This privacy policy (“Privacy Policy”) discloses the privacy practices of Player Development Systems, LLC, d/b/a Player Development Index (“PDI”), and its affiliates and subsidiaries (“we,” “us,” “our”) and applies solely to information or data collected from or about you when you access, use, or interact with us online through our website (e.g., https://www.golfpdi.com/), mobile application (e.g., the Golf PDI app, downloadable from the iOS store or the Google Play store), or other online applications on which this privacy policy is posted (collectively, the “Service”). Please read this Privacy Policy carefully to understand how any information that you provide to us is used, stored, shared, and protected and to learn about the rights you have with respect to your information.

Acceptance Of Terms

By visiting or using the Service, such as by submitting information to us online, you agree to the terms of this Privacy Policy and our accompanying Terms of Use (“Terms”), incorporated by reference herein, and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, including the Terms, you may not use the Service.

Information Collection, Use and Sharing

PDI collects information, including your personal information, when you visit or use the Service, such as to complete a registration form; submit or post communications through the Service; access assessments, training videos, instructional guides and other content on the Service; purchase, request, or subscribe to access and/or use a product, program, plan or other content through the Service; or contact us directly, such as by email or by submitting a request form. When you access or use the Service, we may also collect technical information from or about you automatically logged by our servers, and information collected indirectly from you through our third-party service providers (“Service Providers”) acting pursuant to a separate agreement between the Service Provider and PDI.

Personally Identifiable Information (PII)

For purposes of this Privacy Policy, “personal information”, “personal data”, “personally identifiable information”, and any other equivalent term defined in applicable data privacy law (collectively, “PII”), mean any information or set of information that could be reasonably used, directly or indirectly, alone or in combination with other information, to identify a natural person. PII does not include information that has been irreversibly de-identified, aggregated, or anonymized, or publicly available information that has not been combined with non-public PII.

PDI collects and maintains PII that you may provide to us through your use of the Service, which may include:

• identification and contact information, such as full name, address; email address; and telephone number;
• basic demographic information, such as age, date of birth, and gender;
• location Information, including precise geolocation if you allow the Service to access location services through the permission system used by your device’s mobile operations system or browser;
• basic physical characteristics, such as height and weight;
• payment information, such as credit or debit card number, expiration date and security code;
• purchase history, such as subscription plans, transactions, and your content or assessment consumption tendencies on the Service;
• account settings preferences, such as whether you have selected to join our email and/or text messaging listserv;
• information you voluntarily give us, such as questionnaire responses about your current levels of exercise, or pictures or videos that you post on our Blog page or Review page;
• information about your athletic progress and certifications, such as your scoring average, progress toward your custom golf training plan, or (if you are a coach) your coaching certification; and
• technical information and usage data, such as IP address, operating system, browser type, web pages visited, and unique device identifiers (see the “Cookies” section below for more detail).

Third Party Platforms
If you choose to communicate with us through a third-party social media platform, such as by tagging us or otherwise directing a message or post at any of our accounts on those third-party social media websites, applications, or platforms (collectively, “Social Media Pages”), the information you post may be visible to any other visitors to that Social Media Page, including members of the public. PDI does not control and is not liable for the data practices of these third-party sites or services. We are not responsible for the safety or security of any PII you include in such posts or how such information may be collected, processed, or used by any other visitor to our Social Media Page(s). We encourage you to review the privacy policies of any third-party websites, including Social Media Pages, that you visit and interact with.

Cookies
We use cookies, pixels, web beacons and other technologies (collectively, “cookies”) to recognize your browser or device when you visit our website or use the Service. A cookie is a piece of data stored on your hard drive when you visit a website or use an online service. The use of cookies allows us to recognize your browser or device when you visit the Service again, which helps us improve your access to the Service and identify repeat visitors. Cookies may store unique identifiers, user preferences and other information.

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

Cookies help us better understand our users and how they interact with the Service by providing us with information about which parts of the Service are most popular, enabling us to analyze technical and navigational information about the Service, and helping us to detect and prevent fraud.

We also use cookies to help improve your experience with the Service. For example, we use Google Analytics to help analyze how users use the Service. These tools use cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Service (including IP address) is transmitted to our data collection tool Service Providers. This information is then used by us to evaluate visitors’ use of the Service and to compile statistical reports on website activity for PDI.

If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose. You may be able to disable cookies and/or other locally stored cookies by disabling them in your web browser or on your device. Some browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet, or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. However, if you decide to block or reject cookies from us, the Service may not function properly.

How We Use The Information We Collect

We may use the information we collect for any of the following purposes:

• to provide the Service to you, including to register your Account and subscription, to develop customized programs under applicable subscription plans, to communicate with you, and to improve the Service;
• to create and manage your Account or subscription with PDI, and to manage your relationship with us;
• to operate, improve, and personalize the products and content we offer, and to give each user a more consistent and personalized experience when interacting with us;
• for marketing purposes, such as to personalize our advertising (e.g., through audience targeting) and marketing communications, your shopping experiences, and our promotional offers, and to deliver promotions and offers to you that we think may interest you;
• if you sign up for our email and/or text messaging listserv, to send promotional messages, materials, and updates about the Service or Service-related products, offers that we think might be of interest to you, or other information requested by you;
• for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Service;
• for research and analysis purposes;
• to complete and fulfill your order or to facilitate your sales requests, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase or a sales inquiry, including your subscription and/or renewal order, and provide you with related customer service;
• to respond to your requests and inquiries, such as a request sent to our customer service/support staff or an inquiry sent to our sales team, messages received through email, telephone calls, text messaging, or other channels of communication that you have approved;
• to send you surveys regarding your satisfaction with our services, products and overall experience with PDI;
• for our business purposes, such as data analysis, audits, developing new products, enhancing the Service, improving our products, programs, plans, and content, identifying Service usage trends and determining the effectiveness of our promotional campaigns; and
• as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

How We Share Information

We may share your PII with third parties, including Service Providers, for the following reasons:

• As needed to provide you with the Service. We share your PII with our independent contractors (e.g., golf-related professionals) and Service Providers as necessary to provide you with the Service and to perform other functions, as necessary to fulfill our business goals. For example, we may use third parties to host the Service, to assist us in providing functionality (e.g., payment processing) on the Service, and to provide data analytics on the Service. We may also use individuals to help us develop the materials, content, and similar features offered through the Service.
• Changes of Control. As PDI develops, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, bankruptcy, or similar event, the PII and other Information may be part of the transferred or assigned assets.
• For Legal Purposes. To the extent permitted by law, we may also disclose the PII and other Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of PDI or others.

How To Make Changes To Your Information

You may review and/or make changes to your PII by contacting PDI as described in the “How to Contact Us” section below. We will use commercially reasonable efforts to process such requests in a timely manner.

Security

We take commercially reasonable steps to protect PII and other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. When we collect PII through our website, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the website. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from the Service may not be secure, and you should, therefore, take special care in deciding what information you send to us via email.

Your Privacy Rights

Depending on where you reside, you may have various rights associated with your PII, including:

• The Right to Access and Correction. You have the right to access the PII we hold about you and to request that it be corrected if it is inaccurate or incomplete.
• The Right to Deletion. You have the right to request that we delete your PII, subject to certain exceptions, such as when we need to retain it for legal or legitimate business purposes.
• The Right to Object. You have the right to object to the processing of your PII in certain circumstances, such as for direct marketing purposes.
• The Right to Data Portability. You have the right to receive your PII in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• The Right to Withdraw Consent. If we are processing your PII based on your consent, you have the right to withdraw your consent at any time.
• Rights Related to Automated Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

To exercise any of your privacy rights, contact us by referring to the “How to Contact Us” section below. Note that prior to fulfilling your access, correction or deletion request, we will take reasonable steps to verify your identity, including by verifying your email address or certain of your information in our records, such as recent order information (if applicable), name, phone number, and zip code.

Do Not Track Signals

PDI does not respond to web browser “do not track” signals or other mechanisms that permit an individual to exercise choice regarding the collection of PII and other personal information about that individual’s activities over time and across third-party websites and online services. However, see the “Cookies” section above for detail on how you can exercise control over the PII collected from you while visiting our website and accessing the Service, and see the “Your Privacy Rights” section above for detail on the may privacy rights you have over your PII and how to exercise those rights.

Communications

By providing your email or phone number to us online, you agree to our Terms and this Privacy Policy, and authorize us to contact you in the same or reasonably similar manner. For example, if you provide your email address in a request form submitted to our support staff, you acknowledge and accept that we may respond to your request by contacting you at the email address provided. Your agreement to receive these communications is not a condition of purchasing any products, goods, or services and you may elect to do business with us over the phone. Where applicable, message & data rates may apply, and message frequency may vary. You may unsubscribe from email communications via the unsubscribe link in the footer of all emails. You may unsubscribe from text communications by replying STOP to any text message. Please note that if you opt out of receiving promotional messages from us, this does not impact other necessary transactional and administrative messages which you will continue to receive (such as emails relating to billing and payment information or changes to this Privacy Policy).

Links to External Websites and Online Services

The Service may contain links to third-party websites and online services. Any access to and/or use of such third-party websites and online services is not governed by this Privacy Policy but is instead governed by the privacy statements of those third parties. PDI has no control over the content or privacy practices of those third-party websites or online services, and PDI is not responsible for the content or privacy practices of those websites. We encourage our users to be aware when they leave our Service and to read the privacy statements of any other website that our users may visit.

Children’s Information

Our Services are intended for a general audience and are not directed toward children under the age of 13. Users cannot be under 13 and must be of legal age to accept our Terms and create an Account. In jurisdictions where the age or consent or majority varies, we comply and align with any age requirements and restrictions.

We do not knowingly collect PII from children under the age of 13 without express parental consent; however, if your child is registered by a coach, they or you may provide relevant account information and assessment data to us to the extent permitted by law. By providing such information to us or the coach, you expressly consent to use of the account information and assessment data as contemplated for the Services and provided under the Terms. If you are a parent or guardian and believe we have unauthorized information about your child under the age of 13, please contact us as provided below.

California Residents

If you are a resident of California, we have additional disclosure obligations to you and you have additional rights under the California Consumer Privacy Act and its implementing regulations, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”). The disclosures included below are in addition to those addressed above and below this section.

Notice at Collection: We may collect (and may have collected during the 12-month period prior to the “Last Updated” date of this Privacy Policy) the following categories of PII:

• Identifiers: This includes your name, email address, postal address, phone number, IP address, online identifiers, and account usernames.
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, credit card number, debit card number, and other financial information, education, and medical information.
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender identity, gender expression, sexual orientation, medical condition, disability, citizenship status, and military and veteran status.
• Commercial Information: This includes information about products or services you have purchased, considered, or shown interest in.
• Internet Activity: This includes your browsing history on our website, search queries, interactions with our online ads or content, and device information.
• Sensory Information: audio, electronic, visual and similar information.
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.
• Geolocation Data: This includes your device’s location when you use our services.
• Inferences: We may draw inferences from your PII to create a profile reflecting your preferences and interests.

Sources of Information: We obtained this PII from the following categories of sources:

• directly from you, such as when you create an account on the Service;
• your devices, such as when you use the Service;
• our affiliates and subsidiaries;
• your friends, such as when someone uses the Tell-a-Friend feature;
• vendors who provide services on our behalf;
• business partners;
• your employer, if you are a representative of one of our business partners;
• online advertising companies;
• social networks;
• recruiting and talent agencies;
• job references, such as your employers; and
• data brokers, such as public databases, credit bureaus, credit reporting service providers, and background check services.

 Categories of Third Parties: During the 12-month period prior to the “Last Updated” date of this Privacy Policy, we may have disclosed the following categories of PII to the following categories of third parties:

• Identifiers: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), business partners, online advertising services, data analytics providers, internet service providers (“ISPs”) and operating systems and platforms, social networks, and data brokers (such as credit bureaus, credit reporting service providers, and background check services).
• Additional Data Subject to Cal. Civ. Code 1798.80: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), payment card companies and financial institutions, internet service providers (“ISPs”) and operating systems and platforms, and data brokers (such as credit bureaus, credit reporting service providers, and background check services).
• Protected Classifications: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), internet service providers (“ISPs”) and operating systems and platforms, data brokers (such as credit bureaus, credit reporting service providers, and background check services).
• Commercial Information: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), business partners, online advertising services, data analytics providers, internet service providers (“ISPs”) and operating systems and platforms, social networks, and data brokers (such as credit bureaus, credit reporting service providers, and background check services).
• Online Activity: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), business partners, online advertising services, data analytics providers, internet service providers (“ISPs”) and operating systems and platforms, social networks, and data brokers (such as credit bureaus, credit reporting service providers, and background check services).
• Sensory Information: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), business partners, online advertising services, data analytics providers, internet service providers (“ISPs”) and operating systems and platforms, and social networks.
• Inferences: Our affiliates and subsidiaries, vendors who provide services on our behalf, professional services organizations (i.e., auditors and law firms), business partners, online advertising services, data analytics providers, internet service providers (“ISPs”) and operating systems and platforms, social networks, and data brokers (such as credit bureaus, credit reporting service providers, and background check services).

In addition to the categories of third parties identified above, during the 12-month period prior to the “Last Updated” date of this Statement, we may have disclosed PII about you to government entities (e.g., in response to a request from law enforcement authorities) and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions or divestitures.

Selling and Sharing PII: We do not sell your PII in exchange for monetary compensation. We may disclose your PII by allowing certain third parties (such as online advertising services and social networks) to collect PII via automated technologies on our Online Services for cross-context behavioral advertising purposes.

Under California law, these kinds of disclosures may be considered a “sale” when the PII is exchanged for non-monetary consideration, or “sharing” when the PII is disclosed for cross-context behavioral advertising purposes.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of PII about you to online advertising services and social networks:

• Identifiers;
• Commercial Information;
• Online Activity; and
• Inferences.

Anti-Discrimination: You have the right under the CCPA not to be discriminated against for exercising your privacy rights. We will not discriminate against you in any way, including by impacting your ability to access the Service or our website, if you choose to exercise your privacy rights.

Children’s PII: We do not have actual knowledge that we sell or share the PII of minors under 16 years of age.

De-Identified Data: To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

California Consumer Privacy Rights: You have certain choices regarding your PII, including:

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the PII we have collected, used, disclosed, and sold or shared about you, including the categories of PII collected, the categories of sources from which the PII is collected, the business or commercial purpose for collecting, selling, or sharing PII, the categories of third parties to whom we disclose PII, and the specific pieces of PII we have collected about you.
• Correction: You have the right to request that we correct the PII we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain PII we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your PII or the sharing of your PII for cross-context behavioral advertising purposes.
• Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of PII 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 an access, correction, deletion, or Shine the Light request, email us at info@golfpdi.com. To opt out of the sale or sharing of your PII, click here or use the Global Privacy Control signal (“GPC”). If you use the GPC, we will process it for your browser, but it will not apply outside of that browser to your device, account, or offline sales or sharing. After using the GPC, if you clear your cookies in your browser, you will need to use the GPC again for us to process your opt-out request for that browser. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your PII or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction, or deletion of your PII, we may require you to provide certain information in our records, such as: e-mail address, recent order information if applicable, name, phone number, and zip code. In addition, if you do not have an account and you ask us to provide you with specific pieces of PII, we will require you to sign a declaration under penalty of perjury that you are the consumer whose PII is the subject of the request. If you designate an authorized agent to make an access, correction, deletion, or opt-out of sale or sharing request on your behalf, (a) we may require you to provide the authorized agent written permission to do so, and (b) for access, correction, and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: 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 info@golfpdi.com if you have any questions about this Statement or our information practices, or to request this Statement in an alternative format.

Colorado and Oregon Residents

We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act or the Oregon Consumer Privacy Act.

Changes to This Privacy Policy

This Privacy Policy is updated from time to time, including when changes are made to applicable privacy laws. The last time it was updated is stated at the top of this Privacy Policy. Modifications shall become effective immediately upon being posted on the Service. Please be aware that, to the extent permitted by applicable law, our use of the PII and other Information is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

How To Contact Us

If you have questions about this Privacy Policy, feel that we are not abiding by this Privacy Policy, want to exercise any of your privacy rights or have any other questions or concerns about our privacy practices, please contact PDI via:

• Email at info@golfpdi.com with “PRIVACY POLICY” in the subject line; or
• Postal mail addressed to: Privacy Administrator, Player Development Systems, LLC d/b/a PDI, 75 Danbury Rd Suite B5-1, Second Floor, Ridgefield, CT 06877.

Our intent is to promptly reply to every message we receive. This information is used to respond directly to your questions or comments. We also may file your comments to improve our services in the future.