Privacy Policy

Game Your Game Inc. ("Game Golf", "we", "us" or "our") provides online and mobile services, including our mobile application (the "App"), website ("gamegolf.com" or the "Site"), and other mobile-communications and web-based services intended to enhance your use of the Game Golf products (the "Products"). We recognize the importance of your privacy and strive to be straightforward regarding our policies with respect to your personally-identifiable information.

This privacy policy ("Privacy Policy") describes the privacy practices for our devices, applications, software, websites, products, and services (collectively, the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

This Privacy Policy supplements and forms a part of our Website Terms of Use ("Terms of Use"), available here. Capitalized terms not defined in this Privacy Policy (if any) have the meanings set forth in the Terms of Use.

PERSONAL DATA WE COLLECT

When you use our Products and Services, we collect the following types of personal data in the following ways.

Information You Provide to Us

Communications With Us

We may collect information from you, such as your name, email address, phone number or mailing address, when you choose to request information about our Products and Services, register to receive Game Golf newsletters and other communications by email, participate in promotions or loyalty programs that we may offer from time to time, request to receive support or otherwise communicate with us.

User Account Information

Some information is required to create an account on our Services, such as your name, username, email address (which will be your login ID), password, date of birth (which we use to verify your age), and payment information.

If you choose to register for an account using your social media or other third-party credentials (if applicable), you will be asked to allow Game Golf access to information accessible from such third-party site, such as your name, date of birth, profile picture, gender, networks, third-party site user ID, and other content and information.

Purchases and Membership

If you purchase Products directly from Game Golf or register for our Services, you provide your payment information, including name, credit or debit card number, card expiration date, CVV code, and billing address. 

Your credit or debit card information is processed by an e-commerce platform or payments processor and we do not collect, store or maintain this information. Those platforms or processors may retain this information in accordance with their own privacy policies and terms.

Additional Information

User Content: You may choose to provide additional information such as your profile photo. For example, if you choose to complete your user profile, your first and last name (or fictitious names that you may provide) and username are included on your profile page and in search results. Your golf handicap is automatically included on your profile page. You may also post or share other content and information through the Services, such as data, images, comments, location information, and other information ("User Content"). You can modify and correct this information by logging into your account.

Other Information You May Share: You may share information with us through features of the Services to help you find people you know and connect with other services. For example, you may choose to upload information from your contacts or to connect your Game Golf account to third-party services such as Facebook or Twitter. Game Golf will match the information you provide with the contact information provided by other users. When you connect your Game Golf account to other services, you may post your User Content to those services.

You may disconnect your Game Golf account from third-party services at any time. When you disconnect one of your third-party services from your Game Golf account, we will take reasonable steps to delete information obtained from that connection other than publicly-posted User Content.

Information You Share with Other Users and Services: If you choose to share information from your account with others, we will collect personal data you provide about your contacts, such as name and email address. You may choose to share your Golf Data and related statistics and analytics with others, but only as permitted by, and using the facilities of, the Game Golf Dashboard.

You also have the option to publicly share your profile information and other User Content with other users and third-party services. Publicly sharing this information is optional.

Information We Receive from Third Parties

Services: If you choose to connect your account to another service, we may receive information from the other service. For example, if you connect to Facebook or Twitter, we may receive information from those services such as your name, profile picture, language, email address, and friend list. You can stop sharing the information from the other service with us by removing our access to that other service.

Other Users: Other users may provide information about you when they choose to share information from their accounts with you, and we may collect your name, username, or email address.

Automatically Collected Information

Golf Data:  In connection with your use of Products and the App, the following Golf Data is collected:

Geolocation Data:  The App uses your mobile device to collect precise geolocation data from the Global Positioning System. We may also derive your approximate location from your IP address. 

You must first enable location services in the App. You may disable location services within the App at any time. Disabling location services may impact or eliminate certain functionalities in the App and other Products and Services.

Camera:  We use your mobile device’s camera to enable you to add a Profile picture to your account.

Other Sensors:  We may also collect Golf Data from other sensors on your mobile device, for example the accelerometer, gyroscope and barometer.

Log Data: We collect log data about the browser and operating system you are using, the address of the external or internal page that referred you, your IP address at the time of account creation, and the IP address associated with the device running the App each time you sync. We also keep a log of the pages that you visit on the Services in association with your IP address. We may also collect information about your access times, pages viewed, search terms, mobile carrier, device type, device IDs, application IDs, and version of the App. We may also collect information on how you access and interact with the Services, such as email notifications and third-party services.

We collect this information to generate statistics about use of the Services and use the results to customize as well as improve the overall quality of the Services. In general, we either delete log data or remove any personal identifiers, such as your name, username, email address, or IP address to protect your privacy.

Cookies: We use cookies and similar technologies for the purposes described above. For more information, please read our Cookie Policy.

Third-Party Products or Services

Third parties may offer separate products and services through advertisements on our App or Site and through the Services that may be complementary to your use of our Products and Services, such as golf attire and equipment, training materials, or related products and services. If you choose to use these separate products or services, disclose information to the providers, or grant the third parties’ permission to collect information about you, their use of your information is governed by their privacy policies and not by the Game Golf Privacy Policy.

HOW WE USE PERSONAL DATA

The following describes how we use the personal data that we collect.

Provide Our Products and Services

We use information we collect to provide you with our Products and Services. We use your Golf Data to track your performance and provide you (and if you choose, others) with Services. We may also use your information to administer your account, send push notifications when you are using the Services, send you text messages, and connect you with other people who may use the Services. We use information we collect to tailor our Services to you, including to assess your needs and determine suitable content and Services, and to provide content based upon your interests. 

We may use information we collect to ship Products to you, notify you about changes to our Terms of Use or related policies, and to provide information about our Products and Services. We also use information we collect to respond to questions, concerns and customer service requests, and to send you promotional communications by email and/or text message.

We use information to customize content available on the Services and to improve the quality of advertisements that offer third-party products and services. We also use information we collect to tailor the promotional communications we send you. You can opt out of promotional communications through a link provided in the communication.

Maintain And Improve Our Products and Services

We use information we collect to conduct research and analysis relating to our Products and Services, and to improve the overall experience of all of our users. We also use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.

We may use aggregate, de-identified location or other data, alone or in the aggregate with information obtained from other sources, to help us improve our Products and Services or develop new products and Services, or to share and report statistics through the Services. For example, we may use Golf Data to determine and display the average drive length of App users on a given hole. 

Promote Safety and Security

We use the information we collect for other legitimate purposes to promote the safety and security of our Products and Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing personal data to provide our Products and Services, for purposes of our legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

HOW WE SHARE PERSONAL DATA

We may share your information as described in this Privacy Policy or with your permission.

When You Agree or Direct Us to Share

You may direct us to disclose your information to third parties. For instance, you may have the Services share your information with other users. You may also direct us to share your information in other ways, for example, when you give a third-party application access to your account. For example, if you connect your account to Facebook or Twitter, we may disclose your information to those applications.

Service Providers

We transfer information to our service providers who process it for us, based on our instructions, and in compliance with this Privacy Policy, applicable law, and appropriate confidentiality and security measures. These service providers provide us with services including customer support, information technology, payments, sales, marketing, data storage and analysis, research and surveys.

We may share the information we collect with companies that provide support services to us (such as printers, e-mail providers, marketing services, analytics providers, web hosting providers, call center/chat providers, sweepstakes vendors, payment processors, data enhancement services, fraud prevention providers or shipping services providers, including product vendors) or that help us market our products and services. These companies may need information about you in order to perform their functions. We limit information shared with service providers to what is necessary to fulfill the services.

Professional services providers such as golf coaches that have created a special account to engage in Permitted Professional Use of the Dashboard have access to Game Golf App Users’ Golf Data and certain User Information.

Non-identifiable Or Aggregate Information

We may share non-identifiable or aggregate information with third parties for lawful purposes such as market research and targeted advertising.

Public Information

We may share or disclose your public information, including your public profile information such as your name, username and profile picture, as well as any other information on your profile that you choose to make public. Public information also includes content, such as data from your use of the Products, that you choose to share on or through the Services, as well as your interactions with content shared by others.

Legal Requirements

We may disclose information we collect when we believe disclosure is appropriate to comply with the law; to enforce or apply applicable terms and conditions and other agreements; to prevent, detect, or investigate illegal activity, fraud, or abuse; to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or disposal of all or part of our business or assets; or to protect the rights, property or safety of our company, our customers and others.

Subsidiaries, Affiliates and Partners

We share the information we collect with Game Golf subsidiaries and affiliates, such as Active Mind Technology Limited, our 100% Irish subsidiary. We also may share information with business partners, such as retailers and manufacturers of golf equipment, with whom we may jointly offer our Products and Services, or whose products or services we believe may be of interest to you.

Business Transfers

In connection with the sale or transfer of some or all of our business assets, we may transfer personal information. We also may retain a copy of that information.

ACCESS AND CONTROL OF YOUR PERSONAL DATA

We provide account settings and tools to access and control your personal data regardless of where you live. If you live in certain jurisdictions, you may also have legal rights with respect to your information.

You can access some of the information that we collect about you. If you are a currently-registered user, you may access or modify your personally-identifiable information at any time by signing into your account. You may access or modify your communications preferences by following the instructions included in any communications you receive. Administrative communications concerning the Services are provided to all registered users and considered to be a part of the Services.

You may modify or delete your information or User Content, subject to limitations, through your account. You can also permanently delete your Game Golf account by contacting us. We take reasonable steps to remove personally-identifiable information and other information associated with your account promptly after you delete your account. In certain circumstances, however, Game Golf may be unable to remove some of your information and User Content, such as information you post through the Services to other services or otherwise publicly share.

Depending on your location, you may have the right to file a complaint relating to our handling of your personal data with the data protection authority in your country. For example, users in the European Union may submit such requests to the data protection authorities in the country in which they live.

DATA RETENTION

We keep your account information, such as your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. For instance, if you provide your contact list for finding friends on the Services, we will delete the list after it is used for adding contacts as friends. We keep other information, like your performance data, until you use your account settings or tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm.

 

ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications. To learn more, please read our Cookie Policy.

 

CHILDREN

Our Services are not directed to children under the age of 13 and Game Golf does not knowingly collect personal data from children under 13. If you believe your child under the age of 13 has provided Game Golf with personal data without your consent, please contact 

us. If we become aware that a child under 13 (or under the age of 16 in certain jurisdictions) has provided us with personal data, Game Golf will take reasonable steps to delete the personal data as soon as possible and terminate the child's account.

HOW WE PROTECT YOUR INFORMATION

We take reasonable measures to protect and secure your personal data against unauthorized access or disclosure. We cannot guarantee, however, that these security measures will protect your information from hackers or human error. We review our business practices periodically for compliance with policies and procedures governing the security of our information.

To register with the Services, you will be required to select a password to protect your account unless you choose to register your account using a third-party service (if applicable). You are responsible for maintaining the security of your login ID and password. If you believe that your login ID or password have been compromised you should immediately change your password. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of this Privacy Policy or our Terms of Use.

INTERNATIONAL OPERATIONS AND DATA TRANSFERS

You agree that all personal information that we collect may be transferred, processed and stored anywhere in the world, including but not limited to, the United States, Canada, the United Kingdom, the European Union, in the cloud, on our servers, on the servers of our affiliates or on the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities as described above. By providing information to Game Golf, you explicitly consent to the storage of your personal information in any of these locations.

EUROPEAN PRIVACY DISCLOSURES

Data Controllers

Game Golf is the data controller for the personal data collected in connection with use of our Products and Services in the European Economic Area (the “EEA”), the United Kingdom and Switzerland.

Lawful Basis for The Processing of Personal Data

For personal data subject to the General Data Protection Regulation (“GDPR”), we rely on several legal bases to process the data, including:

  • When you have given your consent, which you may withdraw at any time using your account settings and other tools or by contacting us;

  • When the processing is necessary to perform a contract with you, like the Terms of Use; and

  • Our legitimate business interests, such as in improving, personalizing, and developing our Products and Services, marketing new features or products that may be of interest, and promoting safety and security.

Further information about our processing of personal data can be found above in the section entitled How We Use Personal Data.

Data Subject Rights

If you are a resident of the European Union (the “EU”), you have rights that you can exercise under certain circumstances in relation to your personal data that we hold. These rights are to:

  • Request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;

  • Request rectification of your personal data;

  • Request the erasure of your personal data;

  • Request the restriction of processing of your personal data;

  • Object to the processing of your personal data.

  • You also have the right to receive your personal data in a structured, commonly used and machine-readable format and to have us transmit your personal data to another controller, if you have provided your personal data to us, and if the processing is based on consent or is necessary for the performance of your agreement with Game Golf, and the processing is carried out by us by automated means, subject, however, to legal restrictions which may apply.

If you want to exercise one of these rights, please contact us.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state. The EU Commission has a list that can be obtained here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact us as described below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case we process your personal data for direct

marketing purposes, you have the right to object at any time, in which case we will no longer process your personal data for such marketing purposes.

If your personal data has been shared with one or more Game Golf business partners or otherwise as provided above, you will need to contact each such entity separately to withdraw your consent.

CHANGES TO THIS POLICY

We may revise this Privacy Policy from time to time. The most current version, which you should periodically review, is always available here. If we make a change to our Privacy Policy that, in our sole discretion, is material, we will notify you via email to the email address registered with your account or, in appropriate circumstances, through the Services (e.g., notification upon accessing the App, Site, or other web-based services).

By continuing to access or use the Services after those changes become effective, you consent to the terms of the revised Privacy Policy.

HOW TO CONTACT US

If you have questions about this policy, or wish to exercise your privacy rights, please contact us at: 

Email:  support@gamegolf.com 

 

Game Your Game, Inc.

2479 E. Bayshore Road

Suite 195

Palo Alto, CA 94303

United States

 

Notifications
Identification
Active Mind Technology Ltd. T/A GameGolf is the data controller for this website. This policy is established to provide you with a clear understanding of how we manage the data we collect through this website, with consideration for security and protection of Personally Identifiable Information (PII).

Representative
Dominic Poole is the nominated management representative for the management of relevant data processing aspects, applicable to this website.

Collection
The data we collect from users of this website is as follows:
  • Personal identifiers, including; name, mobile phone number, email address
  • Data submitted voluntarily where the user elects to to provide feedback or make a complaint
  • Cookies data via the user's browser settings
  • IP address
  • Browsing behavior on which pages the user navigates to and wherever ever user clicks on pages


  • Usage
    We process your data for the following purposes:
  • Where the user is required to login to purchase our products and services
  • To process payments made for our products and services
  • To process requests for appointments and calendar bookings
  • To process user enquiries sent via the contact form, including feedback and complaints
  • To enroll users in marketing communications, such as; newsletters, product launches, marketing campaigns, etc
  • To deliver device hardware ordered from our E-Com site


  • Recipients
    Data submitted through this website is directed to the appropriate department to meet the requirements of the processing, as described above. All personnel involved in the processing of data, including PII, are committed to confidentiality and non-disclosure by contractual arrangement. Where necessary, recipients of submitted data will be to external parties, as documented below.

    Storage
    Data submitted through this website is stored on our secure information systems, as follows:
  • E-Com https://www.shopify.com/


  • Retention
    We retain users' data for the duration of the processing, extending to not longer than 12 months subsequent to the purpose of the processing. Exceptions to this policy include:
  • Where we need to maintain an account for user's, which will require us to keep records of relevant account activity
  • Where we are required by law to retain transactional information with regard to user's purchases or our products and services
  • Where there is a need to maintain a record of customer preferences, including where appropriate, personal information submitted by the user
  • Regular evaluation of our information systems provides for the effective management of this retention policy, ensuring that applicable personally identifiable information (PII) is purged according to established controls.

    Transfer
    Internally, access to data is provided to only those parties who are involved with the direct processing of user enquiries, purchases, etc.
    To provide for an excellent user experience, we engage with the following third party providers, through the use of website plugins and other embedded applications, as follows:
  • https://www.paypal.com/ - Payment Processor
  • https://www.zendesk.co.uk/ - Customer Support
  • Order fulfillment
  • https://www.klaviyo.com/ - Marketing & E-Com Automation
  • https://www.privy.com/ - Email and SMS messaging
  • https://loox.app/ - Product Reviews
  • https://adoric.com/ - Email Automation
  • Shopify ECom & Plugins
  • This website contains links to external websites which are outside of our control. Please read the privacy information for the destination website should you select one of these externally linked websites.

    Contact
    For any queries regarding this policy or the stated controls, please contact us:
  • By completing this form https://shop.gamegolf.com/pages/contact-us
  • By sending an email to support@gamegolf.com
  • By writing to us:
  • Forramoyle West
  • Barna,Galway,Ireland
  • Choice
    Opt-in & Opt-out
    For user information submitted through this website, consent is obtained at the point of submission. Where the user subsequently decides to opt-out, withdrawing their consent, this is done by making direct contact, by the various means documented above.
    Access & Correction
    Rectification, Erasure & Restriction of Processing Rights of Data Subjects
    We are committed to ensuring that our obligations toward the data protection rights of users of this website are effectively met, as follows:
  • The right to access: All user data stored on our information systems is available to the data subject upon request by contacting us directly as documented above. Typically, we provide this data in digital format sent to the user provided email address, unless other specific arrangements are agreed
  • The right to rectification: Where a user identifies that stored information is inaccurate, this can be easily corrected by direct contact, as above
  • The right to erasure: Where relevant conditions are met, users of this website can request that their personal data is erased by direct contact, as above
  • The right to restrict processing: Where relevant conditions are met, users of this website can request that the processing of their data is restricted to specific purposes
  • The right to object to processing: Where relevant conditions are met, users of this website have the right to object to their data being processed in any manner
  • The right to data portability: Users of this website can request that their data is transferred to a third party organization nominated by them, by direct contact, as above
  • Upon receipt of a user request to exercise any of these data protection rights, we are committed to responding to meet our obligations within the earliest practicable timeframe, which will not exceed 30 days.
    Security
    Controls
    To ensure that user information submitted through this website is always managed securely, we have implemented technical and organizational measures, appropriate to the nature of the processing and the data being processed.
  • All personnel assigned to processing activities are subject to confidentiality and non-disclosure clauses in their contracts of employment
  • Information systems are secured with various controls, including:
  • Encryption of data repositories and endpoints
  • Malware Protection
  • On all Employee Devices - https://www.f-secure.com/en
  • To provide a framework for best practice through our organization with regard to information and privacy security management, we have implemented a formal management system which is closely aligned to ISO 27001. We regularly review this privacy policy to ensure it remains suitable and effective in communicating all relevant privacy information, as required by our website users and applicable legislation.
    Enforcement
    Reporting
    Users of this website who would like to request information, enforce their rights as data subjects, make a complaint, or other relevant matters, are advised to seek a remedy from us in the first instance, by contacting us directly as documented above.
    If our response does not adequately meet the expectations of the user (data subject), please contact the National authority:
    Data Protection Commission
    21 Fitzwilliam Square South
    Dublin 2
    D02 RD28
    https://www.dataprotection.ie/
    Cookies
    General Information
    Cookies are small pieces of data stored on a site visitor's browser. They are typically used to keep track of the settings users have selected and actions they have taken on a site. Our website uses first-party and third-party cookies for several purposes.
  • First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
  • The third-party cookies used on our website are mainly for:
  • understanding how the website performs
  • understanding how you interact with our website
  • keeping our services secure
  • providing advertisements that are relevant to you
  • providing you with a better and improved user experience and help speed up your future interactions with our website
  • Click on the “Manage consent” link at the bottom of this page, to manage your cookie preferences.

    Third party processors
    Cookies deployed to manage links to third party processors, as notified above, are described in the cookies settings management section of this website. Please click on the "Cookies settings'' button at the bottom of this page to review and manage relevant cookies.

    Guidance on Erasing Cookies
    The following links explain how to access cookie settings in various browsers:
  • Cookie settings in Firefox: http://support.mozilla.com/en-US/kb/Enabling%20and%20disabling%20cookies
  • Cookie settings in Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-de lete-manage-cookies
  • Cookie settings in Google Chrome: http://www.google.com/support/chrome/bin/answer.py?answer=95647
  • Cookie settings in Safari (OS X)http://support.apple.com/kb/PH17191?viewlocale=en_US&locale=en_US
  • Cookie settings in Safari (iOS):https://support.apple.com/en-us/HT201265
  • Cookie settings in Android:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAnd roid&hl=en&oco=0
  • To opt out of being tracked by Google Analytics across all websites, visit this link:http://tools.google.com/dlpage/gaoptout