____ May 2018
____ January 2016
Maintaining the security of your data is a priority at Velasa Sports, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Velasa Sports is also dedicated to being transparent about what data we collect about you and how we use it.
This updated Velasa Privacy (“The Policy") will apply to all users and is in response to the enhanced data protection rights required by the EU general data protection regulation (GDPR) effective May 25, 2018 for all EU-resident users who are natural persons.
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://www.sparxhockey.com/pages/terms-services.
SECTION 1 - WHAT INFORMATION DO WE COLLECT?
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.
When you browse our store, we automatically collect certain information about your device, 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).
To track and store this information, we use the following technologies/services:
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.
Additionally, when you fill out registration forms, complete an online purchase, or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. 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. Here are some examples of situations in which you have the opportunity to provide personal information to us:
Signing up for email notifications;
Completing a form related to one of our products;
Entering an online contest;
Enrolling on social media;
Contacting us for customer service support;
Making an online purchase.
Collectively, all types of information gathered or provided to us by you is "Personal Information."
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 13. If we become aware that a person under 13 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. In order for us to best provide our products and services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. We have a legitimate interest in using the information we collect, including personal information, for these 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 WE GET YOUR CONSENT
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason (e.g., marketing), we will either ask you directly for your expressed consent or provide you with an opportunity to say no.
SECTION 5 – HOW DO I WITHDRAW MY CONSENT
You may withdraw your consent for us to contact you, and to continue collecting, using and disclosing your personal information, at any time, by contacting us at email@example.com or mailing us at: Velasa Sports, Inc., 30 Sudbury Road, Acton, Massachusetts 01720, USA.
If you wish to delete or block cookies from your browsing activity, you may do so within your browser.
SECTION 6 - DISCLOSURE AND SHARING OF SERVICE DATA
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.
SECTION 7 - SHOPIFY - OUR E-COMMERCE VENDOR
Our store, which is located at the Site, is currently hosted by Shopify Inc. 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) or Privacy Statement (https://www.shopify.com/legal/privacy).
SECTION 8 - 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.
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 9 - 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. 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.
SECTION 10 – COOKIES
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 iste. 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.
Preferences and Features
Analytics and Performance
Additionally, you can also control, manage and/or delete cookies via your browser settings. A useful resource for information about deleting and controlling cookies can be found at https://www.aboutcookies.org/.
SECTION 11 - 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 12 - 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 13 - BUSINESS TRANSFERS
SECTION 14 - NON-US USERS
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
SECTION 16 - 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 firstname.lastname@example.org or by mail at
Velasa Sports, Inc.
Attn: Compliance Officer
30 Sudbury Road
Acton, Massachusetts 01720, USA