vIQtori^sm PRIVACY POLICY

What Personal Information is collected and how?

We collect Personal Information about you that you provide to us through the Site, automatically collected information, and information from other sources in order to provide our services. The information includes what you provide to us through the Site like your name, email address, company name or school name, phone number, vIQtori account password and your mailing address as well as automatically collected information like your IP address, type of browser, date and time you access the Site and any website address that may have linked you to our Site and other de-identified traffic data. We may request additional Personal Information in order to provide services such as your date of birth or taxpayer identification number, and request documents like a signed written consent to use your academic records, athletic performance statistics, and credit card information. If you are under 18, we will also collect the names of your parents or legal guardian, their email address and phone number, along with their approval of your use of the Site and services. In compliance with the Children's Online Privacy Protection Act (COPPA), we collect parent or guardian contact information — including phone numbers — solely for the purpose of obtaining verifiable parental consent before activating a minor's account. We may contact parents or guardians via email and/or SMS text message to request and confirm consent. Parent and guardian phone numbers are stored securely and are not used for marketing purposes. Message and data rates may apply. Reply STOP to any vIQtori text message to opt out, or reply HELP for assistance.

We may also receive and store information about your use of the Site including pages visited and when, the source of the request, your browser type, and other information about your engagement with the Site and services. We may also collect your IP address and your Device Identifier. A Device Identifier is a number automatically assigned to the computer, cell phone or tablet used to access the Internet. We may associate your Device Identifier with the personal information you provide.

In some cases, you may provide information to us about other people, such as employees, students, team members, family members, and athletes. For example, if you create an athlete profile or seek parental consent through our services. We may also receive data about students from their coaches, schools, or team members, as more fully described in the athlete profile page section. We collect and protect this information in accordance with an agreement with the students' schools.

How is Personal Information used?

We use your Personal Information to:

• Provide, operate, maintain, and improve the Site and Service;
• Create and manage user accounts;
• Process subscriptions, registrations, payments, and transactions;
• Facilitate communications between athletes, parents, Institutions, Sponsors, vendors, and authorized users;
• Provide customer support and respond to inquiries;
• Verify identity and maintain account security;
• Provide recruiting, NIL, educational, compliance, performance analytics, and career-planning services;
• Conduct research, analytics, quality assurance, and product improvement activities;
• Detect, investigate, prevent, and respond to fraud, abuse, security incidents, and violations of our Terms;
• Comply with legal obligations and enforce our rights;
• Communicate with users regarding account activity, updates, and Service-related matters; and
• Carry out any other purpose disclosed at the time information is collected or with your consent.

We may send marketing emails and push notifications where permitted by law and where you have provided the necessary consent.

SMS/text messages sent by vIQtori are limited to transactional, informational, operational, authentication, parental consent, security, and account-related communications for users who have expressly opted in to receive such messages.

SMS Messaging and Mobile Information

By providing your mobile phone number and affirmatively opting in through a vIQtori SMS consent form, you consent to receive SMS messages from vIQtori related to account notifications, parental consent verification, authentication and security codes, operational alerts, and other platform-related communications.

Message frequency varies based on your use of the Service. Message and data rates may apply.

You may opt out of SMS communications at any time by replying STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, or QUIT to any message. For assistance, reply HELP or INFO or contact support@viqtori.com.

Consent to receive SMS messages is not a condition of purchase, registration, subscription, or use of the Service.

SMS consent records may include the date and time of consent, consent language presented, IP address, device information, and source of consent.

No mobile information, phone numbers, SMS consent data, or text messaging opt-in information will be sold, rented, shared, transferred, disclosed, or otherwise provided to third parties or affiliates for marketing or promotional purposes.

All categories of personal information described in this Privacy Policy exclude text messaging originator opt-in data and consent; such information will not be shared with any third parties except as necessary to provide messaging services through our service providers, comply with applicable law, protect our legal rights, or fulfill services specifically requested by the user.

Lawfulness of the processing

Lawfulness of the processing is one of the main principles relating to processing of your Personal Information — we apply the following legal processing grounds:

• Processing is necessary for the purposes of our legitimate interests like improving the quality of the Site and our services.
• Processing is necessary for compliance with our legal obligations or that is otherwise lawful under applicable data protection laws.
• You have given consent.

This policy does not restrict what we do with aggregated, de-identified, or anonymized information that we collect which we may combine with information from other sources for purposes described in this policy.

How is Personal Information shared?

To be able to provide the Site and improve our operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your Personal Information externally. Parties we might share data with include Site hosting services, e.g., for managing the Site and/or underpinning technology for the Site.

Whenever we share Personal Information internally or with third parties, we have appropriate safeguards in place in accordance with applicable data protection laws. As required under applicable law, third parties are required to use appropriate safeguards to protect Personal Information and they can only access Personal Information that is necessary for performing their specific tasks. Some circumstances in which we may disclose your Personal Information include these categories of recipients: our contractors, our vendors, Institutions, Sponsors, advertising partners, third parties in connection with a sale or business transaction involving vIQtori, and other third parties with your consent.

If you create an athlete profile page you will provide us with and share with coaches, team administrators, recruiters, Institutions, and Sponsors information including: name, user ID, home and email addresses, phone number, school (name and location), graduation year, GPA, ACT/SAT scores, transcripts, parent/guardian information, age, birth date, photograph, height, weight, jersey number, social media handle, sports position, athletic performance scores, speed and strength information, sports awards, short biography written by the athlete, any educational facility or organization you are associated with, and other athlete profile information, as may be updated from time to time.

Notwithstanding anything else in this Privacy Policy, mobile phone numbers, SMS consent records, and text messaging opt-in information will not be shared, sold, rented, transferred, disclosed, or otherwise provided to third parties or affiliates for marketing or promotional purposes.

How is Personal Information stored and for how long?

We are committed to keep your data secure. Any Personal Information that you provide to us and from which you can be identified is stored securely and confidentially and is processed in accordance with the applicable law. We employ commercially reasonable technical and organizational measures to protect against unauthorized or unlawful processing of your Personal Information.

We store your Personal Information for one year after you terminate your account except for transaction history and legal documents which we retain for longer periods.

How is Personal Information protected?

We follow generally accepted industry standards to protect the Personal Information you submit to us, but no method of transmission or storage is 100% secure so we cannot guarantee your Personal Information is absolutely secure. However, we will not share, give away, sell, rent or trade your Personal Information other than what is described in this Policy. In addition, we limit access to Personal Information by our employees, contractors, and agents to those who need it to perform their job functions.

What rights do I have with my Personal Information?

Your rights include the following:

• Right of access ("an overview of your Personal Information"): the right to get an overview of your Personal Information that we process.
• Right to rectification ("correct your Personal Information"): if your Personal Information is inaccurate or incomplete, the right to ask us to rectify or complete your Personal Information.
• Right to erasure ("right to be forgotten"): the right to request that we delete your Personal Information to the extent permitted by applicable law. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if processing is necessary for the performance of a contract.
• Right to data portability ("transfer your Personal Information"): the right to ask us to transfer your Personal Information directly to you. This applies to certain Personal Information if processed by automated means and with your consent or based on a contract you have with us. On your request, and where technically feasible, we will transfer your Personal Information to another party of your choice.
• Right to restrict processing: the right to request that we restrict or stop the processing of your Personal Information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Right to object: the right to object to the processing of your Personal Information. The reasons for objection should relate to your particular situation and be related to a processing based on the legitimate interest condition. We will then no longer process the Personal Information, unless we can demonstrate compelling reasons otherwise. In certain circumstances you have the unconditional right to object; for instance, in the context of direct marketing activities.
• Right to withdraw consent: the right to withdraw your consent to the processing of your Personal Information at any time; for instance, after you consented to keeping you informed about the Site, you have the right to withdraw this consent at any time.

To exercise your rights and/or for any other questions about the handling of your Personal Information, please see the "How you can contact us" section below.

How are cookies used?

"Cookies" are small files which might be stored on your computer or mobile device and are used to enhance the functionality of websites and mobile applications. We use cookies to optimize our Site and analyze Site traffic and Site use, including how and when you access and use the Site. We collect your IP address, internet service provider, device information (such as your mobile device ID, manufacturer, and model), version information, and operating system type. We do not use this type of information to identify you but rather aggregate it to analyze how this Site is used and gather demographic information to tailor the Site and display content according to preferences.

We may use Cookies belonging to one of the four categories listed below:

• Necessary Cookies — these mandatory Cookies are needed for the Site to function properly.
• Functional Cookies — these Cookies add additional functionality to the Site.
• Performance Cookies — these Cookies support analytics that help us to improve the Site's functionality and user experience.
• Interest Cookies — these Cookies can be applied to collect insights about you to serve personalized content and advertising to you on our Site and other websites.

Linked Websites

Our Site may contain links to external third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of Personal Information collected through other websites. We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website's own policies. Please review the privacy notices posted on the other websites that you access through this Site to understand what information they collect.

Educational Records and Student Information

Certain information uploaded to the Service may constitute educational records, student information, or other protected information under applicable law.

Institutions, coaches, administrators, parents, and users are responsible for ensuring they possess all necessary permissions, authorizations, parental consents, and legal rights to provide such information to vIQtori.

vIQtori processes such information solely as authorized by users and Institutions and in accordance with applicable law.

AI, Analytics, and Automated Processing

The Service may utilize artificial intelligence, machine learning, predictive analytics, and automated decision-support technologies to generate insights, recommendations, rankings, projections, valuations, recruiting benchmarks, career guidance, and other informational outputs.

These outputs are generated using information supplied by users and third parties and may not always be accurate, complete, or current.

Users should independently evaluate all information generated by the Service before relying upon it for any decision.

How you can contact us

If you have any questions about how we process your Personal Information or if you want to exercise one of your rights, you can contact us by emailing support@viqtori.com. In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.

No Sale of Personal Information

We have not sold any Personal Information of a California resident in the past 12 months and we will not do so in the future. We have not and will not sell the Personal Information of minors under the age of 18 without affirmative authorization. California residents also have the right to request that we limit or stop the "selling" (broadly defined to include some types of sharing) of their Personal Information under certain circumstances.