The Website is owned and operated by WME|IMG China Culture Development Co., Ltd., with registered offices at Unit 1701, Two ICC, Shanghai ICC, No.288 South Shanxi Road, Shanghai 200031, China and/or IMG Worldwide, LLC, with offices at 1360 E 9th St #100 Cleveland, OH 44114 (and referred to in this Policy as “IMG China” “we”, “us”, or “our”).  

The IMG China business is part of the IMG Group, which forms part of the Endeavor group of companies, and we may share data (as described further below) with these affiliated entities (collectively, “Endeavor”).

This Privacy Policy sets out how we, as data controller, collect, hold, use, process and disclose your personal information, why and according to what legal reasoning we process it, with whom and for what purposes we share it, the rights to which you may be entitled, and your choices about our use of your personal information, all of it in compliance with the Chinese Personal Information Protection Law (“PIPL”).

This Privacy Policy covers our use of your personal information arising from the use of the IMG China website as well as registering/subscribing for our services.

We will collect and use your personal information to:

·         Create, verify, and manage user accounts and features

·         Allow you to access this website and register for/subscribe to our services

·         Provide IMG services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates)

·         Develop, deliver, and improve IMG China services and other offerings, some of which may be offered in partnership with other parties

·         Personalize your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests (for instance, if you frequently access content on a certain sport, we may infer that you’d be interested in that sport and suggest similar content to you)

·         Promote IMG services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events

·         Conduct data analytics (like analyzing how the IMG services are used so we can better understand, improve, and personalize them)

·         Meet our legal obligations

·         Secure IMG China services, such as by detecting fraud and otherwise protecting IMG and other users from illegal or harmful actions

·         Fulfill any purpose we make known to you when we collect your personal information

·         Fulfill other purposes set out in more detail in this section

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.

Your information will be shared with members of our group and some third parties as described below.

Some of the personal information we request is required to provide the services and if it is not provided, we may not be able to provide the relevant services to you.

The table below indicates what we collect, how we use it, and whether such information is required to provide services to you.

We may also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the Endeavor group and combined with information collected on the IMG China and Endeavor websites.

SOCIAL MEDIA

We use several social media and blogging platforms to communicate with our customers, some of which are operated by third parties, such as Facebook, Instagram, Twitter (X) and LinkedIn. This Policy applies to our use of personal information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.

Our services may include features and functionalities that allow you to share personal information with us that you have already provided to a third party social media platform. For example, you may be able to create an account on our services or log-in to our Services using your Facebook account or other third party credentials. If you do so, then personal information that you have provided to that third party may be made available to us, pursuant to the third party’s terms and conditions and privacy policy, and you consent to our use of that personal information in accordance with this Policy.

We may also include tools on our Services that allow you to share and/or publicly post content or information from our Services to your profile on a third party social media. Third party social media platforms and blogging platforms have their own privacy policies which explain how they will use, protect and share your personal information, including any information you share on those platforms from our Services, and we encourage you to read them.

LEGAL REQUIREMENTS

Your personal information will be processed as follows: if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency; to enforce or apply IMG China’s Terms of Use and other agreements; in an emergency; to protect the rights, property or safety of Endeavor’s group of companies, customers, clients and others; or in the defense of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows for it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.

Due to the legal, regulatory, and security environment in which we operate, we may be required to disclose information about you under certain circumstances, and we may not be permitted to inform you that we have done so.

HOW LONG WE KEEP YOUR INFORMATION

We generally keep your information as needed to provide services and to deal with legal claims.

We will keep your information for as long as is reasonably necessary to deal with claims. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

We will also retain a copy of your contact details if you object or opt out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

We consider the following issues to determine retention periods:

·         Guidance from relevant Chinese Regulatory Agencies, or industry best practice recommendations

·         The specific purposes for which the  personal data is being used

·         The business rationale for collection and expiry of the purpose for which personal data was collected

·         Our ongoing ability to ensure the accuracy of the data

·         Legal and regulatory requirements under Chinese law.

INFORMATION WE SHARE

There are certain circumstances where we will transfer your personal data to employees, contractors and other parties.

We will share information about you with other members of our group of companies so we can provide the best service across our group.

Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the discharge of their functions for us. Under our contracts with them, they would be prohibited from using or disclosing the information for their own purposes.

Your personal information will be transferred to other third-party organizations in certain scenarios if we are:

·         discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers and their advisors under appropriate terms as to confidentiality;

·         reorganized or sold – information may be transferred to a buyer who can continue to provide services to you;

·         required to by law, or under any regulatory code of practice we follow, or if we are asked by any public or regulatory authority – for example, law enforcement authorities;

·         defending a legal claim – your information may be transferred as required in connection with defending such claim; or

·         your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Your personal data may be also shared:

·         with service providers for the purposes of settling or making payment in connection with any wager, verifying your identity, and other purposes in connection with the services;

·         with payment management or debt collection companies engaged by us to handle payment and collection processes;

·         with our co-sponsor(s) if we obtain your personal information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties as long as you have consented or opted in for it.;

·         with any Chinese governmental agency, regulatory authority or licensing body;

·         when we believe in good faith that disclosure is necessary or appropriate to protect or enforce our rights or property, protect your safety or the safety of others, investigate or seek to address fraud, money laundering, intellectual property infringement or violation of law, respond to a government, judicial or other legal request, or to comply with the law;

·         for purposes of disaster recovery; and

·         with credit reporting agencies, such as information about late payments, missed payments, or other defaults on your account.

When your personal data is transferred to entities within Endeavor and/or authorized third parties located outside of China, we implement rigorous organizational, contractual, and legal safeguards. These measures ensure that your personal data is processed exclusively for the designated purposes and that your data is adequately protected.

For any international transfer and if required, we will obtain your explicit consent and ensure the recipient's country or organization offers data protection standards recognized by Chinese regulators.

WHERE YOUR INFORMATION WILL BE HELD

In our commitment to transparency and compliance with the Chinese Personal Information Protection Law (PIPL), we wish to inform you about how we operate and manage your personal information:

We operate the Services globally across various jurisdictions. However, our primary site operations for IMG China are based in the Hong Kong Special Administrative Region in the People’s Republic of China, where your personal data may likely be stored and processed . Before any cross-border transfer of your personal data occurs, we will obtain your explicit consent and ensure that the transfer meets the rigorous data protection standards stipulated by the PIPL.

There may be instances where your data is disclosed in response to legal inquiries or requests from government authorities. This disclosure will only occur in the countries where we operate and store your information, and only when mandated by applicable local laws or regulatory obligations.

COOKIES

We use cookies that identify your browser. They collect and store information when you visit our website about how you use it, through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website and undertake analytics. The personal data we collect through these technologies will also be used to manage your session.

We use the following categories of cookies on our website:

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Social Media Cookies

These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. These cookies are not within our control.  Please refer to the respective privacy policies for how their cookies work.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

DO NOT TRACK

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Like many websites, our site is not currently able to respond to these “do-not-track” signals. To learn more about “do-not-track” signals, you can visit http://www.allaboutdnt.com/.

SECURITY

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through the IMG China website and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorized access.

LINKS TO THIRD-PARTY WEBSITES

The IMG China website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including members of our groups, our partner networks or advertisers and/or social networks as offered to you and supported by your browser. The personal data that you provide through those other websites is not subject to this Privacy Policy and the treatment of your personal data by the operators of such websites is not our responsibility. If you follow a link to any of these websites, please note that the operators of those websites may have their own privacy policies which set out how your information is collected and processed by them. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of entities through which you choose to share.

For more information about third party advertisers and how to prevent them from using your information, please visit Aboutads.info at www.aboutads.info/choices/ or Your Online Choices at www.youronlinechoices.eu.

YOUR PRIVACY RIGHTS

In compliance with the PIPL, you are granted the following rights concerning your personal data:

·         Access. You have the right to access personal information we hold about you and ask us for other information such as purposes of processing, categories of personal information and recipients of the information.

·         Portability. You have the right to request a copy of personal information about you and request that we transfer it to a third party (with certain exceptions).

·         Correction. You may be entitled to request correction of any personal information about you which is incomplete or inaccurate.

·         Erasure. In certain circumstances, you have the right to request deletion or erasure of the personal information we hold about you.

·         Restriction of processing to storage only. You have the right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances.

·         Objection. Where we are processing personal information about you on the basis of legitimate interests, you have the right to object to our processing of personal information about you. You also have the right to object to marketing by opting out at the bottom of our emails to you.

·         Withdrawal of Consent. Where we rely on consent to process personal information about you, you have the right to withdraw this consent at any time by contacting us.

·         Complaint. If you feel that we have not processed your personal data in accordance with the PIPL, you have the right to lodge a complaint with the relevant Chinese supervisory authority.

If you want to exercise any of these or other rights, please contact us at buicklpga_cn@img.com. We may require you to prove your identity with approved identification.

You may also have the right, in certain circumstances, to object to our processing your personal information. However, we may be entitled to continue processing it in line with Chinese laws. You can exercise this right by contacting us at buicklpga_cn@img.com. You may also have the right, to ask us to stop processing your personal information for direct marketing purposes. You can exercise this right by checking certain boxes on the forms we use to collect your information or by clicking “unsubscribe” on the emails you receive. You can also exercise this right by contacting us at buicklpga_cn@img.com.

UPDATES

Any updates we may make to our Privacy Policy will be posted on this page, and we may also provide a website notice of any material changes for a reasonable period of time. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use our services.

CONTACT

Questions or comments regarding this Privacy Policy should be submitted to us at buicklpga_cn@img.com or by postal mail at: Becky.Hu, WME|IMG China Culture Development Co., Ltd. Unit 1701, Two ICC, Shanghai ICC, No.288 South Shanxi Road, Shanghai 200031, China.