Effective Date: 09/01/2021
Overview and Scope
This Policy applies to the Site(s), which includes truespecgolf.com, its subdomains, and all of the websites and internet properties owned or operated by us, and regardless of the medium by which the Site is accessed by Users (e.g., via a web or mobile browser).
Information We Collect
We are the sole owner of information collected on the Site. We collect several types of information from and about Users of the Site, including:
Personal Information : We may collect PII from you when you complete forms, navigate web pages, and in connection with other activities, services, features, or resources we make available on the Site. The type of PII we may collect, use, store, and disclose include the following:
|Category||Type of Information|
|Contact Information and Identifiers||First Name, Last Name, Email, Device ID|
|Internet Identifiers and Activities||Browsing History, Search History, Interactions with the Site|
|Physical Characteristics||Handedness/Dexterity, Height, Weight, etc.|
|User Free Text Box Responses||Customer Reviews, User Feedback, etc.|
Deidentified Information: We may collect deidentified information from you that may not by itself reasonably identify you as the source when you navigate the Site (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.
We do not offer our services or promote the Site to, nor do we intentionally collect or retain PII from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.
How We Collect Information
The information we collect depends on what Users do when they visit or utilize the Site. We collect PII and Deidentified Information in various ways, including:
Directly from You: We collect PII when you voluntarily submit PII to us while completing forms on the Site and in connection with other activities, services, features, or resources we make available on the Site. The PII we collect depends on what you do when you visit or utilize the Site or how you choose to communicate with us. Please note that we do not collect PII about you unless you voluntary provide such PII by completing forms available on the Site and/or contacting us regarding the Site or our products and services.
Through Your Use of the Site: We may collect PII and Deidentified Information that your browser transmits when you visit the Site. We may also collect Deidentified Information about how you access and interact with the Site through the use of automated tracking technologies, such as session cookies, persistent cookies, and web beacons.
A cookie is a small data file that is transferred to an internet browser, which enables the Site to remember and customize your subsequent visits. We may use session cookies to make it easier for you to navigate the Site. In particular, we may use session cookies to record session information, such as which web pages you visited and to track your activity on the Site. Session cookies expire when you close your browser. We may also use persistent cookies to track and target your interests to enhance your experience on the Site. Persistent cookies remain on your device for an extended period of time.
Most internet browsers automatically accept cookies. However, you can instruct your internet browser to block cookies or to provide you with a warning prompt before you accept cookies from the Site. Please refer to your internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Site may be limited and you may not be able to participate in several of the Site’s features.
Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.
From Third Party Services: We may collect PII about you from third parties whose privacy practices may differ from the practices described in this Policy. We do not make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available through third parties. Your use of third parties’ services and/or third party websites is governed by and subject to the terms and conditions of those third parties and/or third party websites. We encourage you to carefully review the privacy policies and statements of such third parties and/or third party websites.
How We Use Information
We may use Users’ PII for various general, lawful purposes to help enhance the User experience. These purposes include:
Direct Marketing: We may use your PII to send you promotional materials. You have the right to opt-out of receiving direct marketing.
Customer Service and User Communications: We may use your PII to help us respond to your inquiries, questions, requests, and support needs more efficiently.
User Experience Personalization: We may use Users’ PII and/or Deidentified Information in the aggregate to analyze Users’ browsing and usage activities and patterns in order to understand Users’ interests and preferences with respect to the Site and our services. This will help us optimize your experience on the Site.
Business Optimization: We may use your PII and/or Deidentified Information to improve the content on our web pages, to customize the content and layout of our web pages, and in managing our everyday business needs. We may also use your feedback to improve the Site and our services. All of this is done with the intention of making the Site more useful for you.
We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Disclose Information
We may disclose Users’ PII to third parties for a business purpose as described below. Otherwise, we do not sell PII and will not disclose Users’ PII to third parties without your permission.
To Service Providers: We may disclose your PII to third party service providers that assist us in providing user support, communicating with Users, and promoting our services, as well as third party service providers that provide other services to us relating to our services and/or the Site.
Law Enforcement, Safety, and Legal Processes: We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and credit risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal or administrative process.
Sale or Acquisition of Assets: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your PII pursuant to its own privacy policies, and those policies may be different from this Policy.
The security and confidentiality of your PII is very important to us. We use commercially reasonable security measures to protect your PII on the Site. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure (i) from misappropriation by hackers or from other nefarious or criminal activities, or (ii) in the event of a failure of computer hardware, software, or a telecommunications networks.
GDPR Data Subject Rights
If you are a data subject located in the EEA, the GDPR grants you certain data privacy rights. Your rights include the:
- Right to Access: You have the right to request a copy of your PII.
- Right to Rectification: You have the right to request that we correct any mistakes in your PII.
- Right to Erasure: You have the right request that we delete your PII.
- Right to Restrict Processing: You have the right to restrict processing of your PII.
- Right to Object to Processing: You have the right to object to our processing or your PII.
- Right to Data Portability: You have the right to receive your PII in a in a structured, commonly used and machine-readable format.
To exercise your rights, please contact us at the Contact Information provided below. Please be aware that your rights are limited to the extent permitted by the GDPR.
California Privacy Rights
California’s “Shine the Light” law permits Users of the Service that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Information provided below.
Generally, we do not process PII based on consent. However, in the event we do, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on said consent before its withdrawal. If you would like to withdraw your consent, please contact us at the Contact Information provided below.
File a Complaint
If you would like to file a complaint with us about our privacy practices, please contact us at the Contact Information provided below. If you are a data subject located in the EEA, the GDPR grants you the right to lodge a complaint with a competent supervisory authority as well. To find a competent supervisory authority, please use the following resource: https://edpb.europa.eu/about-edpb/board/members_en.
Cross Border Data Transfer
To deliver the services through the Service, it may be necessary for use to share data subjects’ PII outside the EEA. We may share data subject PII with our affiliates and services providers located in in the US. In the event we transfer PII outside the EEA, we will take commercially reasonable measures to ensure the transfer complies with data protection laws and PII is securely transferred. Our standard practice is to use standard contractual clauses approved by the European Commission to facilitate such data transfers. If you have any questions about our data transfer practices, please contact us at the Contact Information provided below.
We will retain Users’ PII while they maintain an account with us or to the extent necessary to provide the services through the Service. Thereafter, we will keep PII for as long as necessary: (i) to respond to any queries from Users; (ii) to demonstrate we treated Users fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws. We delete PII within a reasonable period after we no longer need the information for the purposes set out in this Policy.
Do Not Track Disclosure
Some internet browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Site does not currently respond to these “do-not-track” signals.
We do not participate in bulk email solicitations that you have not consented to receiving (i.e., “Spam”). We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share PII with any third party advertisers.
Third Party Links
The Site and/or our products, may contain links to other websites or applications (“Linked Sites”) that are not owned by us. We do not control the collection or use of any information, including PII, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Sites are framed within a page of the Site.
Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Site and read the privacy policies of Linked Sites.
Accessing, Updating, and Controlling Information
If you ever wish to access, update, change, or delete your PII, you may do so or make such changes by contacting us at the Contact Information provided below. To help us process your request, please provide sufficient information to allow us to identify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any PII to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete.
If you do not wish to receive update messages and/or direct marketing communications from us, you may opt-out by following any instructions included in the communication or by contacting us at the Contact Information provided below. To help us process your request, please include sufficient information for us to identify you in our records. Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Site, as permitted under the CAN-SPAM Act.
We will make commercially reasonable efforts to respond to opt-out requests, and handle requests to access, update, change, or delete PII as quickly as possible.
If you have questions about this Policy or wish to contact us with questions or comments, please contact us at:
Attn: Legal Team
7350 E Evans Rd. Building D. Scottsdale, AZ 85260