SCHEELS PRIVACY POLICY

Effective Date: October 19th, 2026

1. Introduction and Scope. This Privacy Policy (“Policy”) describes how Scheels All Sports, Inc. (“SCHEELS,” “we,” “us” or “our”) collects, uses, discloses and protects personal information obtained through our physical retail stores, websites, mobile applications, and customer service channels (collectively, “Services”). By using the Services, you acknowledge that you have read and understood this Policy. Our California Privacy Notice supplements this Policy for California residents.

2. Information We Collect. We may collect the following categories of personal information when you interact with our Services:

   1. Information You Provide Directly.

      • Contact information, including name, gender, mailing address, email address, phone number and online usernames or aliases.

      • Purchase information, including transaction histories, payment method details and billing and shipping addresses.

      • Account profile information, including account credentials, birthday or date of birth, product reviews and stated preferences.

      • Loyalty program information, including MyScheels membership status, points, rewards and the purchase activity associated with your membership.

      • Communications with our customer service team via phone, email or online chat, including communications with AI-powered chat assistants.

      • Information you provide when you enter a sweepstakes, contest or event, including promotions we co-sponsor with other companies.

      • Identification and address verification information required by law for the sale or shipment of regulated products, including firearms and ammunition. This information is submitted to a third-party verification provider (currently Id.me) and is not retained by SCHEELS, except as required by applicable law. Declining to provide this information will prevent SCHEELS from completing the applicable transaction.

   2. Information Collected Automatically.

      • Device and browsing information, including device type, IP address, cookie identifiers, advertising identifiers, browser type, internet service provider, pages viewed, links clicked, products viewed and search histories on our platforms.

      • Information collected through cookies, pixels, tags, software development kits and similar technologies, including technologies that record how you interact with our websites (such as clicks, scrolling, mouse movements and page navigation) and transcripts of online chat sessions. Some of these technologies are operated by third parties, including analytics providers, advertising partners and advertisers on the Scheels Media Platform and their approved measurement providers, which may collect information directly from your browser or device. See our Cookie Policy for more information.

      • Location information provided by your device when accessing our online Services, including precise geolocation where you permit it through your device settings.

      • Shopping cart data, including abandoned cart contents, collected via cookies and used to send cart reminder messages.

      • Log files and other technical records generated by interactions with our websites.

      • Device and location information from devices connected to our in-store Wi-Fi services.

      • Video and photographic data collected by surveillance systems in and around our store locations. However, we do not use facial recognition or biometric identification technologies unless expressly disclosed at the point of collection.

   3. Information from Third Parties and Social Media. Our websites incorporate features from social media platforms, including Facebook, X (formerly Twitter), Instagram and YouTube. When you interact with these features, information such as your IP address and browsing activity may be collected by the applicable platform, and cookies may be set on your device. Your interactions with social media features are governed by the respective platform’s privacy policy, not this Policy.

3. How We Use Your Information.

   1. We use the personal information we collect for the following purposes: 

      • To process and fulfill orders, verify shipping and billing addresses and facilitate payments through our financial partners, including banks, PayPal and major credit and debit card networks.

      • To personalize your shopping experience and provide product and service recommendations based on your purchase history and stated preferences.

      • To display advertising on and off our Services, including sponsored product placements and other advertising from brands and advertisers on the Scheels Media Platform, and to measure the effectiveness of that advertising, including by grouping customers into audience segments based on purchase history, browsing activity and other information we collect.

      • To administer our loyalty program, sweepstakes, contests and events.

      • To operate and improve our physical stores, websites and other Services, including AI-powered features.

      • To send you promotional communications by mail, email or SMS, where you have provided consent or we otherwise have the right to do so.

      • To support customer service inquiries and resolve disputes.

      • To solicit and process applications for the SCHEELS Visa credit card, in coordination with our banking partner.

      • To verify customer age and identity as required by applicable law, including for the purchase of age-restricted products.

      • To detect, investigate, and prevent fraud, theft and other unlawful activities.

      • To comply with applicable legal obligations.

   2. Automated Processing and Profiling. We may use automated processing, including profiling, to personalize your experience, such as recommending products, tailoring marketing communications and analyzing shopping behavior. We do not use automated decision-making that produces legal or similarly significant effects without appropriate safeguards. Where required by applicable law, you may have the right to opt out of certain types of profiling used in furtherance of targeted advertising.

   3. Artificial Intelligence. Some features of our Services use artificial intelligence (AI) technologies, such as chat assistants, product recommendations and promotional tools. When you use an AI-powered chat feature, you are interacting with an automated system, not a person. Information you provide through these features, and information we use to operate them, may be processed by our AI service providers, which are contractually required to use it only to provide services to SCHEELS.

4. How We Share Your Information. We do not sell your personal information for monetary consideration. However, some of the ways we share personal information for advertising, including with advertising partners and advertisers on the Scheels Media Platform, may be considered a “sale” of personal information or “sharing” for targeted advertising under certain state privacy laws. You may opt out of these activities as described in “Your Privacy Rights and Choices” below. We may also share your information in the following circumstances:

   • Service Providers. We share information with third-party vendors and service providers who perform functions on our behalf, such as payment processing, order fulfillment, shipping, website hosting, analytics and marketing. These parties are contractually required to handle your information only as directed by SCHEELS and consistent with this Policy and are prohibited from retaining, using, or disclosing personal information for purposes other than providing services to SCHEELS, except as permitted by applicable law.

   • Analytics and Advertising Partners. We share certain browsing, device and activity data, such as cookie identifiers, referring page information and interactions with our Services with third-party analytics and advertising partners to support targeted advertising, advertising measurement and site optimization.

   • Scheels Media Platform Advertisers. We may share aggregate or de-identified audience insights and campaign performance data (such as audience segment sizes and ad performance metrics) with the brands and vendors that advertise on the Scheels Media Platform, our retail media advertising program. This data is used only so that those advertisers can measure and optimize their own advertising campaigns, is maintained by us only in aggregate or de-identified form, which we do not attempt to re-identify and is not sold or otherwise disclosed to those advertisers in a form that identifies you individually. We limit how long advertisers may retain this data and require them to delete it once it is no longer needed for the applicable campaign and any additional retention period we specify has expired. We contractually prohibit advertisers from attempting to re-identify this data. Advertisers and their approved measurement providers may also use tracking technologies on our Services, subject to our requirements, as described in ‘Information Collected Automatically’ above.

   • Third-Party Services You Choose. When you choose to use a third-party service offered through our Services, such as package protection, buy-now-pay-later financing or gift card services, we share the information needed to provide that service. The third party’s use of your information is governed by its own privacy policy.

   • Promotional Partners. If you enter a sweepstakes, contest or event that we co-sponsor with another company, we may share your information with that co-sponsor as described in the applicable official rules or at the time of entry.

   • Financial Partners. Information necessary to process credit, debit, and SCHEELS Visa transactions is shared with applicable banks and card networks.

   • Affiliates and Corporate Transactions. We may share information with our current and future parent companies, affiliates and subsidiaries for purposes consistent with this Policy. We may also disclose or transfer information in connection with a merger, acquisition, reorganization, financing, sale of assets or similar transaction, including during negotiations.

   • Legal and Regulatory Requirements. We may disclose your information to law enforcement, regulators, or other third parties when required by applicable law, legal process or governmental request, or when we believe disclosure is necessary to protect the rights, property or safety of SCHEELS, our customers, or others.

5. Text Message (SMS) Marketing Program. This section describes our practices specific to our text message marketing program (“Messaging Service”), delivered through our service provider Klaviyo.

   1. Collection and Use. By enrolling in the Messaging Service, you expressly consent to receive recurring automated marketing messages from SCHEELS at the number provided. Consent to receive automated marketing text messages is not a condition of any purchase. By enrolling, you represent that you are the authorized user of the mobile number provided and that you are authorized to consent to receive messages at that number. Message and data rates may apply. We also collect your messaging history and any information you include in messages sent to us. We may use cookies to personalize your experience, including sending cart reminder messages. Your information is used to deliver, analyze, maintain and improve the Messaging Service and to personalize your experience.

   2. Sharing. We may share your Messaging Service information with service providers as necessary to deliver the program, and as otherwise required by law. We may share aggregate or de-identified data with third parties for analytics and promotional purposes.

   3. Opt-Out. You may opt out at any time by replying STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any of our text messages, or by any other reasonable means of telling us you no longer wish to receive messages.

6. Data Security. We implement reasonable physical, administrative and technical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

   • SSL/TLS encryption for data transmitted via our websites (indicated by “https://” in the browser URL).

   • Case-sensitive password requirements, including minimum length and character complexity standards, for online accounts.

   • Restricted access to servers storing personal information, limited to personnel with a legitimate operational need.

7. Data Retention. We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, comply with applicable legal obligations, resolve disputes and enforce our agreements. Personal information that is no longer needed is periodically purged in accordance with our then-current data retention schedule. You may request deletion of your information at any time as described in Section 8.

8. Your Privacy Rights and Choices. We are committed to transparency and providing you with meaningful choices regarding your personal information. Depending on your state of residence, in addition to the below, you may also have the right to: (1) opt out of the sale or sharing of your personal information; (2) opt out of targeted advertising; (3) limit the use of sensitive personal information; (4) obtain a portable copy of your personal information; and (5) appeal our decision regarding your privacy request.

   • Do Not Sell or Share My Personal Information. Depending on your state of residence, you may opt out of the sale or sharing of your personal information and of targeted advertising by clicking the “Your Privacy Choices” link in the footer of our website or by contacting us as provided in the “How to Exercise Your Rights” section below. We also recognize Global Privacy Control (GPC) and similar browser-based opt-out preference signals as a valid request to opt out for the browser or device sending the signal and, if you are signed in, for your account.

   • Cookie Preferences. Most browsers accept cookies by default. You may adjust your browser settings to disable or limit cookies or use the cookie preferences tool on our website. Please review our Cookie Policy for further details.

   • Email Marketing. You may unsubscribe from promotional emails at any time by clicking the “UNSUBSCRIBE” link in any marketing email or contacting us as provided below.

   • Postal Mail. You may opt out of promotional mailings by contacting us as provided below.

   • Account Information. You may manage your user profile, including controlling the visibility of information such as wish lists, through your account settings.

   • Loyalty Program. If you participate in the MyScheels program, we use information about your participation and purchases to administer the program and provide rewards. You may withdraw from the program at any time.

   • Access, Correction and Deletion. You may request access to, correction of, a portable copy of or deletion of your personal information by contacting our privacy team as provided below. We will verify your identity before processing your request and will respond within the time required by applicable law. We may deny or limit certain requests as permitted by applicable law, including where we are unable to verify your identity or where an exception applies.

   • Authorized Agents. Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf. We may require proof of the agent’s authority and may verify your identity directly.

   • Appeals. If we deny your request in whole or in part, you may appeal by emailing [email protected] with the subject line “Privacy Request Appeal.” We will respond to your appeal within the time required by applicable law. If you disagree with our decision on appeal, you may contact the attorney general of your state.

   • Non-Discrimination. We will not discriminate against you for exercising your privacy rights. However, some program benefits that depend on personal information, such as loyalty rewards, may not be available if you ask us to delete that information.

   How to Exercise Your Rights. For privacy-related inquiries, please contact us by:

   • Calling: 701-670-8388;

   • Emailing: [email protected];

   • Mailing to: SCHEELS.com - Privacy 1715 Gold Drive S. Fargo, ND 58103 (include your name, mailing address, phone number, and/or email address);

   • Visiting our "Your Privacy Choices” website page; or

   • Making a request through the “Privacy Request Form.”

   We will verify your identity before processing your request and may deny or limit requests as permitted by law.

9. California Privacy Rights. If you are a California resident, please see our California Privacy Notice for additional information about your rights under California law, including your rights to know, access, delete, correct, and opt out of the sale or sharing of personal information. The California Privacy Notice supplements this Policy and applies solely to California residents.

10. Children’s Privacy. Our Services are intended for a general audience and are not directed to children under the age of 13. We do not knowingly collect or share personal information from children under 13 or use such information for targeted advertising without verifiable parental consent, in accordance with the Children’s Online Privacy Protection Act (COPPA). Where required by applicable law, we do not sell the personal information of, or use it for targeted advertising directed to, consumers we know to be under 18 without the consent required by that law. If you believe your child has submitted personal information to us without your consent, please contact us immediately at [email protected] or 701-670-8388.

11. Updates to This Policy. We may update this Policy from time to time to reflect changes in our practices, legal requirements or the Services we offer. When we make material changes, we will post the updated Policy on our website and, where appropriate, notify you by email. We encourage you to review this Policy periodically. Your continued use of the Services following the posting of changes constitutes your acceptance of the revised Policy.

12. SCHEELS Visa. Applications for the SCHEELS Visa credit card are approved or denied solely by our banking partner. Sensitive account information, including balance, payment history and credit limit, is managed exclusively through our secure banking partner and is not accessible to SCHEELS stores or SCHEELS.com.