Privacy Policy

1. INTRODUCTION

FROZ Sport Development Corp. (“FROZ”, “we”, “us”), based in Atlanta, Georgia, USA, respects your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you use www.frozsports.com and our services.

2. TERRITORIAL SCOPE

FROZ operates from the United States. This policy is governed by U.S. federal and state laws, including the California Consumer Privacy Act (CCPA/CPRA) and other applicable state laws (VCDPA, CPA, CTDPA, UCPA).

3. INFORMATION WE COLLECT

• Identifiers: name, email, phone number, address, date of birth, nationality.
• Academic information: grades, transcripts, standardized tests (SAT, ACT, TOEFL, Duolingo).
• Athletic information: position, statistics, highlight videos, competitive history, physical measurements.
• Commercial information: services purchased, payment history.
• Technical information: IP address, browser type, device, pages visited, cookies.
• Minors’ data: collected only with verifiable parental consent (COPPA, 15 U.S.C. §6501).

4. HOW WE USE YOUR INFORMATION

We use your data to: evaluate profiles, deliver advisory services, communicate opportunities, process payments, comply with legal obligations, prevent fraud, and improve the Site.

5. DISCLOSURE TO THIRD PARTIES

We may share your information with: (a) colleges, coaches, and athletic governing bodies (NCAA/NAIA/NJCAA) with your authorization; (b) service providers (hosting, analytics, payment processors) under confidentiality agreements; (c) authorities when required by law.

6. SALE AND SHARING OF INFORMATION

FROZ does NOT sell your personal information for money and does NOT share your data for cross-context behavioral advertising as defined under CCPA/CPRA.

7. YOUR RIGHTS UNDER CCPA/CPRA AND STATE LAWS

• Right to know what data we collect and how we use it.
• Right to access and obtain a portable copy of your data.
• Right to correct inaccurate information.
• Right to delete your personal data.
• Right to limit the use of sensitive personal information.
• Right to non-discrimination for exercising these rights.
• Right to designate an authorized agent to act on your behalf.

8. HOW TO EXERCISE YOUR RIGHTS

Send your request to hello@frozsports.com with the subject “Privacy Request”. We will verify your identity and respond within 45 days (extendable for an additional 45 days).

9. COPPA — CHILDREN UNDER 13

We do not knowingly collect data from children under 13 without verifiable parental consent. If we discover such collection, we will delete the information immediately. Contact: hello@frozsports.com.

10. INTERNATIONAL TRANSFERS

If you reside outside the United States, your data will be transferred to and processed in the U.S., whose laws may differ from those of your country. By using the Site, you consent to such transfer.

11. DATA RETENTION

We retain your data for as long as necessary to provide services and comply with legal, tax, and accounting obligations. Academic and athletic records may be retained for up to 7 years after service completion.

12. SECURITY

We implement reasonable technical, administrative, and physical safeguards (encryption in transit, access controls, backups) to protect your information. No system is 100% secure.

13. BREACH NOTIFICATION

In the event of a security incident affecting your personal data, we will notify affected users and competent authorities as required by applicable state breach-notification laws.

14. THIRD-PARTY LINKS

The Site may contain links to external sites. We are not responsible for their privacy practices. We recommend reviewing their policies.

15. DO NOT TRACK

Our Site currently does not respond to browser “Do Not Track” signals due to the lack of a uniform industry standard.

16. NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT)

California residents may request information about disclosures of personal information to third parties for direct-marketing purposes under California Civil Code §1798.83 by emailing hello@frozsports.com.

17. UPDATES

We may update this Policy periodically. We will post the current version with its update date. Continued use of the Site constitutes acceptance of the changes.