Effective as of Feb 15, 2020
Thanks for choosing http//aboutgolf.com and the aG mobile application which is available for download on your mobile device (the “aG Services”) for your Golf experience!
We want to give you the best possible experience on the aG Services to ensure that you enjoy our services and content today, tomorrow, and in the future. To do this we may seek to understand who you are, so we can deliver exceptional and personalized services specifically for you. Your privacy and the security of your personal data is, and will always be, important to aG. So, we want to transparently explain how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.
For the purposes of EU data protection laws (« Data Protection Law »), aG is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- a) Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- b) Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the aG Services and Content; and
- c) Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 14 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the aG Services and Content.
3. YOUR RIGHTS AND YOUR PREFERENCES: GIVING YOU CHOICE AND CONTROL
You may be aware that a recent European Union law, called the General Data Protection Regulation or « GDPR » gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls in our Privacy Center and Privacy Settings to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- a) Right of Access – the right to be informed of and request access to the personal data we process about you;
- b) Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- c) Right to Erasure – the right to request that we delete your personal data;
- d) Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- e) Right to Object –
- (i) the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- (ii) the right to object to your personal data being processed for direct marketing purposes;
- f) Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- g) Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how aG uses your personal data, we provide you with access to the following settings via your Account Settings page:
- a) Privacy Settings – allows you to control some of the categories of personal data we process about you and enables you to access your personal data, and,
- b) Notification Settings – allows you to choose which communications you receive from aG, manage your publicly available personal data, and set your sharing preferences.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this Policy.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If aG sends you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from aG (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails sent to you).
If you have any questions about your privacy, your rights, or how to exercise them, please contact us. We will respond to your request within a reasonable period of time upon verification of your identity.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data in the following ways:
- a) When you sign up for the aG Services – when you sign up to the aG Services, we may collect certain personal data such as your email address, birth date, gender, and country.
- b) Through your use of the aG Services and Content – when you use the aG Services, we may collect personal data about your use of the aG Services, such as what games or golf courses you have played.
- c) Personal data collected that enables us to provide you with additional features/functionality – from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. As described further below, we will not collect photos, precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.
- d) From third parties – we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with the aG Services and Content (please see ‘Sharing your personal data’ Section 7 below). We will use this personal data either where you have provided your consent to the third party or to aG to that data sharing taking place or where aG has a legitimate interest to use the personal data in order to provide you with the aG Services and Content.
We use anonymized and aggregated information for purposes that include testing aG IT systems, research, data analysis, creating marketing and promotion models, improving the aG Services, and developing new features and functionality within the aG Services.
5. WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We have set out below the categories of personal data we collect and use about you:
a) Personal data collected when you sign up for the aG Services
This is the personal data that is provided by you or collected by us to enable you to sign up for and use the aG Services. This includes your email address, birth date, gender, postal code, and country. Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized. The exact personal data we will collect depends on the type of aG Services Membership plan to which you subscribe, and whether or not you use a Third Party Service such as Facebook to sign up and use the aG Services. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.
b) aG Service Usage Information
Personal data that is collected about you when you are using the aG Services may include:
- (i) Information about your type of aG Membership plan.
- (ii) Information about your interactions with the aG Services which includes the date and time of any requests you make, games and courses you have played, video content you’ve watched, and your interactions with others aG users. This also may include details of your use of third party applications and advertising you may receive.
- (iii) User content you post to aG including messages you send and/or receive via aG and your interactions with the aG Customer Service team.
- (iv) Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the aG Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and aG application version.
- (v) Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the aG Services and Consent to you.
- (vi) Personal data collected with your permission that enables us to provide you with additional features and functionality.
c) Categories of Personal Data
In addition to the mobile data we collect to provide you with the aG Services, also have the option to give aGs your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your aG Services experience. We will not access any of the personal data listed below without first obtaining your consent:
- (i) Your photos – If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll;
- (ii) Your precise mobile device location – If you give aG permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the aG Services. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements;
- (iii) Your voice data – If you give us permission, this enables us to access the voice commands captured via your device microphone to enable you to interact with the aG Services with your voice. Please note you will always have the ability to turn off the microphone feature; and,
- (iv) Your contacts – If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use aG Services.
d) Payment Information
We may collect such personal data if you purchase any of our Membership Subscriptions and other purchases through the aG Services. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
- (i) Name;
- (ii) Date of birth;
- (iii) Credit or debit card type, expiration date, and certain digits of your card number;
- (iv) Postal code;
- (v) Mobile phone number; and
- (vi) Details of your transaction history.
If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices.
e) Contests, Surveys and Sweepstakes Data
This personal data is used to allow you to sign up and participate in promotions. The exact personal data collected will vary depending on the promotion. The exact personal data collected will vary depending on the promotion.
f) Marketing Data
This personal data is used to enable aG and its partners and service providers to send you marketing communications by email, while using the aG Services and or directly from a third party.
6. LEGAL BASIS FOR PROCESSING
The purposes for which we process your personal data are:
- a) the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
- b) where it is necessary for compliance with our legal obligations laid down by EU law;
- c) where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
- (i) to contact you and respond to your requests and enquiries;
- (ii) for business administration, including statistical analysis;
- (iii) to provide the aG Services to you;
- (iv) for fraud prevention and detection; and
- (v) to comply with applicable laws, regulations or codes of practices.
7. SHARING YOUR PERSONAL DATA
We have set out the categories of recipients of the personal data collected or generated through your use of the aG Services.
a) Publicly available information
The following personal data will always be publicly available on the aG Services: your name and/or username, profile picture, who you follow and who follows you on the aG Services, your recently played games and courses.
b) Personal data you may choose to share
The following personal data will only be shared with the categories of recipients outlined in the table below if:
- (i) you choose to make use of a specific aG Services feature where sharing of particular personal data is required for the proper use of the aG Services feature; or
- (ii) you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the aG Services.
c) Categories of Recipients
(i) Third Party Applications you connect to your AG Account.
Reason for sharing: If you connect your aG account to a Third Party Application, such as, for example, social media, audio, television, or automotive platforms, aG may share your service usage data so you can connect to your aG account.
(ii) Third Party Applications you use to log into AG.
Reason for sharing: If you log into a Third Party Application using your aG account credentials, then that Third Party Application may have access to certain service usage data such as your saved content and activity. You will receive a notification before connecting to the Third Party Application to let you know what personal data will be shared or accessible to that Third Party Application.
(iii) Your aG Followers.
Reason for sharing: There also may be times when you want aG to share certain service usage data, specifically information about your use with other aG users.
(d) Service Providers and Others
Reason for sharing: aG uses technical service providers which may operate the technical infrastructure needed to provide the aG Services, in particular providers which host, store, manage, and maintain aG applications, its content and the data processed. aG may use technical service providers to help aG communicate with you. aG uses marketing and advertising partners to show you more tailored content, or to help aG understand your use of the aG Services, to provide you with a better service. aG may share personal data with certain marketing and advertising partners to send you promotional communications about aG.
e) aG Partners
Reason for sharing: If you access the aG Services through an offer that you received or purchased from a third party such as your mobile network operator, we share personal data with that third party about your use of the aG Services, such as whether and to what extent you have used the offer, activated an aG account, or actively used the aG Services. Depending on how you sign up for the aG Servicse (e.g. through a third party service or a mobile provider), we share your aG username or other account registration data as necessary to enable your account. We may also share your personal data in a pseudonymized format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service.
f) Academic Researchers
We may share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.
g) Law Enforcement and Data Protection Authorities
We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. aG will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
8. DATA RETENTION AND DELETION
aG will retain your personal data only as long as necessary to provide you with the aG Services and Content and for legitimate and essential business purposes, such as maintaining the performance of the aG Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the aG Services. If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
a) If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
b) Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
c) Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
9. TRANSFER OF DATA TO OTHER COUNTRIES
aG may share your personal data globally with other companies or partners, in order to carry out the activities specified in this Policy. aG may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence. Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances aG shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Policy.
10. AG WEBSITE LINKS
aG may display advertisements from third parties and other content that links to third-party websites. aG cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the aG Services and Content on the website, and any personal data you provide will not be covered by this Policy. Please read the privacy policies of any third party websites in order to determine how they collect and process your personal data.
11. KEEPING YOUR PERSONAL DATA SAFE
aG is committed to protecting its users’ personal data. aG implements appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the aG Services.
The aG Service are not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the aG Services, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to aG, please contact us. If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the aG account for that child.
aG may occasionally make changes to this Policy. When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the aG Services Terms of Service or by sending you an email. We may notify you in advance. Please, therefore, make sure you read any such notice carefully.
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