Collection and Use of Personal Information

Personal information is information about an identifiable individual. Depending on local law, publicly available information, such as business contact information, including your name, title or position, business, telephone or facsimile number, may not be considered personal information.

What Personal Information We Collect

We may collect and process different types of personal information in the course of operating our business. These include:

• Contact information such as name, address, email address and telephone number;

• Biometric information such as height, weight and other material.

• Biographical information such as job title, employer, professional associations, or regarding membership in industry trade groups;

• Your attendance at various events;

• Data from any surveys or questionnaires that we may have provided to you;

• Past requests that you may have made for information from us;

• Recruitment information such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment or association to or with RinkNet;

• Unique IDs such as your mobile device identifier or cookie ID on your browser;

• IP address and information that may be derived from IP address, such as geographic location;

• Information about the content you access on our website and the nature of your visit, including the time of your visit to our website (by day, week, and duration) and whether you are a new visitor or a returning visitor;

• Information about a device you use, such as browser, device type, operating system, the presence or use of apps, screen resolution, and the preferred language.

How We Use Your Personal Information

We may use personal information and other information in the manner set out below. In each case, we identify the grounds that we rely on to use your personal information.

• The personal information we collect allows us to keep you posted on RinkNet Software’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by sending us an email to Info@RinkNet.com or by unsubscribing on a current announcement that was sent to you. Applicable legal grounds: legitimate interests, consent, contract performance;

• We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes;

• We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. Applicable legal grounds: legitimate interests, consent, contract performance;

• From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. As this information is important to your interaction with RinkNet Software, you may not opt out of receiving these communications. Applicable legal grounds: legitimate interests, contract performance;

• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve RinkNet Software’s products, services, and customer communications. Applicable legal grounds: legitimate interests, consent, contract performance;

• If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs. Applicable legal grounds: legitimate interests, consent, contract performance;

• To enable us or our shareholder, Banyan Software Holdings, LLC and its affiliates, to process applications for employment and to assess suitability for any position for which an individual may apply at RinkNet. Applicable legal grounds: legitimate interests (to ensure that we can make the most appropriate recruitment decisions for RinkNet), contract performance (in order for us to take steps to enter into a contract with someone who requested it);

• For relevant background checks as may be required by applicable law, regulation and best practice at any given time, as well as to enforce our legal rights and/or to protect the rights of third parties. Applicable legal grounds: legal obligations, legal claims, legitimate interests;

• To process and receive payments, evaluate credit standing and to recover any payments due to us and, where necessary, to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings). Applicable legal grounds: contract performance, legal claims, legitimate interests (to ensure that we are paid amounts due); and

• In the event that we undergo a reorganization (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer to that reorganized entity or third party your personal information for the same purposes as set out in this Privacy Policy or for the purpose of analyzing any proposed reorganization. Applicable legal grounds: legitimate interests (in order to allow us to change our business).

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

• We may collect information such as language, zip code, area code, location, and the time zone where a RinkNet Software service is used so that we can better understand customer behavior and improve our products, services, and advertising.

• We may collect information regarding customer activities on our website, online version, ISS Hockey Store and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.

• We may collect and store details of how you use our services, including online screen usage. This information may be used to improve the relevancy of upgrades provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

• With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Sharing of information

We may also share personal information with certain third parties such as:

• Third-party service providers who provide website, application development, hosting, maintenance, and other services to us, including allowing us to analyze the usage of our website, engagement on our social media channels and our ability to effectively communicate with potential vendors. These third parties may have access to, or process personal information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information;

• Law enforcement and governmental entities when required by law. For greater clarity, we may disclose personal information or other information if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies; and

• An acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Selling of personal information

RinkNet Software does not collect any personal information for the purpose of selling that personal information.  Despite this, some jurisdictions require us to make the following additional statement:

• We have not sold any personal information in the past twelve months.

• We do not sell personal information to third parties.

Cookies and Other Technologies

RinkNet Software’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

RinkNet Software and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with RinkNet more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit RinkNet Player Management and Scouting System. Knowing your country and language − helps us provide a customized and more useful experience. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize and set up your scouting software, which will provide you with better customer service.

Category

Use

• Basic functionality cookies

• Required to offer basic functionalities of our website and to remember a user’s cookie settings.

• Analytics cookies

• Collection of data to allow us to understand how our visitors use our website and how we can improve our website.

• Functionality cookies

• Remember user choices to improve the user’s experience and to provide enhanced and personalized features.

• Performance cookies

• Collect anonymous data on the pages visited and determine devices used by the user.

• Architecture cookies

• Third party cookies used for load balancing, caching, content management, and third-party authentication.

• Third-party targeting and advertising cookies

• These cookies collect data about the user’s browsing habits in order to provide advertising relevant to the user’s interests.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. RinkNet Software may use this information in our marketing and advertising services. In some of our email messages, we use a “click-through URL” linked to content on the RinkNet Software website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Integrity and Retention of Personal Information

RinkNet Software makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Requesting access, changes, or limits to your information

Under applicable law, you may request from us the following:

• a copy of any of your personal information which we may have

• to update or correct any inaccuracies in your personal information that we may have;

• to request that we limit our use of your personal information, including but not limited to instructing us not using your personal information for a specific purpose;

• to erase some or all of your personal information that we do not have a legal entitlement to keep; or

• withdraw any previously provided consent for our use of your personal information.

In addition, while RinkNet Software does not sell personal information to third parties, some jurisdictions still require that we provide you a means to opt out of the sale of your personal information to third parties.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to Info@RinkNet.com with details of your request. For the purposes of verifying your identity we may ask that you provide us sufficient personal details to allow us to identify you.  Such information will only be used for the purpose of verifying your identity.

Location-Based Services

To provide location-based services on RinkNet Software services, RinkNet Software and our partners and licensees may collect, use, and share precise location data. Where available, location-based services may use GPS, Bluetooth, and IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by RinkNet Software and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

Third-Party Sites and Services

RinkNet Software websites, products, applications, and services may contain links to third-party websites, products, and services. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

International Users

All the information you provide may be transferred or accessed by entities as described in this Privacy Policy.

How to Contact Us?

If you have any questions, comments, or suggestions related to data privacy, please contact us at:

RinkNet Software, Inc.

1440 King Street North, Suite B, P.O. Box 524

St. Jacobs, ON   N0B 2N0

www.RinkNet.com

Updates to this Privacy Policy

We may change the content of our websites and how we use cookies without notice and consequently our Privacy Policy may change from time to time in the future. We therefore encourage you to review them whenever you visit the website to stay informed of how we are processing personal information.

 This Privacy Policy was last updated February 7, 2022