PRIVACY
POLICY
Version 2.5 - Effective Date: November 19, 2025
1. INTRODUCTION
This Privacy Policy explains how SPARCKS INC. ( FANLINC ,
"Company," "we," "us," or
"our") collects, uses, discloses, and protects personal
information through the FANLINC Application, yourfanlinc.com website, and
related services (collectively, the "Platform"). The Platform
operates as a social network connecting fans with athletes through video
content, live casting, and direct engagement features.
We are committed to protecting your privacy and handling
your personal information in accordance with applicable privacy laws including
the Personal Information Protection and Electronic Documents Act ( PIPEDA )
in Canada, the General Data Protection Regulation ( GDPR ) in the
European Union, and the California Consumer Privacy Act ( CCPA ) and
other U.S. state privacy laws.
This Privacy Policy forms an integral part of our End User
License Agreement and Additional Terms. By using the Platform, you consent to
the data practices described in this policy. If you do not agree with our
privacy practices, please do not use the Platform.
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
We collect information you voluntarily provide when using
the Platform. This includes account registration information such as name,
email address, date of birth, and username. For Player Users, we additionally
collect league affiliation, team information, player identification numbers,
and verification documentation.
The Platform collects profile information including
biographical details, profile pictures, and user preferences. Content you
create comprises videos, photos, comments, reactions, and live cast recordings.
Communication data includes messages between users, support inquiries, and
feedback submissions.
2.2 Information Collected Automatically
When you use the Platform, we automatically collect certain
technical information. Device information includes device type, operating
system, unique device identifiers, mobile network information, and IP address.
Usage data encompasses app feature usage, content viewing patterns, interaction
metrics, and session duration. Location information may be collected with your
consent, including precise location for location-based features and general
location derived from IP address. Performance data includes crash reports,
performance metrics, and error logs necessary for Platform improvement.
2.3 Information from Third Parties
We may receive information about you from third parties
including service providers who assist with identity verification, leagues and
teams for Player User verification purposes, other users who may reference you
in content or communications, and service providers. We also collect
information from publicly available sources for Player Users, such as official
league statistics and publicly posted team rosters.
2.4 Special Categories of Data
For users in the European Union, we recognize that certain
information constitutes special category data under GDPR. This may include
health information if voluntarily disclosed by Player Users discussing injuries
or fitness, and potentially racial or ethnic origin visible in profile pictures
or videos. We process such data only with your explicit consent or where
otherwise permitted by law. Player Users discussing injuries or health
conditions do so voluntarily, and such information is not required for Platform
participation.
3. HOW WE USE YOUR INFORMATION
3.1 Platform Operations
We use your information primarily to provide and improve
the Platform services. This includes creating and managing your account,
facilitating connections between fans and athletes, enabling content creation
and sharing features, powering live casting functionality, and providing
customer support. We also use information for Platform optimization including
personalizing your experience, recommending relevant content and connections,
improving Platform features and functionality, and conducting analytics to understand
usage patterns.
3.2 Safety and Security
Your information helps us maintain a safe and secure
environment through identity verification, particularly for Player Users,
content moderation and community guidelines enforcement, detection and
prevention of fraud, abuse, and security incidents, and compliance with legal
obligations and law enforcement requests. For Minor Athletes, we implement
additional protective measures using age information to restrict certain
interactions and enhance moderation oversight.
3.3 Communications
We use your email or other contact information that you
provided to us to send Platform-related communications including service
announcements and updates, security alerts and account notifications, responses
to your inquiries and support requests, and marketing communications where you
have provided consent. Player Users may receive additional communications
regarding verification status, monetization opportunities, and league-related
matters.
3.4 Legal and Compliance
We process information as necessary to comply with legal
obligations, respond to legal process and government requests, enforce our
terms and agreements, protect our rights and property, protect the safety of
users and the public, and investigate potential violations of our terms or law.
This includes cooperation with league investigations regarding Player User
conduct where appropriate.
3.5 Business Operations
Information supports our business operations including
analyzing Platform performance and user engagement, developing new features and
services, conducting research and development, and facilitating corporate
transactions if applicable. Aggregated and de-identified data may be used for
industry research and reporting that does not identify individual users.
4. HOW WE SHARE YOUR INFORMATION
4.1 Sharing with Other Users
Certain information is shared with other Platform users by
design. Your public profile information is visible to all users. Content you
post is shared according to your privacy settings. Interactions with other
users including comments and reactions are visible based on context. Player
Users' status is displayed publicly. During live casts, participant information
is visible to viewers.
4.2 Service Providers
We share information with trusted service providers who
assist in Platform operations including cloud storage and hosting providers,
content delivery networks, identity verification services for Users and Player
Users, email and communication platforms, analytics and performance monitoring
services, and customer support tools. These providers are contractually
obligated to protect your information and use it only for the services they
provide to us.
4.3 Legal and Safety Disclosures
We may disclose information when required by law including
in response to subpoenas, court orders, or other legal process, to comply with
applicable laws and regulations, to respond to lawful requests from public
authorities, and to protect the rights, property, or safety of FANLINC and its
staff, our users, or others. For Minor Athletes, this includes reporting
suspected abuse to appropriate authorities.
4.4 League and Team Coordination
For Player Users, we may share limited information with
leagues and teams for verification of eligibility and good standing,
investigation of potential policy violations, and coordination of official
partnership activities. Such sharing is limited to information necessary for
the specific purpose and subject to appropriate confidentiality agreements.
4.5 Business Transfers
In the event of a merger, acquisition, reorganization,
bankruptcy, or sale of assets, your information may be transferred as part of
that transaction. We will notify you via email and Platform notification of any
change in ownership or use of your personal information.
4.6 Aggregated and De-identified Information
We may share aggregated or de-identified information that
cannot reasonably be used to identify you. This includes Platform usage
statistics, demographic insights, and trend analyses that help improve the
hockey community's understanding of fan engagement patterns.
4.7 With Your Consent
We may share your information for other purposes with your
explicit consent. This includes sharing Player User content with media partners
for promotional purposes.
5. YOUR RIGHTS AND CHOICES
5.1 Access and Portability
You have the right to access personal information we hold
about you. You can view your data through the Platform or make a request to
download your data by contacting our privacy team.
5.2 Correction and Update
You maintain the ability to correct or update your personal
information through your account settings on the Platform. For information that
cannot be self-corrected, contact our support team. Player Users requiring
updates to verification information should provide appropriate documentation.
5.3 Deletion
You have the right to request deletion of your personal
information, subject to certain exceptions. We may retain information as
necessary for legal compliance, safety investigations, enforcement of our
agreements, or legitimate business purposes. When you delete content, it may
persist in backup systems for a limited period. Fan interactions with deleted
content may remain to preserve Platform integrity.
5.4 Restriction and Objection
You may request that we restrict processing of your
information in certain circumstances. You have the right to object to
processing based on legitimate interests or for direct marketing purposes.
These rights may be limited where we have compelling legitimate grounds for
processing or legal obligations.
5.5 Consent Withdrawal
Where processing is based on consent, you may withdraw
consent at any time. This does not affect the lawfulness of processing before
withdrawal. Withdrawing consent may impact your ability to use certain Platform
features, up to and including complete loss Platform functionality,
particularly for Player Users.
5.6 Marketing Communications
You can opt out of marketing communications through the
unsubscribe link in emails or your account settings. Service-related
communications necessary for Platform operation cannot be opted out of while
maintaining an account.
5.7 Location Services
You can disable location services through your device
settings. This may impact location-based features but will not affect basic
Platform functionality.
5.8 California Privacy Rights
California residents have additional rights under the
California Consumer Privacy Act including the right to know categories and
specific pieces of personal information collected, the right to delete personal
information subject to exceptions, the right to opt out of the sale of personal
information (we do not sell personal information), and the right to
non-discrimination for exercising privacy rights.
5.9 European Privacy Rights
If you are located in the European
Economic Area, you have additional rights under GDPR including the right to
lodge a complaint with your local supervisory authority, the right to data
portability in structured, commonly used formats, and enhanced rights regarding
automated decision-making and profiling.
6. CHILDREN'S PRIVACY
6.1 Users Under 13
The Platform requires users to be at least thirteen years
old. We do not knowingly collect personal information from children under 13.
If we learn we have collected or received personal information from a child
under 13 without verification of parental consent, we will delete that
information. If you believe we might have any information from or about a child
under 13, please contact us at privacy@yourfanlinc.com.
6.2 Users aged 13-17
Users between thirteen and seventeen require verifiable
parental consent in certain jurisdictions. Enhanced privacy protections apply
including restricted data sharing, limitations on targeted advertising, and
additional safeguards for interactions with adult users.
6.3 Minor Athlete Protections
Player Users under eighteen receive additional protections
including enhanced privacy settings by default, restricted visibility of
personal information, limitations on direct messaging with adult users, and
priority content moderation. We do not share Minor Athlete information for
commercial purposes without explicit parental consent.
7. DATA SECURITY
7.1 Security Measures
We implement comprehensive security measures to protect
your information including encryption in transit and at rest, secure data
storage with access controls, employee training on data protection, and
incident response procedures. Player User verification documents receive
enhanced security given their sensitive nature.
7.2 Data Breach Notification
In the event of a data breach affecting your personal
information, we will notify you as required by applicable law. Notification
will include the nature of the breach, types of information involved, steps
taken to address the breach, and recommendations for protective measures. We
maintain incident response procedures to minimize impact and restore security
quickly.
7.3 Account Security
You play a crucial role in maintaining account security.
Choose a strong, unique password. Do not share account credentials and be
cautious of phishing attempts. Report suspicious activity immediately. Player
Users should be particularly vigilant given the public nature of their
profiles.
8. DATA RETENTION
8.1 Retention Periods
We retain personal information for as long as necessary to
provide Platform services and fulfill the purposes outlined in this policy.
Account information is retained while your account is active and for a
reasonable period thereafter. Content may be retained longer for legal, safety,
or legitimate business purposes. Player User content may be archived for
historical significance to the Platform community.
8.2 Deletion Practices
When information is no longer needed, we either delete or
de-identify it. Deletion from active systems is followed by removal from backup
systems according to our backup rotation schedule. Some information may be
retained in aggregated or de-identified form for analytics and improvement
purposes.
8.3 Legal Preservation
We may preserve information beyond standard retention
periods when subject to legal hold obligations, government investigations, or
litigation requirements.
9. INTERNATIONAL DATA TRANSFERS
Your information may be transferred to and processed in
countries other than your country of residence, including Canada and the United
States. These countries may have data protection laws different from your
jurisdiction. We ensure appropriate safeguards are in place for international
transfers.
10. COOKIES AND TRACKING TECHNOLOGIES
10.1 Types of Cookies
We use various cookies and tracking technologies including
session cookies that expire when you close the app, persistent cookies that
remain until deleted, first-party cookies set by us, and third-party cookies
from service providers. These serve purposes including authentication,
preferences, analytics, and security.
10.2 Cookie Management
You can manage cookie preferences through your device
settings. Disabling certain cookies may impact Platform functionality. The
Platform respects Do Not Track signals where required by law.
10.3 Analytics and Advertising
We use analytics services to understand Platform usage and
improve services. In the future, we may use advertising technologies for
marketing purposes where you have consented. Player Users' content may be used
for Platform promotion with appropriate consent. We do not use behavioral
advertising targeted at users under eighteen.
11. LEGAL BASIS FOR PROCESSING (GDPR)
11.1 Contractual Necessity
We process information necessary to fulfill our contract
with you, including providing Platform services, managing your account, and
enabling features you request. For Player Users, this includes verification and
potential future monetization services outlined in Additional Player Terms.
11.2 Legitimate Interests
We process information based on legitimate interests
including Platform safety and security, service improvement and development,
and fraud prevention and legal compliance. We conduct balancing tests to ensure
our interests do not override your privacy rights.
11.3 Legal Obligations
We process information to comply with legal obligations
including regulatory requirements, law enforcement requests, and safety
reporting obligations. For Minor Athletes, this includes mandatory reporting of
suspected abuse or exploitation.
11.4 Consent
We obtain consent for processing including marketing
communications, location services, and special category data processing.
Consent is freely given, specific, informed, and can be withdrawn at any time.
11.5 Vital Interests
In rare circumstances, we may process information to
protect vital interests including preventing imminent physical harm or
responding to medical emergencies disclosed during Platform use.
12. AUTOMATED DECISION-MAKING
12.1 Content Moderation
We use automated systems to assist with content moderation
including detecting policy violations and identifying potentially harmful
content. Human review is available for significant decisions affecting your
account. You can request human review of automated moderation decisions.
12.2 Recommendations
The Platform uses algorithms to recommend content and
connections based on your interests, behavior, and location. These
recommendations do not have legal or similarly significant effects. You can
influence recommendations through your interactions and preference settings.
12.3 No Profiling for Significant Decisions
We do not use fully automated decision-making for decisions
with legal or similarly significant effects. Player User verification always
involves human review. Future monetization eligibility decisions will also involve
human evaluation.
13. PRIVACY POLICY UPDATES
13.1 Notification of Changes
We will notify you of material changes to this Privacy
Policy through Platform notification and email to your registered address.
Changes will be effective upon posting unless otherwise specified. Your
continued use after changes constitutes acceptance.
13.2 Historical Versions
We maintain archives of previous Privacy Policy versions
for reference. You may request copies of historical versions that applied
during your Platform use.
14. CONTACT INFORMATION
For privacy-related inquiries, requests, or complaints:
SPARCKS INC.
Attention: FANLINC Privacy Officer
1608 Sudbury Road.
Sudbury, ON.
P3G 1A8
Email: privacy@yourfanlinc.com