AICOSPORTS A.S. and its affiliates and subsidiaries (collectively, “AICOSPORTS”, “we,” “our,” “us”) respect your privacy and value your trust and confidence. This Privacy Policy explains what types of data or information we may collect from you (which may include your personal data) when you use or interact with this website (aicosports.com) (the “Site”), when you make a purchase from us online (including via the Site) or via other means (i.e., offline and/or by phone), when you attend any events or experiences which we help to organize or promote, and when you otherwise communicate or interact with us, including via the Site, social media, direct marketing, contests, sweepstakes, surveys and/or focus groups we may facilitate for our own benefit and/or on behalf of and for the benefit of our clients and partners (collectively, the “Services”). In addition, this Privacy Policy explains how we collect, disclose and secure such information, and describes your rights regarding deletion, use, access, correction and sharing of your personal data.

Please read this Privacy Policy carefully to understand how we collect and use your information (including your personal data). By using any of the Services, you agree to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, you cannot use the Services.

Who We Are

AICOSPORTS is a sports and entertainment consulting firm and a hospitality / premium sports and entertainment experience provider. For purposes of this Privacy Policy, AICOSPORTS A.S. is the data controller and is responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:

AICOSPORTS A.S. – Burhaniye – Balıkesir, Turkey
Email: nfo@aicosports.com

In connection with providing Services to you, we may share your personal data with our current clients, other sports and entertainment properties with whom we have agreements or other relationships (collectively, our “Partners”), and other third parties, such as our service providers, as described further below. For more information on how our Partners or such other third parties may use personal data that we share with them in accordance with this Privacy Policy, please review the privacy policy of the applicable Partner or third party. We are not responsible for the privacy policies of other websites or applications, including those of our Partners or other third parties, and we encourage you to read all applicable terms, conditions and privacy policies prior to using other websites and applications.

Types of Information and How We Collect It Personal Data Collected Directly From You or That You Provide Us

When you access or use the Services, we may request certain personal data from you or you may choose to voluntarily provide such personal data to us. Examples of means by which we may collect personal data include:

When you provide such information to us via the Site, mobile applications or other digital channels, by signing up, creating an account, filling out forms or otherwise interacting or engaging with these Services;

When you communicate with us directly by phone or e-mail;

When you subscribe to any newsletters or e-mail messages we produce and distribute;

When you engage in a transaction with or otherwise make a purchase from us via the Site or otherwise (i.e., offline and/or via phone);

When you report a problem or request support in connection with the use of the Services and/or a purchase you have made;

When you participate in any contests, promotions, sweepstakes, surveys or focus groups that we facilitate or administer; and

When you attend any event or experience that we organize, host, promote or otherwise help facilitate.

The types of personal data we collect directly from you will vary depending on the circumstances and context of its collection, but generally may include:

Identity Data such as first name, last name, maiden name, username or similar identifier, title, date of birth, country of residence, language and gender;

Contact Data such as billing or mailing address, e-mail address, telephone number(s) and/or fax number(s);

Financial Data such as bank account and payment card details;

Transaction Data such as details about payments to and from you and other details of products and Services you have purchased from us;

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses; and

Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

Information We Collect Via Automated Technologies or Interactions

We also may collect certain information automatically when you visit the Site or otherwise engage or interact with the Services, including:

Technical Data such as internet protocol (IP)address, your login data, browser type and version, time zone setting and location, geolocation information, browser plug-in types and versions, operating system and platform, other unique identifiers, including mobile device identification numbers, and other technology on the devices you use to access the Site; and

Usage Data such as information about how you use the Site and or engage or interact with the Service, sites you visited before and after visiting the Site, pages you view and links you click on within the Site, including articles, videos, job postings, and photo galleries viewed, information collected through cookies, pixel tags, and other similar technologies, and information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded.

We may use cookies, pixel tags, and similar technologies to automatically collect Technical Data or Usage Data. These technologies are used for analyzing trends, administering the Site, and tracking users’ movements around the Site.

Cookies are small bits of code that are stored by your computer’s web browser and that may automatically identify your browser whenever your computer is used to visit the Site or otherwise engage or interact with the Services. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

By using the Services, you consent to our use of cookies, pixel tags and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies and similar technologies, you may not be able to use the Site fully or interact with certain online products, services or features on the Site.

Information We Collect From Other Sources

AICOSPORTS works closely with a number of third parties, including our Partners, technical service providers, ticketing providers, promotions companies, advertising networks, market research firms, and analytics providers, and may receive information about you from them. Depending on the relationship and activity, such third parties will provide us with certain information that will help us understand how you interact with our Services so we can tailor our marketing and provide better, more personalized Services to you. In some cases, third parties also provide us with information that helps us keep track of transactions, address technical or logistical issues, and prevent fraud.

Some of the most common third-party sources from whom we receive your personal data include:

Our Partners, who we provide services to or otherwise work with to host/ organize premium sports and entertainment events and experiences around the world;

Ticket sellers who sell tickets to sports and entertainment events in collaboration with our Partners or otherwise;

E-Commerce providers and/or payment processors, who facilitate transactions and processing of payments for goods and services you may purchase from us via the Site or otherwise; and

Venues which host events and provide various marketing, advertising, customer support, and security services related to events of our Partners or third parties.

How We Use Your Personal Data and Legal Basis of Processing

We will only use your personal data in accordance with applicable law and this Privacy Policy. In order to use or otherwise process such personal data, applicable law may require us to inform you of the legal basis upon which we will use or otherwise process your personal data. Most commonly, we will use or process your personal data under one or more of the following legal bases:

Performance of Contract – means processing your personal data (including sharing your personal data with third parties) where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract or transaction. For example, processing activities undertaken on the basis of Performance of Contract may include providing you with products, promotions, services, newsletters, and information you request and responding to correspondence that we receive from you inquiring about a purchase you have made or are considering.

Legitimate Interests – means processing personal data (including sharing your personal data with third parties) to the extent it is necessary in pursuing the legitimate interests of our business, including conducting and managing our business, and your interests and fundamental rights do not override those legitimate business interests. For example, processing activities undertaken on the basis of Legitimate Interests may include contacting you via email and otherwise about products, services, and events that we think might be of interest to you, sending you promotional material or special offers on our behalf or on behalf of our Partners and/or their respective affiliates and subsidiaries and other third parties, performing business analyses, providing, maintaining, administering or expanding the Services, or for other internal purposes, in each case, to improve the quality of our business, the Services, and other products and services we offer.

Legally Required – means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, which may vary depending on the laws applicable to us as the party processing the data and you as the data subject. For example, processing personal data on the basis that it is Legally Required may include storing and maintaining your personal data where it is necessary for tax purposes.

Consent – means processing your personal data with your express, or where permitted by applicable law, implied, consent to the means and nature of processing we intend to undertake and communicate to you. For example, consent may be required by applicable law in connection with our processing of special categories of personal data or we may seek your consent in connection with our direct marketing efforts.

Notwithstanding anything to the contrary in this Privacy Policy, we may use aggregated information and/or other de-identified information for any reason at our sole discretion, to the extent permitted by applicable law. How We Share Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share your information. We will share your personal data with third parties only in the ways that are described in this Privacy Policy and in accordance with applicable law.

Service Providers: We may share your personal data with carefully selected third-party service providers that process personal data in connection with their performance of certain functions or services on our behalf, including, without limitation, cloud storage providers, e-commerce providers, payment processors, marketing partners, information technology and/or data security providers, and customer service providers. These service providers are authorized to use your personal data only as instructed by us and as necessary to perform these services for us or on our behalf.

Subsidiaries and Affiliates: We may share your information with members of the AICOSPORTS family, including our subsidiaries and affiliates, to further our and their legitimate business interests and to assist us in providing the Services to you.

Select Business Partners: We may share your personal information with our Partners and other select third-party business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, you may be presented with an opportunity to have certain personal data shared with our Partners or other third-party business partners when you elect to receive marketing offers or other information via e-mail, SMS or other means. We take measures to help ensure that these third parties protect the confidentiality, integrity, and security of any information we share with them; however, we are not responsible for the privacy practices of these third parties.

Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your personal data as part of such transaction.

Administrative or Legal Process: We may disclose your personal data to third parties in order to protect the legal rights, safety, and security of our organization, our affiliates, subsidiaries, business partners, and other users of the Site and the Services, respond to and resolve claims or complaints, prevent fraud or for risk management purposes, and comply with or respond to law enforcement or a similar legal process or request for cooperation made by a government or other entity, whether or not legally required.

Other Parties with Your Consent: We may share personal data with third parties when you provide your consent to such sharing. For example, we may ask your permission to publicly post certain information on the Services that you have shared with us.

Aggregate and De-identified Information: We may share aggregate information and/or other de-identified information, such as demographic and usage statistics, with third parties for any reason at our sole discretion.

We may also allow third parties to place and read their own cookies, pixel tags, and similar technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics.

We Do Not Sell Your Personal Data

We do not sell your personal data to third parties for money. However, we may share your personal data with third parties in a manner that may be deemed a “sale” under applicable data privacy laws. You may opt-out of the sale of your personal data at any time by contacting us at info@aicosports.com. You will be asked to provide certain information to us in order to exercise this option so we can verify your identity and locate your records with us.

Please note that your decision to opt-out of the sale of your personal data may impact the availability and quality of some of the Services provided to you.

Table: Overview of Data Processing

The following table provides an overview of the purpose for which we collect personal data from you, the categories of personal data collected for such purposes, and which of the legal bases we rely on to in order to undertake such processing activities. Please note that we may process your personal data under more than one legal basis depending on the specific purpose for which we are using such personal data. Please contact us at info@aicosports.com if you have questions or would like additional details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose: To register you as a new customer.

Categories of Personal Data: Identity; Contact

Legal Basis for Processing: Performance of Contract

Purpose: To process your purchase and deliver aspects of your purchase, including sending you invoices and managing payments, fees and charges, collecting and recovering money owed to us and/or delivering goods and services you purchase to you.

Categories of Personal Data: Identity; Contact; Financial; Transaction, Marketing & Communications

Legal Basis for Processing: Performance of Contract; Legitimate Interests

Purpose: To manage our relationship with you, including notifying you about changes to our Terms of Use or this Privacy Policy, asking you to provide feedback or take a survey regarding your experience with AICOSPORTS or the Services, and/or providing you with general customer service and communications related to your account and order, including last minute or emergency communications regarding your purchase and/or the associated event.

Categories of Personal Data: Identity; Contact; Profile; Marketing & Communications; Technical

Legal Basis for Processing: Performance of Contract; Legally Required; Legitimate Interests

Purpose: To enable you to participate in a prize drawing, contest, giveaway, survey and/or focus group that we facilitate on our own behalf or on behalf of our Partners.

Categories of Personal Data: Identity; Contact; Technical

Legal Basis for Processing: Legally Required; Legitimate Interests; Consent

Purpose: To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Categories of Personal Data: Identity; Contact; Profile; Marketing & Communications; Technical; Usage

Legal Basis for Processing: Legitimate Interests; Consent

Purpose: To use data analytics to improve the Site, our Services, and related marketing, customer relationships and experiences.

Categories of Personal Data: Technical; Usage

Legal Basis for Processing: Legitimate Interests; Consent

Purpose: To make suggestions and recommendations to you about goods or services that may be of interest to you.

Categories of Personal Data: Identity, Contact, Profile; Technical; Usage

Legal Basis for Processing: Legitimate Interests; Consent

Co-branding

We may offer some Services in connection with one or more of our Partners and/or another third party or parties via a co-branded webpage, including ticket sales, hospitality and/or travel sales or job applications. When you have provided personal data on a webpage that is co-branded with a third party, then that personal data will generally be made available to both us and such third party. Whereas our data practices and your choice options are described in this Privacy Policy, we encourage you to consult the co-branding partner’s privacy policy to ensure that you understand how it intends to use your information and how you may exercise control over it.

E-Mail Marketing and Unsubscribing

When you interact or engage with the Services, we may request to add you to our mailing lists so that you can receive e-mail communications from AICOSPORTS and its Partners. If you provide us with your e-mail address in order to receive communications from AICOSPORTS or its Partners, you can opt-out at any time by using the unsubscribe links at the bottom of such e-mails. Please note that opt-out requests may take some time to be effective.

Your opt-out request will not apply to messages that you subsequently request, that are necessary to perform a contract with you or which are otherwise legally required. For example, we may contact you concerning any purchases you have made with us, even if you opt-out of receiving unsolicited commercial e-mail messages. If you have any questions about a previously made opt-out request, please contact us at info@aicosports.com.

Links To Other Web Sites or Mobile Applications

The Site and/ or other aspects of the Services may contain links to other websites or online services that are operated and maintained by third parties and that are not controlled or otherwise operated or maintained by AICOSPORTS. Such links do not constitute an endorsement by AICOSPORTS of these other websites or online services, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to any such third-party websites, online services or associated content. We are not responsible for the privacy policies, practices or content of such other websites or online services. We encourage you to review the privacy policies of those third-party websites or online services prior to engaging with them.

Security Measures

We have adopted reasonable and appropriate security procedures to help protect against loss, misuse, and unauthorized access to the information you provide to us. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us in connection with the Services, and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

Where We Store Your Information

We operate the Site and the Services primarily from the United States, and as such, we store your information in data centers located in the United States. In addition, we may store, process and transmit your personal data to other locations around the world to in connection with our provision of the Services, and we may use service providers located in both European Community and elsewhere (Turkey) to help us run our Site or to otherwise provide the Services to you.

If we or our service providers transfer any personal data out of the European Economic Area (EEA), it will only be done with the relevant protection being in place. In particular, when your personal data is transferred outside or inside the EEA, we ensure (i) such transfers are limited only to countries which are recognized as providing an adequate level of legal protection by the European Commission or (ii) one of the specific safeguards approved by the European Commission is in place, such as the Standard Contractual Clauses as approved by the European Commission.

Retention of Your Personal Data

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and/or where you have provided your consent to future marketing and other related communications.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we may be required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data (please see “Right to be Forgotten” below for further information). In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Children’s Privacy

The Site and the Services are not directed at or otherwise authorized for use by children under the age of 16, as set forth in our Terms of Use. As such, we do not knowingly collect, use, or disclose personal information from children under the age of 16, except with the express consent of a parent or guardian of such child. The limited circumstances we might need to collect the personal data of a child include if such information is necessary for the performance of a contract with you (e.g., in connection with your purchase of travel-related services). If we are made aware, we have collected personal information from a child under 16 years old in a manner that is inconsistent with this Privacy Policy and/or the Children’s Online Privacy Protection Act, we will delete this information as soon as possible.

Do Not Track

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.

Your Rights With Respect to Your Personal Data

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Depending on laws applicable to you and your personal data, these rights may include:

The Right of Access –This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

The Right of Correction –This enables you to have any incomplete or inaccurate personal data we hold about you corrected.

The Right of Portability –This enables you to obtain a copy of your personal data in a safe and secure way and in a structured and readable format, so that you may use your personal data for your own purposes.

The Right to be Forgotten –This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to certain processing activities (see below). Note, however, that we may not always be able to comply with your request to delete your personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

The Right to Object –This enables you to object to any processing activities we are undertaking with respect to your personal data for direct marketing purposes or where we are processing such personal data on the basis of our legitimate interests, and there is something about your particular situation which makes you want to object to processing on this ground. Please note, our processing of your personal data is required in order to allow us to provide you with certain goods or services, so we will be unable to provide such goods or services to you if you elect to object to such processing.

The Right to Restrict Processing –This enables you to ask us to suspend the processing of personal data we hold about you, for example, if you want us to establish its accuracy or the reason for processing it.

The Right to Withdraw Consent –This enables you to withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so pursuant to applicable law.

If you wish to exercise any of the rights set out above, please contact us at info@aicosports.com. No fee is usually required, meaning you will generally not have to pay a fee to access your personal data (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Changes to this Privacy Policy

Privacy laws and practice are constantly developing. Our policies and procedures are therefore under continual review. We may, from time to time, update this Privacy Policy. Any such changes will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy. The date of the most recent updates to this Privacy Policy are set forth at the top of this Privacy Policy. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

Contact Us and Complaints

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we process your personal data, please contact us using the following contact details:

AICOSPORTS A.S.

Burhaniye- Balıkesir, Turkey

Attn: Privacy Department

E-mail: info@aicosports.com

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