Privacy Policy

OPERATION 36 PRIVACY POLICY

This Privacy Policy describes how Golf Genius Software, Inc. (“we,” “us,” or “our”) collects and uses personal information about individuals participating in online golf programs conducted through the operation36.golf and related websites, including their webpages, interactive features and applications and their respective contents and any other associated interactive content, whether accessed by computer, mobile device or other technology (collectively the “Site”), which is owned and operated by us. The Site features an interactive computer software application known as Operation 36 that provides an online, but controlled access, environment for participating in golf programs.

Because some of the participants in golf programs offered through the Site are under the age of 13, this Privacy Policy follows the express mandates of the Children’s Online Privacy Protection Act (COPPA). In this regard, this Privacy Policy seeks to clearly and comprehensively describe how personal information is collected from children under age 13, describing not only our practices but the practices of any others collecting personal information on the Site.

This Privacy Policy can be found on the operation36.golf home page and at the following link: https://operation36.golf/privacy. This Privacy Policy is also accessible wherever we collect personal information from children. This Privacy Policy references our Terms of Use (“Terms”). A copy of the current Operation 36 Terms of Use governing the Site are found at this link: https://operation36.golf/terms.

Information about us including our contact information can be found at the following website link: https://operation36.golf

1. About Participation in Golf Programs Offered Through the Site.

We offer users through the Site the ability to register online and participate in golf programs and related activities offered through the Site (the “Golf Programs”).

Professional golf instructors and facility managers (“Our Licensed Golf Professionals”), who have entered in to a licensing agreement with us, may have access to use portions of the Golf Programs relevant to their program activities and program participants for such purposes as conducting their coach-specific or facility-specific Golf Programs and participating in broader Operation 36 community-wide program activities.

Children under the age of 13 are not allowed to use this Site without a parent’s permission. Children under the age of 13 also may not subscribe to, or create their own account with, this Site. Children may only have a child account that is established by, and with the permission of, a parent.

2. Parental Consent.

We are required by COPPA to use reasonable efforts to ensure that before we collect any personal information from a child, the child’s parent receives notice of and consents to our information practices. As a parent, you should know that through the Site children under the age of 13 may participate in activities that involve the collection or use of personal information. However, children may not participate in any Site activities without a parent’s permission.

If your child is under age 13, we must have “verifiable parental consent” before we collect and use your child’s personal information. We obtain such “verifiable parental consent” by (i) requiring a parent to execute an online consent form; and (ii) acceptance of an “invitation” sent to the parent by us to include their child on a Program roster using the tools available after the parent has created their own account on the Site.

3. Listing of Those Collecting Personal Information.

Children’s personal information is either collected by us directly or collected by Our Licensed Golf Professionals within the Site. You may contact us directly by emailing us at privacy@op36golf.com if you have any questions about information either collected by us directly or collected by Our Licensed Golf Professionals. If your questions pertain to information collected by one of Our Licensed Golf Professionals, we will respond on behalf of Our Licensed Golf Professional.

4. Description of Personal Information and How It Is Collected.

We process two basic types of information - personal information and anonymous information.

We will collect your personal information when you apply to register to participate in Golf Programs through the Site and when you do in fact participate in Golf Programs through the Site.

The type of personal information we collect includes your name, birthdate, email address and contact information. Through your participation in the Golf Programs we also collect information about your performance and progress in the Program (“Program Statistics”) including such things as data of play action like score and yardage, and data of train action like hours practiced. Sometimes Golf Program participants share photographs and other information pertaining to their performance and progress in the Program (“Participant Materials”). We share Program Statistics and Participant Materials through the Site with other Program Participants and Our Licensed Golf Professionals.

The personal information that is collected is used to track and share your performance and progress in the Golf Programs within the Site with other users of the Site.

We do not disclose personal information within any “third parties” except Program Participants and Our Licensed Golf Professionals within the Site. We do not disclose personal information to advertising networks or other “outside” third-parties.”

We sometimes use cookies to track and obtain information relevant to participation in the Golf Programs.

When your child is logged into his or her account, we may track your child’s activities within the Site. For example, we track the pages visited, the length of time spent logged in, the information submitted about preferences and comments posted on the team’s dashboards. This information is associated with your child’s Program username and may be combined with the personally identifiable information we collect from him or her.

We may use the personal information that we collect from a child to determine whether he or she is eligible to use our site, to obtain consent from his or her parent to use the service, to provide an interactive online experience, to respond to requests for assistance in the use of the Site, to send newsletters, and to provide content that we believe that the child may be interested in.

We may use non-personal information such as information about the pages visited to improve the design, content and performance of our site, or to analyze site usage and the popularity of certain pages of the Site.

We may disclose personally identifiable information in response to legal process – for example, in response to a court order or a subpoena. We may also disclose such information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Policy, or as otherwise required by law. In addition, we may transfer personal information if we are acquired by or merged with another company or as part of a bankruptcy proceeding.

We may also share aggregate or anonymized information about children with non-affiliated third parties for advertising, marketing or research purposes.

5. Description of Parental Rights.

The mechanism for obtaining parental consent is as follows: A parent must enter their child’s first name, user ID and a password to create the child’s account. We may also request additional optional information about a child directly from the child or the child’s parent, such as last name; date of birth; email address; contact information; nickname and grade level. We may also ask a child for information relating to his or her preferences however, such information is optional and as a parent you may prevent your child from submitting such information or delete such information at any time. A child’s participation in Golf Programs activities is not conditioned on the child providing any more personal information than is reasonably necessary for participating in the activities.

You may always review your child’s personal information, instruct us to delete it, and refuse to allow any further collection or use of your child’s information, and/or prohibit its disclosure to any third parties. The procedures to follow to exercise the foregoing rights are explained within the account set up section of the Site, and you can email us with any specific questions or requests to exercise these rights at Privacy@Op36Golf.com.

All of the information provided by a child is always visible to the child’s parent. A parent can disable, delete or modify any of his or her child’s information by logging in and accessing that child’s profile.

If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's Personal Information.

6. Data Security.

We have implemented commercially reasonable safeguards to protect personal information that we collect and store. Despite these precautions, however, no data security safeguards are foolproof. Unauthorized individuals may find ways to obtain personal information from or to access the Site. Please keep in mind that we cannot and do not guarantee that content posted at the Site will not be viewed by unauthorized persons. Any content that you post or allow your child to post is at your own risk.

7. Text message communications.

We use text messaging to communicate with you about your service. Normal messaging rates apply and the frequency of messages may vary. Mobile Carriers are not liable for delayed or undelivered messages.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Opt-out of text message communications. You may opt out of text messaging at any time by replying to any message with STOP or contacting us at support@op36golf.com. This will end the communications from that particular phone number. You may continue to receive service-related and other non-marketing text messages from other phone numbers managed by Company, and you may opt out of those in a similar fashion.

8. Contact Us.

If you have questions, comments or concerns about any of our privacy policies or practices, or to raise any other issue related to privacy, you may contact Golf Genius Inc. at:

Last Updated: October 18, 2024