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.
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.
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.
Third-Party Products or Services
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 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
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.
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.
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.
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.
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.
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
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.
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
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;
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
HOW TO CONTACT US
If you have questions about this policy, or wish to exercise your privacy rights, please contact us at:
Game Your Game, Inc.
2479 E. Bayshore Road
Palo Alto, CA 94303