PRIVACY POLICY

Last Updated: November 2, 2024

Thank you for choosing to be part of our community.  At Golf Daddy and our subsidiary and affiliated sites, we are committed to protecting your personal data and respecting your privacy rights.  This Privacy Policy (“Policy”) explains what personal data is collected and how it is processed by Daddy Sports, Inc., d/b/a Golf Daddy (“Golf Daddy”) and its subsidiaries and affiliates when you access or use any website, mobile site or mobile application (including Golf Daddy Simulator) operated by us or our brands that link to this Policy (collectively, the “Platform”).  This Policy and other documents referenced in it apply to all personal data collected through our Platform and any related services, sales, marketing or events. In those cases, Golf Daddy and its subsidiaries and affiliates act as controllers of your personal data.

Personal data is any information relating to an identified or identifiable natural person.  It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers.  These are just examples and there are many other types of information that would be considered personal data.

This Policy describes our data collection and use practices. To make this easier for you to navigate, please use the links below:

A.        WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

1.        Personal Data You Disclose To Us

2.        Data Automatically Collected By Us

3.        Data Collected From Other Sources

4.        Other Purposes For Which We May Use The Personal Data We Collect

B.        DO WE COLLECT DATA FROM MINORS?

C.        HOW WE HANDLE YOUR SOCIAL LOGINS

D.        USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

E.        HOW YOUR PERSONAL DATA IS SHARED

F.        PROCESSORS AND INTERNATIONAL DATA TRANSFERS

G.        HOW LONG WE KEEP YOUR INFORMATION

H.        HOW WE KEEP YOUR INFORMATION SAFE

I.        DE-IDENTIFIED (ANONYMIZED) AND AGGREGATE DATA

J.        YOUR PRIVACY RIGHTS AND CHOICES

1.        How to Submit a Request to Exercise Your Rights

2.        Your Account and Communication Choices

3.        California Shine the Light Notice

K.        UPDATES TO THIS POLICY

L.        HOW CAN YOU CONTACT US ABOUT THIS POLICY?

ANNEX 1 – ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Platform and our services.  If you have any questions or concerns about our collection or use of your information, please contact us at help@golfdaddy.com.

1. NOTICE OF MONITORING

Please note that if you use the chat function on our site or app, all information you send and receive will be recorded.  If you do not wish for us to record this information, please do not use the chat on our website or app. By using our chat you consent to Golf Daddy monitoring all communications.

2. WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

Golf Daddy uses personal data it collects directly from you, automatically from your device, or from third party providers. Below we describe the personal data that we collect from the various sources and the purposes we use the data for. We also describe the legal bases. Please note, those laws that apply to the processing of personal data (including regulations, guidelines, government issued rules, and court opinions interpreting laws) (hereinafter collectively referred to as “data protection laws”) may require us to describe our processing using certain terms or in a specific way. Although we have tried to use terms consistent with data protection laws, we aren’t always able to use terms that may be used in your jurisdiction. If you have any questions about this Policy, please contact us at help@golfdaddy.com.

1. Personal Data You Disclose To Us

We collect personal data that you provide to us when registering to use the Platform, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Platform or otherwise contacting us.

The personal data that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use, including for the following purposes:

• To facilitate account creation, setup, and logon process. We use personal data you provide to create an account with us, including: your email address, phone number, age, username, and app onboarding questionnaire answers that you submit to us or provide us access to in connection with the Platform. Processing is necessary in order to enter into a contract with you or for the performance of the contract with you. Without providing your personal data, you cannot create an account with us.
• To provide the services. We may use your personal data you decide to share with us in order to provide you with the golf swing simulation and any other services we offer.  The personal data we collect from you may include videos of your golf swing, voice recordings while using the voice control feature on our app, app onboarding questionnaire answers such as but not limited to your height and golf skill level. Please note that without providing your personal data, we would not be able to analyze your golf swing, provide our analytics to you, and communicate with you on our Platform. Additionally, you may decide which data you wish to share with us relevant to your use of our simulator, app, and services. Processing is necessary for the performance of the contract with you.
• To send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies, including email addresses, name, mailing address, and phone number. Processing is necessary for the performance of the contract with you or in order to fulfill our legal obligations.
• To fulfill and manage your purchases. We may use your personal data to fulfill and manage your orders for products, services, and payments, and to address any issues with services provided through the Platform, including billing address, mailing address, IP address, email, phone number, name, and order information. All payment data is stored by our third-party payment providers as set forth below. You should review its privacy policies and contact the payment provider directly to respond to your questions. Processing is necessary for the performance of the contract with you.  
• Customer Service.  We have different avenues to provide you with customer service, allow you to ask questions, and resolve issues.  When you contact us by email, phone, or chat, we may collect your name, address, email address, purchase details, and inquiry, as well as any other information that you choose to provide.  Processing is necessary for the performance of the contract with you.
• To post reviews and testimonials. We post testimonials on the Platform that may contain personal data, including your first and last name (if provided) and the review or testimonial which you submitted. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• When you post on community forums and social media.  When you post on community forums, we will collect your post, time of posting, and public account information.  When you engage with us on social media, we will collect your public account information, and the contents of your engagement.  We collect this information so that you and others are able to engage on community forums and on social media.  When you post on either community forums or on social media, the privacy policy of the forum or social media channel will apply, so please carefully read those privacy notices before posting.  
• To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about our new products, services, or features. The personal data collected for these purposes includes mailing address, billing address, email, phone number, name, website sessions, engagement with our social media, and engagement on our app. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness. The personal data collected for these purposes include name, email address, order history, phone number, location, IP address, and app onboarding questionnaire answers. We will ask your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• To request feedback. We may use your personal data to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users. The personal data collected for these purposes include email address, phone number, name, and app usage history (such as log information, clicks, and actions you take on the site). The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. We always carry out a legitimate interest assessment in such cases. If you have any questions about this, please contact us.
• Activity Recordings. Where you voluntarily record yourself, we may collect recordings of you through certain features, such as the in-app trail of your activities, videos of your swings, and voice commands issued to the app. The recordings support and enable the key features of the product, and additionally will be used to improve the product and AI algorithms over time and create new products.  If you do not wish to be recorded, you will not be able to use the product or services.  Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

• Job Applications. When you submit an application for a job on our website, we collect your name, position, email, phone number, the accompanying message, resume, and any other documents or information you choose to provide.  We will use this information to contact you in response to your application or inquiry, and to consider you as a candidate for employment.  

2. Data Automatically Collected By Us

We automatically collect certain information when you visit, use or navigate the Platform. For more information about the use of Cookies on our platform and the choices you have, please see our >>Cookie Policy<<.

• To provide the products and services.  We collect information automatically from your devices, namely from your Golf Daddy mat and the device(s) you use with the product, website, or our app, in order to provide the product and services to you.  In particular, we collect IP Address and Device characteristics from your device, and mat sensory information from your mat so that we can provide the services.  Processing is necessary for the performance of the contract with you.
• To request feedback.  We may use your personal data to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users. The personal data collected for these purposes include IP address, referring and exit pages, and time spent on each page. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. We always carry out a legitimate interest assessment in such cases. If you have any questions about this, please contact us.
• Activity Recordings. Where you voluntarily record yourself, we may collect recordings of you automatically through your devices, including your recording devices and your mat. Certain features, such as the in-app trail of your activities, videos of your swings, and voice commands issued to the app. In addition to the information we collect directly from you, in order to provide and improve our products and services we will collect information and images of your surroundings, body, diagnostics, and usage data.  Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences, including IP address, browsing history within our platforms, device characteristics, referring URLs, and language preferences. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• To send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies, including device type, operating system, browser type, and unique device identifiers automatically from devices.  Processing is necessary for the performance of the contract with you or in order to fulfill our legal obligations.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including location, name, device characteristics, browsing history, email address, and phone number.  We will ask your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• Google Analytics.  We use Google Analytics to evaluate the functionality and features of our website and website visitors, and to improve our products and services.  We may collect any of the information described in this section in conjunction with Google Analytics.  In addition to our use, Google Analytics may also use personal data to improve its own software and algorithms and to provide marketing services, including creation of marketing profiles where applicable.  The processing of your personal data for this purpose is based on our legitimate interest in analyzing and improving our products and services.
• To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform, and other technical information. The processing of your personal data for this purpose is based on our legitimate interest.
• To improve the Platform. We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience, including IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform, and other technical information. The processing of your personal data for this purpose is based on our legitimate interest or the processing is necessary to comply with legal and regulatory obligations.

Please refer to our >>Cookie Policy<< for more information on how we use cookies.

3. Data Collected From Other Sources

We may use third party service providers to help us with our day-to-day business activities. Where we use third parties, they may share personal data about you with us.

• To facilitate account creation and logon process.  If you choose to link your account with us to a third party account (such as your Instagram, TikTok, or Discord account, or your Google Store or Apple Store account), we use the personal data you allowed us to collect from those third parties to facilitate account creation and logon process. Personal data we may receive from your social media provider include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public). Personal data we receive from your app store account include device characteristics and email address.  Processing is necessary to enter into a contract with you, or for the performance of the contract with you or the processing is based on our legitimate interest.

• To send system generated communications to you. We may use third parties to send you administrative information about products or services you have purchased. We may receive personal data about you from the third party, including your time zone, your set notification preferences, and your app usage history. Processing is necessary for the performance of the contract with you or the processing is based on our legitimate interest.
• To fulfill and manage your orders for services. All payment data is stored by our third-party payment provider when we fulfill and manage your orders for services, subscriptions, and payments. When you make a purchase our third party payment provider may share your name, email address, billing address, transaction ID, time, and amount, and payment type. Processing is necessary for the performance of the contract with you.  Third party payment providers act as independent controllers over your personal data when you conduct a transaction with them. For more information on how your personal data is processed by our third party payment providers, please review their relevant privacy policies:

• Adyen - https://www.adyen.com/policies-and-disclaimer/privacy-policy 
• Apple Pay - https://www.apple.com/legal/privacy/ 
• Braintree (a service of PayPal, Inc.) - https://www.paypal.com/us/legalhub/privacy-full 
• dLocal - https://www.dlocal.com/legal/privacy-hub/ 
• Google Pay - https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice 
• Mollie - https://www.mollie.com/privacy 
• Paypal - https://www.paypal.com/us/legalhub/privacy-full 
• Stripe - https://stripe.com/privacy 

• To manage orders placed with third parties.  If you place an order for our products or services through a third party, such as a retail store, that party will share information with us to fulfill your order.  This information will include your name, email address, billing address, transaction ID, order details, time, amount, and payment type.  Processing is necessary for the performance of the contract with you or the processing is based on our legitimate interest.
• To send you marketing and promotional communications. Our third-party marketing partners may share your personal data for our marketing purposes, depending on your marketing preferences, including your email address, name, cookies and tracking technologies, device characteristics, IP Address, and social media engagement. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• To send you non-personalized advertising.  We may use third parties to deliver information about our products, services, and promotions.  These third parties may share with us your name, mobile phone number, mailing address, email address, and demographic information.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including your device characteristics, cookies and tracking technologies, website and app usage history, IP Address, name, and email address. We will ask your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices).

4. Other Purposes For Which We May Use The Personal Data We Collect

We may use any personal data we collect as described above for the following business purposes:

• To develop our products and services.  We may use your personal data to further develop or improve our existing products and services, including artificial intelligence tools and features, or to develop new products and services.
• To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
• To enforce our terms, conditions and policies.  We may use your personal data to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
• To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your personal data and potentially provide your personal data in response to the request.  We may also need to use your personal data as needed to comply with applicable laws and regulations.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience.

We have a legitimate interest in using your personal data for these purposes if you are our customer, otherwise we will obtain your consent. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

3. ARTIFICIAL INTELLIGENCE AND OUR PRODUCTS AND SERVICES

Like many companies, we continuously work to improve our products and services for you, including through use of artificial intelligence.  This section is meant to help you understand what types of data we may use to develop, use, and improve our products using artificial intelligence, and generally the purposes for which data may be used with artificial intelligence. As we improve our existing products and services and develop new products and services for our customers,

1. For What Purposes Will We Use Data With Artificial Intelligence?

As we improve our existing products and services and develop new products and services for our customers, we will use artificial intelligence to make our products and services more accurate, easier to use, faster, and to improve how well they work overall.  We may also use artificial intelligence to develop and test new product features and to customize our products and services for you.  

2. What Data Will We Use With Artificial Intelligence?

Will use aggregate/de-identified where possible

• Visual Data, such as video recordings, still images, movement patterns, and images of surroundings.
• Physical Activity Data, such as the actions you take in our app and on our mat, for example when you use certain services or features.
• Digital Activity Data, such as website and app activity, which may include your IP Address and Device characteristics from your device, and mat sensory information from your mat, as well as usage data.
• Voice Data, including any voice commands or recordings.
• Responses to Questionnaires, including any surveys or feedback we solicit or you provide.

1. Examples of How We Intend to Use Artificial Intelligence

In addition to the purposes we just mentioned, below are examples of the purposes for which we intend to use our users’ data with artificial intelligence:

• Improving products and services, such as allowing our products and services to be more accurate at recognizing certain things, or to generally function more quickly and efficiently.
• Developing new products and services, such as new features for existing products or entirely new services that are related to the products and services we currently provide.
• Providing relevant advertisements or offers, such as identifying our current or future products, services, or features to you, or those of third parties.

4. DO WE COLLECT DATA FROM MINORS?

Our Platform is not directed to minors under the age of 18 (or under the age of majority as determined by applicable, local law) and we do not intend to collect personal data from minors under the age of majority. Therefore, we encourage parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at help@golfdaddy.com and we will promptly delete or de-identify this information.  We do not knowingly sell minors’ personal data.

5. HOW WE HANDLE YOUR SOCIAL LOGINS

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third party social media account details (like your TikTok or Instagram logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name and email address.

We will use the information we receive for the purposes that are described in this Policy.

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We suggest that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

6. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect or store information. Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our >>Cookie Policy<<. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.

Do-Not-Track Features (U.S. Residents only). Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  We will update this Policy if that changes in the future.

7. HOW YOUR PERSONAL DATA IS SHARED

We and our subsidiaries and affiliates may generally share personal data with each other so that we can provide our services to you, in so far as there is a legal basis.  In addition, we may share your personal data with the following categories of third-party service providers for one or more of the purposes described above and if there is a legal basis:

• Content optimization service providers
• Invoice and billing service providers
• Social media companies to which you enable access
• Software service providers that parse and match resumes with job postings
• Website and application analytics providers
• Website hosting providers
• Website testing and optimization service providers

In addition, we may share your personal data with the following types of marketing and advertising service providers for the purposes described in this Policy:

• Advertising, direct marketing, and lead generation providers
• Social media site advertising providers
• Targeted advertising platforms

Where we believe it necessary or appropriate to do so, we may share your personal data with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive.  In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible. 

Finally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

8. PROCESSORS AND INTERNATIONAL DATA TRANSFERS

We will only engage processors who adequately implement appropriate technical and organizational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors. This is compulsory under the data protection laws. The data processing agreement regulates, among other things, data security, confidentiality and your rights.

If your personal data are transferred to ‘third countries’ – i.e., countries outside the European Economic Area (“EEA”) – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA – which as at the date of the last update of this Policy include Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, the United Kingdom under the GDPR and Directive (EU) 2016/680, the United States (commercial organizations participating in the EU-US Data Privacy Framework) and Uruguay (for more information and up to date list of the countries please, check here) – your personal data are sufficiently protected in accordance with European data protection laws and regulations. Where this is not the case, we provide appropriate safeguards to ensure adequate data protection, such as the most recent standard contractual clauses as approved by the European Commission and by additional safeguards, a copy of which can be obtained by sending an e-mail to help@golfdaddy.com.  If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.

9. HOW LONG WE KEEP YOUR INFORMATION

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations.

When there is/are an indication(s) of potential legal claim(s) or liability, the retention period will be extended accordingly.

When we have no ongoing legitimate business need to process your personal data, i.e. when we no longer have a legal basis in accordance with applicable law, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of personal data is based on your consent, the data will be stored for as long as there is valid consent for the processing.

10. HOW WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. We will do our best to protect your personal data taking into account the state of art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. You should however access the Platform within a secure environment.  If you believe your account has been compromised, please contact us at help@golfdaddy.com.

11. DE-IDENTIFIED (ANONYMIZED) AND AGGREGATE DATA

Golf Daddy may de-identify (as also referred to as “anonymize”) and aggregate data for its business purposes, including but not limited to, to improve the products and features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes.  "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer “personal data” under applicable data protection laws. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. Golf Daddy may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.  

12. YOUR PRIVACY RIGHTS AND CHOICES

The rights described in this section apply to all users.  Note: Some data protection laws may use other terms to describe these rights differently. If you have any questions about these rights please contact us at help@golfdaddy.com.

Right to Access and to Know — You have the right to access the personal data collected about you. You also may request to know the categories of personal data collected about you, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. However, there are certain exemptions, meaning that data subjects may not always receive all of the information we process.

Right of Complaint — If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at help@golfdaddy.com.  We will always try to find a solution together. Should this not be possible, you have the right to complain to a Data Protection Authority about our processing of your personal data. If you are in the EEA, please contact your local Data Protection Authority in the EEA.  For contact details of your local Data Protection Authority, please see here.  

Right to Correct — Without prejudice to your right to review or change the information in your account to make sure it is accurate and up-to-date, you also have the right to request rectification of any other of your personal data provided to us if you consider it to be inaccurate or incomplete.

Right to Data Portability — Under certain circumstances, you may request us to transfer your personal data, provided by you, to another controller. Also, you have the right to receive your personal data, which have been provided by you, in a structured, commonly used and machine-readable format and to transmit that data to another controller.

Right to Delete / Erasure — You generally have a right to request your personal data or part of it to be erased (e.g., when your personal data are no longer necessary for the stated purposes in this Policy, or the personal data have been unlawfully processed); however, we may not always erase your personal data because sometimes the processing is still necessary. For example, for complying with statutory obligations or for lodging, exercising, substantiating, or defending against legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for our legitimate interests. Please be aware that if you request us to delete your personal data, you may also not be able to continue to use the Platform. 

Right to Restriction.  Under certain circumstances, you may have the right to restrict a business’s ability to process personal data about the you. For example, if the accuracy of your personal data is contested, the processing is unlawful, or personal data is no longer needed for purposes of the processing. However, we can still use restricted data in certain circumstances (e.g., when your personal data is needed for legal claims or to protect another data subject’s rights).

Right to Notification of Correction, Deletion or Restriction.  Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about correction, deletion or restriction of processing.

Right Against Automated Decision Making/ Profiling — You may have the right to not be subject to a decision based solely on an automated process without human input. 

Right of Objection — Under certain circumstances, you may object to the processing of your personal data by us or third parties engaged by us. We will consider several factors when assessing an objection to our processing in furtherance of our legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. For example, you may object to the use of your personal data for direct marketing purposes.

Right to Withdraw Consent — If we have requested your explicit consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.

Right to Opt In for Sensitive Data Processing — Under certain circumstances, you may have the right to opt in (or consent) before we can process your sensitive data.

Right to Opt Out of Sale or Sharing.  Where applicable, in the U.S., you may opt out of the Sale or Sharing of personal data to third parties, as those terms are defined by U.S. federal, state and local laws.  You may exercise this right by clicking on the “Your Privacy Choices” link located at the bottom of our homepage or by submitting a request as described in the How to Submit a Request to Exercise Your Rights section below. 

In addition, will not treat a consumer who exercises their privacy rights differently than a consumer who does not exercise a right.

1. How to Submit a Request to Exercise Your Rights

Submission of Requests.  You may submit a request regarding your personal data by:

• In the U.S. you can call us at +1 888-409-5294.
• Email us at help@golfdaddy.com – please provide your name, email address, state of residence, phone number, and order number, if applicable
• Mail us at 24A Trolley Sq, #1180, Wilmington, DE, USA

What We May Need from You.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to someone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Verifying Your Identity. To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal data and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we may ask you to confirm your email address and your order number, date of last purchase, or billing address to verify your identity, so that we can help protect your information.  

Requests from Authorized Agents  You may designate an authorized agent to make a request for you.  If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

Responses to Requests.  We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the applicable laws. If a longer period of time is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.

2. Your Account and Communication Choices

Delete or Update Account Information.  If you are a registered user of our Platform, you may delete or correct the personal data in your account in your account settings. It is your responsibility to make sure the personal data we hold about you is accurate and up-to-date.  Please note, we may not be able to delete or anonymize all your personal data where applicable law requires us to retain such information. Once the legal basis for its retention has expired, we will delete or de-identify your personal data in accordance with our data retention policy.

Opt Out of Email Marketing.  We will send you marketing emails about our own products and services if you are our customer of have given your consent (opt in). However, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. If you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

Opt Out of SMS Messages (Applicable in U.S. Only). We do not send SMS or text messages to you without your consent to do so. If you change your mind at any time, you can opt out of SMS messages by replying “STOP” to any message we send, or by changing your communications preferences within your account settings by reaching out to help@golfdaddy.com. Please see our Terms and Conditions for more information.

3. California Shine the Light Notice

We provide California residents with the option to opt-in to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than with our affiliates, for such third parties’ own direct marketing purposes. We do not share personal information with non-Affiliate third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law and/or withdraw previously given consent to sharing with non-Affiliate third parties for their direct marketing purposes by contacting using the methods in the How to Submit a Request to Exercise Your Rights section above. Requests must include “California Direct Marketing Privacy Request” in your description of which right(s) you wish to exercise. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address.

13. UPDATES TO THIS POLICY

We may update this Policy from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make any material changes to the Policy, we will notify you by reasonable means, such as by posting a the changes on our website with the date the changes will become effective or the date of the last update.  We encourage you to check this Policy from time to time. 

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions about this Policy, you may contact us at help@golfdaddy.com.

     If you have questions or comments about this Policy, you may contact our Data Protection Officer (DPO) by email at [help@golfdaddy.com].

Daniel Puumalainen / CEO

help@golfdaddy.com

1. ANNEX 1 – ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This Annex summarizes how Golf Daddy processes Personal Information in accordance with California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), The terms used in this Annex 1 shall have the same meanings as given to them under the CCPA.

Information, where we have a legitimate interest, legal obligation or consent for processing:

Note: Golf Daddy Services include the ability for the user to upload and share unstructured personal data, such as videos and content posted to forums or message boards, which could include personal data not included in this Privacy Chart. Golf Daddy does not intentionally collect or use any sensitive personal data.