Privacy Policy
Last Updated: 14-Aug-2025
INTRODUCTION
This Privacy Policy explains how information
about you is collected, used, and shared by GOLFdistrict
Inc. (hereafter “GOLFdistrict,”
“our,” “we,” or “us”). This Privacy Policy is intended to inform our users (“user(s)”, “you”, or “your”) about
how we may collect and use the personal information that you provide through
your use of and access to our website, mobile applications, and other services,
or when you otherwise interact with us (collectively, the “Services”), the manner in which we may use such information, how we
protect it, and the choices available to you regarding our use of your personal
information.
We
may modify or supplement this Privacy Policy from time to time by posting those
changes on this page. Any changes will become effective as of the date of
posting. Please review this Privacy
Policy often so you are always fully informed of any changes.
It
is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship
with us or if you are aware that any personal data, we hold is inaccurate.
This
Privacy Policy is binding on all those who access, visit, and/or use the
Services, whether acting as an individual or on behalf of an entity. If
you do not agree to be bound by this Privacy Policy, then do not access or use
the Services.
This
Privacy Policy is part of our Terms
of Use, which govern your use of the Services. By using the Services,
contacting us to inquire about the Services, or otherwise providing us with
information, you consent to our Privacy Policy and agree to our Terms of Use.
The
Services may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties
to collect or share data about you. We do not control these third-party
websites, including our third-party payment processors, and are not responsible
for their privacy statements. When you leave the Services, we encourage you to
read the privacy policy of every website you visit.
Depending on your
location, you may be subject to different protection standards and broader
standards may therefore apply to some. In order to
learn more about the protection criteria, please refer to the applicable
section below.
If you have any questions about this Privacy Policy, please
contact us as directed below.
CHILDREN’S
DATA PROTECTION AND PARENTAL RESPONSIBILITY
We recognize the importance of
children’s safety and privacy. The Services are not designed to attract
children and are not intended for use by any children under the age of 13. We
do not request, or knowingly collect, any personally identifiable information
from children under the age of 13. Minors under the age of 18 (but older than
12) may use the Services only under the supervision of a parent or legal
guardian who agrees to be bound by our Terms of Use. If you are the parent or guardian of a
child under 13 who has provided her or his information to us, please contact us
at support@golfdistrict.com to request the deletion of that information.
THE DATA WE
COLLECT ABOUT YOU
Personal data, or personal information, means any
information about an individual from which that person can be identified. It
does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together as follows:
● Identity
Data includes (but is not limited
to) first name, last name, username or similar identifier, title, and date of
birth.
● Contact Data includes (but is not limited to) billing address,
residential address, email address and telephone numbers.
● Transaction
Data includes (but is not limited
to) details about bids, course history, payments to and from you and other
details of products and services you have purchased using the Services.
● Technical
Data includes (but is not limited to)
internet protocol (IP) address, unique mobile device identification numbers,
type of device, login data, browser type and version, browser plug-in types and
versions, operating system and platform and other technology on the devices you
use to access the Services.
● Location
Date includes (but is not limited to)
your general location data (e.g., IP address), and, with your permission, the
precise location of your mobile device. Please note that for most mobile
devices, you can manage or disable the use of precise location services for all
applications in the settings menu of your mobile device.
● Profile Data includes (but is not limited to) your login details,
purchases or tee times made by you, preferences (including past courses
booked), feedback, photos, and other input you choose to include.
● Usage Data includes (but is not limited to) information about how
you use the Services.
● Marketing
and Communications Data includes
(but is not limited to) your preferences in receiving marketing from us and our
third parties, news about our products and your communication preferences.
If you make any purchases using the Services (including booking a tee time), Financial Data, which includes your bank account and payment card details, will be collected and processed by our external payment service provider. In order to provide you payouts for tee times you may have sold, we will collect your physical address in order to facilitate such payments by providing your address to our payment processor to complete the transaction. Your physical address will not be used or stored for any other purposes, including any marketing or solicitation purposes.
We also collect, use and share Aggregated Data such as statistical data, demographic data and
data relating generally to the Service for any purpose. Aggregated Data may be
derived from your personal data but is anonymized and is not considered
personal data by law as this data does not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing
a specific feature of the Services. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
We use mobile analytics software to allow us to better
understand the functionality of our mobile software on your device. This
software may record information such as aggregated usage and performance data.
We do not link the information we store within the analytics software to any
personal information you submit within the Services.
Where we need to collect personal data by law, or under the
terms of a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a
product or service you have with us.
HOW YOUR
DATA IS COLLECTED
We use different methods to collect data from and about you
including, but not limited to:
● Direct
interactions. You may give us your Identity
Data, Contact Data and Financial Data by filling in forms or by corresponding
with us by mail, phone, email or otherwise. This includes personal data you
provide when you:
● make purchases in the Services;
● create an account;
● request marketing to be sent to you;
● request support for the Services; or
● give us feedback.
● Automated
technologies or interactions. As
you interact with the Services, we may automatically collect Technical Data and
Location Date about your equipment, browsing actions and patterns. We collect
this personal data by using cookies, pixels, server logs and other similar
technologies. We may also receive Technical Data and Location Date about you if
you visit other websites employing our cookies. Please see out Cookie Policy for more
information.
● Third
parties or publicly available sources. We
may receive personal data about you from various third parties and public
sources as set out below:
● Technical Data and Location Data from analytics providers,
advertising networks and search engine providers.
● Identity, Transaction, Financial and Contact Data shared
with us by a business you interact with that uses the Services as part of their
business, such as a golf course.
● Contact and Transaction Data from providers of technical,
payment and delivery services.
● Identity and Contact Data from data brokers or aggregators.
● Identity and Contact Data from publicly availably sources.
HOW WE USE
YOUR DATA
We will only process your personal data as allowed by law.
Most commonly, we will use your personal data in the following circumstances:
● For the performance of a contract
we are about to enter into or have entered
into with you.
● Where it is necessary for our legitimate interests (or those
of a third party) and your interests and fundamental rights do not override
those interests.
● Where we need to comply with a legal or regulatory
obligation.
You have the right to withdraw consent to marketing at any
time by contacting us at support@golfdistrict.com. The withdrawal of consent
will not affect the lawfulness of any processing that took place before the
withdrawal.
PURPOSES FOR WHICH WE WILL USE YOUR
PERSONAL DATA
We have set out below, in a table format, a description of
all the ways we may use your personal data, and which of the legal bases we
rely on to do so.
Note that we may process your personal data for more than
one lawful ground depending on the specific purpose for which we are using your
data.
|
Purpose/Activity |
Type of data |
Basis for processing
|
|
To register you as a new user |
(a) Identity (d) Location |
Performance of a contract with you |
|
To process your purchases including: (c) Updating your transaction history |
(a) Identity |
(a) Performance of a contract with you (c) Necessary for our legitimate interests (to keep our
records updated) |
|
To manage our relationship with you which will include: (c) Fulfilling our business relationship with you |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and the Services
(including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data) |
(a) Identity (d) Location |
(a) Performance of contract |
|
To deliver relevant content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, to grow our business
and to inform our marketing strategy) |
|
To use data analytics to improve the Services, marketing,
user relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of
users, to keep the Services updated and relevant, to develop our business and
to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods
or services that may be of interest to you |
(a) Identity |
Necessary for our legitimate interests (to develop our
products/services and grow our business) |
|
To process your job application to work with us |
(a) Identity |
Performance of a contract with you |
|
To facilitate a duty of care to you |
(a) Identity |
Necessary for our legitimate interest (to help you manage
aspects of your activities when interacting with our products/services) |
We may disclose information where we are required to do so
by law, for example, in response to a court order or a subpoena, or where we
disclose information to data processors who act on our behalf (service
providers or other group companies who provide support for the operations of
the Services and who do not use or disclose the information for any other
purpose). To the extent permitted by applicable law, we also may disclose
personally identifiable information in response to a law enforcement agency’s
request or other public agency’s (including schools or children services)
request or if we feel that such disclosure may prevent the instigation of a
crime, facilitate an investigation related to public safety or protect the
safety of a child using the Services protect the security or integrity of the
Services and networks, and/or enable us to take precautions against liability,
misuse or unauthorized use.
Marketing
We provide you with choices regarding our use of your
personal data for marketing and advertising purposes. You will receive
marketing communications from us if you have subscribed for an account with us
or purchased goods or services from us and you have not opted out of receiving
that marketing. All of our marketing communications to
you contain an opt out option and you can opt out at any time. Please note that
the opt out will not affect the lawfulness of processing that has taken place
before the opt out.
Third-Party
Marketing
We will get your explicit opt-in consent before we share
your personal data with any company outside of GOLFdistrict
for marketing purposes.
Opting
Out
You can ask us to stop sending you marketing messages at any
time by contacting us at support@golfdistrict.com at any time.
Opting
Out of Geolocation
If you have previously allowed us to access your geolocation
data, you can stop making geolocation available to us by visiting your mobile
device’s settings for the Services or the “settings” page for the Services.
Opting Out
of Other Communications
When you install the Services on your mobile device you can
choose to receive push notifications, which are messages we send you on your
mobile device even when the mobile app is not on. You can turn off
notifications by visiting your mobile device’s “settings” page.
Cookies
You can set your browser to refuse all or some browser
cookies, or to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information regarding the use
of cookies, please see our Cookie
Policy.
Change
of Purpose
We will only use your personal data for the purposes for
which we collected it, unless we reasonably consider that we need to use it for
another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated
purpose, we will notify you and obtain your consent to do so.
Please note that we may process your personal data without
your knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
WHY WE MAY
SHARE YOUR DATA
Where necessary, we transmit your personal data to
processors and other recipients (including those listed below) for one or
several of the purposes described above:
●
Other users of the Services;
●
Our affiliates and subsidiaries;
●
External service
providers, including payment processors, authentication providers, and golf
courses and related entities;
●
Government agencies and
public authorities; and
●
External operators of
websites, applications, services and tools.
The Service offers social sharing
features and other integrated tools (such as the Facebook “Like” button), which
let you share actions you take on the Service with other media, and vice versa.
The use of such features enables you to share your information with your
friends or the public, depending on your selected settings on those platforms.
For more information about the purpose and scope of data collection and
processing in connection with social sharing features, please visit the privacy
policies of the entities that provide those features.
DATA
SECURITY
We
incorporate commercially reasonable safeguards to help protect and secure your
personal information. However, no data transmission over the Internet, mobile
networks, wireless transmission, or electronic storage of information can be
guaranteed 100% secure. As a result, we cannot guarantee or warrant the
security of any information you transmit to or from the Services, and you
provide us with your information at your own risk.
If
you have any questions about security on the Services or if you become aware of
any unauthorized use of an account or suspect a security breach, notify us
immediately via email at support@golfdistrict.com. If our security system is
breached, we will notify you of the breach only if and to the extent required
under applicable law.
DATA
RETENTION
We will only retain your personal data for as long as
necessary to fulfill the purposes for which it was collected, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal
data, we consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorized use or disclosure of your personal
data, the purposes for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal
requirements.
In some circumstances we may anonymize your personal data
(so that it can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without further
notice to you.
YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA
PROTECTION REGULATION (GDPR)
If you are a resident of or located
within the European Economic Area (EEA), you have certain additional data
protection rights. These rights include:
● The right to access, update or delete the information we
have on you. Whenever made possible, you can access, update or request deletion
of your personal information directly within your account settings section. If
you are unable to perform these actions yourself, please contact us to assist
you.
● The right of rectification. You have the right to have your
information rectified if that information is inaccurate or incomplete.
● The right to object. You have the right to object to our
processing of your personal information.
● The right of restriction. You have the right to request that
we restrict the processing of your personal information.
● The right to data portability. You have the right to be
provided with a copy of the information we have on you in a structured,
machine-readable and commonly used format.
● The right to withdraw consent. You also have the right to
withdraw your consent at any time where we relied on your consent to process
your personal information.
Legal Basis for Processing Personal Information Under GDPR
Our legal basis for collecting and
using the personal information described in this Privacy Policy depends on the
personal information we collect and the specific context in which we collect
it.
We may process your personal
information because:
● We need to perform a contract with you;
● You have given us permission to do so;
● The processing is in our legitimate interests
and it is not overridden by your rights; or
● To comply with the law.
Retention of Information
We will retain your personal
information only for as long as is necessary for the purposes set out in this
Privacy Policy. We will retain and use your personal information to the extent
necessary to comply with our legal obligations (for example, if we are required
to retain your information to comply with applicable laws), resolve disputes
and enforce our legal agreements and policies.
We will also retain usage data for
internal analysis purposes. Usage data is data collected automatically either
generated by the use of the Services or from the
Services’ infrastructure itself (for example, the duration of a page visit).
Usage data is generally retained for a shorter period of time,
except when this data is used to strengthen the security or to improve the
functionality of the Services or we are legally obligated to retain this data
for longer periods.
Transfer of Information
Your information, including personal
information, may be transferred to – and maintained on – computers located
outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction.
If you are located outside the
United States and choose to provide information to us, please note that we
transfer the data, including personal information, to the United States and
process it there.
Your consent to this Privacy Policy
followed by your submission of such information represents your agreement to
that transfer.
We will take all the steps
reasonably necessary to ensure that your personal information is treated
securely and in accordance with this Privacy Policy and no transfer of your
personal information will take place to an organization or a country unless there
are adequate controls in place including the security of your data and other
personal information.
Disclosure of Personal Information
Disclosure for Law Enforcement -
Under certain circumstances, we may be required to disclose your personal
information if required to do so by law or in response to valid requests by
public authorities (e.g., a court or a government agency).
Legal Requirements
We may disclose your personal
information in the good faith belief that such action is necessary to:
● To comply with a legal obligation
● To protect and defend our rights or property
● To prevent or investigate possible wrongdoing in connection
with the Services
● To protect the personal safety of users of the Services or
the public
● To protect against legal liability
Security of Information
The security of your personal
information is important to us but remember 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 information, we
cannot guarantee its absolute security.
Please note that we may ask you to
verify your identity before responding to such requests.
Should you wish to raise a concern
about our use of your information (and without prejudice to any other rights
you may have), you have the right to do so with your local supervisory
authority; however, we hope that we can assist with any queries or
concerns you may have about our use of your personal information first.
For
more information, please contact your local data protection authority in the
EEA.
STATE PRIVACY RIGHTS
Under some U.S. state
laws residents may have the rights listed below. For additional information on
state-specific disclosures, please see our State
Privacy Disclosures:
●
Right to Know: The right to request the personal data that
we collect, uses or discloses and information about our data practices;
●
Right to Request Deletion: The right to request that we delete the
personal data we have collected about a user;
●
Right to Opt-Out of Data Sales: The right to restrict the sale to third
parties of a user’s personal data that we have collected;
●
Right to Non-Discrimination: The right to not be discriminated against
for exercising any of these rights;
●
Right to Correct Information: The right to update or correct the personal
data that we collect;
●
Right to Limit Use or Disclosure of Sensitive
Personal Information: The right to limit the
use and disclosure of Sensitive Personal Information (as defined under the CPRA);
●
Right to Access Information Related to Automated
Decision Making: The right to inquire
about our logic involved in automated decision-making applied to personal data
we collect; and
●
Right to Opt-Out of Automated Decision-Making
Technology: The right to request a
user’s removal from having automated decision-making applied to a user’s
personal data that we collect.
To request further
information pursuant to a user’s “right to know” or to request deletion of
personal data pursuant to the user’s “right to request deletion”, please
contact us at support@golfdistrict.com.
We will acknowledge
receipt of such request within 10 business days, and provide a substantive
response within 45 calendar days, or inform the user of the reason and
extension period (up to 90 days) in writing.
Only a user or an
authorized agent may make a request related to such user’s personal data. Note
that to respond to a user’s requests to access or delete personal data as
outlined in applicable state laws, we must verify the user’s identity.
Meta Platform Data Deletion Instructions
If you have used Golf
District through a Meta platform (such as Facebook or Instagram), you may
request that your data be deleted in accordance with Meta’s Platform Terms.
To request data
deletion:
● Email us at privacy@golfdistrict.com
● Include the subject line: Meta Data Deletion
Request
● In the body of the email, include:
○ Your full name
○ The email address associated with your
Facebook or Instagram account
○ A short message (e.g., “Please delete all my
data associated with my use of Golf District via Meta.”)
We
will process and respond to your request within 30 days.
CHANGES
IN THIS PRIVACY POLICY
We
reserve the right to modify and update this Privacy Policy at any time by
posting an amended version of the statement on the Services. Please refer
to this policy regularly. If at any time we decide to use personal information
in a manner different from that stated at the time it was collected, we will
notify you either on the Services or via email.
QUESTIONS AND COMMENTS
If you would like to
provide feedback to us about this Privacy Policy, or if you have any questions,
please contact us at support@golfdistrict.com.