Last Updated August 18, 2023
Additionally, PGA TOUR encourages parents and guardians to spend time with their children online, and to be fully familiar with the sites visited by the children in their care, including PGATOUR.com. The Sites are not intended for use by people under the age of thirteen (13). Subscribers under the age of eighteen (18) should not participate in contests or sweepstakes or other promotional opportunities on the Sites, nor should they post information to the Sites without a parent or guardian’s consent.
1. THE INFORMATION WE COLLECT.
(a) Your Personal Information. At some Sites, you may be able to register a profile, order products, enter contests, participate in surveys, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters, or participate in one of our online forums or communities. We may collect personal data from other sources, such as vendors, data brokers and public sources. In the course of these various offerings, we often seek to collect from you various forms of personal information. Examples of the types of personal information that may be collected at these sites and other sources include:
· Contact information (e.g., name, address, e-mail address, telephone number)
· Username & password
· Age, gender and other demographic information
· Information about your interests in and use of various products, programs and services
· Precise geo-location information as derived from your IP Address and/or via cell phone towers which may identify your longitude and latitude coordinates.
· Financial information such as credit card number
Registering a profile or participation in surveys or contests is completely voluntary. Therefore, you have a choice whether or not to disclose this information. Where this information is required for participation and you choose to participate, you hereby give consent for the collection of personal information.
When you visit any of our Sites, we, our service providers, advertisers and partners may automatically collect various types of information about your device and your internet activity. A representative list of this type of information that we may collect and use includes:
· IP address and type of browser you are using (e.g., Firefox, Internet Explorer)
· Type of operating system you are using, (e.g., Microsoft Windows or Mac OS)
· Internet service provider (e.g., Comcast, Verizon or AT&T)
· Web pages/Sites you have visited
· Type of mobile device used to view the Site & device identifier location information
· Site content you have accessed & the advertisements you have been shown and/or clicked on
· Other third-party data, consisting of the information above, collected from third-party sources outside of our Sites, such as data from our vendors, data brokers, or public sources
We store this data in log files that do not directly identify individual users. We use this information, to analyze trends, to administer the site, to track users’ movements around the Sites and to gather demographic information about our user base as a whole.
(b) Third-Party Sign-On & Social Media Sites. You can log in to some of our Sites using a third-party single sign-on service. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. This service gives you the option to post information about your activities on each relevant Site to your profile page to share with others within your network.
You also can engage with our content, such as video, games, applications, and other offerings, on or through third-party social networking sites, such as Facebook, or third-party social media plug-ins and applications. When you engage with our content on or through third party social networking sites, plug-ins and applications, you may allow us to have access to certain information from your social media profile (e.g., name, e-mail address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the ‘likes’ you make) to deliver the content or as part of the operation of the application.
We may also obtain information (e.g., content viewed, game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on) from your interaction with our content.
(c) Others’ Personal Information. At some Sites, you may also be able to submit information about other people. For example, you might submit a person's name and e-mail address to send an electronic message and, if you order a gift online and want it sent directly to the recipient, you might submit the recipient's name and address. Examples of the types of personal information that may be collected about other people at these pages include: recipient's name, address, e-mail address, and telephone number. We may use this information to provide the service you requested, and the person may contact us if they no longer want us to use his or her information.
2. HOW WE USE THE INFORMATION.
(a) Use of Your Information. We may use the information we collect for various purposes, which are either based on: (i) your consent, (ii) in order for us to fulfill a contractual obligation or agreement with you, (iii) our legitimate interests, or (iv) compliance with a legal obligation(s). Examples include:
• Fulfilling your requests for our products, programs, and services: We use your information in this way on the basis that it is necessary for us to perform our agreement with you;
• Responding to your inquiries about our offerings and offering you other products, programs or services that we believe may be of interest to you; We use your information in this way on the basis that it is necessary for our legitimate interests to respond to you and to provide you with offers based on our past experience with each other;
• Notifying you when you have won one of our contests: We use your information in this way on the basis that it is necessary for us to perform our agreement with you (i.e. the terms and conditions of the contest) and in order to comply with a legal obligation;
• Enforcing the legal terms that govern your use of our Sites: We use your information in this way in order to comply with a legal obligation;
• Contacting you about your account with us: We use your information in this way on the basis that it is necessary for our legitimate interests in protecting the Sites and services we provide;
• For other purposes for which you provided the information: We use your information in this way on the basis of your consent.
There are additional areas where your information allows for deeper connections for you and our community as well as provide us more insight about our products and services. These include:
• Surveys & Polls: We use this information to learn more about specific users and the user experience on the site as well as attending our events. We may use a third-party service provider to conduct these surveys or polls; that company will be prohibited from using our users’ personal information for any other purpose. The use of your information in this way is on the basis of your consent.
• Online Forums/Communities & Content for Publication: In our online forums and communities, the information you provide allows for an interactive experience and, from time to time, guides us in offering you products, programs, or services. If you choose to submit content for publication (e.g., a letter to our editors, comments sent to our television personalities, a posting to a blog or a discussion board, a video), we may publish your screen name and other information you have provided to us. We may on occasion combine information we collect through our Sites with information that we collect from other sources. Without limiting the generality of the foregoing, if you register and create a profile with our site, the screen name you select as well as other content you submit to your profile (e.g., photos, comments, video, reviews) will be displayed publicly on the Sites and may be reused and redistributed by us in our discretion. Therefore, we use your information in the foregoing way on the basis of your consent and that it is necessary for our legitimate interests to provide you with better Sites and services. To request removal of your personal information from our blog or community forum, contact us via thisform. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We use the non-personally identifiable information that we collect to improve the design and content of our Sites, to deliver more relevant marketing messages and advertisements and to enable us to personalize your Internet experience. We also may use this information to analyze usage of our Sites, as well as to offer you products, programs, or services.
(b) Use of Information about Others. We may use the information that you provide about others to enable us to send them your gifts or cards or emails you may wish to send them from our sites, and for such other purposes as may be stated at the point where the information is collected.
(c) Limitation on Use of Information. We collect data for only purposes that are necessary, required or will enhance the user experience. Your personal information will only be retained for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
3. INFORMATION SHARING AND DISCLOSURE.
(b) Business Transfer. We may transfer personal information about you if we, or one of our business units, are acquired by, sold to, merged with or otherwise transferred to another entity.
Additionally, if you have signed up to receive our e-mails and prefer not to receive marketing information from the Site, follow the "unsubscribe" instructions provided on any marketing e-mail you receive from this Site. To provide visitors with additional or more relevant product and service opportunities, we may share non-personally identifiable information with third parties.
In some circumstance we share general geo-location data such as DMA area as derived from your IP Address. This is used by third parties for the purpose of them serving you ads for places or things in your area. You may opt out of location-based services at any time by editing your settings at the device level.
4. COOKIES & WEB BEACONS.
(a) Cookies and Their Function. To enhance your online experience, we use "cookies" or similar technologies. Cookies are text files placed in your computer's browser to store your preferences. Cookies do not contain personal information; however, once you choose to furnish a site with personal information, this information may be linked to the data stored in the cookie.
(b) Web Beacons. We, our third-party service providers, advertisers or our partners may also use "web beacons" or clear .gifs, tags and scripts, or similar technologies, which are small pieces of code placed on a web page, to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We, our third-party service providers, and our partners, with our permission based on the consent you have provided, may share this data with third parties for purposes of third parties offering targeted advertisements and other marketing to you.
(d) Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile application on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
(e) Do Not Track. We do not respond to Do Not Track signals at this time. However, in respect of our users’ right to privacy, we provide the option to block cookies as outlined in Section 4(d) above.
(f) Global Privacy Control. Some browsers and browser extensions support the Global Privacy Control(“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. In certain territories, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
5. COLLECTION OF INFORMATION BY THIRD-PARTY SITES, AD SERVERS, AND SPONSORS.
Some of our sites contain links to or integrations with other sites such as Facebook, Twitter, Google, LinkedIn, etc., whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
(c) Interest-Based Ads & Marketing. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests. To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
-Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices)
-European Interactive Digital Advertising Alliance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu)
-Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/)
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices.
Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.
Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity may use LSOs such as HTML 5 to collect and store information. We use a third-party service to publish ads on the Sites. When you view or click on an ad a cookie will be set to help better provide advertisements that may be of interest to you on the Sites and other websites. You may opt-out of the use of this cookie by visiting the page here. Various browsers may offer their own management tools for removing HTML5 LSOs.
We utilize a third-party service for targeting purposes. This service uses a variety of techniques including cookie-less device recognition technologies to recognize the user, and their activities across the Sites and other sites for the purpose of targeted marketing by us and other companies that utilize this service. If you wish to opt-out of this service, please visit the opt-out page here. Please be aware that this will not opt you out of advertising in general, but only in relation to this service.
Additionally, we work with the service provider LiveRamp Inc and its group companies (“LiveRamp”) that uses browser technologies such as cookies to match user information, such as your email address in hashed form, with data in their marketing databases. This then creates a pseudonymous privacy-centric identifier for our use in real time bidding in digital advertising. We may also share with LiveRamp hashed and de-identified email addresses, IP addresses, and advertising identifiers. That information may then be used to create a connection between your device and its databases. Such connection may be shared with our partners and advertisersglobally for the purpose of enabling interest-based content or advertising by third parties unaffiliated with our Site throughout your online experience and across your various devices and platform. To opt out of this use of your information, please click here.
Furthermore, when you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR). LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognizing you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you. To opt out of this use of your information, please click here.
6. INTERNATIONAL TRANSFER.
PGATOUR.com, LLC adheres to the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (collectively, “DPF”) as set forth by the U.S. Department of Commerce. PGATOUR.com, LLC relies on the EU-U.S. DPF as a legal basis for transfers of personal information. PGATOUR.com, LLC will rely on the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF as a legal basis to transfer personal information from the UK and Switzerland once the applicable local authorities approve Adequacy Decisions. In the meantime, PGATOUR.com, LLC continues to rely on standard data protection clauses and standard contractual clauses for the purposes of UK and Swiss data protection law. To learn more, review the Data Privacy Framework section below.
(a) Data Privacy Framework
PGATOUR.com, LLC is responsible for the processing of personal data it receives as detailed herein, and in accordance with the DPF, and subsequently transfers to a third party acting as an agent on its behalf. PGATOUR.com, LLC complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over PGATOUR.com, LLC’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, PGATOUR.com, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, PGATOUR.com, LLC commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.
7. OUR COMMITMENT TO SECURITY.
The security of your personal information is important to us. We have put in place reasonable physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Sites, you can contact us at firstname.lastname@example.org.
8. HOW YOU CAN ACCESS, CORRECT, OR DELETE INFORMATION.
Access to personal information that is collected from our Sites and that we maintain may be available to you. For example, if you created a password-protected account within our site, you can access that account to review the information you provided.
You may also send an email to the following email email@example.com or submit a data subject access request form found here requesting access to, deletion of, correction of or transfer of your personal information. For verification purposes please include your first name, last name, and e-mail address you use for such service.
We will endeavor to respond to your request to access within 30 days. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort.
9. HOW TO CONTACT US.
10. CALIFORNIA RESIDENTS PRIVACY RIGHTS
This section applies to California residents only and is meant to supplement the other provisions of this policy. Under the California Consumer Privacy Act (“CCPA”), California residents have the following rights:
(a) Right to Know. You have the right to request that we disclose to you the following information about our collection and use of your personal information over the twelve (12) months prior to your request:
· The categories of personal information we collect about you.
· The categories of sources for the personal information we collect about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information collected about you.
· If we disclosed or sold your personal information for a business purpose, (i) a list of the categories of personal information we have disclosed in the prior twelve months and (ii) a list of the categories of personal information we have sold in the prior twelve months.
(b) Right to Deletion. You have the right to request that we delete any of your personal information that we have collected. However, in certain circumstances, we will not be able to delete your information. Examples of these circumstances include, but are not limited to, retaining your information to protect the security or functionality of our systems, complying with legal requirements and obligations, completing a transaction for you, servicing your account or where data is not reasonable able to identify you.
(d) Do Not Sell My Information Right. You also have the right to direct us to not sell your personal information at any time. In the past twelve (12) months, we have disclosed or sold to third parties the following categories of your personal information for business purposes described in this policy (e.g., advertising and to protect against fraud and malicious activity): personal identifiers, commercial information, information gathered for site registration, information gathered from survey or sweepstakes entries, Internet/other electronic network activity information, geolocation data, characteristics of protected classifications, characterizations based on site use and inferences drawn from this information. To opt out of the sale of your personal information, please submit a form here, or email us at firstname.lastname@example.org.
11. USERS FROM THE EUROPEAN ECONOMIC AREA ("EEA").
In accordance with the EEA’s privacy law known as the General Data Protection Regulation (“GDPR”), this Section 11 applies to users who are located in the EEA when their personal information is collected. We are the data controller (as defined in the GDPR) for processing of personal information when you use the Sites.
· Your consent (which consent you can withdraw at any time),
· Fulfillment of a contractual obligation or agreement with you
· Our legitimate interests (provided that your interests and fundamental rights do not override those interests); and
· Compliance with a legal obligation(s).
Examples of each of these legal bases are set forth in Section 2(a) above.
(b) Rights of Individuals Based in EEA. Subject to certain exceptions under the GDPR and any other applicable law, you may be able to exercise certain rights with regard to your personal information, including the following:
· Right of access to personal information
· Right to correct your personal information where it is incorrect or incomplete
· Right of erasure of your personal information if certain grounds are met
· Right to restrict/suspend processing of your personal information
· Right to complain to a supervisory authority if you believe our processing of your personal information infringes applicable law
· Right of data portability (if processing is based on consent and automated means)
· Right to withdraw consent at any time (if processing is based on consent)
· Right to object to processing (if processing is based on legitimate interests or is for direct marketing purposes)
Requests to exercise any of these rights by individuals in the EEA should be submitted through our standard form or by emailing us at email@example.com.
12. UPDATES & EFFECTIVE DATE.