This privacy policy (“Privacy Policy”) governs Personal Information (as hereinafter defined) that we collect, use, or disclose about you: (i) on or through our websites and the subscription services offered through our websites, or in email, text, and other electronic messages between you and the websites (including, without limitation: the Sharpway Sports Consulting website and other websites operated by us that link to this Privacy Policy) (each, a “Website” and collectively, the “Websites”), (ii) on the mobile, tablet and any other Sharpway Sports Consulting apps (all of which together are referred to herein as the “Apps”) (the Websites and Apps and any services or functionality available in connection therewith are collectively referred to as the “Services”), which are operated and/or controlled by 1000250387 Ontario Corp., d/b/a Sharpway Sports Consulting (referred to herein as “Sharpway Sports Consulting”, “we”, “us”, or “our”), (iii) when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this Privacy Policy. This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below) and does not govern the data and privacy practices of third parties that may interact with our Services.

In addition, please review our Terms of Use which govern your use of the Services as well as the rules applicable to any games, contests or similar promotions within the Services (each a “Promotion”) that will be offered subject to additional guidelines, policies and rules provided separate from and in addition to the Terms and Conditions (collectively, the “Promotions’ Official Rules”).

By using our Services, you consent to our Privacy Policy, the Terms of Use and any applicable Promotions’ Official Rules and our collection, use and sharing of your Personal Information (as hereinafter defined) and data, and other activities, as described below. We will only use your Personal Information in accordance with this Privacy Policy. We take steps to ensure that the Personal Information that we collect about you is limited to that which is necessary for the purposes identified in this Privacy Policy. From time-to-time, Personal Information may also be collected for other purposes, or as permitted or required by law. We will always identify any additional purpose prior to, or at the time, of collection.

If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information (as hereinafter defined) and do not use the Services.

Table of Contents
It is important that you read and understand the entire Privacy Policy before using the Services. The table of contents below highlights the topics covered and you can click on the headings to be taken to the full explanation.

The Full Detailed Privacy Policy

1. The Information the Services Collect

2. How We Use the Information Collected

3. How and When We Disclose Information to Third Parties

4. Your California Privacy Rights

5. Your Nevada, Connecticut, Virginia and Colorado Privacy Rights

6. Your Canadian Privacy Rights

7. Ads and Information About You

8. Do Third-Party Content, Links to Third-Party Sites and/or Third Party Apps Appear on the Services?

9. How Do I Change My Information and Communications Preferences?

10. What About Transfer of Information?

11. What about Security?

12. What About Data Retention?

13. What Should Parents Know About Children?

14. What About Changes to the Privacy Policy?

15. Withdrawing Your Consent

16. Contact Information and Challenging Compliance

1. The Information the Services Collect

(a) Information you Provide to Us

When you use our Services, we or our service providers may ask you to provide certain types of information such as: (1) personally identifiable information, which is information that can be used on its own or with other information to identify you personally, such as your first and last name, email address, home or mailing address, birth date, credit card or other banking information, social security number, social insurance number and phone numbers, voice or likeness (“Personal Information”); and (2) demographic information, such as information about your gender and age (“Demographic Information”). We may collect Personal Information and Demographic Information through various forms and in various places on the Services, including through “contact us” forms, when you register for an account with the Services, deposit funds into an account, on document upload pages, when you wager or otherwise purchase products or services from us. Personal Information once “De-identified” (i.e., the permanent removal or modification of the personally identifiable elements, or the permanent extraction of non-personally identifiable elements including through anonymization, pseudonymization and/or hashing) is not considered Personal Information provided the de-identification process cannot be reversed and/or personally identifiable elements derived from such de-identified information, and such de-identified information may be used and shared by us or other third parties without obligation to you, except as prohibited by applicable law.

(b) Information We Collect and Store as You Access and Use the Services

In addition to any Personal Information or other information that you choose to submit to us via our Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Services. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information. This Usage Information may include:

We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

We may use Tracking Technologies for a variety of purposes, including:

There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with our Services, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

(c) Information Third Parties Provide About You

We may receive information about you from your friends and others that use the Services, such as when they submit your information to us about you, if for example, they invite you to take part in a special promotion we are offering. Additionally, we may from time to time supplement the information we collect directly from you on our Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content and ads to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.

(d) Interactions with Third-Party Services

The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party website, application or other service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Services to facilitate your sending a communication from the Services. For example, we may use third parties to facilitate emails, Tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Sharpway Sports Consulting does not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Services.

(e) Information You Provide About a Third Party

You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain a consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

(f) California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms; provided, however if required by applicable law or third-party platform, we will make commercially reasonable efforts to honor a user’s settings.

2. How We Use the Information Collected

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including the following business purposes:

Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

3. How and When We Disclose Information to Third Parties

We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may now or in the future share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. If you are a California resident, you have the right to request additional information about this sharing, so please see Section 4 below. In addition, we may share the information we have collected about you, including Personal Information, Demographic Information and/or Usage Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may disclose your information as follows:

(a) When You Request Information from or Provide Information to Third Parties

When You Request Information from or Provide Information to Third Parties. You may be presented with an option at the time of use of our Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to that third-party’s privacy policies and practices. In addition, third parties may store, collect, disclose or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Services or link to them from our Services. This may include using third party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf

We may use third-party vendors to perform certain services on our behalf and in relation to the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) to host the Services; (iv) to design and/or operate the Services’ features; (v) to track the Services’ activities and analytics; (vi) to enable us to send you special offers or to perform other administrative services; and (vii) to offer other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available upon request pursuant to the procedure set forth in Section 15 herein. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer

We may share your information, including your Device Identifiers, Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Contests and Promotions

We may offer contests, and other promotions (each, a “Promotion”) through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion and age gating. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency. We also use a temporary cookie to remember your age selection so to enhance your experience on our website.

4. Your California Privacy Rights

This Section 4 provides additional information regarding the personal information (as defined below for the purposes of this Section 4 only) about California residents that we collect, how we use it, what sources it is derived from, and who we share it with, and provides information regarding to California residents’ rights, and Sharpway Sports Consulting’ responsibilities, under the California Consumer Privacy Act (“CCPA”) and other relevant California laws and regulations.

For the purposes of this Section 4 only, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. It includes information collected via any medium, including online and offline. Personal Information does not include publicly available information, information that has been permanently de-identified or aggregated, or other information covered by certain sector-specific privacy laws.

(a) Personal Information We Collect

Sharpway Sports Consulting may collect, or has collected, the following categories of Personal Information about you over the last twelve (12) months:

Identifiers

Commercial information

Geolocation data

Inferences drawn from other Personal Information

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

(b) How We Use Your Personal Information

We use the Personal Information we collect about you for all of the business purposes outlined in Section 2 above.

(c) Sources of Personal Information

We may collect Personal Information from the following categories of sources:

We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.

(d) Who We Share Personal Information With

We limit our disclosure of the categories of Personal Information above to our service providers for one or more business purposes. We do not sell your Personal Information to third parties and have not in the immediate preceding twelve (12) months. As with many businesses with an online presence, we do share a limited set of data that is gathered when you visit our Services, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. Please review the other disclosures in this Privacy Policy, including Sections 1 and 5, for more information about these practices. To the extent this activity is interpreted as included in California’s broad definition of “data sale”, we have provided you with opt-out rights as to that activity as described in Section 4(f) below.

In the last twelve (12) months, we have not shared any Personal Information to any third parties. We do not have actual knowledge of collecting or selling any Personal Information of California residents under the age of thirteen (13).

(e) Your Privacy Rights
If you are a California resident, you have the following rights under applicable California law in relation to your Personal Information, subject to certain exceptions:

Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. In order to verify you, you must provide us with name and email address, other verification documents issued by a government, and a utility bill. These rights are also subject to various exclusions and exceptions under applicable laws.

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to info@sharpwaysports.com.

We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of thirteen (13), as we do not collect personal information from any person under the age of thirteen (13).

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

You may exercise any of the rights described in this section by sending an email to: Sharpway Sports Consulting at info@sharpwaysports.com. , with “California Privacy Rights” as the subject line or mail us a letter to: Sharpway Sports Consulting,778 Sheppard Ave W, Unit 104 North York, ON M3H 6B7.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


(f) Notice of Right to Opt-Out

If you wish to opt-out of our sharing of the data that is gathered when you visit our Services for purposes of targeted digital advertising, we encourage you review the information and options described in Section 7 – Ads and Information About You.

(g) Right to Opt-Out of Sharing for Direct Third-Party Marketing

We may now or in the future elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2022 will receive information about 2021 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: info@sharpwaysports.com, with “California Privacy Rights” as the subject line or mail us a letter to: Sharpway Sports Consulting, 778 Sheppard Ave W, Unit 104 North York, ON M3H 6B7. You must include your full name, email address with which you registered on Sharpway Sports Consulting, and postal address in your request.

(h) Right to Request Correction of Inaccurate Personal Information

As of July 1, 2023, California residents have the right to request correction of inaccurate personal information that we have about you, and to request that we limit disclosure or use of your sensitive personal information. Please note, however, that any right to request correction is limited by our legal rights relating to content on our website as set forth herein. You can learn more about how to submit a data rights request by sending an email to info@sharpwaysports.com.

5. Your Nevada and Connecticut Privacy Rights

(a) Your Nevada Privacy Rights

While we don’t sell your Personal Information as defined by Nevada law, we reserve the right to sell Personal Information to third parties in the future should we change this policy. Nevada S.B.220 allows Nevada residents to opt-out of the sale of their Personal Information now in the event we change our policy in the future. If you are a Nevada resident we want you to know that you have choices and can opt-out of Sharpway Sports Consulting selling your Personal Information by contacting us at info@sharpwaysports.com. This may prevent or restrict your use of the Services in the future.

(b) Your Connecticut Privacy Rights

Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

Connecticut’s Data Privacy Act (“CDPA”), which goes into effect July 1, 2023, grants Connecticut residents certain rights pertaining to our collection, use, and sharing of their personal data. We do not sell your personal data and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. We may engage in “targeted advertising” as that term is defined in the CDPA. As of July 1, 2023, residents of Connecticut will have the right to opt-out of targeted advertising by sending an email to info@sharpwaysports.com. As well, starting on July 1, 2023, as a resident of Connecticut you will have the right to (1) request to know what personal data we have collected about you, and to access that information; (2) request the correction of inaccuracies in your personal data; (3) request deletion of your personal data, though exceptions under the CDPA and other laws may allow us to retain and use certain personal data notwithstanding your deletion request; and (4) obtain a copy of your personal data. You can learn more about how to submit a data rights request, or appeal denial of a request, by email to info@sharpwaysports.com. If we agree to delete certain personal data in response to your request, it may prevent or restrict your use of the Services in the future.

(c) Your Virginia Privacy Rights

Virginia’s Consumer Data Protection Act (“VCDPA”), which goes into effect January 1, 2023, grants Virginia residents certain rights pertaining to our collection, use, and sharing of their personal data. We do not sell your personal data and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. We may engage in “targeted advertising” as that term is defined in the VCDPA. As of January 1, 2023, residents of Virginia will have the right to opt-out of targeted advertising by sending an email to info@sharpwaysports.com. As well, starting on January 1, 2023, as a resident of Virginia you will have the right to (1) request to know what personal data we have collected about you, and to access that information; (2) request the correction of inaccuracies in your personal data; (3) request deletion of your personal data, though exceptions under the VCDPA and other laws may allow us to retain and use certain personal data notwithstanding your deletion request; and (4) obtain a copy of your personal data. You can learn more about how to submit a data rights request, or appeal denial of a request, by email to info@sharpwaysports.com. If we agree to delete certain personal data in response to your request, it may prevent or restrict your use of the Services in the future.

(d) Your Colorado Privacy Rights

Colorado’s Consumer Privacy Act (“CCPA”), which goes into effect July 1, 2023, grants Colorado residents certain rights pertaining to our collection, use, and sharing of their personal data. We do not sell your personal data and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. We may engage in “targeted advertising” as that term is defined in the CCPA. As of July 1, 2023, residents of Colorado will have the right to opt-out of targeted advertising by sending an email to info@sharpwaysports.com. As well, starting on July 1, 2023, as a resident of Colorado you will have the right to (1) request to know what personal data we have collected about you, and to access that information; (2) request the correction of inaccuracies in your personal data; (3) request deletion of your personal data, though exceptions under the CCPA and other laws may allow us to retain and use certain personal data notwithstanding your deletion request; and (4) obtain a copy of your personal data. You can learn more about how to submit a data rights request, or appeal denial of a request, by email to info@sharpwaysports.com. If we agree to delete certain personal data in response to your request, it may prevent or restrict your use of the Services in the future.

6. Your Canadian Privacy Rights

Canadian Anti-Spam Legislation (“CASL”)

This Section provides additional information regarding the use of Personal Information about Canadian residents and the process to be followed in order to send unsolicited electronic communications to them, and Sharpway Sports Consulting’ responsibilities under CASL.

For the purposes of this Section:

“Commercial activity” means any transaction of commercial character, regardless of whether there is an expectation of profit or not.

“Commercial electronic message” (“CEM”) are commercial electronic messages that encourage participation in commercial activity. Even if a commercial message is not sent with an expectation of garnering profit, it still qualifies as a CEM.

“Electronic address” means an address used in connection with the transmission of an electronic message to an electronic mail account, and instant messaging account, a telephone account or similar account.

“Electronic message” means message sent by any means of telecommunication, including text, sound, voice or image.

“Express consent” means permission obtained when a recipient “opts in” to receive CEMs. Consent can be oral or written and could be an unedited audio recording, paper or electronic checkbox on a website. Express consent never expires unless the recipient chooses to unsubscribe. Sharpway Sports Consulting will maintain records of all contacts for whom express consent exists.

“Unsubscribe” means a withdrawal of consent to receive CEMs.

You may unsubscribe from our CEMs via the link found at the bottom of every electronic message.

All partners, employees, contractors, vendors and any other person sending CEMs on behalf of Sharpway Sports Consulting will ensure that all such CEMs contain:

Unsubscribe Requests: All unsubscribe requests will be managed within ten days of receipt. Partners, employees, contractors, vendors and any other person sending CEMs on behalf of Sharpway Sports Consulting will not send an unsubscribed party any further communications by electronic means.

When Sharpway Sports Consulting plans to introduce significant changes to its privacy practices, it will notify Canadian-resident users prior to the changes coming into effect. Significant changes include using personal information for a new purpose not anticipated originally or a new disclosure of personal information to a third party for a purpose other than processing that is integral to the delivery of a service.

7. Ads and Information About You

Data about your activities online is being collected on our Services for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

You may see certain ads on our Services as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites by collecting information through automated means, including through the use of the Tracking Technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our Services, such as the pages you have viewed. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.

This collection and ad targeting take place both on our Services and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a Google Ads cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services. To learn more about how to opt out of Google’s use of cookies, visit the Google’s Ads Settings, https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies. To learn more about how to opt out of use of the Google Analytics cookies, visit the opt-out page, https://tools.google.com/dlpage/gaoptout

Third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit Network Advertising, https://thenai.org/ which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance (“DAA”) website at https://digitaladvertisingalliance.org/. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

8. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

The Services may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Services are served to you for their own commercial purposes. In addition, when you are using the Services you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Services onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

9. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You may provide updates and changes by contacting us at info@sharpwaysports.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails, or in some cases by logging into your Services account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and Services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us as follows:(Attn: Privacy) Sharpway Sports Consulting, 778 Sheppard Ave W, Unit 104 North York, ON M3H 6B7, or at info@sharpwaysports.com

10. What About Transfer of Information?

Our Services are intended for users and may only be used by users who are located in specific states in the United States and specific provinces of Canada identified in our Promotions’ Official Rules or on the Services. If you are located outside of the United States and Canada, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in countries whose data protection laws may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, law enforcement and national security authorities in those countries according to laws of those countries. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, outside of the United States and Canada as set forth in this Privacy Policy. Sharpway Sports Consulting will take all reasonable commercial steps to protect your Personal Information from unauthorized uses and disclosures while it is in the hands of any entity located in a country other than the United States or Canada. Sharpway Sports Consulting will seek to ensure that policies and processes in place in any such country, including training for staff and effective security measures, will ensure that your Personal Information will be properly safeguarded at all times.

11. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out Personal Information in public areas of the Websites like message boards, which any visitor of the Websites can view.

12. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

13. What Should Parents Know About Children?

Pursuant to the Terms of Use, the Services are for an audience aged 21 and up, and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13). We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us via email at info@sharpwaysports.com.

14. What About Changes to the Privacy Policy?

When Sharpway Sports Consulting plans to introduce significant changes to its Privacy Policy, including changes that would involve (i) your Personal Information being used for new purposes not anticipated when you originally provided such Personal Information to Sharpway Sports Consulting, or (ii) a new disclosure of Personal Information to a third party for a purpose other than processing that is integral to the delivery of a service, Sharpway Sports Consulting will notify you prior to such changes coming into effect. We reserve the right to make non-significant changes to this Privacy Policy at any time without notice to you. Any such non-significant changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Services will indicate your consent to the Privacy Policy posted at the time of use. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

15. Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the right to withdraw your consent under certain circumstances. To seek to withdraw your consent, contact us at: (Attn: Privacy) Sharpway Sports Consulting, 778 Sheppard Ave W, Unit 104 North York, ON M3H 6B7, or at info@sharpwaysports.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

16. Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at:

(Attn: Privacy) Sharpway Sports Consulting, 778 Sheppard Ave W, Unit 104 North York, ON M3H 6B7, or at info@sharpwaysports.com.

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws. To discuss our compliance with this Privacy Policy please contact our Privacy Officer using the contact information listed above.