It would be helpful to start by explaining some key terms used in this policy:

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

This personal information is required to provide products to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing products to you.

• Cookies (or mobile cookies). A cookie is a small file placed on your computer or smartphone. Cookies are small text strings that the websites visited by a user install on the user’s terminal. These strings are then re-transmitted to the site that installed them upon further requests by the user. When the user also receives cookies sent by other sites or web servers during site navigation, those cookies are considered third-party cookies. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your computer or smartphone. However, if you select this setting, you may be unable to access certain parts of our Platform.
• Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Platform statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

• From publicly accessible sources (e.g., property records);
• Directly from you when you provide it to us, such as when you make a purchase, visit or use our website, place an order with us, contact us by email, by phone, or by online chat, register for an online account, participate in a contest or sweepstakes, respond to a survey, comment on blog posts, engage in a promotional activity, or sign up for emails, newsletters, or marketing;
• Certain information from third parties, such as social media platforms and networks that you use in connection with our Platform, or that share or allow you to share information with us; service providers that we use that provide us with information about you and the devices you use online; and other third parties that we choose to collaborate with in order to make the Platform and its services available for your use;
• From a third party with your consent (e.g., your bank or credit card company);
• Automatically when you use the Platform, including automatically collected information, but which generally does not include personal information unless you provide it through our website or you choose to share it with us;
• From cookies on our website; and
• Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

• Advertisers, ad networks, and ad servers;
• Analytics companies;
• Your mobile device manufacturer; and
• Your mobile or internet service provider.

These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Any data provided within the United States will not be transferred by us to third countries or international organizations outside the United States. The hosting of the site is also within the United States.

Any data provided outside the United States will be transferred by us to the United States. Where personal data transfers occur internationally, they are governed by safeguards which include International Group Data Transfer Agreements which contain the appropriate Model Contract Clauses for data protection where required. We may transfer any information we collect mentioned above to the United States.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

• Contacting us at support@horsespot.net; or
• Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

• To our affiliates, including companies within the Horse Spot, Inc. group of brands and companies.
• To service providers we use to help deliver our products to you, such as payment service providers, warehouses and delivery companies.
• To other third parties we use to help us run our business, such as marketing agencies or website hosts, which utilize their own terms and conditions and privacy policies:
• To third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.liver our products to you, such as payment service providers, warehouses and delivery companies. (1) Google (2) Stripe (3) HubSpot (4) Amazon Web Services
• To our insurers and brokers.
• To our banks.
• To parties in business transactions, such as a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Platform users is among the assets transferred. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

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 Network Advertising Initiative ("NAI") on the NAI's website.

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

• When a child enters a competition, Competition Management Companies may ask only for the following:
• (i) Only Personal Information needed for a child to take part, including basic contact and competition-related information, including full name, age, location, and/or any tax related information for the purposes of awarding prize winning, if applicable.
• Beyond competitions, Competition Management Companies shall not knowingly collect Personal information from Children under the age of 18. If you are under 18, please do not provide your Personal Information. We encourage parents and guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information to Horse Spot or to Competition Management Companies without their permission.
• When Competition Management Companies do collect Personal Information from children, they shall take extra steps to protect their privacy including:
• (i) Making sure to inform parents or guardians what personal information is collected, stored, used and processed from their child and explaining whether that information is shared;
• (ii) Meeting legal requirements by asking for parental consent to collect, use and process a child’s data and asking for consent to send their children information about any products and services;
• (iii) Limiting how Personal Information is collected, stored, used and processed from children so only data that is reasonably needed for them to take part in the services offered by Horse Spot competitions is collected;
• (iv) Giving parents access or the option to ask for access to Personal Information collected from their child, parents can also ask for their children’s Personal Information to be changed or deleted.
• Without legal consent from a parent or guardian, children will not be able to take part in Horse Spot’s Platform or Services. Competition Management Companies agree to abide by the following guidelines when collecting information related to onboarding minor(s) to the Horse Spot Platform:
• (i) Asking for parental consent by email: If Competition Management Companies need to collect a child’s personal information to provide a service requested by the child, they shall ask for parental consent according to legal requirements (i.e. CCPA for the US and GDPR for the EU). They will send the child’s parent, guardian and/or trainers as applicable, an email explaining what information they are collecting, how they plan to use it and ask the parent to give or deny their consent. If they do not receive parental consent in a reasonable time, all Personal Information collected will be deleted, including the Personal Information for the adult whose consent was requested.
• At any time, parents or guardians can refuse to allow Horse Spot or Competition Management Companies to use and collect further Personal Information from their child. Parents and Guardians can ask Horse Spot or Competition Management Companies to delete the Personal Information we have collected in connection with their child’s account from our records. As Personal Information is required for some services, deleting a child’s records may result in an account or service being unavailable to the child in the future.
• If a child has an account with Horse Spot, parents or guardians can access, change, or delete the Personal Information we have collected from their child by:
• (i) Using their child’s username and password to log into their Horse Spot’s Account; or
• (ii) Contacting our Support Team at support@horsespot.net.
• • If an underage person provides information and Horse Spot has unknowingly collected said information, we will take the appropriate steps to delete this information immediately upon notice. If you have reason to believe that a child under the age of 18 has provided Personal Information to Horse Spot, please contact us at support@horsespot.net so we can endeavor to delete that information from our databases and other data infrastructure.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driver’s license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

• Right to Access Information: You have the right to access and obtain a copy of your personal data.
• Right to Request Deletion: You have the right to request that we delete personal data provided by or obtained about you.
• Right to Correct: You have the right to correct inaccuracies in your personal data.
• Right to Opt-Out of Targeting Advertising. You may ask us not to use or disclose your information for the purposes of targeting advertising to you based on your personal data obtained from your activity across different businesses, services, websites, etc.
• Right to Opt-Out of Personal Information Sales to third parties.

• To Submit a request to exercise your access, deletion, or correction privacy rights, please email us at support@horsespot.net with the subject line “Privacy Rights Request” and let us know in which state you live.
• Residents of Colorado, Connecticut, Montana, Oregon, Texas, and Virginia may appeal a refusal to take action on a request by contacting us by email at support@horsespot.net.
• Residents of Oregon may request that we provide a list of third parties to which we have disclosed personal data. To make such a request, please follow the instructions above for submitting an access, deletion, or correction request.

• Access and Correction: You have the right of access your data. This is sometimes called a “Subject Access Request”. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
• Object to Processing: You have the right to object to us processing your personal information if we are not entitled to use it anymore.
• Right to Data Portability: You have the right to ask that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Complain to the Regulator: If you are not satisfied with the way we have handled the request, you have the right to escalate a complaint to the regulator.
• Right not to have your Data Sold to Third Parties: Horse Spot will not sell or rent your data unless we are engaged in the sale of the company or part of the company and in such case, we would need to transfer your data to honor our continuing obligations to you.
• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting us at support@horsespot.net and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law.

• Right to Access. You can ask us to: (i) confirm that we have personal information about you; and (ii) provide you a copy of that information.
• Right to Correct: You can ask us to correct any inaccurate or incomplete personal information that we have about you.

You may submit a request by contacting us at support@horsespot.net with the subject line “Canadian Privacy Rights Request”. Before we honor your request, we will need to verify your identity.