Last updated: [October 5, 2022]
- Pickleball OpCo LLC
- Pickleball Brackets OpCo LLC
- Pickleball Holdings LLC
- Pickleball TopCourt LLC
- PPA Tour Operations HoldCo LLC
- “Personal Information” means information or data that directly or indirectly identifies, describes, relates to or is reasonable capable of being associated with or linked to a particular individual, consumer or household. “Personal Information” includes information or data that would be considered “personal information” or “personal data” under applicable data protection laws and regulations.
- “Services” means:
- our sales and provision of pickleball-related goods, content, subscriptions and other offerings, to individuals and organizations (collectively, “Products”);
- our hosting, management and support of pickleball-related brackets, tournaments and events;
- the information provided by us through our Sites;
- our marketing and business development activities, including any social media properties we create and emails that we send (collectively, “Marketing Activities”); and
- all other services, publications and activities owned, controlled or otherwise made available or performed by us.
- “Sites” means our websites, including those available at pickleball.com, pickleballbrackets.com, pickleballcentral.com, pickleballtournaments.com and topcourt.com.
- an individual who engages with our Services, such as by purchasing Products, competing in a bracket or participating in an event that we support;
- an individual such as an employee or contractor of one of our actual or prospective customers;
- another user or recipient of beneficial use of our Services; or
- a visitor to our Sites.
2. Information we Collect and Receive
We collect Personal Information directly from individuals, from third parties, and automatically through the Services and Sites. We collect the following categories of information, which may be considered Personal Information when maintained in an identifiable format. The applicable Personal Information is also summarized in Annex 1 below.
- User account information: When you engage with our Services, you may create or access your user account via the Sites, which may include personal information such as (1) your account log-in credentials; (2) your contact information, such as full name, nickname, email address, phone number, and other similar identifying information; (3) your social media handles and linked accounts; (4) information relating to your participation in pickleball matches, such as age, date of birth, gender, emergency contact information, height, dominant hand, tournament and bracket status, t-shirt size, club participation, and association memberships; and (5) your pickleball interests, playing preferences, skill level / areas of improvement, favorite players and other similar pickleball-related information.
- Content and information submitted through the Services: When a user accesses or receives the Services, including through use of the Products, the user may provide information to us in connection with their use of such Services.
- Content and information submitted through the Sites: When a user participates in interactive features on the Sites, the user may provide information to us, including without limitation through submission of surveys, “contact us” forms, customer support tickets or other forms; participation in contests, gift cards, rewards and affiliate programs; and similar activities.
- Automated technical usage data: When a user accesses the Services (including through use of the Products) or the Sites, we automatically generate and retain records of how the user interacts with the Services and Sites. The generated information may include information such as your IP address, device identifiers, device information (such as operating system type or browser type), cookies, referring and exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, crash data, and other similar technical data. We may use technologies such as cookies and/or scripts to collect this information. Please see the “Cookies Notice” section below for further information.
- Communications: When you communicate with us (via email, phone, through the Services or Sites, or otherwise), we may maintain a record of your communication.
- Business contact information: We may collect or receive contact information about actual and prospective users, customers, vendors, contractors, business partners and other similar third parties, which may include full name, email address, phone number, company, job title, and other similar identifying information.
- Payment information: When a customer purchases Products and Services, we may receive, process and retain payment, shipping and recipient information relating to the transaction. We may also utilize third-party payment processors who may provide us with part or all of the applicable payment information.
- Location information: We may receive information about an individual’s approximate physical location, such as city and country, when they provide such information to us or as determined based on the individual’s IP address, your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.
- Actual and prospective employees: When an individual applies for employment with us, or becomes our employee, we collect information relating to that individual’s contact details, suitability for employment, background, employment history, salary and payment details, and other similar information.
- Information collected from third parties or public sources: We may receive information from third-party sources, such as business partners, marketing service providers, third-party data aggregators, or publicly available sources, in order to make our own information more accurate and useful. Such information may include an individual’s full name, email address, phone number, company, job title and other contact information.
We do not collect, in any automated manner, any special categories of sensitive Personal Information.
We also collect and process other types of information and data which does not constitute Personal Information. For example, we may de-identify and aggregate certain Personal Information we collect such that the information no longer identifies, and cannot any longer reasonably be linked to, a particular user or individual. We may use this information to improve our Products, Services and Sites, to analyze trends, to create market research, and for other development, marketing, research and statistical purposes, and we may disclose such de-identified information to third parties for these and purposes.
3. Purposes and Legal Bases for Use of Personal Information
We use the Personal Information we collect for our legitimate business interests, which include the following purposes:
- Providing the Services and Sites: To perform and provide the Services and the Sites; to authorize and manage access to the Services and the Sites; to communicate with you about your use of the Services and the Sites, respond to your inquiries, and provide troubleshooting; to perform essential business operations; and for other purposes to support users and customers and enable their use of the Services and the Sites.
- Enabling user account management across the Sites: To enable you to receive and access the Services via an integrated user account across our Sites and affiliated entities.
- Performing contractual obligations: To perform our contracts with users, customers and suppliers, and to satisfy contractual necessity to conduct our operations and provide the Services and Products that we offer.
- Sales and business engagement: To inform actual and prospective users and customers about the Services which they have purchased, in which they have indicated an interest or which we determine may be of interest to them; to respond to questions and requests; to provide customer service; and to provide account and subscription notices, including invoices, expiration and renewal notices.
- Personalization: To tailor the content and information that we may send or display to you via the Services and the Site; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences.
- Marketing and promotions: To perform marketing, contests and promotions for the Services and the Sites, such as to send news and newsletters, special offers, and promotions; to conduct surveys and similar inquiries; or to otherwise contact individuals about the Services or other information we think may interest them.
- Advertising: To provide targeted advertising on the Sites and third-party sites; and to measure the effectiveness and reach of ads and services (including in particular geographies and including through third-party advertising networks and services).
- Analytics and development: To gather metrics to better understand how users access and use the Sites and the Services; to evaluate and improve the Services, the Sites, and our Products, including through personalization; to improve the content and layout of the Sites, such as through analysis of the click paths used to access certain information within the Sites; and to develop new Products, Services and websites.
- Compliance: To comply with legal obligations and requests, such as to comply with laws that compel us to disclose information to public authorities, courts, law enforcement or regulators, and to maintain records for a certain period.
- Business and legal operations: To conduct our general business and legal operations, such as accounting, record-keeping, and other business administration purposes; and as necessary to establish, exercise and defend (actual and potential) legal claims.
The following legal bases for processing Personal Information apply to the foregoing purposes (see “European Economic Area, United Kingdom and Switzerland Residents Privacy Rights” for more information):
|Purposes of Processing (see above)||Legal Bases of Processing|
|Providing the Services and Sites||Our legitimate business interestsWhere necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)Compliance with lawAs necessary to establish, exercise and defend legal claims|
|Performing contractual obligations||Our legitimate business interestsWhere necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)Compliance with lawAs necessary to establish, exercise and defend legal claims|
|Sales and business engagement||Our legitimate business interestsWhere necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)Compliance with lawAs necessary to establish, exercise and defend legal claims|
|Personalization||Our legitimate business interests|
|Marketing and promotions||Our legitimate business interestsWith your consent|
|Advertising||Our legitimate business interestsWith your consent|
|Analytics and development||Our legitimate business interests|
|Compliance||Our legitimate business interestsCompliance with lawAs necessary to establish, exercise and defend legal claims|
|Business and legal operations||Our legitimate business interestsCompliance with lawAs necessary to establish, exercise and defend legal claims|
|Prevent misuse||Our legitimate business interestsCompliance with lawAs necessary to establish, exercise and defend legal claims|
4. How we Share and Disclose Personal Information
We share Personal Information with the following categories of recipients and as set forth below:
- Tournaments and brackets: We may make publicly available certain of your Personal Information as applicable when you participate in pickleball-related tournaments and brackets that we host, manage or support, and may share it with third party tournament directors, administrators and associations, as well as providers and management services companies who also host, manage or support such tournaments and brackets.
- Integrations: If you (or third party entities who separately processes your Personal Information) enable a technical integration with our Services or Sites, we may share certain of your Personal Information in connection with the operation of such integration.
- Corporate affiliates: We may share your Personal Information with our corporate affiliates that are subject to this policy.
- Business transfers: When applicable, we may share your Personal Information in connection with an actual or proposed substantial corporate transaction, such as the sale of a Service or business unit, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy; including in negotiations, due diligence, and integrations related to such transactions.
- Third-party management of our advertising: We do not disclose your Personal Information to unaffiliated third parties for purposes of their own advertising. We share Personal Information with third parties that manage or assist with our advertising, including on other sites and applications.
- With your consent or at your direction: We may share Personal Information for any other purposes disclosed to you at the time we collect the Personal Information or pursuant to your consent or direction.
- Other legal reasons: In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests or required disclosures from public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (4) to protect our operations; (5) to protect our rights, privacy, safety or property or those of you and others; and (6) to enforce our terms and conditions or other agreements.
We may disclose de-identified or aggregated information that does not identify any individual (and therefore is not deemed to be Personal Information) without restriction.
5. Data Security
We have implemented privacy and security measures reasonably adequate to preserve Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We use a self-assessment approach to ensure compliance with our privacy statements and verify periodically that our statements regarding our handling and use of Personal Information are accurate and reasonably complete in regard to the information covered. Although we work hard to protect your Personal Information, we cannot guarantee the security of any information you choose to transmit to us through the Services, online forms and applications, chat rooms, or other such mechanisms, and you do so at your own risk. Please note that email is considered a non-encrypted (and therefore nonsecure) form of communication, and it can be accessed and viewed by others without your knowledge and permission. For that reason, to protect your privacy, please do not use email to communicate information that you consider confidential. Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below. In accordance with applicable law, we will let you know promptly if a breach occurs that we determine may have compromised the privacy or security of your Personal Information.
We are not responsible for any outcome if you circumvent any privacy settings or security measures. When applicable, you are responsible for choosing a password of appropriate strength, not reusing passwords used on other websites, and keeping your password confidential. Our employees will never ask for your password, and you should never share it with anyone.
6. Retention of Personal Information
7. Children’s Privacy
We are committed to complying with the Children’s Online Privacy Protection Act (COPPA). The Services and the Sites are not directed to children under the age of 13 and children under the age of 13 are not to use or provide any information to the Services or the Sites without express parental consent. We do not knowingly collect Personal Information from children under the age of 13. If we receive Personal Information that we discover was provided by a child under the age of 13 without parental consent, we will promptly destroy such information.
California residents under 18 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see the “California Residents Privacy Rights” section below for more information.
8. Email Marketing
We may periodically send you relevant alerts and newsletters by email, including for the following purposes:
- to share relevant information about our Services and Products;
- for our marketing and business development activities, including relating to social media postings;
- to provide the Services and Products;
- to notify you of changes to our Services and Products; and
- to notify of outages or other impacts to hosted Services.
You may opt out of or withdraw your consent to receive direct marketing emails from us at any time. Instructions on how to unsubscribe from relevant alerts and newsletters are included in each email, or you may opt out or withdraw your consent by contacting us; please see the “How to Contact Us” section below.
9. Cellular Phone Numbers
By providing a cellular phone number to us, you expressly consent to, and authorize us or a third party on our behalf to deliver calls and/or text messages to the number you provide, including for notifications and account protection. You are not required to consent to these calls and/or text messages as a condition to purchasing any Products or Services, but withholding your consent may prevent us from providing certain Products or Services to you. This consent encompasses all future autodialed or prerecorded calls and text messages from us or a third party placing these calls on our behalf. You may revoke consent to receive calls and/or text messages at any time by contacting us; please see the “How to Contact Us” section below.
10. Your Personal Information Choices
You have choices in how your Personal Information is used and shared. In addition to the rights specified in this section, under applicable law you may have additional or more specific rights, which we will respect. You have the right to:
- Update, access, and delete your Personal Information; and
- Choose whether you wish to receive promotional and newsletter communications.
We may not act upon requests if we determine that they are manifestly unfounded or excessive, in particular because of their repetitive character.
Account Information: If you have an account with our hosted Services, you may update or correct your account information at any time at: http://sso.pickleball.com.
We may retain certain information, including cached or archived copies, as required by law or for legitimate business purposes.
Cookies: Please see the “Cookies Notice” section below.
Blogs: Our Site may offer publicly accessible blogs. Any comments you provide in the comments sections of these blogs may be read, collected, and used by others. To request removal of any Personal Information you post to our blogs, please see the “How to Contact Us” section below. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Certain Exceptions to Deletion Request Rights: You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and, as applicable, direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request, including where retaining the information is necessary for us or our service provider(s) to do the following (where permitted under applicable law):
- Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or Product recall conducted in accordance with applicable law, or otherwise perform our contract with you.
- Retain and continue to make available truthful information regarding your past public participation and rankings in the tournaments and brackets that we host, manage or support.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug Services and Products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.) or other applicable laws.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.
- Enable solely internal uses that are reasonably aligned with individual expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it and permitted under applicable law.
Choice and Opt-Out:
- We provide you the opportunity to “opt-out” of having your Personal Information used for certain purposes and instances. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by contacting us as provided in the “How to Contact Us” section below. We offer an opportunity to opt-out of certain communications on your account profile page, or you may contact us using the information below.
- You may opt out of personalized ads anytime by deleting your browser’s cookies. For more information, please review the “Cookies Notice” section below.
Exercising Access, Data Portability and Deletion Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us as provided in the “How to Contact Us” section below.
Verification of Your Identity: Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. You must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a request to exercise your rights does not require you to create an account with us.
11. Withdrawal of your Consent
Where you have provided consent to process Personal Information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal or the lawfulness of processing based on other lawful bases. You may do this by contacting us as set forth in the “How to Contact Us” section below.
12. Timing and Format for Responses to Requests
We endeavor to respond to a verifiable request within 30 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
If applicable, the response we provide will explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
13. Cookies Notice
What are cookies and why are cookies used: Cookies are small text files containing a unique string of characters that are stored in your web browser’s memory when you visit a website. When you return to a website that has placed a cookie in your browser, the cookie allows a website provider to recognize that you have visited the site before.
While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any Personal Information, they are also used at times to personalize a known visitor’s experience of a website by being associated with profile information or user preferences. They are also used to provide us with insights into usage of the Services and the Sites in order to help us improve the user experience.
Cookies on our Sites are generally divided into the following categories:
- Necessary Cookies: These cookies are necessary to provide you with the Services and the Sites to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how the Services and the Sites function. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than the Sites.
- Helpful Cookies: These cookies allow us to provide you with a better experience when you use the Services and the Sites. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than the Sites.
- Analytics and Customization Cookies: These cookies collect information that is used to help us understand how the Services and the Sites are being used or how effective our marketing campaigns are, or to help us customize the Services and the Sites for you to enhance your experience. This data is anonymous and only used for statistical purposes, analytics cookies do not collect or share any personally identifiable information. These cookies qualify as “third-party” cookies as they are not sent directly by us.
- Targeting Cookies: These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other sites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a subsequent visit to our Sites. You can delete these Cookies via your browser settings. See below for further details on how you can control third-party targeting cookies.
For more information on how to control Cookies:
- You can review your Internet browser settings, typically under the sections “Preferences,” “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you choose to block all cookies, you may not have access to our Sites, our Services will not function as intended, and you will not be able to log in. If you have blocked all cookies and wish to make full use of the features and Services we offer, we recommend enabling at least first-party cookies. Rather than blocking all cookies, you can choose to block only third-party cookies. This will allow the Services to function as intended.
14. California Residents Privacy Rights
Under the California Consumer Privacy Act (CCPA), California residents have the right to request the following information from us by emailing us at [email protected]; we will provide the following information to you upon verification of your identity:
- the categories of Personal Information we collect about you;
- the categories of sources from which your Personal Information is collected;
- the business purpose for collecting your Personal Information;
- the categories of third parties with whom we share your Personal Information; and
- the specific pieces of Personal Information we have collected about you.
You may opt out of any marketing by us and from the disclosure of your Personal Information to third parties.
Personal Information Sales Opt-Out and Opt-In Rights: If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
Non-Discrimination: We will not discriminate against you for electing to exercise any of your CCPA rights. Unless otherwise permitted by the CCPA, we will not: deny you goods or services, charge you a different price or rate for our goods or services, or provide you a different level or quality of goods or services because you exercised such rights. Under the current definition of CCPA, we do not sell your Personal Information.
Other than as provided above, we may offer you certain financial incentives, as permitted by the CCPA, in exchange for your giving us certain information, which incentives may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Eraser Law: In accordance with the Privacy Rights for California Minors in the Digital World Act (“Eraser Law”), California residents under the age of 18 who have posted their content or personal information to the Sites or the Services may have the right to remove, or to request and obtain removal of, certain of such content or personal information. Please be aware of that, in accordance with the Eraser Law, such removal may not ensure complete or comprehensive removal of all of the content or information posted on the Sites or the Services by the individual. Please contact us at [email protected] if you have any questions or in order to request such removal.
Types of Information We Collect: Please see the “Information we Collect and Receive” section above and Annex 1 below.
15. European Economic Area, United Kingdom and Switzerland Residents Privacy Rights
Your Personal Information will be treated in a secure and confidential manner, using appropriate technical and organizational measures, in compliance with all applicable laws and regulations, including the European General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), and the Swiss Federal Act on Data Protection. Depending on the context in which personal information is provided, we may be a data processor (“processor”) or a data controller (“controller”) of your personal information.
As applicable under the GDPR and UK GDPR, individuals have additional rights including the following:
- to obtain a copy of your personal information together with information about how and on what legal basis that personal information is processed;
- to rectify inaccurate personal information (including to have incomplete personal information completed);
- to erase your personal information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
- to restrict processing of your personal information under certain circumstances;
- to export certain personal information in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you and the processing is carried out by automated means;
- to withdraw your consent to our processing of your personal information (where that processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal);
- to obtain, or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization; and
- to object to our use and processing of your personal information that is conducted on the basis of our legitimate interest. You also have the right to object at any time to any processing of your personal information for direct marketing purposes, including profiling for marketing purposes.
Lodging a Complaint: You also have the right to lodge a complaint with your local supervisory authority for data protection, or privacy regulator. A list of data protection supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Submitting a Request: To exercise the above rights or contact us with questions or complaints regarding our treatment of your personal information, contact us at [email protected] Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will respond to your request within the applicable timeframes set out by law.
International Transfers: If you are located within the European Economic Area, the United Kingdom or Switzerland, you should note that your personal information may be transferred to countries outside these jurisdictions, including the United States where we or certain of our third-party service providers are located. The United States is deemed by the European Union to provide inadequate data protection. Transfers of your Personal Information between us and a third party shall be done pursuant to adequate protections, which may include Standard Contractual Clauses, your explicit consent, and/or other permitted mechanisms under applicable law.
16. Links to Third-Party Sites
18. How to Contact Us
Types of Information We Collect – CCPA Table
We collect, and have collected in the past 12 months, the following categories of Personal Information from customers, users of the Services, and visitors to the Sites:
|A. Identifiers.||A real name, alias/nickname, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), gender.|
|D. Commercial information.||Records of products or services purchased, obtained, or considered.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, abilities and aptitudes.|