We at Trophy Golf LLC respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private.
As the owner and operator of www.trophygolf.com (the “Website”) and our mobile application Trophy Golf (the “App”), hereinafter referred to in this Privacy Policy as “Trophy Golf,” “us,” “our,” or “we,” we have provided this Privacy Policy to explain how we collect, use, share, and protect information about the users of our Website and mobile App (collectively referred to as “user,” “you” or “your”). We will not use or share your personal information with anyone except as described in this Privacy Policy.
This Privacy Policy will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled, and your rights with regard to your personal data.
For purposes of this Privacy Policy, “Your Information” or “Personal Data” means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”) and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific person, while sensitive data may include information, comments, content, and other information that you voluntarily provide.
Trophy Golf collects information about you when you use our Website or App to access our services, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The term Services includes, collectively, various applications, websites, widgets, email notifications and other mediums, or portions of such mediums, through which you have accessed this Privacy Policy.
From time to time we may change this Privacy Policy. If and when we make changes, we will notify you by posting the revised Privacy Policy on the Website and in the App. Those changes will go into effect on the “last updated” date shown at the end of this Privacy Policy. By continuing to use the Website or App or Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.
By accessing or using our Services, you consent to the collection, transfer, manipulation, storage, disclosure, and other uses of your information as described in this Privacy Policy. If you do not agree with or consent to this Privacy Policy you may not access or use our Services.
As our Services may be of interest to children under the age of 13 years old, we are committed to complying fully with the Children’s Online Privacy Protection Act (“COPPA”). Parents and guardians of children who are under the age of 13 should ensure that they understand our policies regarding personal information before entering any PII on or through the Website or App. We fully comply with COPPA, which requires us to take special precautions when collecting PII from children under the age of 13. In compliance with COPPA, we have adopted the following policies to keep children safe: (a) PII we collect from children under the age of 13 will be used solely by us or our agents for internal purposes only and will not be sold or otherwise distributed to third parties; (b) We will not knowingly allow children under the age of 13 to access any social media site that may exist on the Services, email accounts, or other services we provide that would allow them to publicly post or otherwise distribute PII; (c) We will not knowingly ask a child under the age of 13 to divulge more information than is needed to participate in any Services; (d) We will not knowingly keep any PII that is inadvertently included in a child's email submission, help inquiry, or other one-time request, if we know that the child is under the age of 13. Information will be automatically purged or purged immediately after the issue has been resolved; (e) We will not knowingly post any PII that is inadvertently included in a child's submission to a general audience contribution area if we know that the child is under the age of 13. These submissions will be deleted and handled anonymously thereafter; (f) We will not knowingly provide any direct link to websites that are unsuitable for children or teens; and (g) Upon request, we will provide a parent or guardian with a description of the information that may have been provided about their child during a registration process for a program, service or contest on the Service.
Consistent with COPPA, there are few instances where we will collect information from children, such as: (a) Requesting the contact information of a parent or guardian for the sole purpose of providing notification to the parent or guardian; (b) Collecting children’s contact information on a one-time basis, such as when they enter a contest or ask us a question using the "contact us" link on our Services. We will use this information on a one-time basis solely to directly respond to the child’s request; (c) Collecting a child's contact information and the contact information of his/her parent or guardian solely to directly respond more than once to a specific request from the child (for example, to satisfy the request for a newsletter subscription). The parent or guardian will have an opportunity at any time to revoke the child's request (i.e., unsubscribe). We will not use the child's personal information to re-contact the child for any other purpose; and (d) Using cookies to collect non-PII information on our Services for analytics and internal operations purposes.
We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, order a subscription to our Services, complete a form, survey, quiz or application, contact customer support, make a purchase, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, business address, phone number, photograph, credit card or other method of payment information, or any other personal information you choose to provide.
The following are situations in which you may provide Your Information to us: (a) When you fill out forms or fields through our Services; (b) When you register for an account with our Service; (c) When you create a subscription for our Services; (d) When you upload a score into your profile; (e) When you provide responses to a survey; (f) When you answer questions on a quiz; (g) When you join or enroll in an event through our Services; (h) When you order services or products from, or through our Service; (i) When you sign up for any newsletters or other materials through our Services; (j) When you provide information to us through a third-party application, service or Website; (k) When you communicate with us or request information about us or our products or Services, whether via email or other means; (l) When you participate in any of our marketing initiatives, including, contests, events, or promotions; and (m) When you participate in forums, reviews or provide or post user generated content or other submissions.
We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your account with a social media service, e.g. LinkedIn, Facebook or Twitter, or a payment provider, e.g. Apple Pay or Google Wallet, or if you engage with a separate app or website that uses our API, or whose API we use, we may receive information about you or your connections from that site or app. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.
Data use is intended to support play and the posting of scores. All handicap related data is the property of the the United States Golf Association® (“USGA”) and the Amateur Golfers’ Association® (“AGA”). We do not hold any handicap related rights or responsibilities to Users with a Handicap Index, whether an existing member or with a new member introduced through the USGA/AGA membership. By using our Company Services, you expressly consent to integrate your handicap data within our Company Services, and likewise consent to the USGA contacting you. You have the ability to revoke any access at any point in time.
We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and other users. This includes, without limitation, identity data, contact data, marketing and communications data, behavioral data, technical data and content data.
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data for the purposes of the General Data Processing Regulation (“GDPR”) as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.
When you visit our Services, we may send one or more Cookies—small data files—to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for recordkeeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. Cookies allow the Website and/or App to remember important information that will make your use more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Website and/or App regardless of whether you are logged in to your account or not.
Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Website and/or App. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Website and/or App. Persistent Cookies, on the other hand, remain in the Cookie file of your browser for much longer (though how long depends on the lifetime of the specific Cookie). When we use Session Cookies to track the total number of visitors to our Website and/or App, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data). We may also employ Cookies so that we remember your computer when it is used to return to the Website and/or App to help customize your web experience. We may associate personal information with a Cookie file in those instances. We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services. Third parties with whom we partner to provide certain features on our Website and/or App or to display advertising based upon your Web browsing activity use Cookies to collect and store information. Our Website and/or App may use remarketing services, such as Google AdWords to advertise on third party websites to previous visitors to our Website and/or App. It could mean that we advertise to previous visitors who haven’t completed a task on our Website and/or App. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use Cookies to serve ads based on your past visits to our Website and/or App. Any data collected will be used in accordance with our own privacy policy, as well as Google's privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager (https://adssettings.google.com/authenticated?hl=en). To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add- on, which is available by visiting Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout). You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie. You can easily delete and manage any Cookies that have been installed in the Cookie folder of your browser by following the instructions provided by your particular browser manufacturer. Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use our Website or App, but your ability to use some features or areas of our Service may be limited. We cannot control the use of Cookies by third parties (or the resulting information), and use of third party Cookies is not covered by this policy. We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or Website and/or App functionality, and to document your consent to receiving products, services or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as PII for purposes of this Privacy Policy. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No PII from your account is collected using these Web Beacons.
When you use our Services through your computer, mobile phone, or other device, we may collect information regarding and relating to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
When you use the Services we may collect your precise location data. We may also derive your approximate location data from your IP address.
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. To verify and authenticate the User’s identity, you agree to receive SMS messages from the Company and from any third party the Company chooses to work with.
We may use elect to use third party payment processing gateways to collect, store, and process payment information. If we do, we may update this policy to share how we collect and store payment information and whether we will store it on our Website, App, or servers.
The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:
When signing up to use our Services, you have given us explicit consent allowing us to provide you with our Services and generally to process your information in accordance with this Privacy Policy; and to the transfer of your personal data to other jurisdictions including, without limitation, the United States. It is necessary for entering into, or performing, the obligations of a contract between you and us, including, without limitation. It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in. It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back- ups of our databases; and communicating with you. To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support. To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. To send promotional communications that may be of specific interest to you. It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you. It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
Our primary purpose in collecting, holding, using, and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared. We will use this information in order to: (a) Provide users with our Services and customer support including, but not limited to, confirming emails and phone numbers related to our services, reminders, confirmations, requests for information and transactions; (b) To process transactions and send users related information, including confirmations and invoices; (c) Provide you with technical support, technical notices, updates, security alerts, disclosures and administrative messages; (d) Analyze, improve, and manage our Services and operations; (e) Resolve problems and disputes, and engage in other legal and security matters; and (f) Enforce any terms and conditions of any subscription for our Services. Additionally, we may use the information we collect about you to: (a) Send you communications we think will be of interest to you, including information about products, services, promotions, news, legal and regulatory disclosures, and events, where permissible and according to local applicable laws; (b) Display advertising, including advertising that is targeted to you or other users based on your location, interests, as well as your activities on our Services; (c) Verify your identity and prevent impersonation, spam, or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties; and (d) We may transfer the information described in this Privacy Policy to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Policy.
We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows: (a) With third party Service Providers to enable them to provide the Services you request; (b) With the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public; (c) With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate; (d) With our subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes; (e) With affiliated entities that provide payment processing services on our behalf; (f) With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf; (g) In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process; (h) With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, or safety of others; (i) In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; (j) If we otherwise notify you and you consent to the sharing; and (h) In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information. We may disclose Your Information: (a) To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney); (b) To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security. These companies are authorized to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential; (c) To third parties when you engage in certain activities through our Services that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party. When we disclose Your Information to these third parties, Your Information will become subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of Your Information; (d) As required by law or ordered by a court, regulatory, or administrative agency; As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another's rights or property, including, without limitation, our rights or property; (e) If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency; (f) To enforce this Privacy Policy, and any other applicable agreements and policies; and (g) To enforce or protect our legal rights.
We are committed to cooperating with law enforcement while respecting each individual’s right to privacy. If we receive a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency. Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), we may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. We will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.
Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. Any information or content that you voluntarily disclose for posting publicly to our Service or the social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to our Service or the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using our Service or the social sharing service, have re-shared, copied or saved that User Content.
We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use Cookies, Web Beacons, software development kits (SDKs), and other technologies to identify your device when you visit our Website and/or App and use our Services, as well as when you visit other online sites and services.
Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties that are beyond our control. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own Cookies to you and independently collect data. If you visit or access a third-party website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any PII. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.
In order to provide our products and services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please contact us at the email address in our Contact section below. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud or violated, we may seek to resolve the issue before deleting your information.
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. 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 any person who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and, in certain cases, updating or deleting such information. Furthermore, if you prefer that we do not share certain information as described in this Privacy Policy, you can direct us not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and, in certain cases, updating or deleting such information. Furthermore, if you prefer that we do not share certain information as described in this Privacy Policy, you can direct us not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine- readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us at the email address in our Contact section below.
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 3 years and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).
If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Data Officer Email: [email protected] Last updated: November 30, 2023