PRIVACY POLICY

This Privacy Policy sets forth the privacy practices of Winter Globe Sports, including its subsidiaries and affiliates (collectively, “Winter Globe Sports,” “we,” “us,” or “our”), in relation to the website located at https://winterglobesports.com/, as well as any other websites owned or controlled by us that display or contain a link to this Privacy Policy (collectively, the “Sites”). This Privacy Policy further applies to our retail stores and any related services (together with the Sites, the “Service”).

This Privacy Policy also outlines the rights and choices available to individuals regarding the collection, use, disclosure, and processing of their personal information in connection with the Service.

Additional provisions applicable to residents of California are set forth in the NOTICE TO CALIFORNIA RESIDENTS section, and information specific to individuals located in Europe is provided in the NOTICE TO EUROPEAN USERS section below.

PERSONAL INFORMATION WE COLLECT

Personal Information You Provide

You may provide personal information to us through the Service or by other means, including but not limited to:

• Contact Information: Personal or business contact details, such as your full name, email address, mailing address, phone number, professional title, and company name.
• Registration Data: Information you provide when registering for an account or signing up for an event, including your date of birth (day and month) and event registration details.
• Third-Party Data: Information regarding other individuals for whom you purchase products or gifts, including their name, delivery address, and phone number. You must ensure that you have obtained the individual’s consent before providing their information.
• Profile Information: Username, password, and preferences that you set when establishing an online account with us.
• Communications: Any information you provide when contacting us for inquiries, feedback, survey responses, or other forms of correspondence.
• Marketing Data: Contact details, including your email address, that we use for marketing communications, as well as your preferences regarding receiving promotional content about our activities, events, sweepstakes, and contests.
• Purchase Data: Transaction history and details necessary to process and fulfill your orders, such as order contents, billing address, and delivery address.
• Other Information: Any additional personal data collected that is not explicitly listed herein will be used in accordance with this Privacy Policy or as disclosed at the time of collection.

Information from Other Sources

We may collect additional information about you from the following sources:

• Business Partners: Such as advertising and joint marketing partners.
• Data Providers: Including information services and data licensors.
• Publicly Available Sources: Including blogs, forums, and social media platforms.

Information Obtained from Third-Party Platforms

If you log in to the Sites via a third-party platform (e.g., Google, Facebook) or link your account to such a platform, we may collect data from that platform, including but not limited to:

• Your account details on that platform.
• A list of your connections or friends (where applicable).
• Your email address and other information you choose to provide.

For further details on managing your privacy settings, refer to the “Your Choices” section.

Automatic Data Collection

We and our service providers may automatically collect and log information about you, your device, and your activity on the Sites, including:

• Device Information: Your computer or mobile device type, operating system version, manufacturer, model, browser type, screen resolution, IP address, referring website, and general geographic location (e.g., city, state).
• Online Activity Data: The pages or screens you view, the duration of your visits, navigation paths, interaction with website elements, and timestamps of access.

Cookies and Similar Technologies

We use cookies and related tracking technologies to facilitate automatic data collection. For more details, refer to our Cookie Policy.

Referrals

Users of the Service may have the option to refer friends or other contacts. If you choose to provide referral information, you must ensure that you have obtained the referred individual’s consent before sharing their contact details with us.

HOW WE USE YOUR PERSONAL INFORMATION

Use of Personal Information

We collect and process personal information for the following purposes, as outlined in this Privacy Policy or as disclosed at the time of collection:

1. Service Delivery

We may use your personal information to:

• Provide, operate, and enhance the Service, including enabling you to purchase clothing and accessories available on the Sites;
• Establish and maintain your account on the Service;
• Communicate with you regarding the Service, including sending announcements, updates, security alerts, and administrative messages;
• Provide customer support and maintenance for the Service;
• Facilitate your login to the Sites via third-party platforms such as Google and Facebook; and
• Enable security features of the Sites, such as sending security codes via email or SMS and recognizing previously used devices.

2. Direct Marketing

If you are an existing customer of Winter Globe Sports (e.g., if you have previously placed an order with us), we may use the personal information you have provided to send you marketing communications regarding Winter Globe Sports products and services, in compliance with applicable law (unless you have opted out).

In cases where legal requirements mandate, we will obtain your consent before sending marketing communications. We may also use information provided by you, as well as data from other Winter Globe Sports products or services (including your interactions with our website and applications), to personalize communications and advertising regarding our offerings that may be of interest to you.

For registered users, this may include data collected from website or app interactions linked to your account. You may opt out of receiving marketing and promotional communications as described in the “Your Choices” section below.

3. Research and Development

We may use your personal information for research and development purposes, including analyzing and improving the Service and our business operations.

4. Creation of Anonymous Data

We may aggregate, de-identify, or otherwise anonymize personal information collected from you and other individuals. This process removes personally identifiable details (such as your name) to create anonymous data. Such data may be used for lawful business purposes, including analysis and improvements to the Service, or may be shared with third parties.

5. Interest-Based Advertising

We may engage third-party advertising and social media companies to display targeted advertisements across our Service and other online platforms. These third parties may utilize cookies and similar technologies to collect data about you—including device information, online activity, and geolocation—over time and across multiple websites and services.

This data is used to serve interest-based advertisements tailored to your preferences. Additional details on how to manage your advertising preferences are provided in the “Your Choices” section below, as well as in our Cookie Policy.

6. Legal Compliance

We may use your personal information as necessary or appropriate to comply with applicable laws, regulations, lawful requests, and legal processes, including responding to subpoenas or government authority requests.

7. Fraud Prevention and Security

We may process and disclose personal information when necessary to:

• Protect the rights, privacy, safety, or property of Winter Globe Sports, our users, or third parties (including by asserting or defending legal claims);
• Conduct internal audits to ensure compliance with legal and contractual obligations;
• Enforce our terms and conditions governing the use of the Service; and
• Detect, investigate, and prevent fraud, unauthorized activities, cyber threats, identity theft, and other security risks.

8. Consent-Based Processing

Where required by law, we may specifically request your consent to collect, use, or disclose your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information with the following third parties and as otherwise described in this Privacy Policy or at the time of collection:

1. Affiliates

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

2. Service Providers

We may engage third-party service providers to perform various functions necessary to operate our business and the Service. Such providers may assist with order fulfillment, shipping, payment processing, customer support, hosting, analytics, email delivery, marketing, database management, returns processing, and risk and fraud mitigation.

3. Advertising Partners

We may provide information about your activities on the Site and other online services to third-party advertising companies to facilitate the marketing of our services. Additionally, we may share hashed customer lists with advertising partners for targeted advertising on their platforms.

4. Third-Party Platforms

If you connect your account to a social media or other third-party platform (e.g., by logging in through a social media service), we may share your personal information with such platforms. Please note that we do not control how these third-party platforms use your personal data.

5. Public Disclosures

Certain aspects of our Service may allow you to voluntarily disclose personal information to other users or the public. For example, if you submit a product review, your name may be displayed alongside your comments. We do not control how others may use, cache, copy, screen capture, or distribute information that you voluntarily disclose.

6. Professional Advisors

We may disclose your personal information to professional service providers such as legal counsel, auditors, bankers, and insurers in connection with the services they provide to us.

7. Legal Authorities and Third Parties for Compliance Purposes

We may disclose personal information to law enforcement, government agencies, or other third parties as required by law or if we believe such disclosure is necessary to comply with legal obligations, protect against fraud, enforce our agreements, or safeguard the security and integrity of our Service.

8. Business Transactions

In the event of a merger, acquisition, reorganization, sale, transfer, divestiture, or other disposition of all or a portion of our business or assets, including in the context of bankruptcy or receivership, we may transfer or disclose your personal information as part of such a transaction.

YOUR RIGHTS AND CHOICES

We provide users with several options regarding the collection, use, and disclosure of their personal information.

1. Access and Updating Your Information

Registered users may review and update their personal information by accessing their account profile.

2. Opting Out of Marketing Communications

• You may opt out of receiving marketing emails by following the “unsubscribe” link at the bottom of such communications.
• You may continue to receive non-marketing communications, including those related to transactions and service updates.
• To opt out of marketing text messages, you may reply “STOP” to the message received.

3. Managing Cookies and Tracking Technologies

Most web browsers allow users to remove or block cookies through browser settings. Additional details are available in our Cookie Policy.

4. Interest-Based Advertising Choices

You may opt out of targeted advertising by following the instructions provided in the “Your Choices” section of our Cookie Policy.

5. “Do Not Track” Requests

Some browsers offer “Do Not Track” (DNT) signals. We do not currently respond to such signals. More information about DNT is available at www.allaboutdnt.com.

6. Location Data and Privacy Settings

Users of our mobile applications can disable location tracking via their device settings.

7. Refusal to Provide Personal Information

If you choose not to provide requested information, we may be unable to offer certain features or services. We will indicate when certain data is required.

8. Third-Party Account Integrations

If you connect your Service account with a third-party platform (e.g., social media networks), you may control what data is shared through the third-party’s settings.

EXTERNAL LINKS AND THIRD-PARTY SERVICES

Our Sites may contain links to external websites or services not owned or controlled by us. We are not responsible for the privacy practices of such third parties and encourage you to review their respective privacy policies before engaging with them.

SECURITY MEASURES

We implement organizational, technical, and physical security measures to protect personal information. However, no security system is entirely foolproof, and we cannot guarantee the absolute security of your data.

INTERNATIONAL DATA TRANSFERS

Winter Globe Sports is headquartered in the United States and may transfer personal information to service providers in other jurisdictions. Such transfers may be subject to varying data protection laws, which may not offer the same level of protection as those in your country.

CHILDREN’S PRIVACY

The Service is not intended for individuals under the age of 16, and we do not knowingly collect personal information from children under this age. If we discover that we have collected such data without verified parental consent, we will take appropriate measures to delete it.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. If material changes are made, we will update the “Last Updated” date and provide notice where required by law (e.g., via email or within the Service).

Your continued use of the Service following any updates constitutes your acceptance of the revised Privacy Policy.

CONTACT INFORMATION

For inquiries regarding this Privacy Policy, please contact us at:

Winter Globe Sports
Email: info@winterglobesports.com

NOTICE TO CALIFORNIA RESIDENTS

Effective as of January 1, 2020, California residents are entitled to additional disclosures under the California Consumer Privacy Act (CCPA) regarding the collection, use, and sharing of their personal information.

• Sale of Personal Information: We do not sell personal data.
• Tracking Technologies: We use cookies and analytics tools for advertising and site functionality.

For a full summary of data collection and sharing practices under the CCPA, please refer to the table in our CCPA Summary Section.

 The business and commercial purposes for which we collect this information are described in the section above entitled How We Use Your Personal Information. The categories of third parties to whom we disclose this information are described in the section above entitled How We Share Your Personal Information.

Your California privacy rights. The CCPA grants California residents the following rights. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Information. You can request information about how we have collected, used, and shared and used your Personal Information during the past 12 months.
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

We have provided additional information about how you can opt-out of the use of your information for interest-based advertising in the “Your Choices” section of our Cookie Policy.

How to exercise your California rights. You may exercise your California privacy rights described above as follows:

• Right to information, access, and deletion. You can request to exercise your information, access, and deletion rights by emailing info@winterglobesports.com. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access, or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to request on your behalf. To designate an authorized agent to request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
• Request a list of third-party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family, or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any). You can submit such a request by sending an email to info@winterglobesports.com with “Shine the Light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

NOTICE TO EUROPEAN USERS

The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area, or the United Kingdom (collectively, “Europe”).

Personal information. Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Winter Globe Sports .

Legal bases for processing. The legal basis of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at info@winterglobesports.com.

USE OF PERSONAL INFORMATION FOR NEW PURPOSES

We may process your personal information for purposes not expressly described in this Privacy Policy, provided such use is permissible under applicable law and is compatible with the original purpose for which the information was collected. If we intend to use your personal information for any purpose that is unrelated to those initially disclosed, we will notify you and provide the applicable legal basis for such processing.

SENSITIVE PERSONAL INFORMATION

Unless specifically requested, we ask that you refrain from providing us with any sensitive personal information, including but not limited to data relating to:

• Racial or ethnic origin,
• Political opinions,
• Religious or philosophical beliefs,
• Health data,
• Biometric or genetic data,
• Criminal records, or
• Trade union membership.

If you voluntarily provide us with such information, you acknowledge that we may process it in accordance with this Privacy Policy.

DATA RETENTION

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, accounting, and regulatory obligations, the establishment or defense of legal claims, and fraud prevention.

If there is no ongoing legitimate business need for processing your personal information, we will either delete or anonymize it. If deletion or anonymization is not feasible (e.g., if your personal information is stored in a backup archive), we will securely store your data and isolate it from further processing until deletion becomes possible.

YOUR RIGHTS UNDER EUROPEAN DATA PROTECTION LAWS

If you are subject to European data protection laws, you have the following rights regarding your personal information:

• Right of Access – You have the right to request details of our processing activities related to your personal information and obtain access to such data.
• Right to Rectification – You have the right to request that we update or correct any inaccuracies in your personal data.
• Right to Erasure (“Right to be Forgotten”) – You have the right to request the deletion of your personal information in certain circumstances.
• Right to Data Portability – You have the right to obtain a machine-readable copy of your personal data and request that we transfer it to a third party of your choice.
• Right to Restriction of Processing – You have the right to request that we limit the processing of your personal data under certain conditions.
• Right to Object – You may object to our processing of your personal data where we rely on our legitimate interests as the legal basis for processing.

To exercise your rights, please submit a request via email to info@winterglobesports.com or send a written request to our postal address listed in this Privacy Policy. We may require verification of your identity before processing your request. If we are unable to fulfill your request due to legal requirements, we will inform you accordingly.

If you are dissatisfied with our handling of your personal data or our response to your requests, you have the right to lodge a complaint with your local data protection authority. You can find information on your relevant data protection regulator here.

CROSS-BORDER DATA TRANSFERS

If we transfer your personal data outside the European Economic Area (EEA) or another jurisdiction with specific data protection requirements, we will implement appropriate safeguards to ensure that your personal data remains protected in accordance with applicable laws. For further information regarding cross-border data transfers and the safeguards we apply, please contact us at info@winterglobesports.com.

WINTER GLOBE SPORTS COOKIE POLICY

1. INTRODUCTION

This Cookie Policy explains how Winter Globe Sports (“Winter Globe Sports,” “we,” “us,” or “our”) uses cookies and similar tracking technologies in connection with the https://winterglobesports.com website and any other sites or mobile applications under our control that reference or link to this Cookie Policy (collectively, the “Sites” and “Apps”).

2. WHAT ARE COOKIES?

Cookies are small text files stored on your computer or mobile device when you visit a website. They serve various purposes, including enabling website functionality, improving browsing experiences, recognizing returning visitors, and tracking user preferences.

We utilize two primary categories of cookies:

• First-Party Cookies – These cookies are directly set by us and help us recognize your device when it interacts with our Sites.
• Third-Party Cookies – These cookies are set by third-party service providers or business partners. They may be used for analytics, advertising, and integrating social media functionalities.

For more details about our use of cookies and how you can manage your preferences, please refer to our full Cookie Policy.

What types of cookies and similar tracking technologies does Winter Globe Sportsuse on the Sites?

On the Sites, we use cookies and other tracking technologies in the following categories described in the table below.

ADDITIONAL TECHNOLOGIES USED

In addition to cookies, our Sites utilize other tracking technologies, including Flash technology and pixel tags, to collect information automatically.

WEB BEACONS

We may deploy web beacons, also known as pixel tags or clear GIFs, on our Sites and within HTML-formatted emails. Unlike cookies, which are stored on a device’s hard drive, pixel tags are embedded invisibly within webpages or emails. These technologies enable us to:

• Track user interactions with our Sites and email communications,
• Measure the effectiveness of our marketing campaigns,
• Assess engagement with our content, and
• Compile statistical reports to improve the usability and performance of our Sites.

MOBILE APPLICATION SOFTWARE DEVELOPMENT KITS (SDKs)

Our mobile applications may incorporate third-party software development kits (SDKs), which are external code components used for various functions, including:

• Analytics and performance tracking,
• Integration with social media platforms,
• Adding features and functionality, and
• Facilitating interest-based advertising.

These SDKs may permit third-party service providers to collect data directly through our mobile applications.

USER CHOICES AND OPT-OUT OPTIONS

Like many online services, we engage third-party tracking technologies provided by Google, Facebook, and other companies for advertising and analytics purposes. You may exercise the following options to limit the collection and use of your personal information for interest-based advertising:

1. Browser Settings: Blocking or Removing Cookies

Most web browsers allow users to manage cookie preferences, including blocking or deleting cookies used for interest-based advertising. Instructions can be found within your browser settings. Many browsers accept cookies by default unless changed manually. More information on cookie management is available at allaboutcookies.org.

2. Mobile Device Settings

Most mobile devices include options to limit the use of the advertising identifier associated with the device. These settings may reduce targeted advertisements based on your device activity.

3. Privacy Plug-ins and Privacy-Focused Browsers

Users may employ browser plug-ins or privacy-focused browsers to block tracking technologies. Examples include:

• Privacy Badger
• Ghostery
• uBlock Origin
• Brave Browser

Configuring these tools may help prevent third-party tracking.

4. Platform-Specific Opt-Out Tools

Users may opt out of interest-based advertising via the settings provided by major advertising platforms:

• Google Ads Settings: https://adssettings.google.com
• Facebook Ad Preferences: https://www.facebook.com/about/ads
• Criteo Opt-Out: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/
• Bounce Exchange Ad Preferences: https://www.bouncex.com/privacy/your-ad-choices/

5. Advertising Industry Opt-Out Mechanisms

Some of our third-party advertising partners participate in broader opt-out programs, allowing users to restrict the use of their personal data across multiple platforms:

• Digital Advertising Alliance (DAA): http://optout.aboutads.info
• Network Advertising Initiative (NAI): http://optout.networkadvertising.org/?c=1
• European Interactive Digital Advertising Alliance (for European users): Click Here (Select country and then click “Choices” or similar option)
• DAA AppChoices (for mobile applications): Download AppChoices

6. Additional Opt-Out Options

Certain third-party companies may offer their own opt-out mechanisms, which may not be included in the industry-wide opt-out programs listed above.

IMPORTANT NOTES ON OPT-OUTS

• Opting out of interest-based advertising does not eliminate ads but may result in advertisements that are less relevant to your preferences.
• Opt-out mechanisms rely on cookies or browser settings; clearing cookies or using a new device/browser may require reapplying opt-out preferences.
• Some companies engaging in behavioral advertising may not participate in industry opt-out programs, meaning users may still receive targeted ads from those entities.

For further details regarding the collection, use, and sharing of personal information, please refer to our Privacy Policy.

POLICY UPDATES AND CHANGES

The information regarding our use of cookies and tracking technologies may be updated periodically. Users are encouraged to review this section regularly to stay informed of any modifications.

Last update: 30 January 2024