LAST UPDATED: DECEMBER 2019
Your privacy is important to us and we will responsibly maintain and protect your information.
WHAT INFORMATION WE COLLECT AND HOW IT IS USED
Information You Provide
The EZLinks Platforms may collect and retain the following information:
Information is used to:
(1) process transactions, including the purchase or reservation of a golf tee time or your registration with the EZLinks Platforms, including verifying information you provide is active and valid;
(2) provide related customer service (for example, to respond to your questions, complaints or comments);
(3) customize content, recommendations and offers we display to you;
(4) market EZLinks or a third party;
(5) provide and improve the EZLinks Platforms and develop new features;
(6) contact you with regard to your use of the EZLinks Platforms including, in our discretion, changes to our policies;
(7) conduct analytics on Platform performance and investigate site activity;
(8) support primary and third-party marketing efforts including the serving and targeting of ads;
(9) enable third-parties to conduct transactional activities and to market to you, such as providing to the golf course to hold or charge a reservation and to market to you in the future;
(10) display historical sales or performance (eg: scorecard) information;
(11) administer loyalty programs.
Select information provided or otherwise collected will be maintained in your customer profile ("Account") which you may edit at any time by accessing your profile in the Account Information section of the EZLinks Platforms. That information includes:
General Contact Information: To create your Account and to fulfill transactions on the EZLinks Platforms, we require that you submit certain contact information for ease of communication throughout your use of the EZLinks Platforms. Such information may include name, address, phone number, email address, date of birth, and gender.
Payment Information: We will also facilitate the collection of payment information from you in the form of a credit card number when you conduct a transaction on the EZLinks Platforms, or reserve a round of golf at a Partner Course. Payment information is encrypted, transferred and stored as a token at a third-party processor to ensure the security of data. Payment tokens may be provided to a Partner Course in the event that the Partner Course is required to charge you in accordance with their no-show policy. By providing payment information and completing the transaction, you consent to the use of this payment information by EZLinks and third-parties for the sole purpose of facilitating transactions (eg: purchases, refunds) and to support the facilitation of EZLinks Terms and Conditions and Sales Policies including applicable Partner Course policies including but not limited to the facilitation of No Show charges.
Records of your contact with us: In addition to Account and Payment information, we also maintain certain information about your usage of the EZLinks Platforms, your contact with us, and your ordering history. This information is maintained to better serve your individual needs, to facilitate a smoother search and transaction process, to audit and investigate site use, and to help us better deliver an experience catered to your needs. Such information may include: past purchases made through the EZLinks Platforms (courses played, etc.); usage of the EZLinks Platforms and marketing information; and other data to help us better personalize your experience on the EZLinks Platforms and marketing.
Information We Collect Automatically
Connection and Usage Information: EZLinks, and our third party service providers (including analytics providers and third party content providers), may automatically collect certain usage information whenever you visit or interact with the EZLinks Platforms, including the browser and operating system you may be using, the URL or advertisement that referred you to the EZLinks Platforms (if applicable), the search terms you entered into a search engine that lead you to the EZLinks Platforms (if applicable), all of the areas within the EZLinks Platforms that you visit, and the time of day you used the EZLinks Platforms, among other information relating to your use of the EZLinks Platforms. We may use usage information for a variety of purposes, including analyzing and improving the EZLinks Platforms and products, to provide special offers, and to select appropriate content to display to you.
Device Identifiers: In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or tablet, or other device you may use to access the EZLinks Platforms. A Device Identifier is a number that is automatically assigned or connected to the device you use to access a service, and our servers identify your device by its Device Identifier. We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software, preferred language, advertising identifiers, serial number, device motion information, and mobile network information. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access a service (i.e., GPS information). Usage information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.
The EZLinks Platforms may contain content served by third parties, including videos and advertisements, and we work with third party service providers to serve EZLinks advertisements elsewhere online. In connection with serving content and providing analytics and advertising services, third parties may collect certain information about your visits to this or other websites and we may receive information regarding the use of the EZLinks Platforms and the effectiveness of our advertisements. These advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your online browsing activities. This information helps us better serve you, troubleshoot any issues you may be experiencing, and provide an overall superior experience.
HOW WE SHARE INFORMATION
Fulfillment of Transaction (Partner Course)
In the event you conduct a transaction through the EZLinks Platforms, we will share your information with the facility or third party that will fulfill your purchase (usually, a golf course). The primary piece of information used to identify you when you purchase a round of golf will be your email address, which will be shared with the golf course. Your use of the EZLinks Platforms confirms your consent for EZLinks and the Partner Course to use your email address for future golf marketing initiatives. You may unsubscribe from such EZLinks messages at any time by utilizing the unsubscribe feature in every email. If you wish to unsubscribe from messaging from a Partner Course, you must communicate directly with the Partner Course.
Service Providers: We may provide access to information to vendors that are performing services on our behalf, including processing payments, providing customer support, analytics providers, and performing other administrative services, in order to carry out such services.
Affiliates: We may share the personal information we collect through the EZLinks Platforms with our subsidiaries and affiliates.
Sales or Transfer of Business or Assets: In addition, we also may share the information described above in connection with a business transfer, such as to another company that may purchase all or substantially all of the assets we use to provide the EZLinks Platforms to you (this includes disclosure during the due diligence process).
We reserve the right to share non-personal information, such as aggregate user statistics, demographic information and usage information with third parties, including advertisers, content providers, and analytics providers.
Social Media/Integration with Third Party Properties
The EZLinks Platforms may permit you to interact with a third-party site or service. If you choose to interact with another site via any of the EZLinks Platforms (e.g., sharing content or otherwise posting information from or via the EZLinks Platforms to a third-party site or service), that information may be publicly displayed, and the third party may have access to certain information about you and your use of the EZLinks Platforms. Similarly, if you interact with us through a third-party site, we may have access to information about you (for example, if you "like" or "follow" our page on a third-party site). When you choose to interact with a third-party site or service, that third party may collect information about your visits to the EZLinks Platforms and may publish that activity to your profile or similar feature on that third-party site (such as if you choose to share one of your golf course reviews from the EZLinks Platforms with your connections on the third-party site). The information collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party site.
HOW LONG WE MAINTAIN INFORMATION
We only maintain your information for as long as is necessary or of value to reporting or of value to conduct business. We take care to only retain personal information for as long as is needed in order to continue to provide you with the services you receive through the EZLinks Platforms. If you wish to discontinue receiving messaging from us, you may indicate that desire at any time by clicking on the unsubscribe function on one of our email communications. Additionally, we will maintain your account information for your ease of use of the EZLinks Platforms, and for fulfillment of purchases made through our channels. We have developed and maintained data retention policies to ensure that personal information is not maintained longer than is needed. We will maintain your data for as long as is needed to fulfill your transactions and to reference your purchases for the relevant time period. We will also maintain your data for as long as needed to comply with tax laws and other reporting and regulatory time periods. When you have created and maintained an active customer account, we will maintain your personal information associated with that account until you notify us to delete your account or certain of your personal information.
YOUR RIGHTS TO YOUR INFORMATION
We believe in your right to access and maintain your information as it exists within the EZLinks Platforms. Accordingly, you may update your account information at any time by accessing the Account Information section of the EZLinks Platforms. If you wish for us to modify information that is inaccessible to you or to remove your information entirely, please submit your request to firstname.lastname@example.org.
In addition, the local laws where you live (e.g., laws of EU or California) may permit you to make certian requests. See the section applicable to the place of your residency below.
We will ask for you to verify your identity as the account holder prior to fulfilling any request you may have about your personal data – to ensure that the data we control is secure and protected. We will make good faith efforts to make requested changes in our then active databases. If you make changes, information may persist internally for administrative purposes and that residual data may remain on backup media or for other reasons. Additionally, if you would like to request that the EZLinks Platforms to cease maintaining records about you, you may request to be forgotten by submitting a request.
If you have made any public postings on or through the EZLinks Platforms, those posts usually will not be removed.
You may opt out of receiving marketing emails by following the opt-out instructions provided to you in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the EZLinks Properties (for example, administrative and service announcements) and these transactional account messages may be unaffected if you opt-out from marketing communications. If you sign up to receive SMS or MMS messages that may be offered on the EZLinks Platforms, you may unsubscribe from any text messages received by replying "STOP". You may opt-out of push notifications by managing settings in your phone or removing the app.
ABOUT THIS POLICY
We take commercially reasonable security measures to protect the personal information submitted to us, both during transmission and once we receive it. For example, when you enter certain personal information, such as a credit card number and CCV2 number on our checkout forms, that information is encrypted using secure socket layer (SSL) technology, to help protect the communications between you and our payment partners. However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit and you do so at your own initiative and risk.
Consent to Transfer
EZLinks is a United States company. If you are located outside of the United States, please be aware that, subject to applicable laws and regulations, information we collect will be transferred to and processed in the United States. By using any of the EZLinks Platforms, or providing us with any information, you fully understand and consent to this transfer, processing and storage of your information in the United States.
Our services are general audience services and are not intended for individuals younger than the age of 16. We do not knowingly collect Personal Information from individuals younger than the age of 16. If EZLinks discovers that it has inadvertently collected Personal Information (as defined below) from anyone younger than the age of 16, it will delete that information. In addition, you must be at least 18 years of age to make a purchase through the EZLinks Platforms.
The following information applies to California residents regarding “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). This information and the rights discussed below do not apply to information collected from or about our employees, former employees, candidates, contractors, service providers, or business contacts.
Categories of personal information we collect, use and disclose. Throughout this Policy, we discuss in detail the specific pieces of information we collect from you and other users (as described above) and discuss how we use and share such information. The CCPA requires us to provide additional information about this collection and use.
• We may collect, use, and disclose for our business and commercial purposes, the following categories of information about you or your use of the Services: Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); user-generated content; device identifiers (such as IP address); internet or other network or device activity (such as browsing history or app usage); professional and employment related information; location data; audio or visual information (such as if you participate phone survey or submit a photo); and other information that identifies or can be reasonably associated with you.
Sale of personal information. California law broadly defines “sale” in a way that may include the delivery of targeted advertising on the Services or other sites, including allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior. We may share the following categories of information for such advertising which may be considered a sale (as defined by California law):
• Device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history or app usage; geolocation information, such as city; and inference data.
If you are a California resident and would like to opt out of our use of your information for such purposes (to the extent this is considered a sale), you may do as outlined on the following page: Do Not Sell My Personal Information.
California Privacy Rights
California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:
• provide access to and/or a copy of certain information we hold about you;
• delete certain information we have about you; and/or • provide you with information about the financial incentives that we offer to you, if any.
Please note that certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights under the CCPA.
If you would like information regarding your rights under applicable law or would like to exercise any of them, please click here
to log into your account or contact us at email@example.com or visit here
. To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests, including by verifying your account information, residency or the email address you provide.
Shine the Light Disclosure.
Under California Civil Code Section 1798.83, California residents who provide us personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us one time per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. To obtain this information from us, please send an email message to firstname.lastname@example.org or to the following mailing address: ATTN: Legal Department, 401 S LaSalle Street, Suite 302, Chicago, IL 60605. You must put the statement "Your California Privacy Rights" in the subject field of your email or in your writing if you write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We will provide the requested information to you at your mailing address, or at our option, your email address in response. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Pursuant to Nevada law, consumers in Nevada have the right to opt-out of the sale of certain covered personal information, as those terms are defined under applicable Nevada law. If you are a Nevada resident and would like to opt-out of the sale of the covered personal information we have collected about you through the EZLinks Platforms, please submit your request to email@example.com. Your request must include “Nevada Opt-Out” in the subject line and the email should include your full name, street address, city, state and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via the email address you use to contact us as needed regarding this request. If you previously provided a phone number to us, including it in your Nevada Opt-Out request email will assist us in identifying you and processing your request. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. EZLinks will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.
European Privacy Rights
In addition to the rights listed above, European residents have rights to:
• Know what personal information we have about you;
• Access and modify or request that we modify or correct your personal information;
• Request personal information be deleted here
You may exercise any of the above-referenced rights, or lodge a complaint about our use of your personal information by contacting our Data Protection Officer at:
Mail: EZLinks Golf LLC
401 La Salle Street, Suite 302
Chicago, IL 60605
Attn: Bart Dolega
If EZLinks is able to process the request of personal data deletion, you acknowledge EZLinks may no longer have the ability to provide or facilitate promotional offers associated with your email including the administration of loyalty points or promotion; inform you of business events (eg: policy updates); support use of features (eg; scorecard history). By requesting to be removed, you actively relieve EZLinks of obligations that require use of your data.
Furthermore, by reengaging with EZLinks marketing efforts (direct or indirect through a third party), visiting the EZLinks Platforms, or submitting information, you are opting in to EZLinks Policies and EZLinks may begin collecting and retaining your information as outlined and protected in this policy.