PRIVACY POLICY

‍2. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us for the purposes of:

→ Providing the Services and operating the PWHL and the Teams. We use personal information to operate our business including providing, personalizing, and improving our products and services. Specifically:

• To develop, operate, improve, maintain, analyze, measure, and report on your use of our Services. This could include troubleshooting, testing new features, improving design or usability of our Services, and personalizing and recommending content.
• To provide you with information, products, or services that you request from us.
• To support our internal business functions, including finance, accounting, and audit.
• To better understand fan preferences when using our Services or attending our events.

→ Communicating with you. We use personal information to communicate with you, including by email, push notifications, or text, about purchases, your account, offers, contests, surveys, changes to policies, customer service inquiries, or to request feedback.

→ Advertising and marketing. We use personal information for marketing and advertising purposes, for ourselves, our affiliates and partners, and those who advertise on our online Services. Specifically:

• To send you promotional messages and deliver advertisements about League products, tickets, services, programs, or events including providing discounts or offerings from our affiliates, business partners, and select third parties.
• To determine which promotional messages and advertisements you see based on personal information that we collect or receive about you, such as your demographic data, location data, usage data, interests, and preferences.
• To provide and improve our advertising services for our ad partners, including ad delivery, targeting, frequency capping, and measurement.
• To conduct internal and market research, identify usage trends, and determine marketing and advertising campaign effectiveness

→ Security, Compliance, and Enforcement.  We use personal information for security, legal, compliance, and enforcement purposes.  Specifically:

• To enhance the safety and security of our Services and our League events.
• To verify your identity, monitor, investigate, and prevent fraud, and halt other unauthorized or illegal activity.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To comply with applicable law, such as to satisfy a tax obligation or government request.
• To enforce, investigate, or report potential violations of our Terms of Use.

→ In any other way we may describe when you provide the information, and for any other purpose with your consent.

We may also use and share aggregated and deidentified information to the extent permitted by applicable law. When we use deidentified information, we maintain and use the information in the deidentified form and do not attempt to reidentify it, except to check whether our deidentification processes satisfy the requirements of applicable law.

3. DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this Privacy Notice as follows:

→ Within the PWHL Organization. We disclose personal information to our affiliated entities to provide and improve our products and services, to build user profiles and predictive models to better understand our fans, to send promotional messages and advertisements about products and services that may be of interest to you, and for other purposes consistent with this Privacy Policy.

→ To Provide the Services. We disclose personal information to vendors and other business partners to perform services for us on our behalf, such as support services related to the operation of the Website, marketing communications, payment processing, advertising and marketing, analytics, automated chat providers, fraud and security, and customer relations. We also work with third parties to operate our products and services and may provide these companies with access to personal data to perform their functions.

→ With Partners and Third Parties. We may disclose personal information to our trusted business partners for advertising and marketing purposes, including so that they can provide our fans with special offers and promotions and for marketing and advertising on and off the Services and on third-party platforms. These third parties may set their own cookies or similar technologies to collect information about users’ online activities over time and across apps and websites. For more information, see Choices About How We Use and Disclose Your Information.

→ As part of a change in business structure.  In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the PWHL and/or Teams, personal information may be disclosed or transferred.

→ When necessary, such as:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PWHL and the Teams, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose personal data for any other purpose as communicated at the time of collection, or when we have otherwise obtained consent.

We may aggregate and/or de-identify information such that it is no longer linked to you or your device. This Notice does not limit our ability to disclose aggregated or de-identified information that is not linked to you. We may use and disclose such information to our partners, advertisers, and any other third parties in our discretion.

4. CHILDREN’S PRIVACY

Our Services are directed to adults and not intended for use by children. We do not knowingly collect personal information from children as defined by local law. If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

5. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

COMMUNICATION PREFERENCES AND DATA ACCESS

You may choose to receive promotional emails, text messages, newsletters, push notifications, and similar communications from us. You may opt out of receiving promotional emails from us by clicking on the opt-out or “unsubscribe” link included in the promotional emails you receive.  You may opt out of receiving marketing text messages by replying “STOP.”  You may also opt out of receiving push notifications by turning off push notifications through your device settings.

Please note that opt-out requests may take some time to be effective where permitted by applicable law.  Your opt-out requests will not apply to messages that you request or that are not commercial in nature.  For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.

You may also have choices available to you to opt out of the collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology.  Where collected, this information may be used in accordance with local laws to serve and display advertising relevant to your location.  To understand your choices and opt-out if desired, please visit your device settings.

OTHER CHOICES

You may have additional choices over your data depending on where you live.

In some jurisdictions, you may have the right to opt out of the “sale” of your personal information and the sharing or processing of personal information for targeted advertising purposes. You can exercise these opt-out choices by sending an email to privacy@thePWHL.com. We do not knowingly sell or share the personal information of consumers under 16 years of age.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance at https://optout.aboutads.info/ and from members of the Network Advertising Initiative (“NAI”) at https://optout.networkadvertising.org/?c=1.

DO-NOT-TRACK SIGNALS

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

6. YOUR PRIVACY RIGHTS

Some laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see .

You may be afforded, in accordance with applicable law, the right to:

1.    Obtain information about the personal information we have collected about you and to request a copy of it.

2.    Delete certain personal information we have about you.

3.    Request correction of inaccurate personal information we have about you.

4.    Object to or request the restriction of processing of your personal information.

5.    Withdraw your consent.

To exercise any of these rights please email privacy@thepwhl.com.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.  If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

We reserve the right to deny requests as allowed by applicable law, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your information consistent with applicable law.

To appeal a decision regarding a consumer rights request please send an email to privacy@thepwhl.com. We will consider your appeal, and our response will inform you of decisions and actions in response to your appeal, including an explanation of the reasons for the decisions. If you have concerns about the results of your appeal, you have the right to contact your state attorney general. If your appeal is denied and you are a Virginia resident, you may contact the Virginia Attorney General to submit a complaint at: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

You may also be afforded, in accordance with applicable law, the right to limit certain uses and disclosures of sensitive personal information. You can exercise this right, if applicable, by sending an email to privacy@thepwhl.com.  Please note that we may still maintain, use, and disclose your sensitive personal information for certain purposes, such as to provide you with services that you have requested, protect the safety and security of services, and comply with our legal obligations.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you.

7. DATA RETENTION

To the extent required by applicable law, we retain personal information for as long as necessary to provide our products and services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

8. DATA SECURITY

The security and confidentiality of your personal information are very important to us. We have implemented measures designed to appropriately protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

9. CHANGES TO OUR PRIVACY NOTICE

We may change this Notice from time to time as our services, technology, and legal obligations change. If we make changes, we will post the updated Notice and revise the “Last Updated” date. Any changes will be effective immediately upon posting of the revised Notice, and your continued use of the Services after that date will indicate your consent to any changes unless applicable law requires us to provide another form of notice and/or seek your agreement to such changes.

10. CONTACT INFORMATION

To ask questions or make any complaints about this Notice or our privacy practices, please contact us at: privacy@thepwhl.com.

11. CALIFORNIA USERS

This section provides additional information with respect to personal information that is subject to the California Consumer Privacy Act (“CCPA”). This section should be read together with the rest of our Privacy Notice, which includes other important information about our handling of your personal information.

INFORMATION ABOUT THE PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

As described further in the Information we Collect About You and How we Collect It section above, the following chart provides information about the categories of personal information that we collect from consumers:

• Contact or identifying information, such as your name, e-mail address, postal address, phone number, profile picture, birthday or other information, such as when you register to use our Services or products while attending our games, events, and other programs, subscribe to our newsletters, enter a sweepstakes or contest, or otherwise interact with us through the Services.
• User credentials, such as username, user ID, password, password hints, and similar information used to create an account and authenticate users of the Services.
• Demographic information, such as your age, gender, or income bracket, as well as survey responses, when you participate in a survey or poll we might ask you to complete for research purposes;
• Purchase information, such as credit card and billing information if you purchase a product or subscribe to one of our paid services, as well as a record of products or services purchased;
• Online account information, including social media information, which we receive from third-party online services, such as social media platforms, when you connect your use of our Online Services through their services.
• Communications and interactions, such as information you provide to us in emails and interactions with us when you reach out to contact us with a question or to report a problem with our Services;
• Interests and preferences, including inferences about your favorite teams and players or your communications preferences. In addition to what you provide directly, we infer your interests and preferences from other data we collect, such as the content and advertisements you interact with while using the Services.
• Audio, electronic, or visual information, such as photographs that you provide to us;
• Search queries on the Website; and
• Comments and other information are posted in our interactive online forums.
• Internet and electronic network activity information, device identifiers, and information about your use of the Services when you visit or use the Services; and
• Additional information as otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you.  For example, from observing your actions on our Services.
• From other sources. For example, from our affiliates, our partners, our customers, our vendors, third-party online services, social media platforms, data brokers, and public sources.
• As otherwise described at the time of collection.

As further described in the How We Use Your Information section, we process personal information for the following business purposes:

• Operating the PWHL business, including providing you with products, services, newsletters, promotions and advertisements, and information you request, and supporting internal business functions such as finance, accounting, and audit.
• Communicate with you about your account or relationship with us and engage in correspondence with you when you reach out to us.
• Conducting analysis on your behavior in order to customize and personalize your use of the Services and to better serve you with offers and content that we think may be of interest to you.
• Sending you promotions, marketing messages, and advertisements on our own behalf or on behalf of our marketing partners, their respective affiliates or subsidiaries, and other third parties.
• Maintaining or administering the Services, performing business analyses, or for other internal purposes.
• Complying with applicable laws.
• Protecting the health and safety of our guests, personnel, and PWHL teams, and the public.
• Protecting or enforcing legal and contractual rights, including applicable agreements with you or others, and preventing fraud.
• As otherwise described to you in this Privacy Notice, at the point of collection, or pursuant to your consent.

Depending on the nature of your relationship with us, and as described further in the Disclosure of Your Information section, we disclose each category of personal information to the following:

• Authorized third parties and service providers;
• Within the PWHL family;
• Select business partners;
• Third-party advertising and audience and traffic measurement services; and
• Other partners, including as part of a business transfer; for administrative or legal process; or with your consent.

Please review the Other Choices section for more information about the circumstances in which we sell or share personal information, such as internet and electronic network activity information, device identifiers, and other information about your use of the Services we collect automatically when you visit or use the Services, and to exercise your rights to opt out.

CONSUMER RIGHTS

If you are a California resident and your personal information is subject to CCPA, then you have certain rights under California law. For more information about the rights you have and how to exercise these rights, please review the Your Privacy Rights section above. California residents may also exercise their rights under applicable law by calling 1-855-265-6894.

“SHINE THE LIGHT”

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@thepwhl.com.

12. ADDITIONAL INFORMATION FOR VISITORS OUTSIDE THE UNITED STATES

This section of the Privacy Notice is supplemental and provides disclosures in addition to those made elsewhere in this Privacy Notice. This supplemental section applies only if you attend an event outside of the United States or use our Services otherwise covered by this Privacy Notice from a country that is not the United States, and where that activity is subject to laws outside the United States.

The data controller for your personal information is PWHL Leagueco US LP located at 227 West Monroe Street, Suite 4800, Chicago, IL 6060

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

PWHL is headquartered in the United States, and we have service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

LEGAL BASIS FOR PROCESSING

When we process your personal information, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., providing the Website to you).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and Services and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consent and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g. when you opt-in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.