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Privacy Policy

Last updated: 14 June 2023

Thank you for visiting this site, which is operated by Torque GC (“we” or “us”). Your privacy is important to us. As such, we provide this privacy policy (“Privacy Policy”) explaining our online information practices as a controller and the choices you can make about the way your information is collected and used by this service. “Users” are persons that use the Services. Please take the time to read the full Privacy Policy. Where US law applies, you consent to the data collection, use, disclosure and storage practices described in this Privacy Policy when you use any of our Services (as described below), including when you access any content. This site is not intended for use by people under the age of thirteen (13).

Overview – Categories and Sources of Information

We collect personal data from Users of our Service when it is voluntarily provided by you, such as your name and email address (see Information We Collect below). We use such information to contact you directly and other purposes described in How We Use the Information and Information Sharing and Disclosure below.

We automatically collect browsing information and other information from Users of our Service and from third parties with whom we work, such as information about your browsing activities and information about the device you use to access the Service (see Information We Collect below). We use such information to customize the Service for you and other purposes described in How We Use the Information and Information Sharing and Disclosure below.

This information is collected to provide, manage, analyze and improve the features and functions available on or through this Service and other services, for marketing purposes and for our internal business purposes.

You can know, access, delete and control certain uses of your information, including opting out of any sales of your personal information (see User Rights – Data Access and Opt-Out below).We will not use or share your information with anyone except as described in this Privacy Policy or with your consent.

I. Information We Collect

We receive both (1) information that is directly provided to us, such as personal data you provide when you visit the Services, and (2) information that is passively or automatically collected from you. In this Privacy Policy, we refer to all of this as the “Information”.

1. Information You Provide To Us.

In the course of using our website, we may collect from you various forms of information, namely: name, address, e-mail address, age, gender.

2. Information That is Passively or Automatically Collected.

We, and our “Partners” who include teams within Torque GC, third party service providers, sponsors, broadcast partners, other golf organizations, advertisers, advertising networks and platforms, agencies, and distribution or other commercial partners may use automated means to collect various types of Information about you, your device used to access, or in connection with, our Services. The list of the types of automatically collected information includes: 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, and product purchase history. Please see our Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.

3. Geo-location Information.

You may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on other Services, when we work with a Partner such as a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

II. How We Use the Information

We may use the Information for the management of our relationship on the basis of the contract between us to:

  1. provide and communicate with you about the Services or your account with us,

  2. fulfil your requests regarding the Services, including without limitation requests for newsletters and notifications,

  3. respond to your inquiries,

Besides, we rely on your prior consent in order to:

  1. communicate with you about other products, programs or services that we believe may be of interest to you,

  2. 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.

Subject to your consent, we may use “cookies” or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser. For information about how these technologies work and how we may use them, please go to Section V, titled Cookies, and Other User and Ad-Targeting Technologies.

In addition, we process Information based on our legitimate interests which consist in:

  1. enforcing the legal terms (including without limitation our policies and Terms of Service) that govern your use of our Services,

  2. providing technical support for the Services,

  3. preventing fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services,

  4. protecting the safety of our Users, performing analysis regarding how you use the Services or any part thereof, and

  5. developing our product offering and improving our Services.

Finally, we process Information to comply with the legal obligations to which we are subject.

III. Information Sharing and Disclosure

We may disclose the Information as follows:

  1. 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, analytics and customer profile development; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) accept and fulfil 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.

  2. 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.

  3. 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.

  4. 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.

Finally, as we rely on certain service providers which are located out of the European Economic Area (“EEA”) and the United Kingdom, this may therefore imply transfers of your Information outside of the EEA/UK. Where the recipient is located in a country whose legislation has not been recognized by the European Commission as having an adequate level of protection, we ensure that the transfer is governed by the European Commission's standard contractual clauses. In this regard, please note that we will provide you with a copy of applicable safeguards upon request, at the contact details specified at the end of this Privacy Policy.

IV. Retention of Information

We shall retain your Information for no longer than necessary for the purposes identified under this Privacy Policy.

With respect to the Services provided to our customers and technical support, we will keep your Information during the period of our contractual relationship, extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your Information for as long as reasonably necessary after the last correspondence with us in order to comply with any request from you not to be contacted.

With respect to the processing carried out in order to protect the safety of our Users and enforce the legal terms, we will keep your Information for the time of the relevant dispute.

As to the processing carried out in order to comply with a legal obligation, we will keep your Information for the duration of such obligation.

Upon expiry of the applicable data retention period, we undertake to erase or irrevocably anonymize the relevant Information.

V. Cookies and Other User and Ad-Targeting Technologies

Subject to your prior consent, we may use cookies and other technologies both to provide our Services to you and to advertise to you as further described below.

Cookies. To enhance your online experience, we may use “cookies”, “web beacons” or other tracking technologies. Cookies are text files placed in your device's browser to store your preferences. We use cookies or other tracking technologies to understand Service and Internet usage and to improve or customize the products, content, offerings, services or advertisements on our Services. For example, we may use cookies to personalize your experience at our Services (e.g., to recognize you by name when you return to a Service), save your password in password-protected areas, and enable you to use shopping carts on our Services. We also may use cookies or other tracking technologies to help us offer you products, content, offerings or services that may be of interest to you and to deliver relevant advertising when you visit this Service, or when you visit other websites or applications. We or a third party platform with whom we work may place or recognize a unique cookie on your browser to enable you to receive customized content, offers, services or advertisements on our Services or other sites. These cookies contain no information intended to identify you personally. The cookies may be associated with de-identified demographic or other data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider solely in hashed, non-human readable form.

We also may use cookies or other tracking technologies to manage and measure the performance of advertisements displayed on or delivered by or through the Services. This also helps us, our service providers and Partners provide more relevant advertising.

We may use Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”) and similar services to collect certain information relating to your use of the Service. Such services may use cookies to help the Service analyze how users use the Service. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).

Syncing Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partners' uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match Users to their likely product interests, or better synchronize, cap, or optimize advertising.

Web Beacons. We and our Partners may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. 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 Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

VI. User Rights – Data Access and Opt-Out1. User Rights.

A. General Rights: We provide you with choices regarding the Information you provide to us.

  • Emails 

    – If you have signed up to receive our marketing e-mails and prefer not to receive marketing information from this Service, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from this Service.

  • Cookies

     – You may accept, delete or block cookies and other technologies by following the instructions above.

B. California Rights: California law provides California residents with specific rights regarding their personal information. The California Consumer Privacy Act of 2018 (“CCPA”) defines “personal information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This section describes the rights that California residents have with respect to such personal information and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA. Please refer to the sections above for more detail about the types of information collected, the purposes for which and sources from where we collect personal information, and the third parties with whom we share personal information.

  • Personal Information

  • Right to Delete – If you would like to delete the personal information we possess about you, please contact us by post or by email at the addresses set out below.

  • Right to Know Categories & Information – If you would like to receive the categories of personal information collected about you, the categories of sources from which the personal information is collected, the purpose for collecting and selling the personal information, the categories of third parties which whom we share the personal information and the specific pieces of personal information collected about you, please contact us by post or by email at the addresses set out below.

Do Not Sell My Personal Information – If you would like us to simply not sell your personal information to a third party, as defined in the CCPA, then you may opt out of such disclosures by contacting us by post or by email at the addresses set out below.

We will maintain procedures to verify that you are authorized to make the requests set forth above. You may designate an authorized agent to make these requests by informing us, though we will need to verify that such agent has the authority to act on your behalf.

We do not discriminate against you for exercising any of your rights above, though we are not able to provide some Services to you without receiving such information.

C. Nevada Rights: Consumers in the State of Nevada have the right to opt out of the sale of personal information processed by us, as defined under Nevada law. To exercise such legal rights, please contact us by post or by email at the addresses set out below.

D. European Economic Area (EEA) and UK Data Subject Rights. If the processing is subject to the General Data Protection Regulation (“GDPR”) or the UK GDPR, you have the following rights:

  • Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.

  • Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.

  • Right to restrict processing – This right allows individuals to restrict processing of personal data under certain circumstances.

  • Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased in specific circumstances.

  • Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.

  • Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing and profiling.

  • Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To exercise your rights under the GDPR/UK GDPR, please contact us by post or by email at the addresses set out below.

In any case, you have the right to lodge a complaint to the relevant European and/or UK data protection authority.

2. Verify Requests.

Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your Information. This is a security measure to ensure that Information is not disclosed to any person who has no right to receive it.

3. How to Contact Us.

If you have any questions or concerns about this Privacy Policy or you would like to exercise your rights under any data protection legislation, you may contact us at:

Postal Address: Torque GC at [insert team address].

You may also contact us regarding your privacy at [insert email address].

VII. Updates & Effective Date

From time to time, we may update this Privacy Policy. Please check this page periodically for any changes. If we make a change to this Policy that is material we will notify you by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. If such change to the Privacy Policy requires your consent, you will have the choice to consent as to whether or not we may use your Information in a different manner. Where US law applies, your continued use of our Service after the posting of any changes constitutes your binding acceptance of such changes.