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Privacy Policy

Updated and Posted – Dec 31/2021

You are entering into a legally binding agreement, read the following terms and conditions carefully.

In this Privacy Policy: “Links2Golf Network”, “we”, “our”, “us” and similar terms refer to Links2Golf Network, with a registered office located at c/o Links2Golf Network, 255 Duncan Mill Road, Suite 307, Toronto, Ontario, Canada M3B 3H9; “Website” refers to our website and mobile applications, if applicable, including without limitation www.links2golf.com; and “you”, “your” and similar terms refer to all visitors and/or users who access the Website.

We are committed to protecting the privacy of all visitors to the Website, including all visitors or users who access the Website or Service through any web application, mobile application, or other platform or device. Please read carefully the following Privacy Policy, which explains how we collect, use and protect the Personal Information (defined below) that we collect about you.

As an organization engaged in commercial activities, we are committed to complying with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), and with any other Canadian and provincial privacy laws applicable to our operations.

This Privacy Policy also reflects European Union (“EU”) Regulation 2016/679 General Data Protection Regulation (“GDPR”) principles and applicable law effective from 25 May 2018 onwards and forms part of our contract.

You must be 18 or older to use our Services. Minors under 18 and at least 13 years of age are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission and under their direct supervision. We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Service. If you are under 13, please do not attempt to register for our Service or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@links2golf.com.

By visiting and/or using the Website, you acknowledge and agree that you have read and understand this Privacy Policy, and consent to the collection, use, and disclosure of your Personal Information under the terms of this Privacy Policy. In most cases, we will ask you to provide explicit consent (through agreeing to a revised version of this Privacy Policy) if we intend to collect, use or disclose your Personal Information otherwise than as indicated in this Privacy Policy, however, sometimes your consent may be implied through your conduct with us or by applicable law or we may otherwise have a legitimate basis for collecting or using your Personal Information.

1. INFORMATION THAT WE COLLECT FROM YOU

1.1. When you use the Website you may be asked to provide information about yourself or individuals for whom you have the legal right to provide such information, including without limitation name, contact details (such as telephone and mobile numbers and e-mail address), demographic information such as your age and gender, and/or other personally identifiable information that may identify you as a natural person (the “Personal Information”). Personal Information does not include business information including but limited to a business address, business title, professional designation(s) or business telephone number. We may also collect information about your usage of the Website and relationship with us, including without limitation usernames and passwords, as well as Personal Information about you derived from the materials you post to the Website and the e-mails or letters you send to us. Such information may include transactional information based on your activities on the Website, computer sign-on data, time and date data, statistics on page views, your IP address, your GPS location, the type of computing environment you use, and traffic to and from the Website (including data about you whenever you interact with the Website, such as when you search, click on links, send messages, make comments, replies or queries, and select best replies), other technical information or data collected from Website traffic, including IP address and standard web log information and information gathered from cookies, beacons, and other mechanisms (see Section 5 Cookies). Collection of Personal Information will be limited to that which is necessary for the purposes for which it was provided and/or as provided under this Privacy Policy and will be collected by fair and lawful means.

1.2. Whenever you interact with our Service, we automatically receive and record technical information such as your device, IP address, “cookie” information (as described in Section 5 Cookies), the version of your operating system (“OS”), and the page you requested. When you use the Service on a mobile platform, we may also collect and record your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), your device name, and your location (based on your IP address). We may also collect information regarding your activity on the Service (both individually and on an aggregate basis).

1.3. We work/partner with some third-party service providers who assist us in managing or providing the Service (e.g., companies performing analytic functions such as Google) and who collect some of the information described above. These third parties provide us with analytic data so we can better run our Website also help us understand how users interact with our content or offerings. We may also collect contextual or demographic data about our users from third parties, in order to more effectively deliver the Service or content in which we think you would be interested. Unless you have been notified otherwise, all information collected through our authorized third-party service providers remains governed by security and confidentiality obligations consistent with this Privacy Policy and applicable law.

1.4. By accessing the Website and/or engaging in an exchange of information with us, including but not limited to providing hard copies of information, using social media, email, and mobile digital routes, such as mobile phones, tablets, laptops or other wireless devices/technology (including mobile applications), you acknowledge and agree that our data collection and usage as set out in this Privacy Policy will apply in that context. We may collect non-personal device information (such as technical information) from your mobile device or your use of the Website or exchange of information with us through a mobile device; for example, location data and certain characteristics of, and performance data about, your device, carrier/operating system including device and connection type, IP address, mobile payment methods, interaction with other retail technology such as the use of NFC Tags, QR Codes or use of mobile vouchers. This information may be collected and used by us automatically if you use the Website or exchange information with us through your mobile device(s) via any of our mobile applications, through your mobile device’s browser, or otherwise.

1.5. We may also collect some personal information through system logs and cookies. For further information on our practices in relation to cookies, please refer to section 5 below.

2. USE OF YOUR PERSONAL INFORMATION

2.1. Depending upon your relationship with us, your Personal Information may be used to create a personal account and/or user profile, and to help manage our relationship with you and with any affiliated, reciprocal, and preferred access golf clubs with which Links2Golf Network has a relationship (“Network Clubs”).

2.2. We will also use and analyze the Personal Information we collect so that we can administer, support, improve and develop our business, for any other purpose notified to you whether statistical or analytical and to help us prevent fraud. Where appropriate, now and in the future you may have the ability to express your preferences around the use of your data as set out in this Privacy Policy and this may be exercised through appropriate means of communication, for example, email, SMS, online updates (such as logging in to your account, if applicable), and mobile applications.

2.3. We may use your Personal Information to contact you to manage our relationships and to notify you occasionally about important changes or developments to the Website or other aspects of our relationship. You cannot opt-out of receiving notifications of important changes or developments, including but not limited to changes to this Privacy Policy or the Website Terms, unless you discontinue use of the Website and our relationship.

2.4. You agree that we may use your Personal Information to let you know about our other products and services that may be of interest to you including but not limited to services that may be the subject of direct marketing and we may contact you to do so by telephone, SMS, as well as by e-mail and social media. It is always your choice whether to continue receiving such marketing materials and updates from us and if you no longer wish to receive such information, you should refer to the unsubscribe process on our Website, email, and other communications.

2.5. You agree that we may also share Personal Information with third parties, including without limitation Affiliate Clubs, in order to let you know about goods and services which may be of interest to you (by post, telephone, mobile messaging (e.g. SMS, MMS, etc.), social media and/or e-mail) and to help us analyze the information we collect so that we can administer, support, improve and develop our business and our relationship with you. Personal Information shared with such third parties will be used in accordance with such third parties’ own privacy practices which we do not have control over, so you should review such privacy practices before agreeing to have your Personal Information shared with such third parties.

2.6. If you do not want us to use your data in this way or change your mind about being contacted in the future, please let us know by using the contact details set out in section 14 below and/or amending the permissions section of your profile accordingly.

2.7. Please note that by submitting information regarding the Website, us, or our relationship, you irrevocably consent to us using such information on the Website and in any marketing or advertising materials without any compensation whatsoever. For this purpose, we will not specifically identify you in relation to such disclosure unless you consent to us doing so.

2.8. This Privacy Policy does not apply to other websites that we have linked to our Website. We are not responsible for the content or information collection policies of such websites.

2.9. In addition to the other permissions granted herein or otherwise, you grant us permission to use your Personal Information to:

2.9.1. manage your personal account, if created;

2.9.2. facilitate our relationship with you and Network Clubs;

2.9.3. marketing of Links2Golf Network and Network Clubs;

2.9.4. facilitate analysis of and improvements to the Website and our business operations;

2.9.5. aggregate data related to visitation and use of the Website; and

2.9.6. facilitate our business relationships.

3. LAWFUL BASIS FOR PROCESSING

3.1. For individuals in the European Union (“EU”) and the European Economic Area (“EEA”) we will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent); via contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)); to protect vital interest; and when we have “legitimate interests”, which includes direct marketing. Where we process Information based on the consent you may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

3.2. Where we rely on contract, we will ask that you agree to the processing of Personal Information is necessary for entering into or performance of your contract with us. We provide a voluntary service; you can choose whether or not you want to use the Service. However, if you want to use the Service, you need to agree to our Privacy Policy. As we operate in countries worldwide (including the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we may need to transfer your Personal Information to the US and to other jurisdictions as necessary to provide the Service.

3.3. Where we rely on legitimate interests as a basis for Personal Information processing, you have the right to object. We may process your Information, including personal data, for the purposes of our legitimate interests or for the legitimate interests of third parties including our partners, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your Personal Information to:

• Protect you, us, or others from threats (such as security threats or fraud)

• Comply with laws that apply to us

• Enable or administer our business, such as for quality control, consolidated reporting, and customer service

• Manage corporate transactions, such as mergers or acquisitions

• Engage in direct marketing;

• Understand and improve our business or customer relationships generally

If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us at privacy@links2golf.com.

4. DISCLOSURE OF YOUR PERSONAL INFORMATION

4.1. The Personal Information you provide to us will be held on our servers which may be located within or outside Canada. In addition, your Personal Information may be accessed by or given to our staff working outside Canada and/or to third parties including without limitation Network Clubs and companies which may be our subsidiaries and affiliates, our ultimate holding company and its subsidiaries and affiliates, who act for us for the purposes set out in this Privacy Policy, as well as for other purposes notified to you. For example, we may send Personal Information outside of Canada for processing and storage by affiliated parties or by other third-party service providers.

4.2. While your Personal Information is outside of Canada, it is subject to the laws of the jurisdiction in which it is held or through which it passes, and may be subject to disclosure to the governments, courts or law enforcement, or regulatory agencies of such other country, pursuant to the laws of such country. Certain countries outside Canada do not always have equivalent strong data protection laws irrespective of the safeguards we have put in place for the protection of your information in accordance with this Privacy Policy.

4.3. The third parties with whom we share your information may undertake various activities including but not limited to processing credit card payments and providing support services for us. In addition, we may need to provide your Personal Information to third parties so as to facilitate our relationship with you. By submitting your personal data, you agree to this transfer, storing, or processing. We will take reasonable steps to provide that your Personal Information is treated securely and in accordance with this Privacy Policy.

4.4. The third parties with whom we share your information, including without limitation Network Clubs, may contact you about other products or services that may be of interest to you. They may contact you by post, telephone, mobile messaging (e.g. SMS, MMS, etc.) as well as by e-mail or social media. If you change your mind about being contacted by these companies in the future, please let us know by using the contact details set out in section 14 below and/or by amending your personal account accordingly, if applicable.

4.5. If our business enters into a business relationship, including without limitation third-party financing, a joint venture with, purchases or is sold to or merged with another business entity, your Personal Information may be disclosed or transferred to the third party, target company, our new business partners or owners or their advisors provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy and applicable privacy laws by the entity acquiring the information.

4.6. We may use the Personal Information that you provide to us if we are under a duty to disclose or share your Personal Information in order to comply with, and/or where we believe we are under a duty to comply with, any applicable legal obligation; or in order to protect our rights and enforce any agreement or support any relationship we have with you. This includes exchanging Personal Information with other companies and other organizations for the purposes of fraud protection and prevention.

4.7. If we provide your Personal Information to third parties who provide services to us, we will take commercially reasonable steps to provide that your Personal Information will be treated in accordance with this Privacy Policy.

5. COOKIES AND LOCATION CONTROLS

5.1. We use cookies to improve the quality of our Website, promote our relationship with you, and try to improve your browsing experience. When you enter our Website our web server sends a cookie to your computer which allows us to recognize your computer but not specifically who is using it. By associating the identification numbers in the cookies with other customer information when for example you log-in to the Website, then we know that the cookie information relates to you (or more specifically to your computer). By using this Website, you consent to our cookie settings and agree that you understand the cookies policy set forth in this section 5, which explains how you can manage your cookie choices and preferences.

5.2. Cookies are small pieces of information that are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are only used where you ask us to remember your login details for when you next return to the site and will last for a longer duration.

5.3. Some of the cookies used by our Website are served by us, and some are served by third parties who are delivering services on our behalf. Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note that by blocking or deleting cookies used on our Website you may not be able to take full advantage of our Website if you do so.

5.4. We use Google Analytics, which Google uses the information shared by sites and apps to deliver our Services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on our partners’ sites and apps. To learn more about the Company’s use of Google Analytics and what Google Analytics does, please see How Google uses information from sites or apps that use or services.

If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.ja) running on websites to prohibit sending information to Google Analytics. To opt out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser.

Updates to your browser or operating system may affect the functionality of the opt-out add-on. Learn about managing add-ons for Chrome here. If you are not using Chrome, check directly with the manufacturer of your browser to determine whether add-ons will function properly on the browser version that you are using.

The latest versions of Internet Explorer sometimes load the Google Analytics opt-out add-on after sending data to Google Analytics. Therefore, if you are using Internet Explorer, the add-on will set cookies on your computer. These cookies ensure that any collected data is immediately deleted from the collection server. Please make sure that third-party cookies aren’t disabled for your Internet Explorer browser. If you delete your cookies, the add-on will, within a short timeframe, reset these cookies to ensure that your Google Analytics browser add-on remains fully functional.

The Google Analytics opt-out browser add-on does not prevent data from being sent to the website itself or in other ways to web analytics services.

Learn about how Google Analytics collects, uses, and processes data here.
Learn about the cookies Google Analytics uses here.
5.5. This Privacy Policy provides you with further details about how we use any Personal Information you give us, although not all information captured by using cookies will identify you.

5.6. We are continually striving to develop improved ways of managing your cookie preferences. As new technologies and solutions emerge, the cookies policy set forth in this section 5 may be updated to reflect any such advances in technology and preference management tools.

5.7. You may be able to set your Internet browser or mobile device to block cookies or other tracking/recording tools, including cookies associated with our websites or Services, or to indicate when a cookie is being set by us. However, it is important to remember that our Website or Service may not function properly if your cookies or location are disabled. We do not support the Do Not Track browser setting. Do Not Track (or DNT) is a preference you can set in your browser to let the websites that you visit know that you do not want them collecting certain information about you. For information and instructions about how to manage your cookies, refer to your Internet browser’s or mobile device’s technical information. Further information on how to adjust your cookie preferences through your browser is available at the external, third-party informational website www.allaboutcookies.org.

6. SECURITY AND DATA RETENTION

6.1. We take technical, administrative, and physical security steps designed to protect your Personal Information from unauthorized access and against unlawful processing, accidental loss, destruction, and damage. We have implemented procedures designed to limit the dissemination of your Personal Information to only personnel with a business “need-to-know” or whose duties reasonably require such information.

6.2. We will keep your information as long as necessary to fulfill the purposes for which that Personal Information was collected, and as permitted or as required by applicable law. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-Personal Information, or account recovery, or if required by applicable law. All retained Personal Information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

6.3. Where you have chosen a password that allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. Unless we negligently disclose your password to a third party, we will not be liable for any unauthorized transactions entered into using your name and password.

6.4. The transmission of information via the Internet is not completely secure. Although we will take commercially reasonable steps to protect your Personal Information, we cannot guarantee the security of your Personal Information or other data transmitted to the Website; any transmission is at your own risk. Once we have received your Personal Information, we will use commercially reasonable organizational and technical safeguards to try to prevent unauthorized access. Please also note that the Website contains links to third-party websites, which are not governed by this Privacy Policy, and we are not responsible for the collection, use, or disclosure of Personal Information by such third-party websites.

7. ACCESSING AND UPDATING

7.1. You have the right to see the Personal Information we hold about you (“Access Request”) and to ask us to make any changes to ensure that it is accurate and up to date. Upon receipt of your written request, we will, within a reasonable time, provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will advise you in writing if we cannot meet your requests within this time limit.

7.2. If you wish to do this, please contact us using the contact details set out in section 14 below. We may charge you a fee to meet our administrative costs in providing this information to you.

7.3. Please note that we may request that you provide sufficient identification before we provide you with the Personal Information that we hold. Any such identifying information shall be used only for this purpose.

8. CASL DISCLOSURE

8.1. Canada’s Anti-Spam Legislation (“CASL”) sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them.

8.2. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at privacy@links2golf.com and we will promptly remove you from email communications.

9. EU/EEA DATA SUBJECT RIGHTS

9.1. We are not established in the EEA; however, individuals located in certain countries, including the EU/EEA, have certain rights related to their Personal Information subject to any exemptions provided by law. Subject to any exemptions provided by law, EU/EEA users have the following rights:

• Delete Personal Information: You can ask us to erase or delete all or some of your Personal Information (e.g., if it is no longer necessary to provide the Service to you).

• Change or Correct Personal Information: You can edit some of your Personal Information through your account. You can also ask us to change, update or fix your Personal Information in certain cases, particularly if it’s inaccurate.

• Object to, or Limit or Restrict, Use of Personal Information: You can ask us to stop using all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Information is inaccurate or unlawfully held).

• Right to Object: If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• Right to Access and/or Take Your Personal Information: You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine-readable form.

• You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries are available here.)

You may contact us using the contact information below, and we will consider your request in accordance with applicable laws.

10. CALIFORNIA PRIVACY RIGHTS

10.1. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 255 Duncan Mill Rd Suite 307, Toronto, Ontario Canada. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.

10.2. California Do Not Track Disclosure: Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.

11. CAN-SPAM ACT DISCLOSURE

11.1. The CAN-SPAM Act sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them.

11.2. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at privacy@links2golf.com and we will promptly remove you from email communications.

12. JURISDICTION

12.1. This Privacy Policy reflects the jurisdiction of the Province of Ontario and Canada. By your access to the Website and/or relationship with us you irrevocably agree that this Privacy Policy and matters related thereto are governed by the privacy laws, regulations, and requirements of the Province of Ontario and Canada, as applicable, and you irrevocably attorn to the exclusive jurisdiction of the courts of the Province of Ontario located in Toronto, Ontario, Canada.

12.2. In the event that a court of competent jurisdiction finally determines that the privacy laws, regulations, and requirements of a country other than Canada have jurisdiction, the Privacy Policy shall be deemed to include the minimum additional requirements for compliance with such jurisdiction.

12.3. In the event that a court of competent jurisdiction finally determines that any provision of this Privacy Policy is not enforceable, that provision shall be deleted and the remaining provisions shall continue in full force and effect.

13. CHANGES TO OUR PRIVACY POLICY

13.1. This Privacy Policy is current as of the date which appears at the bottom of this Privacy Policy. Your continued use of the Website and/or ongoing relationship with us after any change of our Privacy Policy will constitute your acceptance of the revised terms of this Privacy Policy and accordingly, we will treat Personal Information in a manner consistent with the latest applicable version of the Privacy Policy.

13.2. Any changes to our Privacy Policy will be posted to the Website.

14. LANGUAGE

14.1. Where we provided you with a translation of the English language version of the Privacy Policy or any other documentation, you agree that the translation is provided solely for your convenience and that the English language versions of the Privacy Policy and any other documentation will govern the Privacy Policy and your relationship with us. We and you have required that the Privacy Policy and all related documents be drawn up in English. Les parties ont demandé que ces politique de confidentialité ainsi que tous les documents qui s’y rattachent soient rédigés en anglais.

15. CONTACT

15.1. You can help by keeping us informed of any changes such as a change of delivery address for Orders or telephone number. If you would like to access your information, if you have any comments, queries, and requests relating to our use of your Personal Information or if you find any errors in our information about you, please contact us at:

Links2Golf Network Privacy Officer
c/o Links2Golf Network Inc.
255 Duncan Mills Road, Suite 307
Toronto, Ontario, Canada
M3B 3H9
Email: privacy@links2golf.com

Date of Privacy Policy: 12/31/2021

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