Last updated: 14 June 2023
Overview – Categories and Sources of Information
We collect personal data from Users of our Service when it is voluntarily provided by you, such as your name and email address (see Information We Collect below). We use such information to contact you directly and other purposes described in How We Use the Information and Information Sharing and Disclosure below.
We automatically collect browsing information and other information from Users of our Service and from third parties with whom we work, such as information about your browsing activities and information about the device you use to access the Service (see Information We Collect below). We use such information to customize the Service for you and other purposes described in How We Use the Information and Information Sharing and Disclosure below.
This information is collected to provide, manage, analyze and improve the features and functions available on or through this Service and other services, for marketing purposes and for our internal business purposes.
I. Information We Collect
1. Information You Provide To Us.
In the course of using our website, we may collect from you various forms of information, namely: name, address, e-mail address, age, gender.
2. Information That is Passively or Automatically Collected.
We, and our “Partners” who include teams within 4Aces GC, third party service providers, sponsors, broadcast partners, other golf organizations, advertisers, advertising networks and platforms, agencies, and distribution or other commercial partners may use automated means to collect various types of Information about you, your device used to access, or in connection with, our Services. The list of the types of automatically collected information includes: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, device attributes, browser settings, the web pages of the Services you have visited, Services visited before and after you visit a Service, the type of handheld or mobile device used to view the Service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on, and product purchase history. Please see our Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.
3. Geo-location Information.
You may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on other Services, when we work with a Partner such as a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.
II. How We Use the Information
We may use the Information for the management of our relationship on the basis of the contract between us to:
provide and communicate with you about the Services or your account with us,
fulfil your requests regarding the Services, including without limitation requests for newsletters and notifications,
respond to your inquiries,
Besides, we rely on your prior consent in order to:
communicate with you about other products, programs or services that we believe may be of interest to you,
customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them.
Subject to your consent, we may use “cookies” or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser. For information about how these technologies work and how we may use them, please go to Section V, titled Cookies, and Other User and Ad-Targeting Technologies.
In addition, we process Information based on our legitimate interests which consist in:
enforcing the legal terms (including without limitation our policies and Terms of Service) that govern your use of our Services,
providing technical support for the Services,
preventing fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services,
protecting the safety of our Users, performing analysis regarding how you use the Services or any part thereof, and
developing our product offering and improving our Services.
Finally, we process Information to comply with the legal obligations to which we are subject.
III. Information Sharing and Disclosure
We may disclose the Information as follows:
To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research, analytics and customer profile development; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) accept and fulfil orders and user requests; (f) process payments; (g) host our Services, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support our Services.
In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request or similar request.
With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies, our Terms of Service or the law, to verify or enforce compliance with the policies governing our Services.
We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way.
IV. Retention of Information
With respect to the Services provided to our customers and technical support, we will keep your Information during the period of our contractual relationship, extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your Information for as long as reasonably necessary after the last correspondence with us in order to comply with any request from you not to be contacted.
With respect to the processing carried out in order to protect the safety of our Users and enforce the legal terms, we will keep your Information for the time of the relevant dispute.
As to the processing carried out in order to comply with a legal obligation, we will keep your Information for the duration of such obligation.
Upon expiry of the applicable data retention period, we undertake to erase or irrevocably anonymize the relevant Information.
V. Cookies and Other User and Ad-Targeting Technologies
Syncing Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partners' uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match Users to their likely product interests, or better synchronize, cap, or optimize advertising.
Web Beacons. We and our Partners may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
VI. User Rights – Data Access and Opt-Out1. User Rights.
A. General Rights: We provide you with choices regarding the Information you provide to us.
– If you have signed up to receive our marketing e-mails and prefer not to receive marketing information from this Service, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from this Service.
– You may accept, delete or block cookies and other technologies by following the instructions above.
B. California Rights: California law provides California residents with specific rights regarding their personal information. The California Consumer Privacy Act of 2018 (“CCPA”) defines “personal information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This section describes the rights that California residents have with respect to such personal information and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA. Please refer to the sections above for more detail about the types of information collected, the purposes for which and sources from where we collect personal information, and the third parties with whom we share personal information.
Right to Delete – If you would like to delete the personal information we possess about you, please contact us by post or by email at the addresses set out below.
Right to Know Categories & Information – If you would like to receive the categories of personal information collected about you, the categories of sources from which the personal information is collected, the purpose for collecting and selling the personal information, the categories of third parties which whom we share the personal information and the specific pieces of personal information collected about you, please contact us by post or by email at the addresses set out below.
Do Not Sell My Personal Information – If you would like us to simply not sell your personal information to a third party, as defined in the CCPA, then you may opt out of such disclosures by contacting us by post or by email at the addresses set out below.
We will maintain procedures to verify that you are authorized to make the requests set forth above. You may designate an authorized agent to make these requests by informing us, though we will need to verify that such agent has the authority to act on your behalf.
We do not discriminate against you for exercising any of your rights above, though we are not able to provide some Services to you without receiving such information.
C. Nevada Rights: Consumers in the State of Nevada have the right to opt out of the sale of personal information processed by us, as defined under Nevada law. To exercise such legal rights, please contact us by post or by email at the addresses set out below.
D. European Economic Area (EEA) and UK Data Subject Rights. If the processing is subject to the General Data Protection Regulation (“GDPR”) or the UK GDPR, you have the following rights:
Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
Right to restrict processing – This right allows individuals to restrict processing of personal data under certain circumstances.
Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased in specific circumstances.
Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing and profiling.
Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
To exercise your rights under the GDPR/UK GDPR, please contact us by post or by email at the addresses set out below.
In any case, you have the right to lodge a complaint to the relevant European and/or UK data protection authority.
2. Verify Requests.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your Information. This is a security measure to ensure that Information is not disclosed to any person who has no right to receive it.
3. How to Contact Us.
You may also contact us regarding your privacy at email@example.com.
VII. Updates & Effective Date