PRIVACY POLICY

SIA Vertexo, a company established in the Republic of Latvia, with unified registration number 40203073672, and legal address at Rigas iela 47 - 2, Jurmala, Latvia, LV-2015, (hereinafter - "Company", "We", "we", "our", "us") has developed this Privacy policy (hereinafter - "Privacy policy") to inform users visiting and registering on the internet website maxwill-sports.cn and Maxwill Sports Application (hereinafter - Maxwill Sports App), collectively referred to as the "Platform", how we collect, use, store, and disclose users' personal data when they use the Platform and any other product or services (including but not limited to, court reservations, event bookings, public and open matches, classes, courses, tournaments, and Circuits offered through Platform) owned by the Company. This Privacy policy applies to all Services offered to users using or visiting (hereinafter - the "Users") the Platform. Protecting Users' privacy and safeguarding their personal data is paramount to us.

Throughout this Privacy policy, Company will use defined terms "personal data" which means any information or data relating to an identified or identifiable natural person, who can be identified, directly or indirectly, in particular by reference to his name, last name, email address, phone number, address, IP address (hereinafter - "Personal data"). Personal data does not include anonymised information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

What information do we collect?

We may collect Personal data User provides directly, information that we collect automatically when User interacts with our Services available on the Platform (such as, visiting the Platform; creation and management of an account on the Platform; registration and participation in, directly or indirectly, any tournament available; purchase of license; court or event booking; contacting our Services) and information collected from third parts.

Data collection by Sports organizers

The Services available on the Platform allow sports organizations (including but not limited to international/national/regional federations, sports ministries, clubs, local organizations, clubs, schools – and their team members, tournament/event organizers and referees), collectively referred to as the (hereinafter - "Sports organizers") to collect and process Personal data of participants who have registered to participate in their tournament or event, made bookings and purchased licenses. When Users register to a tournament available on the Platform, make event bookings or purchase licenses, they accept that Sports organizers will have access to the Personal data they entered when registered. When User registers a partner for a tournament and enters his/her details, Sports organizers also receive the partner's Personal data. Sports organizers shall be responsible for the collection and processing of data collected for their tournament or event, storage and security of Personal data, including all appropriate technical and organizational measures to protect Users' Personal data.

What are the types of Personal data collected?

Types of personal data collected:

• Account (identification) data: such as – name, middle name, surname, gender, date of birth, email address, username, and password, sport choice, career details, a photograph of the User's profile, social media profiles. We collect this data when User provides it directly to us for the purposes of account creation and management, advertising and marketing, analytics, customer service, and Platform security and maintenance.
• Contact data: such as – postal address, country of residence, country of representation, email address and phone number, language of communication. We collect this data when User provides it directly to us for the purposes of account creation and management, advertising and marketing, analytics and customer service.
• Payment (transactional) data: such as – name, middle name, surname, transaction records.
• Analytics data: such as – cookies, tracking pixels, tags or similar tools, which may collect information about User's browser and/or device (device type, version, operating system, settings), geographical location. We use cookies for the purposes of account creation and management, advertising, marketing and to analyze how Users use our Platform. Please read the Cookie Policy for more information about cookies.
• Location data: such as – IP address, login place, transaction place.
• Correspondence records: such as – chat records, in case chat services are used, via email and/or by phone, or using other tools. We collect this data for the purposes of account creation and management, customer service and Platform maintenance.
• Sport/team information: such as – User's position, statistics, team name, matches, Circuits.
• Event and schedule information: such as – location of matches and tournaments, future events, confirmation of attendance.
• Commercial history: such as – information regarding the purchases Users have made through our Services, User's subscription information.
• Social media data: includes information about Users' social media profiles, links, information that User posts by sharing on a blog or another social media platform.

What are the purposes of collecting Users data?

User's Personal data may be collected for the following purposes, depending on the Services:

• Creation and management of User accounts;
• Performing technical and administrative features of the Platform;
• Providing the Services User requests (registration for the tournament, participation in tournaments, participation payments);
• Sending commercial offers or newsletters by email;
• Providing customer service;
• Providing customer support via chat;
• Monitoring and analysis the use of the Services by Users;
• Platform security and maintenance;
• Sharing information with Sports organizers for the tournaments in which User participates in;
• Sharing information with Sports organizers when purchasing licenses.

What are legal bases for processing Users Personal data?

We will only collect and use User's Personal data when we have a legal base for doing so. Our legal bases depend on the Services Users use and how they use them. In this way, we may use User's Personal data on following legal bases:

• Consent. Where User gives us consent to collect and use User's Personal data for a specific purpose. For example, we may obtain User's consent for commercial offers or newsletters. Users can withdraw consent at any time.
• Performance of a contract. We may process User's Personal data when the processing must be necessary for the performance of the contract, for example, to provide our Services, to authorize and control access to the Services.
• Compliance with law. We may have a legal obligation to use User's Personal data to comply with a common law or statutory obligation. Such cases may include court orders, information on requests for government agencies or criminal investigations.
• Our legitimate interests. We may process User's Personal data when it is necessary for Company's legitimate interests, for example, to provide or improve our Services, to prevent unlawful use of the Services, to defend legal claims and handle User complaints.

Who are the recipients of Users data?

We may share User's Personal data with our processors, payment service providers, business partners and authorities. When User registers to a tournament available on Platform, User accepts that the Sports organizer will have access to the Personal data User entered when registered to the tournament or event. We may share information we collect about Users, including Personal data, in the following ways:

• With third-party service providers, such as agents, contractors, IT companies, security, payment intermediaries, etc;
• Authorities, such as law enforcement agencies and supervisory authorities;
• Sports organizers.

Personal data recipients may process User's personal data acting as data processors and/or as data controllers. When a data recipient is processing User's Personal data on its own behalf as a data controller, the recipient is responsible for providing information on such data processing. When a data recipient is processing User's personal data on our behalf, a data processing agreement is concluded to ensure an adequate level of protection and confidentiality.

International transfers and data sharing

We and our partners process User's Personal data within the European Union/ European Economic Area (EU/ EEA), but in some cases, Personal data is transferred to and processed in countries outside of the EU/EEA. It may also be processed by staff operating outside the EU/EEA who work for the Company or for one of our suppliers. When Personal data is processed outside the EU/EEA the country where the recipient is located should have an adequate level of data protection as decided by the EU Commission (Adequacy Decision), or the controller or processor should provide appropriate safeguards and on condition that enforceable rights and effective legal remedies are available for individuals. If a transfer of Personal data is envisaged to a third country that isn't the subject of an Adequacy Decision and if appropriate safeguards are absent, a data transfer can be made based on a number of derogations for specific situations for example, where an individual has explicitly consented to the proposed transfer. We will take all steps reasonably necessary to ensure User's Personal data is treated securely and in accordance with this Privacy policy.

What are Users rights?

Users are entitled by law to access, correct, restrict or delete personal information about them that we hold. Please note that these rights are not absolute and certain exemptions may apply to specific requests that User may submit to us.

• Right of access: Users have the right to obtain from us confirmation whether or not we are processing Personal data about them, and if so, the right to be provided with the information we process about them. Users also have the right to ask for a copy of their personal data.
• Right to rectification: Users are entitled to request us to rectify the inaccurate or incorrect personal data about them.
• Right to erasure: Users are entitled to request us to erase their Personal data, in case one of the following grounds applies:
  • Purposes of the processing Personal data have been reached;
  • Personal data is no longer necessary in relation to the purposes for which it was collected and processed;
  • Users have objected data processing;
  • Consent for data processing has been withdrawn;
  • Personal data has to be erased for compliance with a legal obligation;
  • Personal data has been processed unlawfully, that is, with no valid legal basis.
• Right to data portability: Users have the right to receive their Personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller.
• Right to the restriction of the processing: Users have the right to request from us to restrict the processing of their Personal data if one of the following grounds applies:
  • Data processing is unlawful and User has requested the restriction as opposed to the erasure of the Personal data;
  • We no longer need User's Personal data, but the data is necessary for User to establish or exercise or defend legal claims;
  • User contests the accuracy of the Personal data, for a period where we will verify the accuracy of the Personal data we collected;
  • User objects to data processing, pending the verification whether our legitimate grounds for processing override User's rights.
• Right to withdraw consent: Users have the right to withdraw previously given consent at any time in the account's profile, or to unsubscribe from the newsletter in email. However, this will not affect the lawfulness of any processing carried out before withdrawal of User's consent.
• Right to object: Users have the right to object to Personal data processing activities concerning targeted advertising, direct marketing or which are based on our legitimate interests. However, the Company reserves the right to ask for the grounds of the objection in particular situations.
• Rights related to automated decision-making and profiling: To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning Users or which significantly affects them, Users have the right not to be subject to such decision-making.

How can Users exercise their rights?

If Users wish to exercise any of the rights listed above, they can submit a request by email to hello@tournated.com or submit a signed request to Rigas iela 47 - 2, Jurmala, Latvia, LV2015. Other authorized persons can submit a request on behalf of the User by providing a valid power of attorney enclosed with the request. Please be aware that we reserve the right to request additional information from the User in order to verify the identity of the person who has sent the request.

How can Users manage advertising and marketing choices?

We may send commercial offers or newsletters to Users but first we will obtain Users consent. Users will always have the right to withdraw their consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying account settings, or by contacting us at hello@tournated.com.

How do we protect Users' Personal data?

The security of Users' personal information is important to the Company. We take various reasonable organizational, administrative, and technical measures to protect User's Personal data from unauthorized access, disclosure, alteration, or destruction. In the unlikely event of a data breach, we will promptly notify Users and/or the relevant supervisory authorities if Users' Personal data is at risk, in compliance with applicable laws and regulations.

How long is Users data stored?

We retain the Personal data we collect for so long as is reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations (including any exemptions or exceptions contemplated by law), and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

Third party links

Our Platform may contain links to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites and cannot accept responsibility or liability for their respective privacy policies. Users are advised to review the Privacy policy of every website they visit.

How children's rights are protected?

To access and use our Services, children aged under 16 years old must be authorized by their legal representative (for example, by their parents, legal guardian or any person of majority age designated by the parents or by the child's legal guardian). If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to this Privacy policy

We may update our Privacy policy from time to time. We will notify Users of any changes by posting the new Privacy policy on this Platform. Anyway, we advise Users to review this Privacy policy periodically for any changes. Any version of the Privacy policy that is published on the Platform replaces all previous versions and takes effect immediately upon posting or from the effective date as indicated.