CALIFORNIA PRIVACY NOTICE

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice is effective as of March 29, 2023.

This notice supplements the PGA Privacy Policy and applies only to residents of California (“California Consumer”). This Notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 ("CCPA"), the California Privacy Rights Act of 2020 ("CPRA"), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Personnel Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

EXERCISING YOUR CALIFORNIA RIGHTS

California Consumers have the right to request:

1. that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know");

   1. To exercise your Right to Know, please submit your request at our privacy request form or by calling us at (877) 410-7865.
   2. In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Consumer whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver’s license number, financial account number, health insurance or medical information number, account passwords, security questions and answers, or unique biometric data, as applicable.

2. that we delete the Personal Information we collect from you ("Right to Delete"); 

   1. To exercise your Right to Know, please submit your request at our privacy request form or by calling us at (877) 410-7865.
   2. Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

3. that we correct inaccurate Personal Information we hold about you (“Right to Correct”);

   1. To exercise your Right to Know, please submit your request at our privacy request form or by calling us at (877) 410-7865.

4. to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”);

   1. “Shared” means the disclosure of Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising. PGA of America does not “share” Personal Information for cross-context behavioral advertising. 

5. to opt-out from the sale of your Personal Information (“Right to Opt-Out of Sale”);

   1. Our use of analytics may be considered a sale of Personal Information. To opt-out of analytics, please visit our cookie banner and adjust your preferences;  

6. to limit the use and disclosure of Sensitive Personal Information; 

   1. As disclosed in the chart below, we may collect certain information that is considered Sensitive Personal Information under California law. Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when such use does not fall within the list of exceptions outlined in CPRA § 7027, subsection (m). Our use and disclosure of Sensitive Personal Information falls within this list of exceptions and we therefore do not offer such opt-out right at this time.

We do not sell, or share for cross-context behavioral advertising, Personal Information or Sensitive Personal Information. For a description on how social media services and other third-party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.

Verifying Your Requests

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may require you to log into your internal personnel account or provide your unique personnel ID. We may also need to ask you to provide us with additional information to verify your identity and fulfill your request. We will only use any such information to verify your identity. If we cannot verify your identity, we will not be able to process the request.

Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sharing, Right to Opt-Out of Sale, or Right to Limit the Use and Disclosure of Sensitive Personal Information.

 

Authorized Agents 

You may elect to use an agent to submit a request on your behalf. If you choose to do so, your agent must follow the instructions below to make the request. You may also make a request on behalf of your minor child. When your authorized agent submits a request on your behalf, we will request written permission signed by you and authorizing your agent to make the request on your behalf. The written permission must state your full legal name as the subject of the request, the full legal name of the individual who is acting as your agent and must be clear about the scope of permission granted. Alternatively, your agent may, but is not required to, submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, your agent should also indicate in their email the nature of the request. Your identity, in addition to your agent’s identity and authorization, will need to be independently verified in order for us to be able to fulfill the request. We may also ask you to directly confirm with us that you provided your agent permission to submit a request. Please keep in mind that if we do not receive adequate proof that your agent is authorized to act on your behalf, we will deny the request.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon your relationship with us or how you interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA

  

Category of Personal Information Collected		Categories of Sources from which the Information was Collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose and purpose	Sold or shared
Identifiers: real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.		We may collect this type of information from: You as a user of our Services Your devices External sources you direct us to (for example data you post publicly).	We may use this type of information to: provide and communicate with you about the Services or your account with us To manage events To conduct the Background Check for membership and job applicants    fulfill your requests regarding the Services, including without limitation requests for newsletters and notifications respond to your inquiries communicate with you about other products, programs or services that we believe may be of interest to you enforce the legal terms (including without limitation our policies and Terms of Service) that govern your use of our Services, and/or for the purposes for which you provided the Information provide technical support for the Services prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services protect the safety of our Users customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them perform analysis regarding how you use the Services or any part thereof	We may disclose this type of information to: To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill orders and user requests; (f) process payments; (g) host our Services, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support our Services. Advertisers and Advertising Networks Partners Social Networks In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request or similar request. With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies, our Terms of Service or the law, to verify or enforce compliance with the policies governing our Services. We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way. We may share the Information with companies and Services affiliated with PGA, so they can provide, improve and communicate with you about their own products and Services.  We may share the Information with unaffiliated Partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you.	N/A
Any categories of Personal Information described in subdivision (e) of Section 1798.80		N/A	N/A	N/A	N/A
Commercial information		N/A	N/A	N/A	N/A
Biometric Information		N/A	N/A	N/A	N/A
Internet or other electronic network activity information		We may collect this type of information from: Your devices Our service providers	We may use this type of information to: To operate our websites and mobile apps provide technical support for the Services prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services protect the safety of our Users Customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them Manage our organization and administration Comply with our legal obligations, including security investigations ·	Our "Partners" who include third party service providers, broadcast partners, other golf organizations, advertisers, advertising networks and platforms, agencies, and distribution or other partners may use automated means to collect various types of Information about you, your device used to access, or in connection with, our Services.  A representative, non-exhaustive list of the types of automatically collected information may include: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, device attributes, browser settings, the web pages of the Services you have visited, Services visited before and after you visit a Service, the type of handheld or mobile device used to view the Service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on. Please see our Privacy Policy Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.	Yes, analytic cookies
Geolocation data		We may collect this information from You, when you are asked to share your precise (GPS level) geo-location information with us	We may use this type of information to: customize your experience on our Services or on other Services when we work with a Partner such as a third party mobile ad platform  You may also choose to provide your location, such as when searching for a golf course or services in a particular area or customizing the Service	We may disclose this type of information to: Service Providers such as a third-party mobile ad platforms	N/A
Audio, electronic, visual, thermal, olfactory, or similar information		N/A	N/A	N/A	N/A
Inferences drawn from any of the information identified above to create a profile about You		You Your device Partners Service Providers		We may disclose this information to:  Partners Advertisers and Advertising Networks Social Networks Service Providers	N/A
	Sensitive Personal Information   This includes: for example, ID numbers, such as social security or passport number; account log-in or financial account information.	We may collect the following information from: You Our service providers	We may use this type of information to: To provide access to your account To customize your experience To administer the Qualifying Test	We may disclose this type of information to: Service Providers Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition.	N/A

Financial Incentive Programs (California Residents Only)

We may offer opportunities to receive certain services or benefits such as discounts or free services which may require the provision of personal information. Such opportunities could be considered a financial incentive under applicable law. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program (e.g., by opting out of emails or terminating a streaming service). To the extent we can determine the value of your information, we consider the value of providing you with a more personalized experience as well as the expenses we incur in providing Incentive Programs that are reasonably related to the costs associated with offering the Incentives.

 

California Consumers Under the Age of 16 

We do not knowingly collect or sell Personal Information of California Consumers younger than 18 years of age.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

California Consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate or retaliate against you for exercising your CCPA and CPRA rights.

More Information

For more information about our privacy practices, please refer to our Privacy Policy.