Summary

The following is a summary of our privacy and data practice. Please note that this summary is not intended to replace the full version of our Privacy Policy, but to help you better understand the key points about our collection and use of your Personal Data.

 

 

  • Who we are:  GOLFTEC Enterprises LLC and its group companies that provide GOLFTEC services in their respective regions collect and use your personal data in accordance with our Privacy Policy. For more details, see “Who we are” section of our Privacy Policy.
  • Type of the data we collect: When you use our services, we may collect some personal data about you, such as your identifiers, data about your golf game, geolocation data and other information obtained through your use of our services. For more details, see “Types of Personal Data Collected” section of our Privacy Policy.
  • How we use your personal data: We will use the collected personal data for various purposes: to contact and identify you, to provide and improve our services, to manage your account, to provide you with news and special offers, and other purposes described in “Use of Your Personal Data” section of our Privacy Policy.
  • Sharing of your personal data: We do not sell your personal data. Your personal data may be shared with third parties such as our service providers, affiliates and franchisees in providing services to youFor more details, see “Sharing of your personal data” section of our Privacy Policy.
  • Data security: The security of your personal data is important to us. While no technology can guarantee an absolute security, we take steps beyond what is legally required to keep your personal data safe.  For more details, see “Data Security” section of our Privacy Policy.
  • Children’s Privacy: We may collect personal data from children under the age of 13. We may require the parent’s consent before we collect your personal data if the laws of your country or region require us to do so. The parent who has given consent can review and delete the child’s personal data at any time. For more details, see “Children’s Privacy” section of our Privacy Policy.
  • Your Rights regarding Your Personal Data: You have the right to access, correct and delete your personal data we hold. For further details, please see “Your Rights Regarding Your Personal Data” section of our Privacy Policy.
  • How to Contact Us: If you have any question or concern about our Privacy Policy or our privacy and data practice, you can contact us at 877.446.5383 (toll-free number) or privacy@golftec.com. You may also contact us by mail. Please see “Contact Us” section of our Privacy Policy.

Privacy Policy

Who we are

For the purposes of this Privacy Policy, “GOLFTEC”, “we”, “our” and “us” include the following GOLFTEC group companies:

  • GOLFTEC Enterprises, LLC
  • GOLFTEC Canada Franchising, LLP
  • GOLFTEC Canada ULC
  • GOLFTEC Canada Holdings, Inc.
  • GOLFTEC Franchising LLC
  • GOLFTEC Franchise Services Inc.
  • GOLFTEC Management LLC
  • GDO GOLFTEC Inc.

    Types of Personal Data Collected

    While you use our Services, we may collect certain types of your Personal Data. We collect, and we have collected in the last 12 months, the following categories of Personal Data from Users.

    Personal information categories
    Examples
    Identifiers
    Examples: A real name, signature, postal address, email address, telephone number, unique personal identifier, online identifier, Internet Protocol address, device identifiers, account name, preferred language, other device identifiers including the operating system, browser type, network information, and other similar identifiers.
    Personal information described in Cal. Civ. Code §1798.80(e)
    Examples: A real name, signature, postal address, physical characteristics for golf play, and telephone number.
    Protected classification characteristics
    Examples: Age, gender identity.
    Commerical Information
    Examples: Purchase histories and tendencies.
    Biometric Data
    Examples: Items related to physical characteristics for golf play including, but not limited to, height and handedness.
    Internet Usage Information
    Examples: Information on your interaction with the Websites and Apps.
    Audio/video data
    Examples: Your swing will be recorded on video during your lessons. You may also, at your discretion, submit a video of your swing to the Websites or Apps.
    Geolocation data
    Examples: Your physical location, generally and specifically.
    Inferences drawn from other personal information
    Examples: Profile reflecting your preferences, characteristics, predispositions, and purchasing behavior.

    There may be additional Personal Data that we may collect but is not reflected by any of the categories listed above. Such Personal Date includes information you provide us about your golf game and your golf equipment.

    We collect those types of your Personal Data directly from you. Also, certain types of information may be collected automatically as explained below.

    Usage data

    When you use the Websites and the Apps, certain usage data is collected automatically. Usage data may include your device’s IP address, browser type, browser version, the areas of our Services that you visit, the time and date of your visit, the time spent on those areas, unique device identifiers and other diagnostic data.

    When you access the Services by or through a mobile device, we may automatically collect certain information such as the type of mobile device you use, your location (to provide you with location specific information), mobile device unique ID, mobile device’s IP address, mobile operating system, the type of mobile Internet browser, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device.

    Information collected while using the Apps

    While using Our Apps, we may collect information about your location and pictures and other information from your device’s camera and photo library. We collect those this information with your prior permission. You can enable or disable access to this information at any time, through the Apps’ device settings menu. You can also enable or disable location services at any time through your device’s device settings.

    Tracking technologies and Cookies

    We use cookies and similar tracking technologies to track your activities on our Services and store certain information when you use a web-based browser (“Cookies”). For the avoidance of doubt, we do not use Cookies to track your activities when you use our mobile applications.

    You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services.

    Cookies can be “persistent” or “session” Cookies. Persistent Cookies remain on your device when you go offline, while session Cookies are deleted as soon as you close your web browser.

    We use both session and persistent Cookies for the purposes set out below:

    • Necessary / Essential Cookies
      • Type:  Session Cookies
      • Administered by:  Us
      • Purpose:    These Cookies are essential to provide you with services available through the Websites and to enable you to use some of their features. They help to authenticate Users and prevent fraudulent use of Users’ Accounts. Without these Cookies, the services that you have asked for may not be available, and we only use these Cookies to provide you with those services.
    • Cookies Policy / Notice Acceptance Cookies
      • Type: Persistent Cookies
      • Administered by:  Us
      • Purpose: These Cookies identify if Users have accepted the use of Cookies on the Websites. 
    • Functionality Cookies
      •  Type: Persistent Cookies
      • Administered by: Us
      • Purpose:  These Cookies allow us to remember choices you make when you use the Websites, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Websites. 
    • Tracking and Performance Cookies
      • Type:Persistent Cookies
      • Administered by:  Third parties
      • Purpose: These Cookies are used to track information about traffic to the Websites and how Users use the Websites. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Websites. We may also use these Cookies to test new advertisements, pages, features, or new functionality of the Websites to see how our Users react to them.

    If you prefer to avoid the use of Cookies on the Websites, you can disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with the Websites. You may use this option for preventing the use of Cookies at any time.

    If you do not accept our Cookies, you may experience some inconvenience in your use of our Services and some features may not function properly. If You’d like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser.

    Google Chrome: https://support.google.com/accounts/answer/32050

    Microsoft Internet Explorer: http://support.microsoft.com/kb/278835

    Microsoft Edge: https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies

    Mozilla Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

    Apple Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

    For other web browsers, please visit your web browser’s official website.

    “Do Not Track” Policy

    Our Services do not respond to Do Not Track signals. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

    Use of Your Personal Data

    • To provide and maintain our Services, including to create and manage your Accounts, monitor the usage of our Services, and provide you with more personalized experience.
    • To process your requests and questions.
    • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
    • GOLFTEC represents the world’s greatest collection of information on the mechanics of the golf swing. Your Personal Data may be used in aggregate with other Users’ data for analysis to gain further insights into the mechanics of the game of golf.
    • To analyze, develop and improve our Services.
    • For the performance of a contract: the development, compliance and undertaking of the purchase contracts for the products, items or services you have purchased or of any other contract with us through the Service.
    • To contact you: to contact you by email, telephone, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
    • To provide you with news, special offers and general information about goods, services and events which we or our business partners offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
    • To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business, or to prevent or investigate possible wrongdoing in connection with our Services.
    • To protect the personal safety of Users or the public.
    • To respond to law enforcement requests, or as required by or to comply with applicable law, court order, or governmental regulations.
    • To protect and defend the rights for property of GOLFTEC or protect against legal liability.
    • As described to you when collecting your personal information.
    • As otherwise permitted by applicable law.

    Sharing of your Personal Data

    We may share your Personal Data by disclosing it to a third party for a business purpose, but we do not sell your Personal Data.

    In the last 12 months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

    Categories
    Categories of Third-Party Recipients
     
    Identifiers
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers, Ad Networks
     
    Personal information described in Cal. Civ. Code §1798.80(e)
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers
     
    Protected classification characteristics
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers, Other Users, Ad Networks
     
    Commercial Information
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Ad Networks
     
    Biometric data
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees
     
    Internet Usage Information
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers, Ad Networks
     
    Audio/video data
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Other Users
     
    Geolocation data
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers, Ad Networks
     
    Inferences drawn from other personal information
    Categories of Third-Party RecipientsGOLFTEC Group, Franchisees, Service Providers, Ad Networkss
     
    We share your Personal Data in the following situations:

    • With Service Providers: We may share your Personal Data with Service Providers to provide services, monitor and analyze the use of our Services, to contact you, or to process your payments
    • For Business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another person or entity or any other type of corporate reorganization.
    • With Affiliates: We share your Personal Data with GOLFTEC Group entities.
    • With Franchisees: GOLFTEC Franchising, LLC, GOLFTEC Canada ULC and GOLFTEC Franchise Services Inc. offer GOLFTEC franchises. Those franchisees (“Franchisees”), their staff and partners, have agreed to and are bound by the terms of this Privacy Policy.
    • With other Users: when you share Personal Data or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed outside. If You interact with other Users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see your name, profile, pictures and descriptions of Your activity. Similarly, other Users will be able to view descriptions of your activity, communicate with you and view your profile.

    Joint Use of your Personal Data among GOLFTEC Group and Franchisees

    As we share and use the above categories of your Personal Data together with GOLFTEC Group entities and Franchisees for the purposes described above, GOLFTEC Enterprises, LLC is responsible for their use of your Personal Data.

    GOLFTEC Enterprises, LLC
    Joe Assell, CEO
    67 Inverness Drive East, Suite A, Englewood CO

    International Transfer

    In the course of sharing your Personal Data, your Personal Data may be transferred from the country or region where you or the GOLFTEC Group entity which collected your Personal Data is located to a different country or region. For instance, your Personal Data will be shared among the GOLFTEC Group entities and Franchisees in the U.S., Canada, Japan, China, Hong Kong and Singapore. By agreeing to this Privacy Policy, you also agree to that transfer.

    The Company will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data.

    Third-Party Services

    We use Service Providers in connection with provision of our Services.

    • Google Analytics
      We use Google Analytics to monitor and analyze the use of our Services. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
    • Email Marketing
      We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, through Your GOLFTEC Clubhouse Account preferences or by contacting us. We may use certain email marketing Service Providers to manage and send emails to you. 

      • Braze
        Braze is an email, SMS and push notification sending service. For more information on the privacy practices of Braze, please visit their privacy policy: https://www.braze.com/privacy
      • Mailchimp
        Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their privacy policy: https://mailchimp.com/legal/privacy
    • Payment Services
      We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their respective privacy policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. Depending on your location, these payment processors may include one of the following: 

    • reCAPTCHA v3 
      We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from your device for security purposes. The information gathered by reCAPTCHA is held in accordance with the privacy policy of Google: https://www.google.com/intl/en/policies/privacy/

      • Facebook Insights
        We use the Facebook Insights function in connection with the operation of the Facebook Pages in order to obtain anonymized statistical data about our Users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Pages. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Pages and services by other companies that use Facebook services.

        For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy.[Nozomi1]

    Retention of Your Personal Data / Data Security

    We retain you Personal Data only for as long as is necessary for the purposes set out in “Use of Your Personal Data” section.

    The security of your Personal Data is important to us, and we have taken steps beyond what is legally required to keep your Personal Data safe. However, please understand that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

    Children’s Privacy

    The Services may contain content appropriate for children under the age of 13. As a parent or legal guardian (as used in this section, “parents”), you should know that through the Services children under the age of 13 may participate in activities that involve the collection or use of Personal Data. We use reasonable efforts to ensure that before we collect any Personal Data from a child, the child’s parent receives notice of and consents to our privacy practices.

    We also may limit how we collect, use, and store some of Personal Data of Users between 13 and 18 years old. In some cases, this means that we will be unable to provide certain functionality of the Services to these Users. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, We may require your parent’s consent before we collect and use that information.

    We ask Users to or during the first lesson. If the User is under the age of 18, the Service will be either blocked or redirected to a parental consent process.

    We do not knowingly collect Personal Data from children, but we may collect and store persistent identifiers such as Cookies or IP addresses from children without parental consent as they use our Services.

    Parents who have already given us permission to collect and use their children’s Personal Data can, at any time:

    • Review or correct the child’s Personal Data
    • Request all of the child’s Personal Data to be deleted from our systems. However, since the Personal Data collected is necessary for us to provide our Services, this will mandate we close your child’s Account with us.

    These can be accomplished in the GOLFTEC Clubhouse account for the child (accessible via the parent’s Account), or you can contact us (please see “How to Contact Us” section)

    Your Rights Regarding Your Personal Data

    Your rights regarding your Personal Data

    We undertake to respect the confidentiality of your Personal Data and to guarantee that you can exercise your rights listed below under this Privacy Policy, and by Your local law if applicable:

    • The right to know Your Personal Data
      The right to know the Personal Data we have collected, used and/or disclosed on you in the previous 12 months. Whenever made possible, you can access your Personal Data directly within your GOLFTEC Clubhouse account settings section.If you are unable to perform this action yourself, please contact us to assist you. We will disclose and deliver categories and/or specific pieces of your Personal Data that we have collected, used and/or disclosed, free of charge, but to the extent such disclosure is required under the applicable law.
    • The right to request correction of your Personal Data that we hold
      You have the right to have any incomplete or inaccurate information we hold about you corrected. In many instances, you can enact these updates in your GOLFTEC Clubhouse account or you can request changes be made by contacting us.
    • The right to request deletion of Your Personal Data
      You have the right to ask us to delete or remove all of your Personal Data. Since the Personal Data collected is necessary for us to provide our Service to you, this will mandate We close Your account with us.
    • Right to Non-Discrimination
      You have the right to be free from discrimination by us as a result of the exercise of your rights under this section.
    • The right to withdraw Your consent
      You have the right to withdraw your consent regarding use of Your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Services.

    Exercise of your right and verification

    To exercise your rights under this Privacy Policy or applicable law, please contact us. For our contact information, please see “How to Contact Us” section below.

    Before we respond to your request to know, correct or delete your Personal Data, we may request you to verify your identity, which process may include submission of your Personal Data such as the data that you have registered on your Account and/or a copy of your government-issued identification document.

    Response Time

    We will confirm receipt of your request within 10 business days. We try to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

    Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable request.

    Authorized Agent

    You may use an authorized agent to submit a request to know, correct or delete your Personal Data. To designate an agent for these purposes:

    • You must provide us with a copy of a written and signed power of attorney given to your authorized agent; and
    • You must verify your own identity directly with us.

    Change to the Privacy Policy

    From time to time, we may change this Privacy Policy. We will notify you of any changes by posting the new Privacy Policy on this page.

     We will let you know via email and/or a prominent notice on our Services and update the “Last updated” date at the top of this Privacy Policy. If a change is material, we will provide at least 30 days’ notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

    You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

    How to Contact Us

    If You have any questions about this Privacy Policy, you can contact the GOLFTEC Privacy Office through one of the means below:

    • North American Toll Free:  877.4.GOLFTEC (877.446.5383)
    • Global Headquarters: +1 303.379.6668
    • Online Privacy Inquiries:  https://www.golftec.com/privacy
    • Global Privacy Office Email:  privacy@golftec.com
    • By mail:
      GOLFTEC Enterprises, LLC
      Attn: Global Privacy Office
      67 Inverness Drive East, Suite A
      Englewood CO, 80112 USA

     

    Definitions

    Account” means a unique account created for you to access our Services.

    Apps” means the software programs provided by GOLFTEC, which are downloadable on your electronic devices, including GOLFTEC Clubhouse App.

    Do Not Track” or “DNT” means a web browser setting that requests that a web application disable its tracking of an individual user.

    Facebook Pages” means public profile pages created by GOLFTEC or Franchisees on the Facebook social network.

    GOLFTEC”, “we”, “our” and “us” mean the companies listed in “Who We Are” section.

    GOLFTEC Group” means the group of the companies defined as GOLFTEC and Golf Digest Online Inc.

    Personal Data” means any information that relates to an identified or identifiable individual. Personal Data includes any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

    Services” means the services we provide to you, including golf lessons, fitting and other services we provide at our centers or online, and our Websites and Apps and online services provided on those Websites and Apps.

    sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a user’s Personal Data to another business or a third party for monetary or other valuable consideration.

    Service Provider” means any natural or legal person who processes the data on behalf of us. Service Providers may be employed by us to facilitate the Services, to provide the Services on behalf of us, to perform services related to the Services or to assist us in analyzing how the Services are used.

    Third-party Social Media Service” means any website or any social network website through which a User can log in or create an account to access some content created by GOLFTEC.

    User” or “you” means the individual accessing or using the Services, or the company or other legal entity on behalf of which the individual is accessing or using the Services.

    Websites” means the GOLFTEC website and the GOLFTEC Clubhouse website. Localized versions of these websites are accessible at: