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ASAL’s Privacy Policy

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this
policy we explain how we will treat your personal information.
1.2 By using our website and agreeing to this policy, you consent to our use of
cookies in accordance with the terms of this policy.

2. Credit
2.1 This document was created using a template from SEQ Legal

3. Collecting personal information
3.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of
this website (including your IP address, geographical location,
browser type and version, operating system, referral source, length
of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website
(including your email address);
(c) information that you provide when completing your profile on our
website (including but not limited to your name, pictures, videos,
gender, date of birth, general personal information, contact
information, interests and hobbies, and educational/ employment/
athletic details);
(d) information that you provide to us for the purpose of subscribing to
our email notifications and/or newsletters (including your name and
email address);
(e) information that you provide to us when using the services on our
website, or that is generated in the course of the use of those
services (including the timing, frequency and pattern of service use);
(f) information relating to any purchases you make of our goods and/or
services or any other transactions that you enter into through our
website (including your name, address, telephone number, email
address and card/payment details);
(g) information that you post to our website for publication on the
internet (including your user name, your profile pictures and the
content of your posts);
(h) information contained in or relating to any communication that you
send to us or send through our website (including the communication
content and metadata associated with the communication);
(i) any other personal information that you choose to send to us; and
(j) any other information collected or provided to us by using our mobile
applications and our services we provide through them (including
your user name, your profile pictures, statistics on use of our services
and applications, and results obtained such as athletic records).

3.2 Before you disclose to us the personal information of another person, you
must obtain that person’s consent to both the disclosure and the processing
of that personal information in accordance with this policy.

4. Using personal information
4.1 Personal information submitted to us through our website will be used for
the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) administer our website and business;
(b) personalize our website for you;
(c) enable your use of the services available on our website;
(d) send you goods purchased through our website;
(e) supply to you services purchased through our website;
(f) send statements, invoices and payment reminders to you, and collect
payments from you;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested;
(i) send you our email newsletter, if you have requested it (you can
inform us at any time if you no longer require the newsletter or
change your settings);
(j) send you marketing communications relating to our business or the
businesses of carefully-selected third parties which we think may be
of interest to you, by post or, where you have specifically agreed to
this, by email or similar technology (you can inform us at any time if
you no longer require marketing communications or change your
(k) provide third parties with statistical information about our users (but
those third parties will not be able to identify any individual user from
that information);
(l) deal with enquiries and complaints made by or about you relating to
our website;
(m) keep our website secure and prevent fraud;
(n) verify compliance with the terms and conditions governing the use of
our website (including monitoring private messages sent through our
website private messaging service);
(o) help you improve your profile and universities application so that you
can maximize your opportunities of attending a U.S. university and
those of receiving scholarships and funding, as described on our
services; and
(p) help you obtain access to our services; in the creation of your
profiles, C.V./resumes, videos, letters, and others; for
communications between universities/ coaches and ASAL, and for all
marketing services that ASAL provides specifically for you as part of
our services.

4.3 If you submit personal information for publication on our website, we will
publish and otherwise use that information in accordance with the licence
you grant to us.
4.4 Your privacy settings can be used to limit the publication of your information
on our website, and can be adjusted using privacy controls on the website.
4.5 We will not, without your express consent, supply your personal information
to any third party for the purpose of their or any other third party’s direct
4.6 All our website financial transactions are handled through our payment
services provider, [PSP name]. You can review the provider’s privacy policy
at [URL]. We will share information with our payment services provider only
to the extent necessary for the purposes of processing payments you make
via our website, refunding such payments and dealing with complaints and
queries relating to such payments and refunds.

5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees,
officers, insurers, professional advisers, agents, suppliers or subcontractors
insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes set out
in this policy.
5.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including
providing information to others for the purposes of fraud prevention
and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset
that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or
other competent authority for disclosure of that personal information
where, in our reasonable opinion, such court or authority would be
reasonably likely to order disclosure of that personal information.
5.4 Except as provided in this policy, we will not provide your personal
information to third parties.

6. International data transfers
6.1 Information that we collect may be stored and processed in and transferred
between any of the countries in which we operate in order to enable us to
use the information in accordance with this policy.
6.2 Information that we collect may be transferred to the following countries
and areas which do not have data protection laws equivalent to those in
force in the United States of America: the European Economic Area, Africa,
Russia, Japan, China and India.

6.3 Personal information that you publish on our website or submit for
publication on our website may be available, via the internet, around the
world. We cannot prevent the use or misuse of such information by others.
6.4 You expressly agree to the transfers of personal information described in
this Section 6.

7. Retaining personal information
7.1 This Section 7 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not
be kept for longer than is necessary for that purpose or those purposes.
7.3 Without prejudice to Section 7.2, we will usually delete personal data after 8
years from its collection date.
7.4 Notwithstanding the other provisions of this Section 7, we will retain
documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or
prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including
providing information to others for the purposes of fraud prevention
and reducing credit risk).

8. Security of personal information
8.1 We will take reasonable technical and organisational precautions to prevent
the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure servers.
8.3 All electronic financial transactions entered into through our website will be
protected by encryption technology.
8.4 You acknowledge that the transmission of information over the internet is
inherently insecure, and we cannot guarantee the security of data sent over
the internet.
8.5 You are responsible for keeping the password you use for accessing our
website confidential; we will not ask you for your password (except when
you log in to our website).

9. Amendments
9.1 We may update this policy from time to time by publishing a new version on
our website.
9.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
9.3 We may notify you of changes to this policy by email or through the private
messaging system on our website, but notification of any changes made is
not mandatory.

10. Your rights

10.1 You may instruct us to provide you with any personal information we hold
about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at 15 USD); and
(b) the supply of appropriate evidence of your identity (for this purpose,
we will usually accept a photocopy of your passport certified by a
solicitor or bank plus an original copy of a utility bill showing your
current address).

10.2 We may withhold personal information that you request to the extent
permitted by law.
10.3 You may instruct us at any time not to process your personal information for
marketing purposes.
10.4 In practice, you will usually either expressly agree in advance to our use of
your personal information for marketing purposes, or we will provide you
with an opportunity to opt out of the use of your personal information for
marketing purposes.

11. Third party websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies
and practices of third parties.

12. Updating information
12.1 Please let us know if the personal information that we hold about you needs
to be corrected or updated. In this way, you are responsible for any
damages caused from incorrect information that you may have provided to

13. Cookies
13.1 Our website uses cookies.
13.2 A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser.
The identifier is then sent back to the server each time the browser requests
a page from the server.
13.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when
the web browser is closed.
13.4 Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.
13.5 We use both session and persistent cookies on our website.
13.6 We use cookies such as Google Analytics on our website to recognise a
computer when a user visits the website, track users as they navigate the
website, enable the use of a shopping cart on the website, improve the
website’s usability, analyse the use of the website, administer the website,
prevent fraud and improve the security of the website, personalise the
website for each user, and target advertisements which may be of particular
interest to specific users. The information collected by cookies is used to

help us understand the users and clients and to help us improve the site
content and experience. In cases such as those with Google Analytics,
visitors and users can download Google’s Opt-Out Browser Add-on to
prevent the collection of this data and its use by Google Analytics.
13.7 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the
cookie handling override settings available by clicking “Tools”,
“Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 36) you can block all cookies by clicking “Tools”,
“Options”, “Privacy”, selecting “Use custom settings for history” from
the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 41), you can block all cookies by accessing the
“Customise and control” menu, and clicking “Settings”, “Show
advanced settings” and “Content settings”, and then selecting “Block
sites from setting any data” under the “Cookies” heading.

13.8 Blocking all cookies will have a negative impact upon the usability of many
13.9 If you block cookies, you will not be able to use all the features on our
13.10 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie
files (you can find instructions for doing so at
(b) in Firefox (version 36), you can delete cookies by clicking “Tools”,
“Options” and “Privacy”, then selecting “Use custom settings for
history” from the drop-down menu, clicking “Show Cookies”, and
then clicking “Remove All Cookies”; and
(c) in Chrome (version 41), you can delete all cookies by accessing the
“Customise and control” menu, and clicking “Settings”, “Show
advanced settings” and “Clear browsing data”, and then selecting
“Cookies and other site and plug-in data” before clicking “Clear
browsing data”.

13.11 Deleting cookies will have a negative impact on the usability of many

14. Data protection registration
14.1 We are registered as a data controller with the UK Information
Commissioner’s Office.
14.2 Our data protection registration number is [number].

15. Our details
15.1 This website, www.asalsports.com, and all our associated sites it is linked to,
including its applications for other electronic devices, are owned and
operated by American Student Athlete Logistics, LLC.
15.2 We are registered in the U.S.A. under EIN 471708685 and our registered
office is at P.0. Box 1965, Lawrence, KS 66044.

15.3 Our principal place of business is online at www.asalsports.com .
15.4 You can contact us by writing to the business address given above, by using
our website contact form, by email to [email protected] or by
telephone on 1-785-551-9231.