials from IMG and our partners;
• Protect the security or integrity of the Sites and our business;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose described to you at the point of data collection.

INFORMATION SHARING

IMG may share the information we collect from and about you as described in this Policy including:

• With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With third party service providers, vendors, and consultants who need access to the information to perform services for us or our students and participants;
• As necessary if we believe that there has been a violation of the IMG Terms of Service or of our rights or the rights of any third party;
• To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law;
• In connection with any merger, sale of assets, financing, bankruptcy, or reorganization of our business; and
• With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

Further, we may share aggregated or anonymous information that does not identify you.

LINKS TO OTHER SITES

Our Sites may contain links to other websites or to third party services, and any personal information you provide in connection with such linked pages or services is provided directly to that third party and is subject to that third party’s privacy policy and terms of use. For example, Get Accounts are managed by a third party, The CBORD Group, Inc. (“CBORD”), and your use of the Get Accounts feature is subject to CBORD’s terms and policies (which are linked to from the Get Accounts sign up page). This Privacy Policy does not apply to such linked sites, and we are not responsible for the privacy and security practices and policies of these websites or any other third-party sites or services that are linked to from the Site. We encourage you to learn about such third-party privacy and security practices and policies before providing them with personal information.

ADVERTISING AND ANALYTICS

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Sites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Sites and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms.

CALIFORNIA PRIVACY RIGHTS

For California residents: IMG may share your personal information with select third parties. Under California law, you may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected].

DATA STORAGE

Your information may be stored on servers in the United States and is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries. Your information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By accessing or using our Sites or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the United States and other countries, where you may not have the same rights and protections as you do under local law.

DATA SECURITY

IMG takes reasonable precautions (including certain physical, administrative, and technical measures) to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Because there is always some risk in transmitting information over the Internet, we cannot guarantee the security of your information

The Service may have links to third-party sites or applications, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications.

YOUR COMMUNICATION CHOICES

Promotional Communications. You may opt out of receiving promotional communications from IMG by following the instructions in those communications or by emailing [email protected]. If you opt out, we may still send you non-promotional communications.

COOKIE POLICY

IMG Academy, LLC (“we”, “us”, “our”) are committed to protecting and respecting your privacy as described in our Privacy Notice, of which this Cookie Policy forms a part.

By consenting to this cookie policy (“Cookie Policy”), you acknowledge and consent to our website using cookies and other similar technologies (as described below) to distinguish you from other users of our website and for analytics. This helps us to provide you with a good experience during your visit to our website. This also allows us to improve our website and provide you with tailored content and advertising. For example we can recognize and remember important information that will make it more comfortable browsing our website such as preferred settings.

A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or your mobile device, if you agree.

We may automatically collect and store certain information about your interaction with our website, including IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamps, and related data. We use this information, which does not identify individual users, solely to improve the quality of our products and services.

Purposes of collection

You can find more information about the types of cookies we use and the purposes for which we use them set out below.

First party cookies

• Session Cookies (Technical Cookies): Their use is strictly limited to sending the session identifiers (random numbers generated by the server) needed for secure and efficient Website browsing. They are not permanently stored on the user’s computer and are deleted upon browser closing. In particular, the use of the session cookies aims at ensuring security and improving of the offered service; and

• Technical Cookie: It is required to keep track of the consent given by the user.

• The described cookies do not require your consent to be installed and used.

Third party cookies

Some third parties can also provide cookies on our website(s). These cookies or similar technologies are managed by the third parties set out in the table below, and are divided into the following categories:

• Analytical Cookies: we use Google Analytics, the web analytics service offered by Google, Inc. (“Google”) to analyse how our Website is used. This service uses cookies generating information on your use of our Website (including your IP address), collected from Google in an anonymous form. Disabling these third-party cookies does not affect the Website use;

• Marketing/Advertising: Cookies used to provide advertising services on a given Website fall within this category. Disabling these third-party cookies does not affect the Website use; and

• Profiling Cookies: They are used to trace the user’s network browsing and create profiles about his/her tastes, behavior, choices, etc. These cookies allow the transmission of online advertising messages to the user’s device with the preferences already expressed by that same user when browsing. In accordance with applicable laws, using these cookies and any processing related thereto require the prior user’s consent. Disabling these third-party cookies does not affect the Website use.

We suggest that you visit these third-party websites to understand how their cookies are used.

You also acknowledge and consent to the use of third party cookies (including, for example, those provided by operators of advertising networks and providers of external services like web traffic analysis services). You acknowledge that where we allow advertising networks, external services, and other third-party services on the website, we have no control over cookies they collect.

Refusing or deleting cookies

Most internet browsers are set up by default to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Please note you may not be able to take advantage of all the features of our Website, including certain personalized features, if you delete or refuse cookies.

To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

For more information on managing cookies, please go to www.allaboutcookies.org.

If you are a resident in the EU

For more information on managing cookies, please visit www.youronlinechoices.eu which has further information about behavioral advertising and online privacy.

Changes to our Cookie Policy

This Cookie Policy may be updated from time to time.

If we change anything important about this Cookie Policy we will notify you through a pop-up on the website for a reasonable length of time prior to and following the change. You may review the Cookie Policy by visiting the website and clicking on the “Policy” link in the footer.

EU RESIDENT PRIVACY NOTICE

This Privacy Notice last changed on December 3, 2020

This notice describes how we use your personal information.

Who we are

We are IMG Academy, LLC and respect your privacy.

Your personal information is collected by IMG Academy, LLC (“we”/”us”/”our”).

IMG Academy’scontact details are as follows: Tel: 941-877-5933; Address: 5650 Bollettieri Blvd, Bradenton, Florida 34210

We have appointed International Management Group (UK) Limited of Building 6, Chiswick Business Park, 566 Chiswick High Road, London W4 5HR as our representative in the EU. If you have any questions or complaints in relation to the use of your personal information or this Notice you can contact our representative as below.

E-mail: [email protected]

Post: Building 6, Chiswick Business Park, 566 Chiswick High Road, London W4 5HR

Telephone: +44 20 8233 6510

Data collection and usage

We will collect store and use your personal information

1. to conduct our business;
2. to allow access to this website, register / subscribe / buy / use our products and services;
3. to meet our legal obligations;
4. to fulfil any purpose we make known to you when we collect your personal information; and
5. to fulfil other purposes set out in more detail in this section.

Certain types of personal information are more sensitive than others. “Special information” about you includes information about health, disability, race, ethnicity, biometrics or religion. We may collect and receive special information about you.

We have identified here the types of information we may collect or receive, how we will use it and why we will use it.

The table below explains what information we collect and how and why we use it.

If you would like to have more information about our legitimate interests to process your personal data, please contact us as set out below.

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 our group companies and combined with information collected by us. We will also receive and display information and content which you make publicly available on your social media accounts.

Some information is processed because you’ve given your consent to that (where consent is required). You can withdraw your consent at any time (in your account preferences or settings) or by contacting [email protected].

Sources of data

Your personal information is either (a) provided by you (e.g. via our website / platform / App /social media pages); (b) obtained from third parties (such as other group companies); or (c) obtained from publicly available sources (e.g. the Internet).

In particular, data may be obtained from the following third parties: social networks, payment processing companies, data brokers, ticketing companies, Google Adwords, LinkedIn, Google Analytics, Adobe Analytics, display partners, social networks, third party site plugins.

Legal and other requirements

In some cases we need to collect or retain personal information for legal reasons.

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 our website, 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 to the primary purpose of the data collection (to provide the services).

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, or in order to investigate, prevent or take action regarding suspected illegal activities or fraud, to enforce or apply our Terms of Use and other agreements, to protect the rights, property or safety of 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.

Any personal information you supply to us through our website must be complete and accurate. You also agree to allow us to contact you to verify your personal information, if we need to.

How long do we keep your information

We generally keep information as needed to provide services and to deal with legal claims

We will keep your information for as long as it is reasonably necessary and to deal with claims. It will depend on factors such as whether you’ve got an account with us, have interacted with recent offers or have attended our recent events. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Information we share

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

• We share information about you with other members of our group of companies so we can provide the best service across our group. They are required to keep and use your information in accordance with this Privacy Notice.
• 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.
  • make use of the personal information we have collected from you to help our advertisers display their advertisements 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 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.
• We 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 service providers include advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, email providers and outsourced call centres. 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 function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Notice.
• We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include data sharing screening agencies and other partners we do business with such as other loyalty scheme partners AND Next College Student Athlete (NCSA – https://www.ncsasports.org/privacy-policy). If we are not able to share information with certain partners who are also in our loyalty scheme, we will not be able to offer that service.

Your personal information may be transferred to other third party organisations in certain scenarios:

• if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
• if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
• if we are defending a legal claim your information may be transferred as required in connection with defending such claim;
• if there is an emergency including which requires us to share your data to protect the health and safety of our website’s or App’s users or the general public.

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

Your information may be transferred outside the European Economic Area.

The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA), including the USA which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our group companies, or for the organisation that hosts our website.

However, to ensure your personal information is properly protected in line with EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation.

We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.

If you would like to obtain copies of the regulator-approved SCCs please contact us on the contact details below.

In addition, we may transfer data to non-EEA jurisdictions, or receive data from EEA jurisdictions, where you give your explicit consent.

Your Rights

You have certain rights in relation to your 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 [email protected].

• 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 may 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.
• Transfer: you may request the transfer of certain of your personal information to another party.
• Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests 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.
• Consent: where we are processing personal data with consent, you can withdraw your consent. If you want to exercise any of these rights, please contact [email protected].

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. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

Right to object

You have a right to object to us processing your information in certain circumstances.

Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests 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.

Direct Marketing

As described above, you can opt-out of receiving direct marketing from us at any time.

We may use the information you give us on our website / App for direct marketing purposes to provide updates, newsletters, events, or other communications that we think may interest you. We will only do this with your consent (where required by law).

You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the “unsubscribe” link included at the end of any marketing email we send to you, or by contacting [email protected].

Analysis and Marketing

We use third party tools to personalize the advertising displayed to you on our website / App.

We use third party tools, to make the advertising we show you on our website, Apps and / or our partner websites more relevant and interesting to you, and to provide advertising to you on third party non-partner websites (including social media websites such as Facebook). Please see our Cookies Policy for further information.

You may opt-out at any time from the collection and use of your data by contacting us at [email protected].

Do Not Track

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 using an iOS device:

• 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.

To submit a Do Not Track request on mobile using an Android device

• open Google Settings,
• select AdsPrivacy and toggle ON the switch next to Do Not Track to opt out of Ads Personalization. Do Not Track is now enabled on your Android device.
• Apps are then instructed not to use your advertising ID to build profiles or show you personalized ads.

Some devices may require a different procedure, so please check your instructions.

Cookies and Similar Technologies

We and our advertising agency partners use cookies and “web beacons” that identify your browser.

Cookies collect and store information when you visit our website including information 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.

Web beacons (also known as “single pixel GIFs”, “clear GIFs” or “tags”) are small graphic images that may be included on our website. Web beacons:

• allow us to optimise our products and services;
• provide us and third-party partners with analytics information, such as how many visitors our website receives; and
• are used by us in our email correspondence to determine whether you open them or take any further action.

We also work with other organisations to place our cookies and web beacons on their websites or in their advertisements. We do this to help us develop statistics on how often clicking on an advertisement on our websites results in a purchase or other interaction on the advertiser’s website.

For more information about cookies and how we use them, please see our Cookie Policy.

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 our 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 website

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser.

The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy notices of entities through which you choose to share.

Changes to this Notice

This notice may be changed from time to time.

If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

Once this notice is posted on our website, it will automatically come into force. The latest version of this notice will prevail over all previous versions.

If you would like to access previous versions of this notice please contact [email protected].

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 notice please contact [email protected].

IF YOU HAVE QUESTIONS

If you have any questions about this Privacy Policy or the practices described herein, you may contact us at [email protected].

REVISIONS TO THIS POLICY

IMG reserves the right to revise this Privacy Policy at any time. When we do, we will post the change(s) on the Sites and update the date at the top of this Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice to you. We encourage you to review the Privacy Policy whenever you access the Sites to stay informed about our information practices and the ways you can help protect your privacy.