Privacy Policy

1Introduction

GolfSimPass is operated by Soarware Labs Inc. In this Privacy Policy, “GolfSimPass,” “we,” “us,” and “our” refer to Soarware Labs Inc. in its operation of GolfSimPass; “you” and “your” refer to an individual who visits, creates an account with, connects to, books through, or otherwise uses GolfSimPass; “Facility” means a participating golf simulator facility, golf business, academy, club, course, recreation facility, or other participating location; and “Services” means the GolfSimPass 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 GolfSimPass. It also explains how GolfSimPass and participating Facilities have separate responsibilities; how information may move between GolfSimPass, 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 GolfSimPass Information?

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

Soarware Labs Inc.
GolfSimPass
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 GolfSimPass, 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 GolfSimPass.

Booking and Facility information

When you book through GolfSimPass 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 GolfSimPass 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 GolfSimPass; security reports; complaint records; and records of actions taken in response.

Device, website, and technical information

When you access GolfSimPass 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 GolfSimPass 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. GolfSimPass does not collect or broadcast bay camera or audio information merely because you have a GolfSimPass 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 GolfSimPass account — a guest must independently create an account and accept the GolfSimPass Terms of Use and Privacy Policy before a permanent player relationship is created.

Information about minors

GolfSimPass 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.

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 GolfSimPass 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 GolfSimPass-supported Facility feature.

Facilities may invite you to join GolfSimPass, but they may not silently create your account, accept GolfSimPass 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 GolfSimPass 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 GolfSimPass features, participating Facilities, memberships, leagues, tournaments, events, promotions, partner offers, and related golf products or services. GolfSimPass 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 GolfSimPass

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 GolfSimPass

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 GolfSimPass. You may not be able to use GolfSimPass without this processing.

Optional Facility connections

Connecting GolfSimPass 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 GolfSimPass 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.

8GolfSimPass and Facility Data Separation

GolfSimPass and a participating Facility may each control different records.

GolfSimPass-controlled information may include

your GolfSimPass account; GolfSimPass profile; cross-Facility player history; GolfSimPass permissions; GolfSimPass consent records; GolfSimPass rewards and milestones; account-security information; GolfSimPass communications; and GolfSimPass 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

GolfSimPass 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

GolfSimPass 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 GolfSimPass 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

GolfSimPass 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 GolfSimPass 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 GolfSimPass.

15Your Privacy Rights

Depending on applicable law and the circumstances, you may request:

• 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 GolfSimPass 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

GolfSimPass 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 GolfSimPass and the third party.

20Public Profiles, Leaderboards, and Social Features

Where GolfSimPass 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, GolfSimPass 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 GolfSimPass. We may maintain access and security logs to prevent misuse.

Recording

GolfSimPass 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, GolfSimPass will implement a separate privacy notice, consent flow, guest procedure, Facility requirements, minor protections, and retention rules.

22Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to GolfSimPass; 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 GolfSimPass 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.

23Complaints and Questions

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

Privacy Officer — Craig Weissenfels
Soarware Labs Inc.
GolfSimPass
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.

24Language

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

25Contact Information

Soarware Labs Inc.
GolfSimPass
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.