Privacy Policy

LAST UPDATED

November 2023

OVERVIEW

Thank you for visiting www.sparxhockey.eu (the "Site"), which is owned and operated by Velasa Sports, Inc. ("Velasa Sports" or "Sparx Hockey"). As used herein, the terms "we", "us" and "our" refer to Velasa Sports, and the term "Service" means the Site and all information, tools, functions, features and services available at the Site. To understand the terms under which you use the Services we provide, please read our Terms of Service, which are available at https://sparxhockey.eu/pages/terms-services.

Maintaining the security of your data is a priority at Velasa Sports, and we are committed to respecting your privacy rights. Velasa Sports is also dedicated to being transparent about what data we collect about you and how we use it.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

Capitalized terms used herein without definition will have the same meanings as defined in the Terms of Service applicable to the Service, which are available at https://sparxhockey.eu/pages/terms-services.

SECTION 1 - WHAT INFORMATION DO WE COLLECT?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide

Certain parts of our Site may ask you to provide personal information.

When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address, and email address.

We may ask you to provide your contact details including your name, email and password in order to register an account with us, to subscribe to marketing communications and email notifications from us, enter competitions or online contests, submit enquires to us and/or ask for customer support.

When leaving a review about our products or services you have obtained from us you may also provide us with your name and email.

Due to the nature of our business, our offerings may change from time to time, the options you have to provide us with personal information may also change.

Information that we collect automatically

When you browse our Site, we automatically collect certain information about your device. In some countries, including countries in the European Economic Area and the United Kingdom of Great Britain and Northern Ireland (together, "Europe"), this information may be considered personal data under applicable data protection laws.

Specifically, the information we collect automatically will include information such as details regarding your web browser, IP address, and time zone. We also collect information about the page(s) you visit, actions you take on the Site (e.g., completing a purchase), or how you arrived at our site (e.g., search, paid advertisement).

Collecting this information enables us to better understand the visitors who come to our Site, where they come from and what content on our Site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site for our visitors.

Some of this information is collected using cookies and similar tracking technologies, as explained below and under Section 9 “Cookies" below and as detailed in the cookie preferences in our consent management platform.

To track and store this information, we use the following technologies/services:

• Cookies. Cookies are small files stored in browsers which are used to save user preferences. For detailed information on how Sparx Hockey uses cookies, see Section 9 – Cookies.
• Google Analytics. To gather information about how customers shop in our store, we use Google Analytics, a service provided by Google. You can view more information on this service here.
• Shopify. Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. See Section 6 – Shopify –Our E-Commerce Vendor for more information.
• Klaviyo. On occasion, we utilize Klaviyo to send out marketing emails on our behalf. Information regarding Klaviyo and its privacy policy can be read here.

SECTION 2 – DO WE COLLECT INFORMATION FROM CHILDREN?

Velasa Sports will not collect personally identifiable information from any person who is actually known to us to be under the age of 18 If we become aware that a person under 18 has provided personally identifiable information, Velasa Sports will take steps to remove such information and terminate that individual’s account, access and use of the Service.

SECTION 3 - HOW DO WE USE YOUR INFORMATION?

We use the information we collect to provide our products and services and for the following purposes:

• • To provide you with enhanced, customized and personalized content, products and services as well as promotional content and services;
• • To administer contests, promotions, events, surveys or other features;
• • To customize and improve features, performance, and support of the site;
• • To create update transaction features, such as placing an order through our online store;
• • To provide relevant advertising, including interest-based advertising from us and third parties;
• • For internal operations, including troubleshooting, data analysis, testing, research, and service improvement;
• • To send you administrative messages and other information about Sparx Hockey, including communication with you about your purchase transaction, account information or customer service inquiries.
• • To create aggregate and statistical data that does not identify you individually (for example, we use mobile device data and IP addresses to gather demographic information);
• • To display relevant marketing to you;
• • For other purposes that you separately authorize as you interact with Sparx Hockey.

SECTION 4 – HOW DO I WITHDRAW MY CONSENT

If we have collected and process your personal data with your consent, you may withdraw your consent at any time, by contacting us at help@sparxhockey.com or mailing us at: Velasa Sports, Inc., 30 Sudbury Road, Acton, Massachusetts 01720, USA. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you wish to delete or block cookies from your browsing activity, you may do so within your browser.

SECTION 5 - DISCLOSURE AND SHARING OF PERSONAL INFORMATION

Currently, Velasa Sports will not share your personal information with any third party for purposes that are not related to providing the Service to you; provided, Velasa Sports may disclose your personal information (a) if reasonably necessary for Velasa Sports (or its third party service providers) to operate the Service, including processing your orders, queries and other messages, (b) to communicate with you, (c) as otherwise permitted under the Privacy Policy or elsewhere in the Terms of Service, (d) if Velasa Sports reasonably believes that such action is necessary to conform or comply with any legal, regulatory, law enforcement or similar requirement or investigation, to protect or defend the rights or property of Velasa Sports or any third party or to enforce the Terms of Service or (e) as otherwise authorized by you.

Velasa Sports does not rent or sell Service Data to outside marketers.

For clarity, we may share your Service Data with trusted service providers that need access to your information to provide operational or other support services for us. These providers must agree to comply with terms and conditions that are consistent with our privacy and data security policies.

We may also partner with third party organizations to provide special programs or offers to Velasa Sports / Sparx Hockey customers, in which case we may disclose to that organization information we collect, such as your name and contact information. Any such partnerships will be communicated and/or disclosed prior to placing an order to purchase Products from us. If you elect not to participate in such special programs or offers, you reserve the right to deny such sharing of information.

We may share your personal data with any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

We may also share your personal data with an actual or potential buyer (and its agents and advisers) as set out in Section 13 "Business Transfers".

SECTION 6 - SHOPIFY - OUR E-COMMERCE VENDOR

Our store, which is located at the Site, is currently hosted by Shopify. They provide us with the online e-commerce platform that allows us to sell our Products to you. Your data is stored through Shopify’s data storage, databases, and the general Shopify application. They store your data on a secure server behind a firewall.

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as it is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) and Privacy Statement (https://www.shopify.com/legal/privacy).

SECTION 7 - THIRD PARTY SERVICES

In general, the third-party providers used by us will only collect, use, and disclose your Service Data to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies regarding the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States laws and regulations, including the Patriot Act. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Service.

When you click on links on the Site, they may direct you away from our Site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

SECTION 8 - SECURITY

Information collected by Velasa Sports is stored in operating environments that are secured using commercially available tools and procedures, and which are not made generally available to the public. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Unfortunately, no data transmission over the Internet and/or wireless networks can be guaranteed to be 100% secure. As a result, Velasa Sports cannot unequivocally guarantee the security of any information you provide, and you do so at your own risk. Once Velasa Sports receives your information, we will make reasonable efforts to ensure its security on our systems.

If you provide credit card information, it will be encrypted using secure socket layer technology (SSL) and stored with an AES-256 encryption.

Where you have created an Account and unique password to enable you to access our Site it is your responsibility to keep this password secure and confidential

SECTION 9 – COOKIES

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. We use cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies") to enhance your user experience, understand usage of our site, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you're visiting.

What types of Cookies do we use?

We use two types of Cookies: "session cookies" and "persistent cookies." Session Cookies are temporary Cookies that remain on your device until you leave our site. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or "lifetime" of the specific Cookie and your browser settings).

What are Cookies used for?

Cookies transmit information about you and your use of our site, such as your browser type, search preferences, product titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use.

We use Cookies for things like:

Authentication

We use Cookies to help us determine whether or not you've signed in to our site and to keep you signed in during visits as you access different pages. We use Cookies to keep your cart data stored so you can continue shopping and browsing and return to your cart at a later time.

Security

We use Cookies to enable and support security features, prevent fraud, and protect your data from unauthorized access.

Preferences and Features

We use Cookies to enable features, help us provide you with personalized content such as showing you your recent cart activity.

Advertising

We use Cookies to deliver, evaluate and improve advertising, such as by using information about you to provide relevant advertising both on and off our site. Our Ad Partners may use a cookie to determine whether you've already been shown an advertisement or how it performed, or provide us with information about how you interacted with an ad.

Analytics and Performance

We use Cookies to analyze how our visitors use our site and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our sites.

Additionally, you can also control, manage and/or delete cookies via your browser settings or in our consent management platform. A useful resource for information about deleting and controlling cookies can be found at https://www.aboutcookies.org/.

SECTION 10 - DO NOT TRACK

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites.

When you turn on the Do Not Track function in your browser, Velasa Sports stops collecting the information from your browser that allows us to tailor the Service specifically to you and to develop valuable Analytics. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.

For clarity, this is just our Do Not Track policy. Velasa Sports cannot and does not make any promise about how third parties react when you set the Do Not Track signal on your browser. In addition, the Do Not Track signal does not apply to the use of information collected prior to such request.

SECTION 11 - CALIFORNIA RESIDENTS

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents who provide personal information in obtaining products or services from Velasa Sports are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2016 will receive information regarding 2015 sharing activities). If you are a California resident and would like a copy of this information, please submit a written request to:

Velasa Sports, Inc.
Attn: California/Shine the Light
30 Sudbury Road
Acton, MA 01720, USA

SECTION 12 – EEA AND UK RESIDENTS

The following section applies if you a resident in the EEA or UK.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you (e.g. to process and deliver an order), we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under Section 15 "Questions and Contact Information".

Your data protection rights

Depending on your location, you may have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under Section 15 "Questions and Contact Information" heading below.

• • You may access, correct, update or request deletion of your personal information.
• • You can object to processing of your personal information or ask us to restrict processing of your personal information.
• • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us or use the marketing setting in your account.
• • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• • You have the right to complain to a supervisory authority about our collection and use of your personal information. For more information, please contact your local supervisory authority. (Contact details for supervisory authorities in Europe are available here.) Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Velasa Sports has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU.

You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/

• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Velasa Sports has appointed European Data Protection Office (EDPO UK) as its GDPR Representative in the UK.

You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

• by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

SECTION 13 - BUSINESS TRANSFERS

Velasa Sports may transfer personal data, including Traffic Data, Service Data (including personally identifiable information) and Analytics to any successor to all or substantially all of its business or assets that concerns the Service provided that we inform the successor it must use your personal information only for the purposes disclosed in this Privacy Policy.

SECTION 14 - CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this policy, we will notify you here that it has been updated so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

Information collected by the Service is subject to the Privacy Policy in effect at the time of use.

SECTION 15 - QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at help@sparxhockey.com or by mail at

Velasa Sports, Inc.
Attn: Compliance Officer
30 Sudbury Road
Acton, Massachusetts 01720, USA