Privacy Policy
Last Updated: February 24, 2023
Welcome to the Versity privacy policy. We are Versity (“Versity”, “we”, “us”, “our”), an Endeavor U, LLC service. WME IMG, LLC (“Endeavor”) is the parent company of the Endeavor group of companies (Endeavor Group) which is comprised of affiliates, wholly owned subsidiaries, joint venture partners, parent or holding companies.
Versity respects your privacy and is committed to protecting your personal data. This Privacy Policy provides information regarding the personal data processed by Versity in relation to (i) individuals who work for, or on behalf of, our business customers (Business Customers), (ii) suppliers or vendors (Suppliers), (iii) business partners, including businesses which cooperate with us in various events (Business Partners).
Additional bespoke notices and supplementary privacy statements may contain further information about how Versity is processing your personal data. In those instances, such privacy notices will be communicated to you separately. These privacy notices may vary among the countries in which we operate to reflect local practices and applicable law requirements.
This Privacy Policy explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
THE CATEGORIES OF PERSONAL DATA WE COLLECT ABOUT YOU
What personal data do we process about you?
We process personal data from and in relation to individuals who are, or who work for or on behalf of or who are representatives of our Business Customers, Suppliers, and/or Business Partners in the following categories:
Business contact and other information (such as job title, department, name of organization and your dealings with Versity on behalf of yourself or the relevant Business Customer, Supplier, Business Partner).
Screening
In addition, in order to comply with legal and regulatory obligations, to protect Versity’s assets and employees/contractors and specifically to ensure that Versity can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business Customers, Suppliers and Business Partners. This screening takes place against publicly available or government-issued sanctions lists and available databases.
The screening does not involve profiling or automated decision making.
THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
For what purposes do we process your personal data?
We process personal data covered by this Privacy Policy for the following purposes:
Business execution - including providing, researching, developing and improving products or services; concluding and executing agreements with Business Customers, Suppliers and Business Partners; recording and settling services, products and materials to and from Versity; managing relationships and marketing such as maintaining and promoting contact with existing and prospective customers, account management, customer service, and development, execution and analysis of market surveys and marketing strategies.
Fraud prevention, audits, investigations, dispute resolution or insurance - including internal and external investigations and audits, litigation and defence of claims.
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.
Security management – including security management for events
Statistical research
WE WILL ONLY PROCESS YOUR PERSONAL DATA WHERE WE HAVE A LAWFUL BASIS TO DO SO
Why do we process your personal data?
- in order to take steps at the request of Business Customers, Suppliers and Business Partners prior to entering into a contract;
- in order for Versity to perform the contracts between Versity and its Business Customers, Suppliers and Business Partners;
- where it is necessary to comply with a legal or regulatory obligation to which Versity is subject;
- where it is necessary for the purposes of the legitimate interests pursued by Versity, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual(s); or
- (only if legally required) with the explicit consent of the individual.
- Communication and marketing
INTERACTING WITH VERSITY THROUGH SOCIAL MEDIA
If you choose to interact with Versity through social media on a Versity administered social media page (Versity Social Media Page) such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in Versity) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to Versity. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. Versity does not track your activity across the different social media sites that you use.
Additionally, to the extent Versity is jointly responsible with a social media platform of a Versity Social Media Page, Versity will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Versity Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
DATA SHARING AND TRANSFERRING
Who will we share your personal data with?
The personal data covered by this Privacy Policy are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
Other companies within the Endeavor Group;
Authorized third party agents, service providers, external auditors and/or subcontractors of Versity; or
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which Versity is subject to or as permitted by applicable local law.
Transfers of your personal data to other countries
Where your personal data has been transferred to companies within the Endeavor Group and/or to authorized third parties located outside of your country, we take organizational, contractual and legal measures to ensure that your personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements.
VERSITY IS COMMITTED TO SAFEGUARDING YOUR PERSONAL DATA
We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to Versity services and we regularly test, assess and evaluate the effectiveness of our security measures.
WHAT ARE THE CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA?
Personal data gathered by Versity for these processes either directly or indirectly are required in order to:
Fulfil legal requirements and/or which is required for entering into a contract with a counter-party and continuing to contract with that counter-party; or
Maintain contact with Business Customers, Suppliers and Business Partners.
Failure to provide us with the information required will negatively affect our ability to communicate with you, or our ability to enter into a contract with a counter-party or continue to contract with a counter-party.
HOW LONG DO WE HOLD YOUR PERSONAL DATA FOR?
With some exceptions which are explained in supplementary privacy statements, any personal data that are required for the purposes of conclusion and execution of agreements with Business Customers, Suppliers and Business Partners or for considering bids or tenders, will be held during the duration of the contractual relationship and up to 7 years after.
In all other cases for the purposes set out above, including personal data gathered as part of any unsuccessful bids to Versity or which relates to the screening against publicly available or government issued sanctions lists or data for organising events and managing security, such personal data are held for no longer than 3 years after it was first gathered.
In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
We aim to keep our information as accurate as possible. You may have certain rights in relation to your personal data which may include the following:
access to your personal data;
correction or deletion of the personal data (but only where they are no longer required for a legitimate business purpose);
that you no longer receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner;
that the processing of your personal data is restricted; and/or
that you receive personal data that you have provided to Versity, in a structured, digital form to be transmitted to another party, if this is technically feasible.
If you have any issues, queries or complaints regarding the processing of your personal data please contact dataprivacy@img.com. If you are unsatisfied with the handling of your personal data by Versity, then you have the right to lodge a complaint to your local data protection authority (if there is one).
CHILDREN
We do not knowingly collect information from children who are under 13 years old. If you are a parent or guardian of a child who is 13-16 years old and using our Services, please send us an email at dataprivacy@img.com to opt in to the use of your personal information or request deletion of any personal information we may have collected about the child. If you are a parent or guardian of a child who is under 13 years old and using our Services, please contact us to arrange for deletion of any personal information we may have collected about the child.
ADDITIONAL NOTICE FOR CALIFORNIA AND VIRGINIA RESIDENTS
This Additional Notice for California and Virginia Residents supplements the information contained in the Privacy Policy and applies to: California residents from whom we collect Personal Information as a business under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 and its implementing regulations, as amended or superseded from time to time (“CCPA”) information subject to California’s Shine the Light law (Cal. Civ. Code § 1798.83) (“Shine the Light”); and Virginia residents from whom we collect Personal Data as a controller under the Virginia Consumer Data Protection Act as amended or superseded from time to time (“VCDPA”).
CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
Information Collection and Use
In the last 12 months, we collected the following categories of personal information:Business contact and other information (such as job title, department, name of organization and your dealings with Versity on behalf of yourself or the relevant Business Customer, Supplier, Business Partner). For more details about the personal information we collect, including the categories of sources, please see the Categories of Personal Data section above.
We collect this information for the business and commercial purposes described in the Purposes for Which we Process Your Personal Data section above. We share this information with the categories of third parties described in the Data Sharing and Transferring section above.
Disclosure of Personal Information
We do not sell or otherwise disclose your personal information to any third parties for any monetary consideration. We may disclose your personal information to companies, organizations, and individuals inside and outside of our group as listed in the “Data Sharing and Transferring” section
Your California Rights
As a California resident you may exercise the following rights regarding personal information about you, subject to our ability to verify your request and certain other limitations:
Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information collected in the preceding 12 months or at your option since January 1, 2022;
Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to us. Certain information that we hold about you may not be deleted. We are not permitted to delete information that we need to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our company;
Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by us, taking into account the nature of the personal information and the purposes of processing the personal information;
Right to Opt Out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context advertising;
Right to Limit Processing of Sensitive Personal Information: You have the right to tell us not to process sensitive personal information except for the purpose for which it was originally collected.
Non-Discrimination: California law prohibits discrimination against you for exercising your privacy rights.
You may exercise any of the above rights by contacting us at dataprivacy@img.com or calling us at 1-866-983-0571.
California’s Shine-the-Light Law
California’s Shine the Light law permits California residents to request and receive, once per calendar year and free of charge, information about our sharing of your personal information (if any) with third parties for their own direct marketing use. If you are a California resident and would like to make such a request, please email dataprivacy@img.com or call us at 1-866-983-0571.
In your request, please include your name and attest to the fact that you are a California resident and provide a current California address. We may ask you for additional information to confirm your identity before responding to this request.
VIRGINIA CONSUMER DATA PROTECTION ACT (“VCDPA”)
Your Virginia Rights
If you are a Virginia resident, you may exercise the following rights with respect to your Personal Data:
Right to confirm whether or not we process your Personal Data and request access to such data;
Right to delete Personal Data you have provided to us or that we have obtained about you, subject to exceptions;
Right to correct inaccuracies in your Personal Data;
Right to opt out of the processing of your Personal Data for purposes of: (i) targeted advertising; (ii) the sale of Personal Data; and (iii) the processing of your Personal Data for certain types of profiling in furtherance of decisions that produce legal or similarly significant effects;
Right to obtain a copy of your Personal Data in a portable and, to the extent technically feasible, readily usable format;
Right to appeal any decision with regard to your privacy request.
Please note that there are exceptions and limitations to each of the rights listed above. To exercise your Virginia privacy rights described above, please submit your request to dataprivacy@img.com or call us at 1-866-983-0571.
COOKIES AND SIMILAR TECHNOLOGIES
Versity may use cookies and similar technologies that aim to collect and store information when you visit a Versity website. This is to enable Versity to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website. You can control and manage your cookies preferences by adjusting your browser settings or using the Versity cookies preference tool on Versity websites - for more information, please refer to the Versity Cookie Policy.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be changed over time. You are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last updated in February 2023