Privacy Policy

Welcome to CoachNow! CoachNow greatly values your privacy and has created this Privacy Policy to describe its use of Personal Information in providing services to you. We process Personal Information in accordance with the principles of transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability. Our Privacy Policy describes how CoachNow, through its operating companies Golf Genius Mobile, LLC and Golf Genius Software, Inc. (“CoachNow”, “we” or “us”) collects, uses, and discloses information about natural persons and entities who use our products and services through our website (“Site”) or mobile application through tablets, phones, wearables or other devices (“Mobile Application”) (each a “User” or “you”), and the choices Users have with respect to how we manage their Personal Information provided or otherwise accessible to us (“User Data”).

1. Contract Acceptance. 

1. As used in this Privacy Policy, the term "Personal Information" means any information that relates to a natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, biometric, genetic, economic, cultural or social identity of that natural person. This definition encompasses the broader scope of 'Personal Data' as outlined by the General Data Protection Regulation in effect in the European Union ("GDPR"), any information that falls under the category of 'Personally Identifiable Information' as defined by the California Consumer Privacy Act and its regulations ("CCPA"), and personal information as defined by the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada. Personal Information includes but is not limited to names, email addresses, social security numbers, account numbers, personal identifiers, financial information, geolocation data, biometric information, internet activity information, and other data that could reasonably be linked, directly or indirectly, with a particular consumer or household.
   
   
2. This Privacy Policy applies to and is binding on all Users in connection with their access to and use of our products and services accessed through our Site and Mobile Application, which includes the set of software platforms operated by us and made available to Users and the available functionality on the Site and/or Mobile Application that allows Users to provide or receive coaching, video upload and download, instruction, sports management, recruiting services, scoring, technique, training, and sharing related data (the “Service”). The Service may be purchased directly from us or through a third-party mobile sales platform such as those operated by Apple, Google, and Microsoft (“Platforms”). By using the Service, you acknowledge that you accept the privacy policies and practices set forth herein. If you do not accept these policies and practices, then you should not use the Service.
   
   
3. Certain Users may be athletes or students who access and use the Service through their coaches' or leagues' accounts. Nevertheless, those athletes and students are considered Users and our access to and use of their Personal Information is subject to this Privacy Policy.
   
   
4. This Privacy Policy is incorporated into and made a part of the Terms of Service, which can be accessed on the Site and Mobile Application (“Terms of Service”). Capitalized terms used, but not otherwise defined in this Privacy Policy shall have the meanings provided for those terms in the Terms of Service. Certain Users may have entered into separate agreements with us that specifically address matters covered by this Privacy Policy. In any instance where a provision of a separate agreement conflicts with or is inconsistent with this Privacy Policy, the separate agreement shall control and prevail solely to the extent of such conflict or inconsistency. In all other respects, such separate agreements are intended to supplement, but not amend or alter, this Privacy Policy. Therefore, in the absence of any conflict or inconsistency with a separate agreement, this Privacy Policy shall apply fully to all Users, including those with separate agreements.
   
   
5. We reserve the right, at any time, and from time to time, to modify, update, or revise this Privacy Policy. We will add this Privacy Policy to our Site and Mobile Application, clearly indicating the effective date. You should review this Privacy Policy periodically so that you keep up to date on the most current versions and related practices and procedures. By using the Service, Website, and/or Mobile Application, you accept the terms of and consent to this Privacy Policy. This consent provides us with the legal basis to process your personal information. You have the right to withdraw your consent at any time.
   
   
6. If you are a California resident, additional information applicable to California residents is below in the Section titled, “Additional Information For Users Who are California Residents.” If you are a resident of the European Union, additional information applicable to European residents is below in the Section titled, “Additional Information For Users Who are EU Residents.” 

2. User Data We Collect and Receive

1. Throughout your use of our Service, we collect information about you and that may include Personal Information.
   
   
2. When you open your Account in accordance with the Terms of Service (and through your use of the Service), we collect the following Personal Information only to the extent required for the stated purposes of providing and improving our Service.
   
   
   1. Your account login information
      
      
   2. Your name.

1. 1. Your email address.
      
      
   2. Your contact preferences.
      
      
   3. Your passwords and other online identifiers.
      
      
   4. Your credit card information is not collected directly by us, but is collected indirectly via our payment processing providers like Stripe or Apple Pay or built-in systems for in-app purchases.
      
      
   5. Your telephone numbers.
      
      
   6. Your address and zip code.
      
      
   7. Data identifying your location.
      
      
   8. The equipment you use to access our Site or Mobile Application (such as your computer, phone, wearables or other devices and including your internet service provider (ISP).
      
      
   9. The times and dates you access our Site or Mobile Application.
      
      
   10. Your biometric data (including photos and videos).
       
       
   11. Your birthdate.
       
       
2. Other information that may, in your use of our Service, be collected, including:
   
   
   1. Information concerning your team and User Group, invitees to your training spaces, and related demographic or identifying information.
      
      
   2. Behavioral or demographic attributes.
      
      
   3. Transactional data based on past purchase behavior.
      
      
   4. Data from marketing opt-in lists, consumer surveys, or publicly available information.
      
      
   5. Unique Id's, such as cookies placed on a computer or device.
      
      
   6. Information derived from the mobile device being used,
      
      
   7. Behavioral data regarding your device or website usage, such as advertisements clicked, websites and content areas accessed, search histories and activities logs.
      
      
   8. Any User Content that you post, own, or control.

 

3. Who Collects and Processes Personal Information.

Decisions regarding collection of Personal Information are made by the “Data Controller”. A “Data Controller” is the person or organization who decides the purposes for which and the way in which Personal Information is collected and processed. A “Data Processor” is a person or organization that processes Personal Information for the Data Controller. Data Processing includes collection, recording, organizing, structuring, storing, adapting, altering, retrieving, using, disclosing, transmitting, disseminating, combining, restricting, erasing or destroying data.  Our Data Controller and Data Processor is Golf Genius Mobile, LLC, whose address is 311 Orchard Way, St. Davids, Pennsylvania 19087and can be contacted by email at: info@coachnow.io.

 

 We collect information from you in the following ways:

1. Usage Information.  Some Personal Information is collected when you provide it to us (for example, when you create an Account). You also provide information when you log in to your account or when you fill in forms, respond to surveys or provide feedback. We may also ask you to provide us with some additional information that will be publicly visible on our services, such as profile pictures, avatars, a name, or other useful identifying information. You may also provide us with credit or debit card and associated account information. We utilize a secured payment processor to process all credit card transactions.
   
   
2. Cookies.  Our Site uses “Cookies” and our Mobile Application uses “App Cookies” (both of which are referred to as “Cookies”), which in each case, are text files on your computer that help identify you and collect internet log information and visitor behavior. Cookies allow us, among other things, to measure activity and personalize your experience, and may also allow us to remember your viewing preferences and create statistical reports on website activity. You may choose to set your browser to reject cookies or manually delete individual or all the cookies on your computer or other devices.   
   
   
3. Cookie Policy. We use the following types of cookies:
   
   
   1. Session Cookies. These cookies are essential to enable users to move around our Site and Mobile Application and use its features, such as accessing secure areas of our Site.

1. 1. Performance Cookies. These cookies allow us to see which areas and features are popular and to count visits to our Site and Mobile Application. These cookies do not collect information that identifies an individual visitor. All information these cookies collect is aggregated, anonymous, and only used to improve the Site and Mobile Application.
      
      
   2. Functionality Cookies. These cookies allow the Site and Mobile Application to remember choices you make to (such as your language or the region you are in) and provide enhanced, more personal features to improve your experience. These cookies are required for basic site functionality and therefore they are always enabled.
      
      
   3. Targeting Cookies. These cookies are used for web analytics purposes. All information these cookies collect is aggregated and anonymous.
      
      
   4. Managing Cookies. Many website browsers automatically accept cookies, but you can change your browser settings. However, if you choose to disable the receipt of cookies, you may not be able to use certain features of the Site or Mobile Application. Our Site and Mobile Application will prompt you to indicate your acceptance of our use of cookies.
      
      
   5. You may learn more about cookies at www.allaboutcookies.org to learn about how to delete and control cookies using the mail browser types.
      
      
2. Web Server Logs.  Web server logs are activity records created when you visit web pages, such as search terms you enter, device information and identifiers, information about your browser, IP address, access times, and pages viewed.
    
3. Web Beacon and Pixels.  Web Beacons are electronic files that allow us to recognize and count users who have visited the Site and can be used in HTML-formatted emails to determine responses and response rates to our communications (for example, by clicking a link in an email). We also automatically collect and aggregate other information about you using tracking pixels and related tracking technologies, browser analytic tools, server logs, and similar technologies. These tracking technologies may be implemented and placed by us or by third-party vendors on our behalf, and they allow us to collect information by automated means. We also may collect geo-location information through your IP address and mobile devices. This information is used for internal analysis only.
   
   
4. Third-Party Data Sources.  We may also receive marketing information from third parties, including information collected from online and offline sources. This could include advertisements or application update notices. We may collect information that other users provide about you when they use the Service. 
   
   
5. Device Information. We collect information from and about the devices you use, such as your location, your hardware and software, operating system, device memory, advertising identifiers, unique application identifiers, apps installed, browser type, language, time zones, and information from device sensors. We may ask for permission to collect images and other information from your device’s camera and photos.
   
   
6. Social Networking Sites.  If you log into your Account using shared sign-in services, such as from social networking sites, you authorize us to access certain information about you from those social networking sites, such as your user profile and profile picture.
   
   
7. Surveys. We also may collect information by periodically conducting business and individual customer surveys. These surveys help us to improve the types of products and services we offer and how we provide them to you.

5. How We Use Information. 

1. We take your privacy seriously and only use your Personal Information in lawful ways to provide our Services to you. You can review and update your Personal Information at any time through your Account settings. We encourage you to promptly update your personal data if it changes.
   
   
2. We process User Data only to provide the Service to Users and to improve the Service. We process User Data to communicate via email with Users, educate them about the Service, communicate information about new features of the Service, and alert them about planned outages for maintenance or new features.
   
   
3. We use Google Analytics to measure and evaluate access to and traffic on the Service and to create user navigation reports for our Service. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Service. Google may use the information collected through Google Analytics to evaluate Users' and Customers' activity on the Service. Google operates independently from us and has its own privacy policy, which we strongly suggest you review.
   
   
4. Lawful Reason for Collecting Information. The lawful reasons for collecting and processing your information are (1) because you have entered into a contract for us to supply goods and services to you, (2) we have a legitimate business interest in using your information (for example, to provide and improve our services, customer support and show you advertisements we think will be of interest to you,) and (3) to comply with applicable law.
   
   
5. Uses of Information. You agree that we are entitled to obtain, use, and process the Personal Information and other information you provide to us to enable us to discharge the Services and for other related purposes, including:
   
   
   1. To protect your privacy and enhance data security.
      
      
   2. To create your Account, provide you with convenient and personalized access to your Account, and deliver and support the Service.
      
      
   3. To update and enhance our records.
      
      
   4. To engage in analysis and reporting for management purposes.
      
      
   5. To carry out credit checks, background checks, and crime and fraud prevention.
      
      
   6. To carry out legal and regulatory compliance.
      
      
   7. to develop, operate, improve, and enhance the safety or performance of our Service and the products and services offered by our Affiliates.
      
      
   8. to send you communications, including by email, such as product announcements and marketing materials for special offers and software updates.
      
      
   9. to respond to your requests for assistance.
      
      
   10. to personalize our Services.
       
       
   11. to provide and improve ad targeting and measurement. 
       
       
   12. to enforce our Terms of Service, legal and contractual obligations, and policies.
       
       
6. Profiling.  We may analyze your Personal Information to create a profile of your interests and preferences so that we can contact you with products and service information that we think may be of interest to you, to complete or process transactions, to inform you of updates, monitor usage and performance and enhance the Service for better User experiences. 
   
   
7. User Content. The Service allows you to supply or post User Content. The User Content you create remains yours; however, by sharing User Content through the Service, you agree to allow others to view, edit, copy and/or share your User Content. We have the right (but not the obligation) in our sole discretion to remove any User Content. Once your Account is terminated or your rights to use the Service are terminated, you will not be given any rights to view or access any User Content, and there may be no way to delete or retrieve User Content once it has been shared
   
   

6. How We Share and Disclose User Data.

Except as described in this Privacy Policy, we do not sell, share, transfer or otherwise intentionally disclose User Data to third parties. We may share User Data with third parties for the following purposes.

1. With Other Users. We may share your username, name, Bitmoji, avatars, profile picture, and your User Content as well as any additional information you have authorized us to share with other Users. How widely your User Content is shared depends on your settings and the way you designate your User Content. For example, you can control the scope of distribution of your User Content by designating it as “public” or “private”.
   
   
2. With Our Affiliates. We may share information with other entities within the GGS family of companies or entities we control, that control us, or that we are under common control with (“Affiliates”).
   
   
3. With Your Explicit and Informed Consent. We may disclose User Data to third parties at your direction or if you otherwise provide your informed and explicit consent to us doing so. You may revoke your consent at any time, and we will provide a simple and clear process for revoking consent.
   
   
4. Information that You Make Publicly Available. Any information that you voluntarily choose to include in a public profile page will be available to anyone who has access to such profiles.
   
   
5. Service Providers. We work with third-party service providers to provide components of the Service. These may include, for example, software, hosting providers, email delivery, text message delivery, problem reporting or resolution, and our knowledge base. These third parties may have access to and process User Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions and require them to maintain the confidentiality of such information. Our Services may also contain third-party links and search results, third-party integrations, or offer co-branded or third party-branded services. Through these links, third-party integrations, and co-branded or third party-branded services, you may be providing information (including Personal Information) directly to the third party, us, or both. Users can disable third-party tracking of their information through a setting in the Application or on the Site.
   
   
6. Automated Information. We may make certain automatically collected or aggregated information available to third parties for various purposes, including (i) for compliance with various reporting obligations; (ii) for legitimate business purposes; or (iii) to provide data to those who seek to better understand how coaches and athletes engage in their sports (the USGA for golfers, for example).
   
   
7. To Protect Us and Others. We may disclose User Data when we believe, in good faith, that such disclosure is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
   
   
8. With Third Parties As Part of A Merger or Acquisition. If we become involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.
   
   
9. With Third Parties For Marketing. Unless otherwise expressly provided in a separate agreement between the User and us, we may share information about you with third party providers for purposes of cross-marketing or making offers to you of their products or services.  We also may use your information to send you email, direct mail, and other marketing of our products and services (and those of our partners), including but not limited to targeted advertising. We may let other companies use cookies, web beacons, and similar technologies on our services to collect information about how you use our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.  Additionally, some companies, including our Affiliates, may use information collected on our services to measure the performance of ads and deliver more relevant ads on behalf of us or other companies.  You have the right any time to stop us from contacting you for marketing purposes. 
   
   
10. With Third Parties for Legal Reasons. We may share information about you if we reasonably believe that disclosing the information is needed to (a) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (b) investigate, remedy, or enforce potential violations; (c) protect the rights, property, and safety of us, our users, or others; (d) detect and resolve any fraud or security concerns; or (e) respond to claims by third parties that your User Content violates their rights. We reserve the right to cooperate fully with any law enforcement authorities or court order requesting or directing us to disclose the identity or other information of anyone.  We reserve the right to take any and all appropriate legal action, including referral to law enforcement agencies.  You waive and hold us and our Affiliates, licensees, licensors, and service providers harmless from any claims resulting from any action taken by any of them during, or because of investigations or legal process. You acknowledge and agree that when your information is shared with third parties, we are not responsible for how those third parties collect or use your information. We encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our services. Third parties with whom we share your information are required to maintain the confidentiality and security of the data, use it only for the purposes for which it was shared, and handle the data in compliance with applicable data protection laws. 

 

We store your Personal Information until you ask us to delete it or for various lengths of time based on different circumstances. If you decide to stop using the Service, you can ask us to delete your Account and the Personal Information collected as part of your Account (Please see “Right to be Forgotten/Deletion of Account Information” below). We will retain your information for a period of time consistent with the original purpose(s) for which we collected it. We will retain your information (i) for as long as we have an ongoing relationship with you and as needed to provide you Services; (ii) as necessary to comply with our legal obligation(s); (iii) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (iv) as necessary to enforce our agreements. If you delete your Account or terminate your subscription by using the functionality in the Mobile Application or Site, your data will be anonymized so that we can no longer associate that data with you or otherwise identify you. Retention periods will be determined taking into account the amount, nature, and sensitivity of your information and the purpose(s) for which it was collected. After the retention period ends, we will delete your information. Where we are unable to do so, we will take appropriate measures designed to prevent unauthorized use of your information.

 

 

We respect User privacy rights. Users may correct inaccuracies in their data through their profile. There are many ways that you can exercise control over the collection, processing, and use of your information, including making requests to access, export, delete, or modify your Personal Information directly in the Mobile Application. In other cases, the User may contact us directly via email at info@coachnow.io.

 

We will not transfer Personal Information from the European Union ("EU"), United Kingdom ("UK") or Switzerland outside the EU, UK, or Switzerland unless in accordance with applicable Data Law (i) to a country or territory that (A) has received an adequacy decision by the European Commission, or (B) provides an adequate level of protection for Personal Data from EU, UK, or Switzerland, and (ii) is subject to an agreement that satisfies the EU, UK, or Swiss (as applicable) requirements for such transfer of Personal Information. All data that is transferred internationally is encrypted from the User’s device to our servers and protected in the same manner as domestic data. We also provide Users an easy way to access their Personal Data and to exercise their Data Subject rights under GDPR. We adhere to the principles of the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, but we have not obtained certification under the Privacy Shield Framework. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov. In light of the Court of Justice of the European Union decision regarding the legal effect of the EU-US Privacy Shield Framework, we do not rely solely upon the Privacy Shield principles. We also currently use, when we deem it to be necessary, “Standard Contractual Clauses” ("SCC") approved by the European Commission (also known as Model Clauses) to provide appropriate safeguards for data transfers from the European Economic Area (EEA) to the United States and other areas outside of the EEA. SCC are sets of contractual terms and conditions that have been previously approved by the European Commission as providing adequate protection for personal information. If the European Commission adopts an amended or updated version of the SCC, the versions most recently approved will apply.

 

 

We do not Sell (as defined by the CCPA) or otherwise disclose Personal Information we collect from you for third-party direct marketing purposes.

 

The Service currently does not recognize or respond to Do Not Track (DNT) signals from your web browser. DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. However, because there is not yet a consensus on how companies should interpret DNT signals, we do not currently respond to DNT signals on our site. We review and update our practices in response to evolving privacy standards and will consider implementing DNT capabilities as part of our compliance with applicable law and privacy frameworks we adhere to. We provide a mechanism for Users to disable tracking activity by third parties. 

 

This section applies only to California consumers. In this section only, any capitalized terms not defined in this Privacy Policy have the meanings set forth in the CCPA. The CCPA provides consumers with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.

1. Right to Know. California residents have the right to request access to the following information: (a) the categories of Personal Information we collected from you in the prior 12-month period, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or Sold your Personal Information, (d) the categories of Personal Information that we Sold to third parties or otherwise disclosed for a business purpose in the prior 12-month period, and (e) the categories of third parties to whom we Sold or shared your Personal Information. In addition, California residents are entitled to ask for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and Affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice or to exercise your rights under CCPA, please submit a written request to us. Residents of the European Union shall have similar rights to receive this information.
   
   
2. Deletion Request Rights. A consumer has the right to request that we delete any of their Personal Information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s Personal Information from our records, unless an exception applies. We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:
   
   
   1. Complete the transaction for which we collected the Personal Information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
       
   2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
      
      
   3. Debug products to identify and repair errors that impair existing intended functionality. 
      
      
   4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
      
      
   5. Comply with the applicable law. 
      
      
   6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if a consumer previously provided informed consent. 
      
      
   7. Comply with a legal obligation. 
      
      
   8. Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.
      
      
3. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Contacting us at info@coachnow.io or where available in the settings in the Mobile Application. We will provide instructions to accomplish this on request. Only a consumer, or a natural person or business entity registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child. A consumer or the consumer’s authorized agent may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
   
   
   1. Provide sufficient information that allows us to reasonably verify a consumer is the person about whom we collected personal information.
      
      
   2. If an authorized agent is being used, provide sufficient proof that the consumer has provided the authorized agent with permission to submit the request on the consumer’s behalf.
      
      
   3. Describe a consumer’s request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
      
      
   4. We cannot respond to a consumer’s or an authorized agent’s request or provide a consumer or authorized agent with personal information if we cannot verify the consumer’s or authorized agent’s identity and/or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided to us in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
      
      
   5. Response Timing and Format. We endeavor to respond to a verifiable consumer request within 30 days of its receipt. If we require more time, we will inform the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will choose a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.
      
      
   6. Charges. We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.
      
      
4. Shine the Light. California residents have the right to receive, once a year, information about third parties with whom we have shared their Personal Information for marketing purposes during the previous calendar year, and a description of the categories of Personal Information shared. To make such a request, please email us and include the phrase “California Privacy Request” in the subject line, along with your name, address, and email address. We will respond to you within thirty days of receiving such a request. You also have the right to opt-out of sales or sharing for cross-content behavioral advertising purposes.
   
   
5. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
   
   
6. Retention. We only retain Personal Information for as long as necessary for the purposes for which the Personal Information was collected, subject to the requirements of applicable law.
   
   
7. California Privacy Statement. This Privacy Statement For California Residents supplements the information contained in our Privacy Policy, and specifically the section entitled “Additional Information For Users Who Are California Residents”. We have adopted this statement to comply with the CCPA and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this statement.
   
   
   1. Information We Collect. We collect personal information. We have collected the categories of Personal Information indicated below within the last twelve (12) months:
      
      
      1. Identifiers, including name, Internet Protocol address, business email address, job title and department, business phone numbers (general, direct, and fax), business related postal address of consumer, and social networking URLs.
         
         
      2. Personal Information Categories Listed in the California Customer Records Statute, including name, business address, business telephone number, education, employment, employment history, and credit or debit card number.
         
         
      3. Commercial Information, including products or services purchased, obtained, or considered.
         
         
      4. Internet or Other Similar Network Activity, including Internet Protocol address and information on a consumer’s interaction with a website, application, or advertisement. 
         
         
      5. Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
         
         
      6. Professional or Employment-Related Information, including business email, business telephone number, business physical address, current or past job history, title, and educational information. 
         
         
      7. Inferences, which may be drawn from the information identified above to make predictions about your preferences and interests.
         
         
   2. Categories of Sources from which Personal Information is Collected. We collect Personal Information from the following categories of sources:
      
      
      1. Publicly available information
         
         
      2. First-hand research
         
         
      3. Submissions from customers or freemium product users
         
         
      4. Third-party data vendors
         
         
      5. Directly and indirectly from activity on Site and Mobile Application
         
         
      6. Directly and indirectly from our customers or their representatives
         
         
      7. Directly from vendors and other contractual counterparties
         
         
      8. Through communications with prospective customers and other
         
         
   3. Purposes for Collection of Personal Information. We collect and share Personal Information for the following business and commercial purposes:
      
      
      1. To fulfill or meet the purpose for which the information is provided.
         
         
      2. To provide the customer with information, products, or services that the customer requests.
         
         
      3. To provide the customer with email alerts, event registrations, and other notices concerning products or services, or events or news, that may be of interest.
         
         
      4. To carry out our obligations and enforce our rights arising from any contracts related to the Service, including for billing and collections.
         
         
      5. To improve the Site and Mobile Application.
         
         
      6. For testing, research, analysis, and product development.
         
         
      7. To protect the rights, property, or safety of ourselves, our Affiliates, our customers, and others.
         
         
      8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
         
         
      9. As described to the customer when collecting personal information or as otherwise set forth in the CCPA.
         
         
      10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding, in which personal information we hold is among the assets transferred.
          
          
      11. To modify, enhance, or improve products and services.
          
          
   4.  Third-Party Recipients. We may share personal information with the following third-party recipients, whom we require to provide the same level of privacy protection as is required under the Privacy Shield principles:
      
      
      1. Our Affiliates
         
         
      2. Our service providers and strategic partners
         
         
   5. Categories of Personal Information Disclosed for a Business Purpose. In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA:
      
      

      Category of Personal Information	Category of Third-Party Recipients and purposes
      	Business Purpose Disclosure	Sales Disclosure
      Identifiers	App usage tracking, marketing and product related communications, business metrics and reporting, App Functionality.	None
      Customer Records	App usage tracking, marketing and product related communications, business metrics and reporting, App Functionality.	None
      Protected Classification Characteristics	App usage tracking, Business metrics and reporting, Year end user stats highlights. Aggregate stats reporting to other Golf partners.	None
      Commercial Information	App functionality, App usage tracking, Business metrics and reporting, Year end user stats highlights. Aggregate stats reporting to other Golf partners.	None
      Internet Activity	Website usage reporting and authentication session management.	None
      Employment Information	None	None
      Education Information	None	None
      Biometric Information	Golf Swing Analysis through Swing ID.	None

      
      
      
   6. We Do Not Sell Personal Information. In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. “Sold” / "Sell" has the definition set forth in the CCPA. We do not collect, sell, or share Personal Information about consumers under the age of 16.