Privacy Policy

1Introduction

Golf SimPass is operated by Soarware Labs Inc. In this Privacy Policy, “Golf SimPass,” “we,” “us,” and “our” refer to Soarware Labs Inc. in its operation of Golf SimPass; “you” and “your” refer to an individual who visits, creates an account with, connects to, books through, or otherwise uses Golf SimPass; “Facility” means a participating golf simulator facility, golf business, academy, club, course, recreation facility, or other participating location; and “Services” means the Golf SimPass website, applications, player accounts, profiles, booking functions, session connections, facility-network functions, rewards, gameplay-sharing features, communications, and related products or services.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use Golf SimPass. It also explains how Golf SimPass and participating Facilities have separate responsibilities; how information may move between Golf SimPass, Facilities, booking platforms, and simulator technologies; how you can manage permissions and preferences; how to request access, correction, export, or deletion; and how to contact our Privacy Officer.

2Who Is Responsible for Golf SimPass Information?

Soarware Labs Inc. is responsible for personal information under its control in connection with Golf SimPass. Golf SimPass is not a separate legal entity. Our contact information is:

Soarware Labs Inc.
Golf SimPass
561 Bayfield Street, Suite 1003
Barrie, Ontario, Canada L4M 4Z9
Privacy Officer: Craig Weissenfels
Email: info@golfsimpass.com
Telephone: 1.647.409.1648

Participating Facilities are separate businesses and may independently collect and control information relating to local bookings; Facility memberships; payments and refunds; waivers; access records; local promotions; premises and safety matters; Facility customer-service records; and other local Facility operations. A Facility’s privacy policy may apply to those activities.

3Personal Information We Collect

The information we collect depends on how you use Golf SimPass, the features you activate, the Facilities you connect, and the technology available at a Facility.

Account and identity information

• first and last name;
• display name or username;
• email address;
• telephone number;
• password or authentication information;
• date of birth or age range;
• preferred language;
• country, province, state, or region;
• profile photograph or avatar;
• account identifiers;
• parent or guardian information where applicable;
• consent and permission records; and
• account status and preferences.

We collect a full date of birth only where reasonably necessary. Where age eligibility can be established through an age range or year of birth, we use the less detailed option.

Golf profile information

Information you provide or authorize for your player profile, including preferred hand; golfer experience level; interests and playing preferences; preferred Facilities; equipment information; golf goals; profile biography; visibility settings; connected players, instructors, leagues, or teams; and other profile fields made available through Golf SimPass.

Booking and Facility information

When you book through Golf SimPass or connect a Facility account, booking, membership, or session, we may receive Facility name and location; booking date and time; bay or simulator assignment; booking duration; booking status; reservation or confirmation number; participant or guest information; membership or customer identifier; check-in information; cancellation or no-show status; league or event registration; Facility connection status; and other information required to connect or administer the booking or session.

Simulator and gameplay information

Where supported by the Facility and applicable simulator systems, we may collect session start and end time; time played; range or course selection; virtual course name; holes played; shots taken; score; par; longest drive; ball speed; club speed; launch angle; carry and total distance; spin data; shot shape or dispersion; putting information; personal bests; course results; league or event results; simulator configuration; player assignment; session milestones; and other data produced by connected simulator hardware or software. Not every Facility or simulator system supplies the same information.

Engagement and progression information

We may create or maintain levels; experience points or points; milestones; badges; achievements; streaks; challenges; rewards; sessions completed; Facilities visited; courses played; hours played; shots recorded; progress toward a goal; and reward eligibility or redemption history.

Transaction information

Where Golf SimPass supports purchases, bookings, subscriptions, or paid features, we may collect transaction amount; currency; tax information; product or service purchased; payment status; refund status; billing contact information; subscription status; renewal date; transaction identifier; and limited payment-method information supplied by the payment provider.

Communications and support information

Emails and support requests; chat or contact-form submissions; feedback; survey responses; reported issues; account-recovery communications; communications with participating Facilities where routed through Golf SimPass; security reports; complaint records; and records of actions taken in response.

Device, website, and technical information

When you access Golf SimPass we may automatically collect IP address; device type; browser type; operating system; application version; device or application identifiers; language and time-zone settings; referring and exit pages; pages or screens viewed; button and feature interactions; session duration; approximate location inferred from IP address; cookie and similar-technology identifiers; authentication events; error logs; performance information; network and connection information; and security and fraud-prevention signals.

Location information

We may use approximate location information to display nearby Facilities, provide regional content, apply appropriate legal or language settings, detect suspicious account activity, or support a feature you request. We will seek separate permission before collecting precise device location where required. You may manage device-location permissions through your device settings.

Gameplay-sharing and remote-viewing information

Where Golf SimPass provides optional gameplay-sharing features, we may process the simulator game screen; virtual course action; scorecards; ball-flight information; shot results; player display name; statistics; session time and Facility; viewer invitations; private viewing links; stream access records; stream status; viewer interactions; reports of misuse; and technical information needed to deliver the stream. Gameplay sharing is off by default unless a specific event or feature is clearly disclosed and supported by another lawful basis.

Bay camera and audio information

A view of the physical simulator bay is different from game-screen viewing. Golf SimPass does not collect or broadcast bay camera or audio information merely because you have a Golf SimPass account. Where camera or audio functionality is introduced, we may require a separate player opt-in; a clear in-product notice; Facility authorization; notice to guests or bystanders; appropriate consent or other lawful authority; restrictions for minors; visible in-Facility notice; separate recording controls; and defined retention periods.

Information about guests

A player may include other people in a booking or session. We may receive limited guest information such as name or display name; email address; booking participation; session assignment; score; gameplay statistics; or invitation status. A guest does not automatically receive a permanent Golf SimPass account — a guest must independently create an account and accept the Golf SimPass Terms of Use and Privacy Policy before a permanent player relationship is created.

Information about minors

Golf SimPass is not intended for children under 18 to create or independently operate accounts. For users who have not reached the age of majority, we may require parent or guardian involvement depending on the user’s age, the feature, the sensitivity of the information, applicable law, and the reasonable expectations of the user.

We may collect limited information to verify age, parental authority, or consent. We do not knowingly use a minor’s information for behavioural advertising. Certain functions may be disabled for minors, including public profiles, player directories, public gameplay streams, camera or audio sharing, direct messaging, location sharing, targeted marketing, and other features presenting heightened privacy risk. See also Children’s Privacy.

4How We Collect Information

Directly from you

When you create an account, complete your profile, make a booking, connect a Facility, connect a simulator session, join a league or event, activate gameplay sharing, contact support, enter a promotion, subscribe to communications, or adjust your settings.

From participating Facilities

A Facility may provide information when you connect your Golf SimPass account, authorize a booking or membership connection, check in, participate in a simulator session, play in a league or event, request assistance, or otherwise use a Golf SimPass-supported Facility feature.

Facilities may invite you to join Golf SimPass, but they may not silently create your account, accept Golf SimPass terms for you, preselect optional participation, or transfer identified historical information without appropriate authority.

From booking, membership and simulator systems

We may receive booking, membership, customer, session, or league information through authorized integrations, and gameplay and session information from systems such as simulator software, launch monitors, range software, course software, or approved Facility integrations.

From service providers

We may receive information from providers supporting authentication; hosting; communications; analytics; payments; security; fraud prevention; customer support; or other authorized Golf SimPass functions.

Automatically

We may collect technical and usage information through cookies, logs, pixels, software development kits, local storage, and similar technologies.

5Why We Use Personal Information

Creating and managing your account

To register and authenticate you, maintain your profile, verify contact information, provide account recovery, apply account settings, determine feature eligibility, and provide requested account functions.

Connecting bookings, Facilities, and sessions

To identify your booking, connect your Facility account, assign or identify your session, load applicable player information, associate gameplay results with your profile, maintain your play history, and support connected Facility experiences.

Providing your golf profile and history

To display sessions, courses, holes, shots, hours played, Facilities visited, personal bests, achievements, milestones, streaks, levels, and other profile information.

Operating bookings and transactions

To facilitate reservations, provide confirmations, process or support payments, administer subscriptions, communicate booking changes, support cancellations and refunds, prevent transaction fraud, and maintain legally required records.

Providing gameplay-sharing features

Where authorized, to generate and deliver a private gameplay stream, display game-screen action, provide viewer access, manage invitations and permissions, prevent unauthorized access, address misuse, and support leagues, events, or approved broadcasts.

Operating levels, rewards, and milestones

To calculate progress, award points or experience, recognize milestones, administer rewards, detect manipulation, correct errors, and display status in accordance with your settings.

Communicating with you

To send verification messages, security notifications, booking information, account notices, service updates, support replies, policy updates, Facility connection notices, gameplay-sharing alerts, and other operational communications.

Marketing

With consent or another legally permitted basis, we may send information about Golf SimPass features, participating Facilities, memberships, leagues, tournaments, events, promotions, partner offers, and related golf products or services. Golf SimPass marketing permission is separate from a Facility’s marketing permission unless the distinction is clearly explained. You can unsubscribe from marketing without closing your account.

Personalizing Golf SimPass

We may use account, session, and usage information to customize your dashboard, display relevant milestones, recommend features, show nearby or connected Facilities, suggest courses, leagues, or challenges, identify incomplete profile functions, and improve usability. We will seek additional consent where personalization involves a new or unexpected use of sensitive information.

Improving and developing Golf SimPass

To understand feature usage, identify errors, measure performance, improve interfaces, develop new features, test functionality, improve Facility integrations, improve session matching, evaluate service reliability, and produce aggregated or de-identified insights. Where reasonably possible, development and analytics work uses aggregated, de-identified, or minimized information.

Security, fraud prevention, and legal purposes

To authenticate users, protect accounts, detect suspicious activity, prevent unauthorized access, investigate abuse, enforce the Terms of Use, maintain audit logs, protect Facilities and players, respond to incidents, comply with applicable laws, respond to lawful requests, protect legal rights, investigate claims, preserve evidence, enforce agreements, address safety or security incidents, and respond to regulators, courts, or law-enforcement authorities where legally required or permitted.

6Consent and Your Choices

We seek consent appropriate to the circumstances and sensitivity of the information. Consent may be express; implied where legally appropriate; collected through a checkbox or button; obtained through an account setting; obtained through a feature-specific prompt; or supported by another lawful basis where applicable.

Required account processing

Certain information is necessary to create and secure an account, provide requested services, maintain session history, deliver bookings, comply with law, or protect Golf SimPass. You may not be able to use Golf SimPass without this processing.

Optional Facility connections

Connecting Golf SimPass with a Facility account, booking history, membership, or simulator session is optional. The connection interface explains what information will be exchanged; why it is exchanged; whether the connection applies once or continuously; what the Facility can see; and how to disconnect.

Optional marketing

Marketing consent is separate from account acceptance and is not preselected where express consent is required.

Optional public, social and gameplay-sharing features

Public profiles, directories, friend connections, leaderboards, and social functions may require separate settings or permissions. Gameplay sharing requires a deliberate player action or a clearly disclosed event-specific arrangement, and camera and audio sharing require separate, heightened authorization.

Withdrawing consent

You may withdraw consent to optional processing, subject to legal and contractual restrictions and reasonable notice. Withdrawal may affect future Facility connections, profile visibility, gameplay sharing, marketing, precise location, optional analytics, or other optional features. Withdrawal does not necessarily require deletion of information already lawfully processed or retained for legal, security, transaction, consent-record, or dispute purposes.

7When We Disclose Personal Information

Participating Facilities

We may disclose information to a connected Facility where necessary to identify your booking, prepare or operate a session, connect gameplay results, administer an event or league, verify membership, provide support, prevent misuse, or deliver another feature you authorize.

A Facility receives only information reasonably necessary for its authorized role. A Facility does not obtain unrestricted ownership of your Golf SimPass account or your complete cross-Facility history.

Booking, simulator, and integration providers

We may disclose information to approved third-party systems where required to process bookings, prepare simulator sessions, receive gameplay data, manage leagues, authenticate accounts, provide access, or operate connected services.

Service providers

We may use service providers supporting cloud hosting; databases; authentication; email and text messaging; customer support; analytics; monitoring; security; payment processing; content delivery; backups; error reporting; document management; and professional advice. Service providers may access information only as reasonably necessary to perform their services and are subject to appropriate confidentiality, security, and data-protection obligations.

Other players and viewers

Information may be visible to other people according to your profile settings, league or event rules, leaderboard settings, gameplay-sharing permissions, viewer invitations, or content you choose to publish.

Business transactions

We may disclose information in connection with a proposed or completed financing, merger, acquisition, corporate reorganization, investment, sale of assets, sale of business, or insolvency transaction, using appropriate safeguards and complying with applicable law.

Legal, security, and protective disclosures

We may disclose information where reasonably necessary and legally permitted to comply with law, respond to court orders or lawful demands, protect users, prevent fraud, investigate security incidents, enforce our agreements, protect our rights or property, respond to emergencies, or protect the rights and safety of another person.

Professional advisers, and with your direction

We may disclose information to lawyers, accountants, auditors, insurers, consultants, and other professional advisers subject to appropriate confidentiality obligations, and wherever you ask or authorize us to do so.

8Golf SimPass and Facility Data Separation

Golf SimPass and a participating Facility may each control different records.

Golf SimPass-controlled information may include

your Golf SimPass account; Golf SimPass profile; cross-Facility player history; Golf SimPass permissions; Golf SimPass consent records; Golf SimPass rewards and milestones; account-security information; Golf SimPass communications; and Golf SimPass network activity.

Facility-controlled information may include

Facility waivers; Facility payment records; Facility membership records; local Facility booking records; Facility access records; local Facility marketing preferences; incident reports; local customer-support records; and other independently maintained Facility records.

9Cookies and Similar Technologies

We may use cookies, pixels, local storage, software development kits, and similar technologies.

Essential

Used to authenticate users, maintain sessions, remember privacy choices, secure accounts, prevent fraud, process requested transactions, and provide core site functions.

Functional

Used to remember language, region, display settings, preferred Facility, account preferences, and other personalization choices.

Analytics

Used to understand pages viewed, feature usage, navigation, errors, session duration, device types, and service performance.

Advertising

Golf SimPass does not use cross-site behavioural advertising cookies and does not disclose player activity for third-party targeted advertising.

You may manage non-essential technologies through our cookie settings, your browser, your device, or available platform privacy controls. Blocking certain technologies may affect functionality.

10Analytics, Aggregation, and De-Identification

We may create aggregated or de-identified information that does not reasonably identify an individual, and use it to understand golf participation; evaluate product performance; improve Facilities and integrations; identify general usage patterns; create operational benchmarks; support business planning; conduct research; develop new features; and provide aggregated reporting.

We will not attempt to re-identify information that has been properly de-identified except to test the effectiveness of de-identification safeguards, to investigate security or fraud, or where legally permitted or required. Aggregated or de-identified information is not presented as another Facility’s identifiable player information.

11Artificial Intelligence and Automated Processing

Golf SimPass may use automated systems to support session matching; statistics; milestones; recommendations; fraud detection; account security; customer support; service diagnostics; personalization; and operational insights.

Our philosophy is that AI and automation should support human judgment rather than remove appropriate human control. We do not use Golf SimPass information to make decisions producing legal or similarly significant effects about players without appropriate notice, review, and safeguards.

Where we introduce a materially different automated decision or AI use, we may provide a contextual notice; an explanation of the purpose; information about the principal inputs; available choices; and human review where appropriate or legally required.

We do not use identifiable player information to train a general-purpose third-party AI model unless the use has been specifically assessed, contractually controlled, appropriately disclosed, and supported by consent or another valid legal basis.

12International and Cross-Border Processing

Golf SimPass is operated from Canada. We and our service providers may process personal information in Canada, the United States, or other jurisdictions in which approved service providers operate.

When information is processed outside your province or country, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies, or governmental authorities under applicable law. We use contractual, technical, and organizational safeguards appropriate to the processing.

You may request details of our current hosting region and material service providers through the contact page.

13Retention of Personal Information

We retain personal information only as long as reasonably necessary for identified purposes, legal obligations, security, fraud prevention, dispute resolution, and legitimate operational requirements.

How long that is depends on the type of information; sensitivity; account status; transaction requirements; Facility connections; legal obligations; limitation periods; security needs; backup cycles; and whether information is subject to a legal hold.

Sign-in sessions expire 30 days after they are issued and expired sessions are removed automatically. Private game-screen streams are not recorded by default, and camera or audio recordings are not retained unless separately disclosed.

When information is no longer required, we may securely delete it, de-identify it, aggregate it, or render it inaccessible through routine systems.

You may ask us for the retention period applying to a specific category of information through the contact page.

14Account Closure and Deletion

You may request closure of your Golf SimPass account. Subject to identity verification, legal requirements, and limited retention exceptions, account closure may include disabling login access; removing your active profile; ending future Facility connections; ending optional gameplay sharing; removing public profile information; deleting or de-identifying information from active systems; and retaining limited records where required.

We may retain limited information for legal compliance; consent evidence; transaction records; security; fraud prevention; enforcement; dispute resolution; legal holds; backups; and protecting other users.

Information already shared with a Facility under your authorization may remain in the Facility’s independently controlled records. Information already displayed or shared with other users may not be fully recoverable from copies they created outside Golf SimPass.

15Your Privacy Rights

Depending on applicable law and the circumstances, you may request the items below. If you live in the United States, United States Residents describes your state-law rights and how we handle them.

• access to personal information under our control;
• information about how it has been used or disclosed;
• correction of inaccurate information;
• completion of incomplete information;
• withdrawal of optional consent;
• deletion of your account;
• an available export;
• review of a privacy concern;
• information about service providers;
• information about automated processing; or
• another right provided by applicable law.

To submit a request, use the contact page with Privacy or my data as the topic, or write to the Privacy Officer at info@golfsimpass.com. Include your name, account email, the nature of the request, enough detail to identify the information, and your preferred contact method.

We may take reasonable and proportionate steps to verify your identity and authority before providing access, correction, export, or deletion.

We may decline or limit a request where legally permitted, including where disclosure would reveal another person’s information; disclose protected confidential information; compromise security; interfere with an investigation; be prohibited by law; or involve information that cannot reasonably be located or attributed. Where we cannot fulfill a request, we will explain the reason where legally permitted.

16Security Safeguards

We use administrative, technical, physical, and organizational safeguards appropriate to the nature and sensitivity of the information. Safeguards may include access controls; role-based permissions; authentication; encryption in transit; encryption at rest where appropriate; logging and monitoring; secure software-development practices; vulnerability management; backup and recovery procedures; employee confidentiality requirements; vendor assessments; incident response; data minimization; retention controls; and security training.

No system is completely secure. We cannot guarantee that unauthorized access, loss, misuse, or disclosure will never occur.

17Privacy and Security Incidents

We maintain procedures to assess and respond to suspected privacy and security incidents. Where legally required, we will investigate; contain the incident; preserve relevant records; assess potential harm; notify affected individuals; report to regulators; notify relevant Facilities or service providers; and take corrective action.

We maintain records of breaches of security safeguards under our control, including incidents that do not meet the threshold for notification.

18Marketing Preferences

You may unsubscribe from Golf SimPass marketing by using the unsubscribe link, changing your account preferences, or contacting us.

We may continue to send non-promotional service communications, such as security messages; password resets; booking confirmations; transaction notices; policy updates; account notices; and messages required to provide the service.

A Facility’s communications and unsubscribe process may be separate. We maintain records of marketing consent and withdrawals where reasonably necessary to demonstrate compliance.

19Third-Party Websites and Services

Golf SimPass may link to or integrate with third-party websites, apps, booking platforms, payment services, simulator systems, social services, or other technologies. Those third parties may independently collect personal information under their own privacy policies.

We are not responsible for an independent third party’s privacy practices. Before connecting an optional service, review the information presented by Golf SimPass and the third party.

20Public Profiles, Leaderboards, and Social Features

Where Golf SimPass offers public or social functionality, information may become visible to other people. Depending on your settings, this could include display name; avatar; level; achievements; scores; courses played; league standings; Facility; gameplay activity; or other information described in the interface.

Our settings are:

• profiles are private by default;
• no public display of your full legal name;
• no public display of email, telephone number, birth date, or precise location;
• heightened restrictions for minors;
• separate permission for public leaderboards;
• blocking and reporting controls; and
• clear visibility indicators.

Do not share information through a public feature that you do not want publicly visible.

21Gameplay Streams and Recordings

Screen-only gameplay sharing

Where enabled, Golf SimPass may transmit simulator gameplay information to people selected by the player or authorized under event rules. The stream may display virtual course action; score; shot results; player display name; league or event information; and session statistics.

Private links

Private links reduce public discoverability but cannot guarantee that an invited viewer will not forward the link, photograph the screen, create a screen recording, or disclose information outside Golf SimPass. We may maintain access and security logs to prevent misuse.

Recording

Golf SimPass does not record or retain private game-screen streams. Where replays, highlights, or recordings are introduced, we will provide additional notice covering what is recorded; who may access it; retention; sharing; deletion; event use; and additional permissions.

Bay cameras and microphones

Bay camera or microphone functionality is not covered by general account creation. Before activating those features, Golf SimPass will implement a separate privacy notice, consent flow, guest procedure, Facility requirements, minor protections, and retention rules.

22The Golf SimPass Mobile App

The Golf SimPass app for iOS and Android is covered by this policy. This section describes what the app itself collects on your device, in addition to everything described above.

Account information. To use the app you sign in with your Golf SimPass account. You may sign in with an email address and password, with a one-time email link, or with Sign in with Apple or Sign in with Google. When you use Apple or Google sign-in, we receive only your name and email address from that provider — never your password. If you use Apple’s private relay address, we store that relay address and never see your real one.

Bookings and play data. The app shows your bookings, payments and refunds, and the play data the simulator bay recorded during your visit — shots, holes, course, score, ball speed and similar measurements. This is the same information shown on the Golf SimPass website.

Push notifications. If you allow notifications, we store a push token for your device so we can send booking reminders and messages about a booking you have made. The token identifies the device, not you personally, and is deleted when you sign out or turn notifications off. You can withdraw permission at any time in your device settings.

Face ID, Touch ID and biometrics. If you switch on the app lock, your device performs the biometric check and tells the app only whether it succeeded. Your fingerprint or face data never leaves your device and is never sent to us or stored by us.

Payments. Card payments are completed on the payment provider’s own secure page. The app never sees, handles or stores your card number.

Information stored on your device. The app keeps your sign-in token in the device keychain, along with your app-lock preference and the email address you last signed in with, so you do not have to retype it. Signing out removes the token.

What the app does not collect. The app does not track your location, does not access your contacts, camera roll or microphone, and does not use third-party advertising or analytics trackers.

Deleting your account. You can permanently delete your account from inside the app, under Account → Settings → Delete my account. Your name, email address, phone number, password and reviews are removed and you are signed out everywhere. Bookings already made remain with the venue as their business records, without your personal identifiers, as described in Account Closure.

23United States Residents

This section applies if you live in the United States. It adds to the rest of this policy, and where the two differ for a US resident, this section controls. For California residents it is our notice at collection and the privacy policy required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”).

What we collect

In the last 12 months we have collected the categories of personal information below. The examples are what Golf SimPass actually holds; not every item applies to every player. In this section, a “venue” is a participating Facility: the business you book with.

We do not collect biometric information (Face ID and fingerprint checks stay on your device), precise geolocation, government identification numbers, full payment card numbers, health information, or professional, employment or education information. We do not currently ask for your date of birth or age.

Where it comes from

• You, when you create an account, book, buy a membership, package or gift card, join a league or a waitlist, or contact us;
• The venues you book with, for example when staff make or change a booking for you or record league scores;
• The simulator software at the venue, which sends the shot and score data from your session;
• Payment providers (the venue’s Stripe or Square account), which tell us whether a payment went through, and the card brand and last digits;
• Sign-in providers, if you choose Sign in with Apple or Sign in with Google (your name and email address only);
• Other players, when someone adds you to a booking, sends you a gift card or signs you up for a league; and
• Your device, automatically, when you use the website or the app.

Why we use it

We use each category for the purposes in Why We Use It: to run your account; to take, confirm and remind you about bookings; to take payments through the venue’s payment provider; to run memberships, packages, leagues, gift cards and waitlists; to show your golf history and statistics; to send service messages and, with your permission, marketing; to keep Golf SimPass secure and prevent fraud; to find and fix problems and improve the service; and to meet our legal obligations. We use sensitive personal information only to sign you in and protect your account.

Who we disclose it to

• Venues. When you book with, buy from or join a league at a venue, that venue receives what it needs to serve you: your name, contact details, booking and purchase details, and your play at that venue. You are directing us to pass it on when you book, buy or join. Each venue is a separate business and handles that information under its own policies (see Data Separation).
• Payment processors. You pay the venue through its own Stripe or Square account, and you enter your card details directly with that provider.
• Service providers that work on our behalf: hosting and databases, email delivery, text-message delivery, push-notification delivery, security and spam prevention, and customer support. Our sign-in and sign-up forms use Google reCAPTCHA to stop automated abuse; Google’s Privacy Policy and Terms of Service apply to it.
• Other players and the public, as you choose and as features work. For example, if you join a league that the venue has made public, the league page shows the name you registered with, your handicap and your scores.
• Legal, safety and business-transfer disclosures, as described in When We Disclose It.

No sale, and no sharing for advertising

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We have done neither in the last 12 months. The Golf SimPass website uses no advertising cookies or advertising pixels, our site statistics are our own and use no cookies, and the app contains no third-party advertising or analytics trackers. We have no actual knowledge of selling or sharing the personal information of anyone under 16.

Because we do not sell or share, we do not show a “Do Not Sell or Share My Personal Information” link. If that ever changes, we will update this policy first and give you a way to opt out before it happens.

Global Privacy Control

Global Privacy Control (GPC) is a browser setting that tells websites you want to opt out of the sale and sharing of your personal information. We treat a GPC signal as a valid opt-out request for that browser and for any Golf SimPass account signed in on it. Today that changes nothing, because we already do neither. If we ever start, the signal will be applied without you having to do anything else.

Sensitive personal information

The only sensitive personal information we hold is your account log-in. We use it only to sign you in and protect your account, which the CCPA permits without a right to limit, and we do not use it to infer anything about you. If that ever changes, we will offer a “Limit the Use of My Sensitive Personal Information” choice.

Your rights

If you are a California resident, you have the right to:

• know what personal information we have collected about you, where it came from, why we use it and who we disclosed it to, and to get a copy of the specific pieces of information, in a portable format where we can;
• delete personal information we collected from you, subject to the exceptions the law allows, such as records we must keep for tax or to complete a transaction;
• correct inaccurate personal information;
• opt out of the sale or sharing of your personal information (we do neither);
• limit the use of your sensitive personal information (we use it only as described above); and
• not be discriminated against for using any of these rights.

You can do much of this yourself. Your account shows your bookings, memberships and play history; Settings lets you correct your name, email address and mobile number; and you can delete your account in the app under Account → Settings → Delete my account (see Delete your account).

How to make a request

• use the contact page and choose Privacy or my data as the topic;
• email info@golfsimpass.com with “US privacy request” in the subject; or
• call 1.647.409.1648.

Tell us which right you are using and the email address on your Golf SimPass account. To protect you, we verify every request before acting on it, usually by matching it to your account and asking you to confirm from your account email address or while signed in. For a copy of specific pieces of information, or to change or delete sensitive details, we may ask for more. We use what you give us for verification only to verify you.

We will confirm that we received your request within 10 business days. We aim to answer within 30 days, and we will answer within 45 days in every case; if we need up to 45 more days, we will tell you why. Requests are free. If we cannot do all or part of what you ask, we will explain why.

Authorized agents

Someone else can make a request for you. The agent must give us your signed permission, and we may still ask you to verify your identity with us directly or to confirm that you gave the agent permission. This does not apply where the agent holds a power of attorney under California Probate Code sections 4121 to 4130.

No discrimination

We will not deny you service, charge you a different price, or give you a different level or quality of service because you used a privacy right.

How long we keep it

• Account and profile information (identifiers, customer records, inferences): while your account is open. When you delete your account, your name, email address, phone number, password and reviews are removed, as described in The Golf SimPass Mobile App and Account Closure.
• Bookings, purchases and payments (commercial information): kept as business and tax records for 7 years. After you delete your account, the venue’s booking records remain without your personal identifiers.
• Golf and play information: while your account is open, as your history. When you delete your account, the shots and scores recorded at a venue stay in that venue’s bay statistics without your name or email address. League rosters and standings are records the venue keeps and controls.
• Website visit records (network activity and approximate location): raw records are deleted after about 13 months.
• Sign-in sessions expire after 30 days. Push-notification tokens are deleted when you sign out or turn notifications off.
• Messages with us and text-message logs: for as long as we need them to answer you, resolve a problem or dispute, or keep a record of the service we provided. Our text-message provider keeps its own delivery records under its retention schedule.
• Privacy requests and how we answered them: at least 24 months, as the CCPA requires.

Other US states

Other states, including Colorado, Connecticut, Oregon, Texas and Virginia, give their residents similar rights. Depending on where you live, you may have the right to confirm whether we process your personal information; to access, correct or delete it, or get a copy of it; and to opt out of targeted advertising, the sale of personal information, and profiling that produces legal or similarly significant effects. We do not sell personal information, use it for targeted advertising, or use it for that kind of profiling.

Wherever you live in the United States, you can use the request process above.

Appeals. If we decline your request, you can appeal by replying to our decision, or by emailing info@golfsimpass.com with “Privacy appeal” in the subject. We will answer within 45 days and explain the outcome. If you disagree with it, you can contact your state attorney general.

Nevada residents: we do not sell covered information as Nevada law defines it.

Questions about this section go to our Privacy Officer; see Complaints and Questions.

24Children’s Privacy

Golf SimPass is a general-audience service for adults. It is not directed to children under 13, and you must be 18 or older to create an account (see Eligibility in the Terms of Use).

We do not knowingly collect personal information online from children under 13, and we do not knowingly sell or share the personal information of anyone under 16.

Junior leagues and junior players

Venues can run junior leagues, and children can play at venues. A parent or legal guardian registers a junior, using the parent’s or guardian’s own account and contact details; a child should not sign up or enter their own details. The registration may include the junior’s name, handicap and league scores, and these stay linked to the parent’s or guardian’s account. The parent or guardian can ask us at any time to see, correct or delete them.

If a junior league is public, its standings show the player name entered at registration to anyone who views the league page, so we recommend registering a junior by first name and last initial.

If we learn we have a child’s information

If we learn that we have collected personal information online from a child under 13 without verified parental consent, we will delete it promptly and close any account the child created. If you believe a child under 13 has given us personal information, email info@golfsimpass.com with “Child’s information” in the subject.

25Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to Golf SimPass; new features; changes to service providers; legal or regulatory developments; changes to processing activities; security requirements; or improved clarity.

We will display the updated date. Where a change is material, we may provide notice through email; the Golf SimPass website; the application; an account notice; or another appropriate method. Where required, we will request renewed consent.

We will not use an updated policy to retroactively authorize a materially different use of personal information where additional consent is required.

26Complaints and Questions

You may contact our Privacy Officer with a question, concern, request, or complaint.

Privacy Officer — Craig Weissenfels
Soarware Labs Inc.
Golf SimPass
561 Bayfield Street, Suite 1003
Barrie, Ontario, Canada L4M 4Z9
Email: info@golfsimpass.com
Telephone: 1.647.409.1648

We will review privacy complaints and respond within a reasonable period. You may also have the right to contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.

27Language

The English version of this Privacy Policy is the current governing version, subject to applicable language laws.

28Contact Information

Soarware Labs Inc.
Golf SimPass
561 Bayfield Street, Suite 1003
Barrie, Ontario, Canada L4M 4Z9

Support, privacy, and legal: info@golfsimpass.com

Telephone: 1.647.409.1648 · Website: GolfSimPass.com

You can also reach us through the contact page.