ACUSHNET COMPANY PRIVACY POLICY

Effective Date: 2007 Last Update: January 1, 2020

THIS PLATFORM PRIVACY POLICY APPLIES TO THE PLATFORMS AND APPS WHERE IT APPEARS.

This platform Policy describes how we treat personal information on the platforms where it is located. This includes Titleist.com, Footjoy.com, Vokey.com, Pinnaclegolf.com, ScottyCameron.com, UnionGreen.com and LinksandKings.com. This also includes our apps. Your use of this platform indicates you agree to our collection, use and disclosure of your information as described in this Privacy Policy.

WE COLLECT INFORMATION FROM AND ABOUT YOU.

We collect contact information. For example, we might collect your name and email address if you create an account on our platform. We may also collect your phone number and mailing address. We may also collect your username and password if you connect to our platforms with your social media account.

We collect payment information. For example, we collect your credit card number and your billing and shipping information if you place an order.

We collect information you submit or post. We collect the information you post in a public space on our platform. We may collect information about you if you complete a survey. We may also collect information if you post blog entries or comments.

We collect demographic information. We may collect information like your gender and date of birth. We may also collect your zip or postal code. We might collect this information when you contact us. We may also collect this information if you complete a survey.

We collect other information. If you use our platform, we may collect information about the browser you're using. We might look at what platform you came from, or what platform you visit when you leave us. If you use our mobile apps, we may collect your GPS location. We might look at how often you use the app and where you downloaded it. We collect this information using the tracking tools described below. To control those tools, please read the Choices section below.

WE COLLECT INFORMATION IN DIFFERENT WAYS.

We collect information directly from you. For example, if you sign up for our emails or make a purchase. We also collect information if you contact us.

We collect information from you passively. We use tracking tools like browser cookies and web beacons to collect information from you. We collect information about users over time when you use this platform. We may allow third parties to collect personal information this way. These third parties may collect information about your online activities over time and across different websites when you use our platforms. We also collect information from our mobile apps. Learn more about these tools and how you can control them, here.

We collect information from your friends. We may collect information if someone uses the Tell-a-Friend feature. This may include your name and email address.

We get information about you from third parties. For example, our business partners may give us information about you. Social media platforms may also give us information about you.

We combine information.For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we get from a third party with information we already have.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

We use information to respond to your requests or questions. For example, we may use your information to respond to your feedback. We may also use your information to notify you if you win a contest or make a purchase.

We use information to improve our products and services. We may use your information to make our platform and products better. We might use your information to customize your experience with us.

We use information for security purposes. We may use your information to protect our company, our customers, and our platforms.

We use information for marketing purposes. For example, we might provide you with information about new products and special offers. We might also use your information to serve you ads about products and offers. We might tell you about new features or updates. If you register with us, we'll enroll you in our email newsletter. To learn about your choices for these communications, read the Choices section below.

We use information to communicate with you. For example, we may contact you about your feedback or our relationship. We might also contact you about this platform Privacy Policy or our platform Terms.

We use information as otherwise permitted by law or as we may notify you. We will get your consent as required to by law.

WE MAY SHARE INFORMATION WITH THIRD PARTIES.

We will share information within the Acushnet family of companies. We will share this information for our business purposes and to otherwise engage in the activities described in this Privacy Policy.

We will share information with third parties who perform services on our behalf. For example, we share information with vendors who provide marketing services for us. We also share information with companies that help us operate our platforms or run a promotion. We may also share information with companies that help us fulfill customer requests. You can contact us if you want to learn more about how our service providers use your information.

We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may share information if a government agency or investigatory body requests it. This includes sharing information with the US government. We might share information if we are investigating potential fraud. This might include fraud we think has happened during a promotion. If you are the winner of a contest, we may also share your information with anyone who requests a winner's list.

We may share information with a successor to all or part of our business. For example, if part of our business is sold we may include customer information as part of that transaction.

We may share information for other reasons we may describe to you.

YOU HAVE CERTAIN CHOICES ABOUT HOW WE USE YOUR INFORMATION.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional email you get from us. Even if you opt out of getting our marketing messages, we will still send you transactional messages. These include responses to your questions.

If you object to our use of your information for direct marketing purposes, please email us at privacypolicy@acushnetgolf.com.

You can control certain cookies and tracking tools. To learn how to manage how we – and our vendors – use cookies and other tracking tools, and to read our Ad and Cookie Policy, please click here. Our Do Not Track Policy: Some websites have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.

THESE PLATFORMS ARE NOT INTENDED FOR CHILDREN.

Our platforms are meant for adults. We do not knowingly collect personally identifiable information from children under the age of 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at privacypolicy@acushnetgolf.com. You can also write to us at the address listed at the end of this policy. Please mark your inquiries "COPPA Information Request." Parents, to learn more about how to protect your children online, go here.

WE USE STANDARD SECURITY MEASURES.

The Internet is not 100% secure. We cannot promise that your use of our platforms will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

We keep personal information as long as it is necessary or relevant for the practices described in this platform Policy. We also keep information as otherwise required by law.

WE STORE INFORMATION IN THE UNITED STATES.

Your information will be transferred to Acushnet Company. Information we collect may be stored in the United States. We may also store information in other countries. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This platform is subject to U.S. laws, which may not afford the same level of protection as those in your country.

We keep personal information as long as it is necessary or relevant for the practices described in this policy.

WE MAY LINK TO THIRD PARTY PLATFORMS OR SERVICES WE DON'T CONTROL.

This platform may contain links to other platforms. We are not responsible for the privacy practices of other platforms. We encourage our users to be aware when they leave our platform. Read the privacy statements of other platforms carefully. This privacy statement applies solely to information collected by this platform.

YOUR CALIFORNIA PRIVACY RIGHTS.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement” below.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.

If you have any questions about this policy or want to access, delete or correct your information, please email us at privacypolicy@acushnetgolf.com.

You can also write to us:
Legal Department
Acushnet Company
333 Bridge Street
Fairhaven, MA 02719
USA

WE MAY UPDATE THIS PLATFORM PRIVACY POLICY.

From time to time we may change our privacy policies. We will notify you of any material changes to our platform Privacy Policy as required by law. We will also post an updated copy on our platform. Please check our platform periodically for updates.

CALIFORNIA CONSUMER PRIVACY STATEMENT

This California Consumer Privacy Statement applies solely to California consumers’ personal information collected by Acushnet Company and its brands online and offline. This Statement does not apply to our personnel or job applicants.

This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, education, and other financial information

• Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender, gender identity, gender expression, and medical condition

• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

• Geolocation Data

• Sensory Information: audio, electronic, visual, and similar information

• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Debugging to identify and repair errors that impair existing intended functionality • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Undertaking internal research for technological development and demonstration • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us • Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Geolocation Data
• Sensory Information
• Inferences

2. Disclosure of Personal Information to Third Parties

We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our platform such as Cookies (see our Cookie Policy here in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you). You have the right to opt out of this disclosure of your information, as detailed below.

If we have actual knowledge that an individual is under age 16, we do not collect or disclose the personal information of a minor under 16 years of age unless we have affirmative authorization.

3. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit a Shine the Light request, email us at privacypolicy@acushnetgolf.com. To opt-out of the sale of your personal information, click here.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: e-mail address, recent order information if applicable, name, phone number, address, zip code, etc. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacypolicy@acushnetgolf.com. to request this Statement in an alternative format.

Contact Us

You can reach Links & Kings by emailing us at:
links&kings@acushnetgolf.com