ANDREW GOLF PRIVACY POLICY
Last Revised on January 1, 2025
This Privacy Policy for Lothian Road WRX, Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s website (www.andrew.golf), the Andrew Golf app (“App”), services, tools and features (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.
Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not use, access, or download any of the Services.
We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy you may not access or continue to use the Services.
When you access or use the Services, we may collect certain categories of information about you from a variety of sources.
Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:
A. Account and Registration. Users may access our App only if they register an Account with us. The personal information we collect as part of the Account creation process includes your first and last name, email, username, password, information to confirm you are old enough to use the Services and use the App, payment information for any in-app purchases or storage of funds in your Andrew Wallet (for example, your name and email associated with your payment account). We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.
B. Prizes and Payments. We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prices, which may include your email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.
C. Feedback. We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the request, name and contact information), resumes provided, or other similar activities. This information may be used to enhance the Services or the App, to market to you or others, and to allow us to make appropriate hiring decisions if submitted for that purpose.
D. Usage Data. We automatically collect information about your use of our Services and the App through cookies, local storage, analytics tools and other technologies, (“Tracking Technologies”) such as your device ID, location information, device name and model, operating system type, name and version, the length of time that you are using our Services and your activities within our Services (“Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.
E. Geolocation Information. We collect and use precise geolocation data to provide and improve our Services. By using the App, you expressly consent to our collection and use of your precise location data. This information is crucial for features such as locating nearby golf courses, tracking your position during gameplay, and ensuring compliance with local regulations.
How we use location data:
● To enable core app functionality;
● To verify your eligibility for certain Contests;
● To comply with legal and regulatory requirements; and
● To prevent fraud and ensure fair play.
You can control location tracking through your device settings. However, disabling location services may limit your ability to use certain features of the App. You may withdraw your consent at any time by disabling location services for the App in your device settings or by contacting us at support@andrew.golf.
We may use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services.
We may obtain information about you from outside sources. Such information may include:
● Information from third parties that you choose to share with us, for example:
o When you choose to link any social media platforms to your account, such as Facebook or Twitter/X. This information is used to maintain your account and login information.
Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.
In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, improve and develop the Services and our product offerings, including as we describe in our Terms of Service, to enforce any applicable terms of service, to protect or defend the Services, our rights, and the rights of our users or others, and for the purpose of combatting fraud, or to otherwise operate our business. This Privacy Policy is integrated into and is expressly a part of the Terms of Service, to be interpreted in conjunction with such Terms. Any capitalized term not defined herein, shall have the meaning ascribed to it in the Terms of Service.
In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:
● With vendors or other service providers, such as cloud storage providers, security vendors, data analytics vendors, banks and payment processors;
● With our affiliates or otherwise within our corporate group;
● When you request that we share certain information with third parties, such as through your use of social media widgets, login integrations, or interactions with other users on the Platform;
● To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries;
● In connection with an asset sale, merger, bankruptcy, or other business transaction;
● To enforce our Terms of Service;
● To ensure the safety and security of the Company and/or its users;
● When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations; or
● With professional advisors, such as auditors, law firms, or accounting firms.
Do Not Track Signals
Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, the Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.
Cookies and Other Tracking Technologies
Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly or not function at all.
We use cookies and similar tracking technologies to collect information about your use of our Services. These technologies help us analyze usage patterns, personalize your experience, and improve our Services.
Types of Cookies:
● Essential Cookies: Necessary for website functionality
● Analytics Cookies: Help us understand user interaction
● Functional Cookies: Enable enhanced personalization
● Advertising Cookies: Deliver relevant advertisements
How We Use Cookies:
● Authenticate users and prevent fraud
● Remember preferences and settings
● Analyze Service performance and user interaction
● Serve personalized content and advertisements
Third-Party Cookies:
Some cookies may be placed by third parties. We do not control these third parties or their use of cookies.
Your Choices:
You can usually set your browser to remove or reject cookies. Note that this may affect the availability and functionality of our Services.
Other Tracking Technologies:
We may also use web beacons and similar technologies to collect information about your interactions with our emails and mobile applications.
We may provide links to third-party websites or other online platforms operated by third parties. If you follow links to sites or interact with features (e.g., applications offered by third parties or social media widgets) not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter/X) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.
Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.
If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the information below to request that it be deleted.
Age Verification and Parental Consent. Our Services are intended for users who are 18 years of age or older. We implement age verification measures during the account creation process to ensure compliance with this requirement. If you are between the ages of 13 and 17, you may only use our Services with the consent and supervision of a parent or legal guardian.
Age Verification Process:
● During registration, users must provide their date of birth;
● We use technical measures to verify the accuracy of the provided age; and
● Additional verification may be required for users near the age threshold.
Parental Consent for Minors:
● Users under 18 must provide verifiable parental consent before using our Services;
● Parents or guardians can provide consent by submitting a signed consent form or verifying via email; and
● We reserve the right to request additional proof of parental consent at any time
If we become aware that a user is under 13 or that a user between 13 and 17 is using our Services without parental consent, we will terminate the account and delete any associated personal information.
Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.
We implement reasonable and appropriate security measures to protect your personal information:
Technical Safeguards:
● Data encryption
● Firewalls and intrusion detection systems
● Regular security updates
● Multi-factor authentication
Organizational Safeguards:
● Employee training on data protection
● Access controls based on least privilege
● Regular security audits
● Incident response plans
Physical Safeguards:
● Secure data centers
● Surveillance systems…
● Proper disposal of physical documents
While we strive to protect your information, no security measures are perfect. We cannot guarantee absolute security of data transmitted electronically.
Your Role:
● Use strong, unique passwords
● Don't share login credentials
● Be cautious on public devices
● Keep your devices updated
Breach Notification:
We will notify you and authorities of any data breaches as required by law. If you notice any suspicious activity, please contact us immediately at support@andrew.golf.
Right to Access | The right to be provided with a copy of your personal information (the right of access) |
Right to Rectification | The right to require us to correct any mistakes in your personal information |
Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data |
Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
Right to Object | The right to object: |
Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
● With our offices outside the EEA;
● With your and our service providers located outside the EEA;
● If you are based outside the EEA; or
● Where the Contests and Services have an international or cross-border character.
These transfers are subject to special rules under European and UK data protection law.
In general, non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please contact us or our Data Protection Officer (see “How To Contact Us” below).
Category | Examples | Collected? |
Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Including but not limited to name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
Protected classification characteristics under California or federal law. | Age (40 years or older), national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information) | NO |
Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
Biometric Data | An individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with each other or with other identifying data, to establish individual identity. Facial recognition technology collects information from your image capture, including biometric data, and shares this information with us, which assists us to verify your ID. | YES. |
Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
Geolocation Data | Physical location/movements | YES |
Audio/visual data | Audio, electronic, visual, thermal, olfactory, or similar information, | YES |
Professional or employment related information. | Current or past job history or performance evaluations. | NO |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, predispositions, behavior, | YES |
Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@andrew.golf.