UPDATED AND EFFECTIVE: December 14, 2022
This privacy notice ("Privacy Notice") applies to our physical locations, including our on-site kiosks ("Locations"), our websites ("Website(s)"), mobile and desktop applications ("Application(s)"), (collectively the Locations, Websites, and Applications, the "Topgolf Offerings"), owned and operated by Topgolf International Inc., and its subsidiaries and affiliates (collectively "Topgolf," "we," "our," or "us").
Please review this Privacy Notice and our Terms and Conditions carefully. To the extent legally permitted, your use of the Topgolf Offerings, including any purchase of any products or services, signifies you have read, understood, and agree to this Privacy Notice and Terms and Conditions.
We may collect information from you directly, automatically when you visit or use the Topgolf Offerings and from third parties. Some of this information may be considered personal information or personal data under various applicable laws. We consider information that identifies you as a specific, identified individual such as name, gender, age, postal address, email, and phone number as personal information ("Personal Information" or "Personal Data"). We will also treat additional information, including IP addresses and cookie identifiers, as Personal Information where required by applicable law. Note that we may de-identify or pseudonymize Personal Information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as "hash". We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified and pseudonymized information as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with Personal Information, then we will treat the combined information as Personal Information under this Privacy Notice.
We may collect Personal Information or other information (such as demographic information or information about your interests) from you when you use or interact with the Topgolf Offerings, such as when you create an account; make a reservation; play games on our Websites or Applications; visit our Locations; visit our Websites; use our Applications; take part in surveys; participate in golf lessons, leagues, and tournaments; book or participate in events at our Locations; sign up for emails, text messages, or other marketing communications; contact us or make purchases; take part in discussion boards or other social media functions on the online Topgolf Offerings; or participate in a sweepstakes or contest.
You may choose to provide us email addresses or contact information of other people, such as if you book an event or make a reservation and give us the contact information of your guests. If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
When you interact with us through the Topgolf Offerings online, we and our third party business partners automatically collect certain information regarding your visit and use of the online Topgolf Offerings, including the total number of visitors, pages visited per use, browser type, IP addresses, exit page, duration of use, and operating system type, to administer the Topgolf Offerings and analyze trends and statistics to evaluate our visitors' preferences and the Topgolf Offerings' effectiveness ("Usage Information"). For our online Topgolf Offerings, you can control the use of cookies at the individual browser level. Usage Information may include the hardware model, browser, the URL or advertisement that referred you to the online Topgolf Offering, the search terms you entered into the search engine that led you to the online Topgolf Offering, among other information. We may use Usage Information for a variety of purposes, including enhancing or otherwise improving the online Topgolf Offerings. In addition, we may automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone, or other device you may use to access the online Topgolf Offerings.
The methods used to collect Usage Information may include the following:
Cookies and Local Storage. The online Topgolf Offerings use cookies and related technologies ("Cookies") to enhance the browsing and usage experience on our online Topgolf Offerings. "Cookies" are small files or records that are placed on a visitor's device or browser (by a third-party or us) to collect information about your activities on our online Topgolf Offerings. Cookies may be used for many purposes by us and third parties, such as:
As detailed below, we also allow certain partners to place Cookies on our online Topgolf Offerings to provide personalized marketing to you. You can find more information about Cookies and how they work at allaboutcookies.org.
Certain browsers or browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to Cookies, and some of the content included on the online Topgolf Offerings may make use of this local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our online Topgolf Offerings and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a Website or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the online Topgolf Offerings, to monitor how users navigate the online Topgolf Offerings, to count how many emails that were sent were actually opened, or to count how many particular links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the online Topgolf Offerings, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the online Topgolf Offerings and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, online functionality, and operational purposes.
We may collect or infer your approximate location through information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers or business partners with information regarding the physical location of your device.
We may also receive Personal Information about you from other sources, including other users who add you to a reservation, third-party business partners (including companies that assist us with online advertising and analytics), or publicly available sources. If you are an existing user of any Topgolf Offering, or later become a user of any Topgolf Offering, we may combine the information we receive from you with information about you from other sources to better understand your interests and preferences and better market our products and services to you.
We may combine the information we receive from those other sources with information we collect through the Topgolf Offerings. In those cases, we will apply this Privacy Notice to the combined information. The information collected and stored by the third party is subject solely to the third party's privacy practices.
The online Topgolf Offerings may permit you to interact with a third-party social media site ("Social Site"), for example, by including a button allowing you to link to a third-party platform (such as Instagram or TikTok) or interacting with you through your social media account ("Social Site Features"). When you access a Social Site through our online Topgolf Offerings or use or access any of our products and services or communicate with us by way of a Social Site, including Social Sites where you can play our electronic games, both we and the Social Site may have access to certain information about you and your use of the online Topgolf Offerings and the Social Sites. The Social Sites may collect information about your visit to the online Topgolf Offerings through Social Site Features we have integrated into the Topgolf Offerings. The Personal Information you allow us to access varies by game and Social Site, and it is affected by the privacy settings you establish at the Social Site. You can control and find out more about these settings at the Social Site where you play our games or otherwise access our content or interact with us. For example, we may access and store some or all of the following information, as allowed by you, the Social Site, and your preferences; your first and last name; your profile picture or its URL; your user ID number, which is linked to publicly available Personal Information such as name and profile photo; the user ID numbers for your friends that are also connected to us or our game(s); and the login email you provided to that Social Site when you registered. Note that through the Social Site Features, these Social Sites may be able to collect certain information about your visits to the online Topgolf Offerings regardless of whether or not you affirmatively interact with the Social Site Features and whether or not you are logged into (or have) an account with the Social Site. If you use the Social Site Features, your interaction and Personal Information may be publicly disclosed on the Social Site.
By accessing our products and services or otherwise communicating with us through a Social Site, you understand we will collect, store, and use, in accordance with this Privacy Notice the Personal Information that you have allowed the Social Site to provide to us, or that we collect through the Social Site, including through an Application Programming Interface ("API").
To manage the Personal Information we receive about you from the Social Site where you play our games or interact with us, you will need to follow the instructions at that Social Site for updating your Personal Information and changing your privacy settings.
Once we receive your Personal Information from a Social Site, that Personal Information is stored and used by us as set out in this Privacy Notice, and you may access and update that Personal Information as described below.
We may use non-personal information for any purpose allowed by applicable law, including for advertising, research, and marketing purposes. We also use information collected from or about you, including Personal Information and Usage Information, as disclosed in this Privacy Notice, including to:
We may share non-personal information, such as aggregate user statistics, hashed or otherwise de-identified or pseudonymized information, and Usage Information, with third parties in our discretion.
In addition to the specific situations discussed elsewhere in this Privacy Notice, we share Personal Information as disclosed at the time you provide it, with your consent, and in the situations described below.
Topgolf is a subsidiary of Topgolf Callaway Brands Corp. which also includes several brands and companies, ("Topgolf Callaway Brands Family of Companies"). You can see the Topgolf Callaway Brands Family of Companies here. Topgolf shares information across the Topgolf Callaway Brands Family of Companies for internal business, analytical, operational, and marketing purposes.
We use service providers and sub-processors ("Service Providers") to provide services to us or on our or your behalf, such as payment processing, customer relationship management, scheduling bookings (e.g., events, reservations, and golf lessons), food and beverage, information technology, employment application tracking, communications, and insurance. We give these Service Providers access to your Personal Information (or allow them to collect information from or about you) so that they can provide these services.
We may ask if you would like us to share your information with unaffiliated third parties who are not described elsewhere in this Privacy Notice and we may permit partner companies and other third parties to collect your information directly from you, with your permission. We do not share your Personal Information with third parties for those third parties' direct marketing purposes unless you consent (opt-in or opt-out) to such sharing. For example, you may be presented with an opportunity to receive marketing offers from a third party or you may engage with a Social Site platform or other third-party application or feature, through which information about you is shared. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
We do not sell or rent for monetary compensation to third parties any of the Personal Information that you provide to us through the Topgolf Offerings or authorize any of our Service Providers to sell or rent any such Personal Information for monetary compensation, and we do not authorize any of our Service Providers to make independent use of your Personal Information for their own purposes, including but not limited to direct marketing.
Aggregated information about customers utilizing the Topgolf Offerings, in surveys or otherwise providing information to Topgolf will be utilized by Topgolf and/or Service Providers in connection with research, benchmarking and other like uses related to general usage analytics.
In case of a transfer or sale of some or all our business or assets, bankruptcy, or merger, or other corporate transaction (including, without limitation during the negotiation stage and in the course of any due diligence process), we may transfer or assign your Personal Information to those involved in such a transfer or sale of business or assets, which you agree that we may do without your further consent.
We may transfer and disclose your Personal Information (i) in response to subpoenas, warrants, court orders, or in connection with any legal process, or to comply with relevant laws or (ii) at the request of governmental authorities conducting an investigation. In addition, notwithstanding any term to the contrary in this Privacy Notice, we reserve the right to use and disclose your Personal Information to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Terms and Conditions [Link] or other applicable policies.
Some Topgolf Offerings may provide the opportunity to post comments, photographs, reviews, or other content in a public forum. If you decide to submit information in these forums, that information will be publicly available, may be used by third parties, and is not typically subject to the restrictions of this Privacy Notice.
We may, with our third-party partners, offer sweepstakes, contests, or other promotions (any of which, a "Promotion") that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion's terms or official rules (such as on a winner's list). If you decide to enter a Promotion that is co-sponsored by a third-party partner, the Personal Information that you provide will be shared with us and with them. Their use of your Personal Information in this context is not governed by this Privacy Notice.
If you apply for a job through our Topgolf Offerings, we or our Service Provider(s) may ask you to provide self-identifying information such as your veteran status, gender, and ethnicity in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints. Please note that we may utilize a careers portal that is operated by a third party, in which case, your registration and use of the careers portal may be subject to the third party's privacy practices as disclosed on the portal.
We use third-party advertising companies, ad agencies, analytics providers, and network advertisers to target and serve ads when you visit our online Topgolf Offerings and elsewhere online and offline, and to provide us with information regarding use of our Topgolf Offerings and effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including Cookies), and they may otherwise collect or have access to certain information about your use of the Topgolf Offerings. Some of these companies may collect Personal Information over time when you visit and/or access the online Topgolf Offerings or other online websites and services. We may share information, typically information that has been aggregated, pseudonymized or de-identified, Usage Information, and location information with third party advertising companies, analytics providers, and other third parties for these purposes.
We use a variety of third parties to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA"). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. Note that these are cookie-based opt-outs. If you disable your Cookies or upgrade your browser after opting out, or if you use different devices or browsers, you will need to indicate your opt-out choices across those other devices and browsers. European Union and United Kingdom residents, please refer to European Digital Advertising Alliance ("EDAA") choice page at youronlinechoices.com. Australian and South Korean residents, please refer to DAA's choice page at youradchoices.com.
Mobile devices may contain settings that allow you to disable tracking advertising and analytics. In addition, the digital advertising industry has provided the ability for mobile users to register their intent not to receive targeted advertising at aboutads.info/appchoices.
One of the third-party tools we use is Google Analytics, which uses Cookies and other technologies to collect and analyze information about use of the online Topgolf Offerings and provide other reports. This service may also collect information regarding your use of other websites, apps, and online resources. For information about opting out from Google, click here and to download the Google Analytics opt-out browser add-on from Google, click here.
Please note that opting out through these mechanisms does not opt you out of being served advertising and you will continue to receive generic ads while online.
Do-Not-Track: Please note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services that you visit. When you choose to turn on the "Do Not Track" setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about and set up "Do Not Track," please visit allaboutdnt.com.
Global Privacy Control: Global Privacy Control ("GPC") is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. To find out more about and set up GPC, please visit globalprivacycontrol.org/#about.
The online Topgolf Offerings may provide links to websites, gaming platforms, and online services operated by third parties. These third parties use their own cookies and other tracking technologies on your device, and they may independently collect Personal Information from you. We assume no responsibility for third parties or their privacy practices. This Privacy Notice applies only to our Topgolf Offerings.
Except as noted in Section 17, Notice to European Economic Area/United Kingdom Residents, our Websites and Applications are directed to persons who are at least thirteen (13) years of age, and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13) years.
If a parent or guardian is made aware that a child under the age of thirteen (13) years has provided us with Personal Information through any point of contact, please call us toll-free at (833) 554-0955 or write to us at the contact details below, and we will delete the Personal Information. If we have actual knowledge that Personal Information about a person younger than the age of thirteen (13) years has been collected without parental/guardian consent, then we will take the appropriate steps to delete such Personal Information.
Although we cannot guarantee that there will never be a security problem (no system can be 100% secure), we have in place commercially reasonable security measures to guard against the loss or misuse of Personal Information collected through the Topgolf Offerings. However, we cannot guarantee or warrant the security of any information you disclose or transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. In the event that we are required by law to inform you of a breach of your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by applicable law. You use the Topgolf Offerings and provide us with information at your own initiative and risk.
For Personal Information that we collect and process, we typically keep such Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, and as otherwise permitted by applicable law or needed to address tax, corporate, compliance, litigation, insurance claims, and other legal rights and obligations. Information that has been anonymized and aggregated is not Personal Information, and we will keep such information in accordance with our retention policy.
Information about our marketing communications to you (e.g., how you may opt in or out) are set forth below.
Updating and Deleting Your Personal Information. Some of our online Topgolf Offerings may allow you to modify or delete your account profile. Note that we may keep some Personal Information as permitted by law.
Email. You may unsubscribe from marketing emails we send you through the opt-out mechanism included in each such email. Note, however, that we reserve the right to send you certain communications relating to your use of our products or services, notices of changes to this Privacy Notice or other terms, or similar administrative and transactional messages.
Text Messages. Personal Information obtained from you in connection with a SMS/text message service may include your mobile phone number, your carrier's name, the date, time and content of your messages, and other information you provide to us as part of this service. You can unsubscribe at any time by texting "STOP" to the number provided in the SMS/text message. A SMS/text message will be sent confirming your removal. We reserve the right to remove subscribers from our messaging database. For more info, text "HELP" to the number provided in the SMS/text message.
Other Privacy Rights. If you are a California resident, please see our Notice to California Residents for additional information about how to exercise your privacy rights. If you are a Nevada resident, please see our Notice to Nevada Residents for more information on additional rights you may have. If you are a Virginia resident, please see our Notice to Virginia Residents for additional information about how to exercise your privacy rights. If you are an Australian resident, please see our Additional Information For Australian Residents. If you are a UK or EEA resident, please see our Notice to European Economic Area/United Kingdom Residents for additional information about how to exercise your privacy rights. If you are a resident of South Korea, please see our Notice for South Korean Residents.
Topgolf is headquartered in the United States. If you use a Topgolf Offering outside of the United States, and provide us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Notice. Please be aware that information that we collect will be transferred to and processed in the United States and other jurisdictions. By using the Topgolf Offerings outside of the United States, you specifically consent to our collection, processing, storage, or transfer of your Personal Information in the United States and other jurisdictions, including in countries where data protection standards may differ from those in the country where you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States and other countries may request to access your Personal Information in accordance with the laws of that jurisdiction.
To the extent allowed by applicable law, Topgolf reserves the right to change our Privacy Notice at any time without prior notice. Topgolf will notify of material changes by posting the changed or modified Privacy Notice by revising the "Last Updated" date at the top of this Privacy Notice. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Notice unless otherwise specified. Your continued use of the Topgolf Offerings after the effective date of the revised Privacy Notice will constitute your consent to those changes to the fullest extent allowed by applicable law. However, Topgolf will provide notice and obtain your consent (opt-in or opt-out) if required by applicable law. Note that you may need to consent to the revised Privacy Notice in order to continue to use the Topgolf Offerings.
This California Privacy Notice supplements the information contained in Topgolf's Privacy Notice and applies only to California residents. This California Privacy 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. Any terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA, CPRA, and the associated regulations, unless otherwise defined.
If you are a California Consumer, you 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"); (2) that we delete the Personal Information we collect about you ("Right to Delete"); (3) that we correct inaccurate Personal Information we hold about you ("Right to Correct"), (4) to opt-out from the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) ("Right to Opt-Out of Sharing"), and (5) to opt-out from the sale of their Personal Information ("Right to Opt-Out of Sale"), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.
In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We cannot respond to your request if we cannot verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.
When you exercise your Right to Know, Right to Delete, or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
If you are an authorized representative submitting a request on a user's behalf, please complete the applicable request per the instructions below. You may also make a request on behalf of your minor child. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate the nature of your request. The consumer's identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer's behalf, we may deny the request.
California Consumers have the right to know what information we have collected about them (the categories and the specific pieces of information).
If you are a California Consumer and would like to exercise your Right to Know, please submit your request at
privacyportal.onetrust.com
In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
California Consumers have the right to request that we delete Personal Information we have collected from them.
If you are a California Consumer and would like to exercise your Right to Delete, please submit your request at
privacyportal.onetrust.com
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.
California Consumers have the right to request that we correct inaccurate information we hold about them.
If you are a California Consumer and would like to exercise your Right to Correct, please submit your request at
privacyportal.onetrust.com
California Consumers have the right to opt-out of the sharing of their Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. Topgolf additionally shares your Personal Information with the Topgolf Callaway Brands Family of Companies which may be considered "sharing" under the CCPA and CPRA. If you are a California Consumer and would like exercise your Right to Opt-Out of Sharing, please submit your request by clicking on the link titled "Do Not Sell/Share my Personal Information" on our Websites.
California Consumers have the right to opt-out of the sale of their Personal Information. Topgolf shares your Personal Information with the Topgolf Callaway Brands Family of Companies which may be considered "sales" under the CCPA and CPRA. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale, please submit your request by clicking on the link titled "Do Not Sell/Share my Personal Information" on our Websites.
Topgolf engages in online advertising practices (and certain analytics or similar activities), which may be considered a "sale" or "share" for cross-context behavioral advertising under the CCPA and CPRA. To disable sharing through Cookies set by third parties that may be considered "sales" or "sharing" under the CCPA and CPRA, please click on the link titled "Manage Cookie Preferences" on our Websites. In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of Personal Information by some or all of the participating companies.
Under the CPRA Regulations, a business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when such use is not collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Topgolf's use and disclosure of Sensitive Personal Information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.
We will retain all categories of Personal Information described in this California Privacy Notice as set forth in Section 9 of the Privacy Notice.
Topgolf does not knowingly Sell or Share Personal Information of users younger than 16 years of age.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
California consumers have the right not to receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising any of your CCPA and CPRA rights.
Under California regulation, certain programs we offer that provide benefits to consumers may be considered financial incentive programs. We may collect Personal Information from you in connection with these programs, for example contact information (name, email address, residential address) and certain commercial information for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program.
To opt into the programs, you may need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with that applicable program. Please also see the terms of the program you are joining for additional description of the program and any additional requirements. Participation in our programs is voluntarily, and you can withdraw at any time.
To the extent that we provide a program that may be considered a financial incentive because the program is directly or reasonably related the collection, deletion or sale or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.
The Personal Information we collect about you will depend upon how you use the Topgolf Offerings or otherwise 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.
[scrollable table]
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 | Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared |
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**Identifiers** *This category includes information such as name, contact information, and online or device identifiers.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Cookies and tracking technologies - Social Sites - Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners | We may use this type of information: - To allow you to participate in the Topgolf Offerings, and features we offer - To respond to your requests (e.g., support, feedback) - To develop and improve our products, services, and marketing programs - To communicate with you and tailor content, ads, and offers - In connection with your purchases and for customer service - To operate and protect our Topgolf Offerings - To display your first and last name and/or username on leaderboards at Topgolf Offerings and Social Sites - To process payments - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Third parties who deliver our communications - Internet service providers - Social Sites - Payment processors and financial institutions - Third parties we partner with for contests, sweepstakes, or promotions - Third party advertising and analytics companies - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, - Third parties or affiliated companies when you agree to or request that we share your information with them - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) | - The Topgolf Callaway Brands Family of Companies. - Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. |
**Any categories of personal information described in subdivision (e) of Section 1798.140** *This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as "personal" under this California law.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Cookies and tracking technologies - Social Sites - Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners | We may use this type of information: - To allow you to participate in the Topgolf Offerings and features we offer - To respond to your requests (e.g., support, feedback) - To develop and improve our products, services, and marketing programs - To communicate with you and tailor content, ads, offers - In connection with your purchases and for customer service - To operate and protect our Topgolf Offerings - To display your first and last name and/or username on leaderboards at our Topgolf Offerings and Social Sites - To process payments - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice. | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Internet service providers - Social Sites - Payment processors and financial institutions - Third parties we partner with for contests, sweepstakes, or promotions - Third party advertising and analytics companies - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition - Third parties or affiliated companies when you agree to or request that we share your information with them - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) | - The Topgolf Callaway Brands Family of Companies. - Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. |
**Characteristics of protected classifications under California or federal law** *This category includes information such as age, sex (including gender), national origin, citizenship, and marital status.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Applicants for employment | We may use this type of information for job applicants: - For prospective employees, background screening to assess applications for employment - For consumers, we may use this type of information to perform market research that allows Topgolf to better understand its - demographic market - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice. | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition - Third parties or affiliated companies when you agree to or request that we share your information with them - Other third parties (including government or regulatory agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) | The Topgolf Callaway Brands Family of Companies. |
**Commercial information** *This category includes, for example, payment information you provide for goods, services, customer service records, and information about the products you have purchased.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Third party business partners, such as data analytics providers or joint marketing partners | We may use this type of information: - To allow you to participate in the Topgolf Offerings and features we offer - In connection with your purchases and for customer service - To operate and protect our Topgolf Offerings - To process payments - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Social Sites - Service Providers - Third parties we partner with for contests, sweepstakes, or promotions, - Third party advertising and analytics companies, - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, - Third parties or affiliated companies when you agree to or direct us to share your information with them - Payment processors and financial institutions - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). | - The Topgolf Callaway Brands Family of Companies - Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. |
**Biometric information** | We may collect this type of information from: - N/A | We may use this type of information: - N/A | We may disclose this type of information to: - N/A | N/A |
**Internet or other electronic network activity information** *This category includes information about the web browser and operating system you are using, the website or ad that referred you to our Sites, areas of the Sites that you visited, and terms entered into a search engine that led you to the Sites.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Cookies and tracking technologies - Social Sites - Third party business partners, such as data analytics providers or advertising networks | We may use this type of information: - To allow you to participate in the online Topgolf Offerings and features we offer - To develop and improve our products, services, and marketing programs - To operate and protect our online Topgolf Offerings - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Internet service providers - Social Sites - Service Providers - Third party advertising and analytics companies - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, - Third parties or affiliated companies when you agree to or direct us to share your information with them, - Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders). | - The Topgolf Callaway Brands Family of Companies - Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. |
**Audio, electronic, visual, thermal, olfactory, or similar information** *This category includes, for example, images, video, or audio recordings.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Social Sites | We may use this type of information: - To allow you to participate in the Topgolf Offerings and features we offer - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice. | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Social Sites - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition - Third parties or affiliated companies when you agree to or direct us to share your information with them - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) | The Topgolf Callaway Brands Family of Companies. |
**Professional or employment-related information** *This category includes job applications and current and/or past employers.* | We may collect this type of information from: - Applicants for employment | We may use this type of information: - To assess applications for employment - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, - Third parties or affiliated companies when you agree to or direct us to share your information with them, - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). | The Topgolf Callaway Brands Family of Companies |
**Education Information** *This category includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)* | We may collect this type of information from: - Applicants for employment | We may use this type of information: - To assess applications for employment - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice. | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, - Third parties or affiliated companies when you agree to or direct us to share your information with them, - Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). | The Topgolf Callaway Brands Family of Companies |
**Inferences drawn from any of the information identified above to create a profile about a consumer** *These inferences may relate to your perceived interests, preferences, characteristics, or behavior.* | We may collect this type of information from: - Consumers - The Topgolf Callaway Brands Family of Companies - Cookies and tracking technologies - Social Sites - Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners | We may use this type of information: - To allow you to participate in the online Topgolf Offerings and features we offer, - To develop and improve our products, services, and marketing programs - To communicate with you and tailor content, ads, and offers - To operate and protect our online Topgolf Offerings - For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice | We may disclose this type of information to: - The Topgolf Callaway Brands Family of Companies - Service Providers - Third parties we partner with for contests, sweepstakes, or promotions - Social Sites - Third party advertising and analytics companies - Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition | - The Topgolf Callaway Brands Family of Companies - Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. |
You can contact us for more information by writing to us at Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231.
California Civil Code Section 1798.83 permits residents of California to request certain details about how their Personal Information has been shared during the calendar year with third parties for those third parties' own direct marketing purposes, unless the business permits California residents to opt in to, or opt out of, this type of sharing. Topgolf qualifies for this alternative option. As noted above, we will not share Personal Information about you with third parties for their own direct marketing purposes without first offering you choice (opt-in or opt-out).
If you are a California resident and have questions about our practices with respect to sharing Personal Information with third parties for their direct marketing purposes and your ability to exercise choice, please submit your request by calling toll-free at (833) 554-0955 or writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. You must put the statement "Your California Privacy Rights" at the top of your letter. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or for those notices which do not have complete information.
Nevada S.B. 220 provides consumers with the ability to opt out of the sale of their Personal Information. We do not sell your Personal Information as defined in S.B. 220. However, you may still submit an opt-out request, and if our practices were to change in the future, we would honor your request. If you are a Nevada resident and would like to opt out of the sale of your covered information, your request must be submitted by calling toll-free at (833) 554-0955 or writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. Your request must include your full name, street address, city, state, zip code, and a valid email address so that we can contact you if needed regarding your request. If you previously provided a phone number, including it will assist us in making sure we identify you as someone who wants to opt out. You may be required to take reasonable steps as we determine from time to time to verify your identity and/or the authenticity of your request.
We set forth above in our Privacy Notice the categories of Personal Data we process, the purpose for processing Personal Data, the categories of Personal Data shared, and the categories of third parties with whom Personal Data is shared. Any terms (including defined capitalized terms) used in this Virginia Privacy Notice have the same meanings given in the Virginia Consumer Data Protection Act ("VCDPA") and any implementing regulations adopted thereunder, unless otherwise defined.
If you are a Virginia Consumer and would like to exercise your rights pursuant to the VCDPA and any implementing regulations adopted thereunder, please complete this form to submit a request.
Virginia Consumers have the following rights, all subject to the exceptions and further terms set forth in the VCDPA:
To opt out of:
the processing of your Personal Data for the purposes of targeted advertising ("Right to Opt-Out of Targeted Advertising").
*Topgolf engages in online advertising practices (and certain analytics or similar activities) that may be considered "targeted advertising" under the VCDPA. To disable sharing through Cookies set by third parties that may be considered targeted advertising under the VCDPA, please click on the link titled "Manage Cookie Preferences" on our Websites.
the processing of your Personal Data for the purposes of a sale ("Right to Opt-Out of Sale").
*Topgolf does not sell Personal Data to third parties for monetary compensation.
the processing of your Personal Data for the purposes of profiling ("Right to Opt-Out of Profiling"). To disable sharing through Cookies set by third parties that may be considered profiling under the VCDPA, please click on the link titled "Manage Cookie Preferences" on our Websites.
Pursuant to the VCDPA, if, for any reason, you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by completing this form. Please include your full name, the basis for your appeal, and any additional information to consider.
If you are a resident of Australia, the following information applies.
Identity and Contact Information – The Topgolf Offerings are owned and operated by Topgolf International Inc. and our address is N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. If you have any questions, concerns, or comments about the Topgolf Offerings, please reach out by calling +1 (833) 554-0955 or writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231.
Likely Overseas Disclosure – Personal Information we collect may be disclosed to overseas recipients that are located in the United States or any other country in which we or our subcontractors maintain facilities. We rely on your consent to facilitate this disclosure in the United States and other jurisdictions, where laws regarding processing of personal information may be less stringent than the Australian Privacy Principles. In certain cases, we may rely on appropriate safeguards such as standard contractual clauses as a basis for the overseas disclosure.
Your Rights to Access and Correct Your Personal Information - You have the right to access and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access and corrections of inaccuracies in your personal information we have in our custody or control by writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Third Party Advertising - As discussed above, we work with certain third-party advertising companies in connection with our online advertising and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. Please refer to EDAA's choice page at youronlinechoices.com to learn more about your choices related to advertising with respect to participating EDAA member companies.
Complaints and Resolving Concerns - If you have any questions or comments about this Privacy Notice or if you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information, you may contact us by writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231.
You may also obtain further information about your privacy rights from the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au. OAIC has authority to investigate complaints and claims for compensation in appropriate cases.
If you are a resident of the European Union ("EU"), other European Economic Area ("EEA") countries, or of the United Kingdom ("UK"), the following information applies.
Purposes of processing and legal basis for processing: We process Personal Data for the purposes and on the following legal bases listed below:
[scrollable table]
Context | Types of Data | Primary Purpose for Collection and Use of Data |
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Account Registration | We collect your name, gender, age, and contact information when you create an account at our Topgolf Offerings. We also collect information relating to the actions that you perform while logged into your account. | We have a legitimate interest in providing account-related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. |
Cookies and First Party Tracking | We use cookies and clear GIFs. "Cookies" are small pieces of information that a website sends to a computer's hard drive while a web site is viewed. | We have a legitimate interest in making our online Topgolf Offerings operate efficiently. |
Cookies and Third-Party Tracking | We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our online Topgolf Offerings so that they can provide advertising about products and services tailored to your interests on our online Topgolf Offerings, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics. |
Demographic Information | We collect personal information, such as your age, gender, or location. | We have a legitimate interest in understanding our users and providing tailored services. |
Geolocation Information | We may collect geolocation data based on your use of the Topgolf Offerings. | We have a legitimate interest in understanding the location of our users. |
Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. | We have a legitimate interest in understanding how you interact with our communications to you. |
Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. | We use information about current employees to perform our responsibilities as an employer. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations. |
Feedback/Support | If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. | We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
Game Activity | When you participate in gameplay at one of our Locations or through the online Topgolf Offerings, we will collect information necessary to track your performance against other participants. | We have a legitimate interest in keeping track of your performance in games to effectively deliver our services to you. |
Golf Lessons and Leagues | We collect your information when you sign up for golf lessons or leagues at one of our Locations. | We have a legitimate interest in communicating with you regarding your golf lessons or league participation. |
Incident Reporting | If there is a circumstance in which an incident takes place at one of our Locations, we may collect information from you to ensure the incident is properly recorded and remedied. | We have a legitimate interest in resolving any incidents that take place at our various Locations. |
Mailing List | When you sign up for one of our mailing lists, we collect your email address or postal address. | We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. |
Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Sites or when visiting one of our Locations. | We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. |
Order Placement | We may collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order. | We use your information to perform our obligations to provide you with products or services. |
Partner Promotion | We may collect information that you provide as part of a co-branded promotion with another company. | We have a legitimate interest in fulfilling our promotions. |
Reservations | We collect your information that you provide in order to make a reservation at one of our Locations. | We have a legitimate interest in facilitating your ability to make advance reservations to one of our Locations. |
Surveys | When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party's privacy policy applies to the collection, use, and disclosure of your information. | We have a legitimate interest in understanding your opinions and collecting information relevant to our organization. |
Sweepstakes or Contests | When you participate in a sweepstakes or contest, we collect information about you which includes contact information to notify you if you are selected. | We have a legitimate interest in operating the sweepstakes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. |
Ticketing Information | When you purchase tickets to one of our events, such as a special event at one of our Locations, admission to one of our camps/academies, or a musical performance, we collect information about you to process the transaction, which includes your contact information and credit card information. | We have a legitimate interest in fulfilling your ticket purchase order. |
Online Topgolf Offering Interactions | We use technology to monitor how you interact with our online Topgolf Offerings. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our online Topgolf Offerings to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
Web Logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring our networks and the visitors to our online Topgolf Offerings. Among other things, it helps us understand which of our services is the most popular. |
Although the table above describes our primary purposes in collecting your Personal Information, in many situations we have more than one purpose. For example, if you complete an online purchase, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your purchase. As a result, our collection and processing of your Personal Information is based in different contexts upon your consent, our need to perform a contract, our obligations, and rights under law, and/or our legitimate interest in conducting our business.
For these processing activities, we require our Service Providers to provide technical and organizational security measures and to only use your Personal Information on our behalf if they are a processor or a sub-processor. For more information on our use of Service Providers, including a current list of authorized sub-processors, please contact us at the contact details set out below (see Section 19, Contact Us).
In some cases, third parties may be a controller in their own right (for example, if you choose to participate in third party promotions, contests/sweepstakes, surveys, or click through to a third-party website from the online Topgolf Offerings). Third-party controllers are responsible for the processing of your Personal Information, and you should carefully review their privacy notice and policies before providing your Personal Information.
Whenever dealing with one of the Topgolf Callaway Brands Family of Companies, the controller of your Personal Information will be the company that decides how and why your Personal Information is used. For more information on the controllers, see Section 19 below.
For the purposes of data protection laws, Topgolf and the Topgolf Callaway Brands Family of Companies are "joint controllers" for the processing of your Personal Information described in this Privacy Notice. This means that Topgolf and the Topgolf Callaway Brands Family of Companies work together to decide why and how your Personal Information is processed.
Depending on the reason for the sharing of your Personal Information, other companies within the Topgolf Callaway Brands Family of Companies may be a joint controller with the Topgolf Callaway Brands Family of Companies, a controller in their own right, or a processor. For more information on how Topgolf Callaway Brands Family of Companies processes your Personal Information please contact us at the contact details set out below (see Section 19, Contact Us).
Regarding data processing within the framework of Topgolf's and the Topgolf Callaway Brands Family of Companies' internal administration and joint procedures through centralized systems, Topgolf and the Topgolf Callaway Brands Family of Companies are jointly responsible as joint controllers and controllers in their own right. The joint processes particularly pertain to the operation and use of jointly used databases, platforms, and IT systems. With respect to the joint processes, Topgolf and the Topgolf Callaway Brands Family of Companies jointly determine the purposes and means of processing.
Topgolf and the Topgolf Callaway Brands Family of Companies use a shared IT services and infrastructure and has legitimate (joint) interests as per Recital 48 of GDPR in group-wide data organization and administration including the exchange of Personal Information for internal administrative purposes such as to ensure compliance and a consistent approach to compliance within the Topgolf Group.
In an agreement on joint controllership under Article 26 GDPR, Topgolf and the Topgolf Callaway Brands Family of Companies have determined how the respective tasks and responsibilities in the processing of Personal Information are structured and who fulfills which data protection obligations. In particular, it was determined how an appropriate level of security and your rights as a data subject can be ensured, how the information duties under data protection law can be fulfilled jointly, and how potential data protection incidents can be monitored. This also includes ensuring that reporting and notification obligations are fulfilled.
We do not perform all processing of your Personal Information as joint controllers. Topgolf makes decisions about certain processing of your Personal Information independently of other companies within the Topgolf Callaway Brands Family of Companies, for which Topgolf is solely responsible. Similarly, the Topgolf Callaway Brands Family of Companies make decisions for certain processing of your Personal Information independently of Topgolf, for which such companies are solely responsible and controllers in their own right when processing your Personal Information independently.
Topgolf is your central contact point. You can also assert your rights regarding the processing of Personal Information in joint controllership by other companies within the Topgolf Callaway Brands Family of Companies. Should you contact us, Topgolf will coordinate the response in accordance with the aforementioned agreement pursuant to Article 26 GDPR in order to respond to your inquiry and to guarantee your rights as a data subject.
Shared Services. Topgolf and the Topgolf Callaway Brands Family of Companies are part of a single group of companies who have a legitimate interest in sharing Personal Information under Recital 48 of GDPR. As such your Personal Information is transferred to the United States where certain of our IT systems are located.
Global Topgolf Venue Membership. As we offer the ability to play and benefit from services at the Topgolf Offerings globally, we will transfer your Personal Information within the Topgolf Callaway Brands Family of Companies for the purposes of fulfilling your contract with us, providing the benefits of global membership, and/or facilitating gameplay at the Topgolf Offerings.
Business Operations. Personal Information we collect from you may be transferred to, stored by, or accessed by other companies within the Topgolf Callaway Brands Family of Companies and our and their Service Providers. We transfer Personal Information for the purposes of fulfilling your contract with us, in our legitimate interests, and, if needed, with your consent.
Topgolf and the Topgolf Callaway Brands Family of Companies and our and their Service Providers may be located outside of the UK/EEA/EU and may not benefit from an adequacy decision issued by the relevant data protection authorities regarding protection afforded to Personal Information in that country. Details of the specific countries that do benefit from an adequacy decision may be found here:
We will only transfer your Personal Information outside of the UK/EEA/EU based on an adequacy decision or an appropriate safeguard such as standard contractual clauses or if a derogation or other lawful basis exists. Where required we have put in place additional safeguards. For more information on the basis on which we transfer Personal Information outside of the UK/EEA/EU, you may contact us at the contact details set out below (see Section 19, Contact Us).
Under the UK and EU General Data Protection Regulation ("GDPR") and Data Protection Act, you have the following rights.
Access. You may have the right to access, review, obtain a copy or port certain Personal Information, for example to verify its existence, content, origin, or accuracy. Please note that we are not always able to provide the Personal Information or take the action that you have requested. We may refuse to provide Personal Information based on a number of lawful exemptions.
Update. Moved? Changed your name, email, address, or phone number? It is important that the Personal Information we hold about you is accurate and up to date. With certain Topgolf Offerings, you may also be able to directly update your Personal Information on the bay player or account management screens.
Deletion. You may have the right to request deletion of certain Personal Information. We may refuse to delete Personal Information if we have a need to keep Personal Information to meet our statutory obligations, dispute resolution, troubleshooting, and other valid legal or business reasons. We may in our discretion anonymize your Personal Information in which case it is no longer Personal Information.
Revocation of Consent. You may have the right to block or withdraw consent to the processing of certain Personal Information (without affecting the lawfulness of processing based on consent before its withdrawal). If you revoke your consent for the processing of Personal Information, we may no longer be able to provide you our products or services. We may retain Personal Information in respect of which you are revoked consent to meet our statutory obligations, dispute resolution, troubleshooting, and other valid legal or business reasons. We may in our discretion anonymize your Personal Information in which case it is no longer Personal Information.
Portability. You have the right, in certain circumstances, to request that we provide your Personal Data to you in a format that can be transferred to another entity.
Restrict Processing. You have the right, in certain circumstances, to request that we limit our processing of your Personal Data if you are contesting the accuracy of your Personal Information; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.
Object. You may object to our processing if we are processing your Personal Information based on legitimate interests, use your Personal Information for direct marketing, or process your Personal Information for purposes of scientific or historical research and statistics. You can opt-out at any time from receiving direct marketing from us. You can do so by clicking the unsubscribe link at the bottom of any email you receive from us, by submitting a request as set out below or by writing to Topgolf (or the relevant company within the Topgolf Callaway Brands Family of Companies) at the address given below. If you do opt-out of receiving promotional and marketing messages, we can still contact you regarding your membership, such as your status and activity updates, survey requests in respect of products and services we have provided to you after you have visited our Locations (if permitted under applicable law), booking confirmations or respond to your inquiries or complaints, and similar communications.
Cookies. You can review your Internet browser settings, typically under the sections "Help" or "Internet Options,"* and use our cookie management page to exercise choices you have for certain cookies, including for interest-based advertising. If you disable or delete certain non-essential cookies, you might not be able to access or use important functions or features of this Site or services, and you may have to re-enter your log-in details. Please note you may also still receive advertisements from the relevant ad serving company you opted out of, but the ads will not be tailored to your interests. For our Applications (if available), please review your device settings or third-party tools available.
Please note, if you elect to exercise one of your choices listed above, you will not receive discriminatory treatment by us for exercising your privacy rights that are conferred upon you by law.
If you need to exercise any of your rights, please contact us at the contact details set out below (see Section 19, Contact Us). To process your request, we may need to ask you for additional information or Personal Information to correctly find you in our systems.
If you are an authorized agent acting on behalf of an individual, you must attach a completed authorized agent designation form or power of attorney indicating that you have the authority to act on behalf of the individual in respect of whom the rights are being exercised and if you are business, proof of your business registration evidencing that you are authorized to conduct business in the relevant country.
We will respond to your request in the time periods permitted by applicable law. We may charge a reasonable fee if we receive multiple requests for the same Personal Information or if your request is manifestly unfounded.
For residents of the UK and the EEA, we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
As discussed above, we work with certain third-party advertising companies in connection with our online advertising and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. The EDAA has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with participating EDAA member companies available for UK and EU residents at youronlinechoices.com.
Our Websites and Applications are directed to persons in the EEA who are at least sixteen (16) years of age, and we do not knowingly collect any Personal Information from children in the EEA younger than the age of sixteen (16) years.
If a parent or guardian in the EEA is made aware that a child under the age of sixteen (16) years has provided us with Personal Information through any point of contact, please call us at +1 (833) 554-0955 or write to us at the contact details below, and we will delete the Personal Information. If we have actual knowledge that Personal Information about a person in the EEA younger than the age of sixteen (16) years has been collected without parental/guardian consent, then we will take the appropriate steps to delete such Personal Information.
EU and UK residents have the right to lodge a complaint about our data collection and processing actions with the Information Commissioner's Office ("ICO") in UK and the relevant national supervisory authority where you reside in the EU, if you believe we have not resolved your concerns. Contact details for UK's ICO are available at ico.org.uk/global/contact-us. Contact details for national supervisory authorities in the EU are available at edpb.europa.eu/about-edpb/board/members_en.
Certain specific privacy rights apply to you if you are a South Korean resident. These are set out in the following sections.
If you are a South Korean resident, you may request information from us about how we may share certain categories of your personal information with third parties. We may provide third parties with Personal Information as set forth below:
Third-Party Recipients / Location | Contact Information for Personal Information Related Inquiries | Personal Information Collected, Purposes, and Retention | Method of Transfer |
---|---|---|---|
Authorize.net / United States |
CyberSource Corporation P.O. Box 8999 San Francisco, CA 94128 ATTN: Data Use and Privacy Office Fax: (650) 286-6547 OR
CyberSource Limited | Authorize.net is a payment processor Service Provider. Your registration information will be processed for the period necessary to fulfill the purposes outlined in this Privacy Notice and in accordance with applicable law. | Data transfer agreement. |
Amazon.com, Inc. / United States |
Customer Service PO Box 81226 Seattle, WA 98108-1226, United States | Amazon.com, Inc. is a cloud Service Provider. Your general personal information will be processed by Amazon.com, Inc. for storage purposes for the period necessary to fulfill the purposes outlined in this Privacy Notice and in accordance with applicable law. | Data transfer agreement. |
Our computer systems are currently based in the United States, so at the time the Personal Information detailed above is collected and processed for the above mentioned purposes; it is maintained by us in the United States. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including the Act on Promotion of Information and Communications Network Utilization and Information Protection of the Republic of Korea. We retain your personal information based on the time period detailed below.
If you have any questions regarding this Privacy Notice, you may raise your questions with us as detailed below.
If you have any questions regarding this Privacy Notice or you wish to exercise any of your data subject rights, you can contact us at the following mailing address:
Topgolf International, Inc.
Attn: Privacy Team
8750 N. Central Expressway, Suite 1200
Dallas, TX 75231
Country | Company | Address |
---|---|---|
Sweden | Topgolf Sweden AB (EU/EEA Representative) |
Svärdvägen, 11 4tr, SE-182 33 Danderyd, Sweden |
Japan | Topgolf Japan GK |
c/o Baker & McKenzie, Ark Hills Sengokuyama Mori Twr. 28F, 1-9-10 Roppongi, Minato-ku, Tokyo |
United Kingdom | Topgolf Limited (UK Representative) |
Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA |
United Kingdom | Topgolf Group Limited |
Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA |
United Kingdom | World Golf System Group Limited |
Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA |
United States of America | Topgolf International inc. |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |
United States of America | Topgolf USA LLC |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |
United States of America | Topgolf Pro LLC |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |
United States of America | Topgolf Payroll Services LLC |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |
United States of America | Topgolf Media Services LLC |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |
United States of America | World Golf Tour LLC |
N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 |