‍(1) What type of personal data do we collect, and how do we receive such personal data?

When you use the Services, we may use different technologies and ask you to provide us with certain personal data for us to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Properties, or as otherwise indicated in this Policy. We may collect the following personal data about you in the following ways.

a. Personal data provided by you

Some of our Services allow you to provide personal data to us about yourself. This may include:

• When you sign up for an event or to receive our newsletter, when you communicate with us (for example, when you send us a message, submit a support ticket, or submit a form for other purposes), or otherwise communicate with us in relation to the Services, we may receive information you provide to us such as your name, email address, physical address or other information you provide to us.
• When you create an account or register for our Services, we may collect information, such as your email address, profile photo, age, and country/state of residence.  
• When you make purchases including subscribing to our print and digital magazines, request a refund, return or exchange or redeem a discount, we will receive account data such as details on your payment instrument (such as a credit card number) and billing information, although this personal data is processed on our behalf by third-party payment processors, and is not retained by us.
• When you participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, casting calls, games, forums, content publishing ("Activity") and when you choose to provide it, we may also collect information about your personal or professional interests, lifestyle, and feedback on our products, programs and services. 

b. Automatically-collected personal data

When you use certain Services, including our Properties, our servers automatically collect certain personal data from your devices, including:

• Device information – this includes personal data such as your device ID, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, and network connection type (e.g., Wi-Fi, cellular).
• Internet or other electronic network activity information - our Services may collect or use your internet protocol address, unique identifiers and other information regarding your interaction with our Services.
• Location information – our Services may collect and use information regarding your general location, such as your IP address, for the purposes of ads where this is permitted. We do not collect or process precise geo-location data.

We also collect personal data regarding your interactions with our Properties, push notifications, and email marketing messages, including interactions with Properties’ advertisements. We and our third-party business partners may collect this personal data through the use of tracking tools such as cookies. You can learn more about the tracking tools we use by visiting our Cookie Policy.

c. Personal data collected from and through third parties

We collect personal data about you from third parties for the purposes described herein. For instance, when you register or log in to our Services using Google or a social media account or interact with our pages on social media platforms, we may collect information from social media platforms such as your social media account ID, username, user ID, profile picture, and your connections. In some cases, we may also collect personal data about you when you interact with Properties and tools offered by third-party companies that have integrated or linked to our Services. If you wish to know more about how such information is collected and used, please refer to the privacy policies of those companies, not this Policy.

Additionally, we may collect personal data about you from our third-party business and marketing partners and service providers, such as sponsors, promotional partners or other strategic partners, fraud prevention agencies, companies you direct to send information to us, companies that provide us with information to enhance the personal data we have about you or your device to better understand our customers and to provide and enhance our Services. We may also receive information from our business partners, such as advertisers or app platforms that may provide us with information about you, such as pseudonymous advertiser identifiers.  

If you choose to use third-party devices and technologies (such as Amazon Alexa or Google Assistant) in connection with our Services, the operators of those third-party devices and technologies will process your personal data in connection with their own terms of service and privacy policies, which you should review. 

(2)  How do we use your personal data?

Minute Media uses the personal data that it collects for several purposes, including:

• Provision of Services - for the provision and improvement of our Services to you, including for support, responding to your queries, providing you with a customized experience (for example, by remembering choices you make when you use the Services), and transactions. 
• Communications - we may send you communications, including but not limited to via email, push notifications, or text, about purchases, your account, offers, changes to policies, customer service inquiries, to request feedback, or to keep you informed of our latest updates to our Services.
• Marketing and advertising purposes - by subscribing to our newsletter, you will receive tips and announcements, including but not limited to via email, push notifications, or text. We may also send you promotional material concerning our Services, or our partners' services, which we believe might interest you; and display certain ads on our Services, which we believe will be relevant for you. We make our reasonable commercial efforts to make sure you see relevant ads and receive relevant communications from us, including but not limited to building a profile based on your personal data.
• Collaborating with third parties - we may partner with third parties to receive or share your personal data for data segmentation, enrichment, and optimization purposes, which allows us or our partners to personalize and optimize the services, advertisements, and marketing activities we or they offer you. 
• Improve our Services  - we may conduct surveys or test features, and analyze the personal data we have to develop, maintain, measure, and improve our Services, and think of new and exciting features for our users.
• Operate our business - we may use personal data to support our internal business functions, including finance, accounting, and audit.
• With your consent- we may use your personal data with your consent for other purposes described at the point of collection.‍
• Protecting our interests - we may use your personal data when we believe it’s necessary to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of Minute Media, its users and/or partners.‍
• Enforcing of policies - we may use your personal data to enforce our policies and the relevant terms of use of our Properties.‍
• Maintenance of security and compliance with legal and regulatory requirements - we may use your personal data to detect and prevent fraud by verifying your identity, maintain the integrity and security of the Services, investigate violations, and as otherwise required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

If you reside in the EEA or the UK, or Brazil, please refer to the International Supplement for details of our purposes and legal basis for processing your personal data, as well as certain rights. 

(3) How and with whom do we share your personal data?

We may disclose the personal data we collect from and about you as described below. 

1. Affiliates 

We share your personal data with companies in our group in connection with any of the uses of your personal data set out in this Policy in our or our affiliate’s legitimate interests to run an efficient business.

2. Service providers and vendors

We use service providers, vendors, and other companies to help us operate the Services (such as hosting, information technology, customer support, email delivery, order fulfillment and delivery, marketing of our Services, provision of third-party advertising, fraud detection, security, consumer research, and Properties analytics). Additionally, we share your personal data with our payment processors to complete payments, process disputes, and/or process refunds. These service providers may have access to your personal data so that they may perform these tasks on our behalf, but they are obligated to comply with contractual privacy obligations.

3. Business and marketing partners

We may disclose your personal data to third-party businesses for their own purposes, including marketing products or services to you, showing you relevant advertising, or providing an enhanced experience that integrates with our Services. For example, we may share your personal data with third-party advertising, marketing, and analytics companies for the interest-based advertising and analytics purposes, as described in our Cookie Policy. Additionally, we may offer content or Activities (e.g., competitions, sweepstakes, promotions, games) that are sponsored by or co-branded with third parties, which may collect or obtain personal data from participants. We may also share your personal data for data segmentation, enrichment, and optimization purposes, which allows us or our partners to personalize and optimize the Services, advertisements, and marketing activities we or they offer you. In some jurisdictions, this is subject to consent or opt-out options set forth in this Policy.

We share personal data collected in connection with the Sports Illustrated business with ABG-SI LLC, the owner and licensor of the Sports Illustrated trademarks. ABG-SI acts as a separate “business” / data controller and uses the Sports Illustrated Data in the manner set forth in its privacy policy at: https://corporate.authentic.com/privacy-policy

4. User profiles and submissions

Certain user profile information, including your name, location, and any related video or image content you uploaded to the Services for publication, will be displayed to other users as part of the Services, to facilitate user interaction within the Services or address your request for our Services in our legitimate interests to provide an engaging Service. Please remember that any content you upload to your public user profile, along with any personal data or content that you voluntarily disclose online in a manner other users can view (e.g., on your published content, forums, discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your name/username may also be displayed to other users if and when you send messages or comments or upload images, content or videos through the Services.

5. Professional advisors, legal enforcement authorities, institutions, and regulators

We may disclose your personal data with our professional advisors (e.g., lawyers, auditors, bankers, and insurers), or to cooperate with government and law enforcement officials and private parties to enforce and comply with the law in our legitimate interests to comply with legal obligations. We will disclose any personal data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

6. Mergers and acquisitions

We may share your personal data if we enter into a business transaction such as a merger, divestiture, acquisition, restructuring, reorganization, dissolution, bankruptcy, or other sale or transfer or business transaction involving all or part of our company or assets, including for the purposes of determining whether to proceed with such transaction, in our legitimate interests to ensure the continuity of our business. Any party that acquires our assets as part of such a transaction may continue to use your personal data in accordance with the terms of this Policy.

7. Activities

When you register for or enter an Activity through our Services, we may disclose the information you provide for such purposes to certain third-party service providers, participating sponsors, and advertising partners in our legitimate interest to facilitate that Activity. By entering into any Activity, you agree to the official rules governing that Activity, which may include a requirement that you allow us or the sponsor of that Activity to use and publicly release your name, voice, and/or likeness in advertising for or associated with the Activity. 

8. Others

We may otherwise disclose personal data if you ask or authorize us to do so, including by interacting with third parties on our Properties, in our legitimate interests to operate and engaging business. We are not responsible for events arising from the distribution of your information that you choose to disclose publicly through our services. 

9. Aggregated information

We may anonymize, aggregate, and/or de-identify information such that it is anonymous, aggregated, or deidentified or no longer able to be used to identify you, in our legitimate interest to run a successful business. This Policy does not limit our ability to use or disclose such aggregated, de-identified, or anonymized information, which we may disclose at our sole discretion. 

(4)  What rights and choices do you have with respect to your personal data?

a.  Email communication preferences.  

You may opt out of receiving promotional emails from us by clicking on the “Unsubscribe” link at the bottom of the email. You may also tell us that you do not want to receive our promotional messages by emailing us at contactus@minutemedia.com (kindly specify the name of the relevant product from which you wish to unsubscribe). Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us. If you subscribed to any of our partners' services, please note we will have no control over our partners' communications, and in order to unsubscribe from it, please contact the relevant partner or use the "unsubscribe" link in their emails.

b.  Push notifications.

If you have opted in to receive push notifications on your device, you can opt out at any time by adjusting the permissions in your device or browser or uninstalling the relevant app.

c.  Browser and device settings. 

You may have more options depending on your mobile device, operating system, or browser. Please review the support materials and/or the privacy settings for the respective devices and systems to learn more about these features and how they apply to targeted advertisements. Blocking cookies may also prevent you from accessing some of our content or Service features.

d.  Targeted advertising. 

In some jurisdictions, including some US states, the UK, the EEA, Canada and other applicable jurisdictions, you can also opt out of targeted advertising through consent tools available on our Properties, as more fully described in our Cookie Policy and in the US State Supplement and International Supplement below. 

e.  Data “sales.” 

In some jurisdictions, you may have the right to opt-out from the “sale” (as defined under applicable privacy laws) of your personal data to third parties by using our designated tools (such as opt-out banners, cookie preference banners, Do-Not-Sell buttons, etc.), as well as by contacting us in the manner set forth below. Please see our US State Supplement and International Supplement for more information. 

f.   Individual rights.

In addition to the rights noted above, depending on your country (or in the United States, your US state) of residence, you may be afforded, in accordance with applicable law, certain other rights with respect to your personal data, such as the right to: 

• obtain information about the personal data we have collected about you and to request a copy of it;
• delete certain personal data we have about you;
• request correction of inaccurate personal data we have about you;
• object to or request the restriction of the processing of your personal data;
• request that your personal data be transferred to another organization; or
• withdraw your consent with respect to any processing of personal data which is based on your consent.

For more information about what rights may be available to you depending on your country or state of residence, please see the US State Supplement (if you reside in the United States) or the International Supplement (if you reside outside the United States, such as the EEA, the UK, Canada, or Brazil). 

Once we receive your request, we may verify it by requesting information in order to confirm your identity. 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 may retain your Information consistent with applicable law. Our goal is to respond to a verifiable consumer request within 45 days (for US residents), 30 days (for UK and EEA residents) of its receipt, or within other applicable periods set forth in the International Supplement of this Policy. If we require more time, limited to the maximum periods stipulated in the applicable law, we will inform you of the reason and extension period in writing within the initial response period. We will deliver our written response electronically. 

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request. 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.

(5)   How do we protect your personal data?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. While we seek to protect your personal data to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your personal data, we cannot ensure or warrant the security and privacy of your personal data or other content you transmit using the Services, and you do so at your own risk.

(6) Third-party links

Our Properties may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Properties and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Properties. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

(7)  How long do we retain your data?

We will retain your personal data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined on a case-by-case basis, taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications, and anything else as required by applicable laws and regulations. If you reside in the EEA or the UK, Canada, or Brazil, please refer to the International Supplement for further details. 

(8) US State Supplement 

Some US state laws require us to inform residents of those states about additional privacy information and rights. Please visit our US State Supplement (Annex A) for additional information. 

(9) International Supplement (UK, EEA, Brazil, and Canada)

The laws in some countries, including the United Kingdom, countries in the EEA, Brazil, and Canada, require us to inform residents of those countries about additional privacy information and rights. Please visit our International Supplement (Annex B) for additional information. 

(10) What is our policy toward children?

Our Services are directed to adults and not intended for use by children under the age of 18. 

(11) Updates to this Policy

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Properties (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. Any changes will be effective upon posting of the revised Policy. If we make material changes to this Policy, we will notify you by providing any notice required by applicable laws. By continuing to use the Services after that date, you consent to any and all changes, unless applicable law requires us to provide another form of notice and/or obtain your consent to such changes. 

(12) Controlling Version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

(13)  How to contact us

Please contact us regarding any questions or complaints pertaining to this Policy or our privacy practices at dpo@minutemedia.com, or by calling us at +1(888) 211-4431.  

Please be advised that dpo@minutemedia.com is designated solely for privacy-related inquiries of our users, and we reserve the right not to respond to any non-privacy inquiries that are sent via the privacy email address. For any non-privacy inquiries, please send an email to contactus@minutemedia.com. Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request, and therefore, we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.

‍Annex A - US State Supplement

Last updated: September 18, 2025

This US State Supplement provides information for United States residents. Our general Privacy Policy explains what personal data we collect about you, how we collect that personal data, and why and how we use and disclose that personal data. Individuals who reside in the United States should read this US State Supplement as well as our Policy to fully understand our collection, use, and disclosure of your personal data. 

1.  Personal Information We Collect, Use, and Disclose

Below we describe the categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute) that we collect about users of our Sites or Services (and have collected during the last 12 months):

• Identifiers, such as name, email address, postal address, telephone number, IP address, social media identifiers, photos, IP address, UDID, and advertising IDs.
• Characteristics of protected classifications and demographic information, such as gender and age.
• Internet or other electronic network activity information, including information regarding your interactions with us online, device ID, IP address, and other internet or device information. 
• Geolocation data, such as approximate location information based on your IP address.
• Inferences based on the above.

The business or commercial purposes of collecting personal information are described in the “How do we use your personal data?” section of our Policy. We disclosed each category to our affiliated companies, advertising partners, data analytics providers, cloud service providers, ID companies, and data segmentation providers, as described in the “How and with whom do we share your personal data?” of our Policy. For additional information regarding the categories of sources, please refer to the “What type of personal data do we collect and how do we receive such personal data?” section of our Policy.

2.  Your rights

Depending on the state you live in, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.

• Delete your personal data. Upon your request, we will delete the personal data we have collected about you, subject to certain legally-permissible exceptions. 
• Access your personal data or receive information regarding our processing of your personal data. You have the right to access a copy of personal data that we have collected about you or to ask us to confirm whether we process your personal data. 
• Correct inaccurate personal data. You have the right to request that we correct any inaccuracies in the personal data we have collected about you. 
• Opt-out of the “sale” or “share” of your personal data. You have the right to tell us not to “sell” or “share” your personal data according to applicable law. 
• Opt-out of our use of your personal data for targeted advertising. You may ask us not to use or disclose your personal data for targeted advertising. Please note that, even if you exercise your right to restrict your use of personal data for targeted advertising, we will continue to collect and use your personal data for other purposes. 
• California “Shine the Light” Law. We provide our California customers with the ability to “opt out” of having their personal information shared with independent affiliates and non-affiliated third parties for their direct marketing purposes under the California Shine the Light (California Civil Code Section 1798.83). You may opt out of having your personal information shared with these affiliated and non-affiliated third parties for their direct marketing purposes by confirming your choices at the “Do Not Sell My Personal Information”  link in the footer of our Properties.

We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations. We also do not knowingly sell or share (as defined by the CCPA) the personal information of minors under 16 years of age. 

3.   How to exercise your rights

To exercise your rights, please send us an email at dpo@minutemedia.com. 

If you wish to opt out of the processing of your personal data for purposes of “selling”, “sharing” or “targeted advertising” (as defined under applicable U.S. state law), please use the consent management tool available on the homepages of our Properties. You may opt out of such sharing by clicking on the “Manage Preferences” link in the footer of our Properties. Depending on your location, we will also treat the receipt of the GPC signal from your device as a valid request to opt out of the sharing with advertisers described above. Additionally, some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals.

For certain rights, to prevent fraud and verify your identity, we usually ask you to provide an email address when you submit a request. You may also designate an authorized agent to submit a request on your behalf. Depending on the nature of your request, we may ask that you verify that the request comes from you, such as by requiring a signed written permission from you that authorizes the agent to act on your behalf. A valid power of attorney will constitute signed written permission, but you are not required to obtain a power of attorney to use an authorized agent. 

If we deny your request or cannot fulfill it, you may appeal our decision by contacting us via contactus@minutemedia.com to ask us to review your request again. Your email should include “Appeal” in the subject line. You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this US State Supplement. 

CCPA Consumer Requests Metrics

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between January 1^st of the previous year to December 31^st of the following year

‍

Annex B - International Supplement (UK, EEA, Brazil, and Canada)

Last updated: September 18, 2025

This International Supplement provides information for residents of certain countries outside the United States which have data protection laws with specific requirements that are addressed in this Supplement, including the UK, the European Economic Area (“EEA”), Brazil, and Canada. 

Our general Privacy Policy explains what personal data we collect about you, how we collect that personal data, and why and how we use and disclose that personal data. Individuals who reside in the UK, EEA, Brazil, and Canada should read this International Supplement as well as our Privacy Policy to fully understand our collection, use, and disclosure of your personal data. 

Any capitalized terms we do not define in this International Supplement are defined in our Privacy Policy. 

(1) EEA, UK, and Brazil

If you reside in the EEA, the UK or Brazil, Pro Sportority (Israel) Ltd is the controller of your personal data provided to, collected by or for, or processed by us in connection with our Services. 

This section of the International Supplement complements the Policy and addresses specific requirements under (a) if you reside in the EEA, the EU GDPR, (b) if you reside in the UK, the UK GDPR, (c) if you reside in Brazil, the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD") and other applicable regulations issued by the Brazilian Data Protection Authority (“ANPD”), and (d) if you reside in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA).

With respect to the processing of personal data of residents of the EU, we participate in the IAB Europe Transparency & Consent Framework and comply with the Policies and Specifications and with the Transparency & Consent Framework provided by IAB Europe. Our IAB Europe vendor ID is 918.

1. Why do we process your personal data?

Your personal data will be processed for the purposes described in more detail below, on the basis of your consent or the legal bases set out below for each processing purpose, as applicable.

Purpose and legal basis

• Provision of our Services and support. We may use your personal data, such as your name and email address, for the provision of our Services to you, including for example, for providing support and responding to your inquiries.
  
  • Legal basis (EEA, UK, Brazil): the performance of our contractual obligations towards you, and compliance with our legal obligations. 
• Push notifications and communications. We may use your personal data to send you notifications and communications, including by email, push notifications, or text, about purchases, your account, offers, changes to policies, customer service inquiries and to request feedback, if you opted in and/or accepted to receive them from us, or if they are relevant to your use of our Services (such as service announcements).
  
  • Legal basis (EEA, UK, Brazil): consent (where required) and the performance of our contractual requirements towards you in the case of any communications required under the terms entered into with you.
• Analytics, surveys, and research. We may process your personal data for analytics purposes, including via surveys and for research in relation to our provision of the Services.
  
  • Legal basis (EEA, UK, Brazil): legitimate interests, which in this case are to improve the Services.
• Protecting our interests and enforcing our policies and/or terms. We may process your personal data for the purposes of enforcing our policies and/or any terms entered into with you.
  
  • Legal basis (EEA, UK, Brazil): legitimate interests, which in this case are enforcing our policies, protection against fraud and misuse of our Services.
• Payments. We collect from our third-party payment processors certain personal data about your payment instruments for the purpose of completing any transaction requested by you, and sending statements, invoices, or receipts to you.
  
  • Legal basis (EEA, UK, Brazil): performance of our contractual obligations, and compliance with legal obligations to which we are subject.
• Improvement of our Services. We and our Partners may conduct surveys or test features, and collect and analyze information about you and your usage of our Services to maintain, measure, and improve the usability and effectiveness of our Services for you.
  
  • Legal basis (EEA, UK, Brazil): consent (where analytics data containing personal data is collected through cookies and similar tracking technologies (as further described below)); and our legitimate interests, which in this case are providing and improving our Services.
• Marketing and advertising. We may use your personal data to send you promotional material concerning our Services which we believe may interest you. We may also use tracking technologies (which may collect personal data) in order to provide you with personalized advertisements when you visit our Properties and use our Services.
  
  • Legal basis: 
    
    • EEA and UK: Consent.
    • Brazil: consent and our legitimate interests, used in cases in which you have a legitimate expectation of receiving marketing and advertising from us.
• Third-party advertising and data segmentation. We may share your personal data with third-party ad networks and data segmentation solution companies to enrich, segment or optimize your personal data for our marketing and advertising purposes.
  
  • Legal basis (EEA, UK, Brazil): consent (where required) and our legitimate interests, which in this case are providing you with tailored Services, content, and advertisements that better correspond with your interests.
• Data security and integrity. We may process certain personal data about you and your usage of the Service to keep the integrity and security of the Services, detect and prevent fraud, verify your identity, investigate violations, and as otherwise required by law.
  
  • Legal basis (EEA, UK, Brazil): compliance with our legal obligations and our legitimate interests, which in this case are keeping the integrity of our Services and the safety of our end-users.
• Operation of our business. We may use your personal data to support our internal business functions such as finance, accounting and audit.
  
  • Legal basis (EEA, UK, Brazil): compliance with our legal obligations and our legitimate interests, which in this case are the efficient operation of our business. 
• Protection of our interests. We may process your personal data where we believe it is necessary to take precautions against liabilities or investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the rights and property of Minute Media, its users and/or its partners.
  
  • Legal basis (EEA, UK, Brazil): compliance with our legal obligations and our legitimate interests, which in this case are the protection of our business against claims or allegations.
• Compliance with applicable laws, legal and regulatory requirements. We may be required to process your personal data in order to comply with applicable laws, legal and regulatory requirements. 
  
  • Legal basis (EEA, UK, Brazil): compliance with our legal obligations. 
• Regular exercise of rights in administrative, judicial, or arbitration proceedings. We may be required to process your personal data in order to exercise our rights in administrative, judicial or arbitration proceedings.
  
  • Legal basis: 
    
    • EEA and UK: our legitimate interests, which in this case are to exercise our rights and defend ourselves in proceedings. 
    • Brazil: exercise our rights in administrative, judicial, or arbitration proceedings. 

2. Transfers of personal data outside of the EEA, the UK and/or Brazil

We operate globally, thus any personal data that we process, collect, disclose or share, can be transferred to, stored and processed in various other jurisdictions around the world outside the EEA, the UK, and/or Brazil, including (but not limited to) the United States and Canada, for the purposes detailed in this Policy. 

EEA and UK

To the extent that the EU GDPR and/or UK GDPR are applicable, we will only transfer or share your personal data to data recipients:

• located in the EEA and/or in the UK;
• located in a country outside of the EEA or the UK which has been determined by the European Commission and/or the relevant UK authorities as providing an adequate level of data protection for individuals’ rights and freedoms for their personal data; or
• located in a country outside of the EEA or the UK who have entered into the European Commission’s standard contractual clauses for the transfer of personal data to third countries (“SCCs”) and/or the UK Information Commissioner’s (“ICO”) international data transfer addendum to the SCCs or international data transfer agreement, as relevant and performed assessments ensuring an adequate level of data protection by the recipient.

Additionally, we adhere to the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We rely on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF as a legal basis for transfers of personal information. 

We and our covered entities, Sportority Inc., Vedia Technologies Inc,. and Sports Publishing Solutions Inc., comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. Our commitment to subject the personal information described in this Policy to the Data Privacy Framework is subject to the enforcement and investigative powers of the United States Federal Trade Commission.

To learn more about the Data Privacy Framework Program, visit  https://www.dataprivacyframework.gov, and to view our certification, please click here.

We may share personal information with third parties under certain circumstances described in this Policy, subject to obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and We remain liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where we are not responsible for the event giving rise to the damage.

In compliance with the Data Privacy Framework Principles, we are committed to resolving complaints about our collection or use of your personal information.  E.U., UK, and Swiss individuals with inquiries or complaints regarding our  Data Privacy Framework policy should first contact us at: dpo@minutemedia.com or by calling us at +1(888) 211-4431.

We are to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

We have further committed to referring unresolved  Data Privacy Framework complaints to an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concern that we have not satisfactorily addressed, please contact our U.S.-based third-party dispute resolution provider, TRUSTe at https://feedback-form.trustarc.com/watchdog/request for more information or to file a complaint.  The services are provided at no cost to you.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Minute Media commits to cooperating and complying respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

If you have such an unresolved complaint, under the recourse mechanism, you may contact the applicable  EU Data Protection Authorities (free of charge). We are committed to cooperating with the DPAs and complying with the advice given by such authorities.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may - under certain conditions described on the Data Privacy Framework Properties - invoke binding arbitration when other dispute resolution procedures have been exhausted. For more information on this option, please see Annex I of the Data Privacy Framework Principles.

Brazil

Your personal data will be processed for the same purposes as described in the UK and EEA supplement above. You can obtain more information about our policies and practices with respect to the use of service providers located in third countries by contacting us as described in our Privacy Policy under the “How to Contact Us” heading. 

3. How long do we retain your personal data? 

We will retain your personal data as follows to the extent necessary to keep your account open, to provide you with the Services, to contact you, to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service and our policies, or as required to operate our business. If you want to know more details about how long we retain your personal data, please contact us at dpo@minutemedia.com  or by calling us at +1(888) 211-4431.

4. Your data subject rights
   ‍If you reside within the EEA, the UK, or Brazil, you have certain rights in relation to your personal data. 

1. Access: You have the right to ask for confirmation as to whether your personal data is being processed, and request access to the personal data we hold about you, together with supplementary information such as how we use your personal data and who we share it with.
2. Portability: You have the right to ask for a copy of the personal data we hold about you in a structured, commonly used and machine-readable format and request that we transfer it to a third party, in certain circumstances and with certain exceptions.
3. Rectification: You have the right to request rectification of your personal data that is in our control.
4. Erasure: You have the right to request erasure of your personal data in certain circumstances.
5. Objection to marketing: You can object to marketing at any time by following the process detailed here (insert link to “(3) How to exercise your rights” of the main body of the policy).
6. Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw your consent at any time by clicking on the “Manage Preferences” link in the footer of our Properties. 
7. Complaints: We take our obligations seriously, and we ask that any concerns be first brought to our attention so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. In any case, you can always lodge a complaint with the applicable EEA data protection supervisory authority if you are located in the EEA, with the ICO if you are located in the UK, or with the ANPD if you are located in Brazil.

EEA and UK

In addition to the above rights, if you reside in the EEA and UK, you have the right to: 

1. Objection: You have the right to object to our processing of your personal data.
2. Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances. 

Brazil

In addition to the above rights, if you reside in Brazil, you have the right to:

1. Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given.
2. Request anonymization, blocking or deletion of unnecessary, excessive personal data or personal data processed unlawfully.
3. Request a review of a decision that was based solely on the automated processing of your personal data and that may affect your interests.

However, please note that these rights pertain to EEA, UK and Brazil residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. ​If you would like to exercise any of the rights mentioned in this section, the request should be addressed to us by submitting a verifiable consumer request to our email address: dpo@minutemedia.com.

5. Our legal representatives

DPO

For the purposes of EEA and Brazilian law, you may contact our Data Protection Officer by email at dpo@minutemedia.com or by mail at Yitzhak Sadeh St 8, Tel Aviv-Yafo, Israel.

EEA

Our representative in the EU is Lionheart Squared (Europe) Ltd., with its address at 2 Pembroke House, Upper Pembroke Street 28-32, Dublin, D02 EK84 Ireland, and their email address is MinuteMedia@lionheartsquared.eu.

UK

For the purposes of UK law, you may contact our Data Protection Officer at their address at 385-389 Oxford St., London W1C 2NB, and by email at dpo@minutemedia.com.
‍

(2) Canada

If you are a resident in Canada, you may have certain rights (including those described below) with respect to your personal data that we process. To exercise any of your privacy rights, please contact us at dpo@minutemedia.com  or by calling +1(888) 211-4431. 

• Updating your personal data - We want to make sure that the personal data that we have collected about you is accurate, complete, and current. However, we may not routinely update this information unless it is necessary for us to do so to fulfill the purposes for which we collected the personal data. Since we generally rely on you to inform us if there have been any changes to the personal data that we have collected about you, please let us know if any of this information has changed. 
• Access to and correction of personal data - If you have any questions about the accuracy of the personal data that we have collected about you, you can have access to that personal data to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such personal data. 
• Withdrawal of consent - Where you have provided your consent to the processing of your personal data, you may have the legal right to withdraw your consent under certain circumstances. 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 make your decision. 
• Unsubscribe from marketing and promotional communications - If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g., email) you receive or by contacting us as set out below under the “How to Contact Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transaction emails or emails about your account and use of our Properties.