This Privacy Policy (the "Policy") explains how Tournament Index, LLC (the "Company," "we," "us," or "our") collects, uses, discloses, and protects information about users ("User," "you," or "your") in connection with your access to or use of our websites, applications, handicap-integrity monitoring and reporting services, and other online products and services (collectively, the "Services"). This Policy does not apply to information collected by any third party, including through any application, content, or advertising that may link to or be accessible from the Services.

Please read this Policy carefully. By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not use the Services.

1. Changes to This Policy

We may modify this Policy at any time in our discretion. If we make material changes, we will provide notice at least thirty (30) days before the new Policy takes effect by posting the updated Policy on the Services and, where appropriate, notifying you by email. The effective date is posted at the top of the Policy. Your continued access to or use of the Services after the effective date constitutes your acceptance of the modified Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you provide directly to us, including when you create an account, complete your profile, subscribe to the Services, upload club data such as scoring records, request customer support, sign up for communications, or otherwise communicate with us. Some information is required to create an account or use certain features (typically marked as required); if you do not provide it, we may be unable to offer those features.

2.2 Information We Collect Automatically

When you access the Services, we may automatically collect certain information, including:

• Log information: browser type, access times, usage data, referring and exit pages and URLs, pages viewed, number of clicks, and IP address.
• Device information: device type, operating system, unique device identifiers, and mobile network information.
• Cookies and similar technologies: small data files stored on your device that help us operate, secure, and improve the Services and remember your preferences. See Section 8 (Cookies and Tracking Technologies) for details.

2.3 Information From Other Sources

We may obtain information about you from other sources, such as golf clubs or associations, event partners, payment processors, and analytics providers, and combine it with information we collect through the Services.

2.4 Categories of Personal Information

Over the past twelve (12) months, we have collected the following categories of personal information:

• Identifiers: legal name, username, email address, postal address, phone number, IP address, and account or membership ID.
• Account and profile data: password (stored in hashed form), profile photo, home club, playing preferences, and communication settings.
• Golf and performance data: posted scores, scorecards, handicap index and history, course ratings, rankings, tournament results, and related review activity.
• Commercial information: products or subscriptions purchased, purchase and billing history, and subscription plan details.
• Financial information: payment and billing information, processed through our third-party payment processors (we do not store full card or bank account numbers).
• Internet and device activity: browser type, device identifiers, access times, pages viewed, referring and exit pages, clicks, and app usage data.
• Location information: general location derived from IP address and, where you permit it, course or club location.
• Photos and media: photos, videos, and content you upload or that are captured at Company-organized events.
• Inferences: preferences and characteristics derived from the above to personalize your experience.

Sensitive personal information. We do not seek to collect sensitive personal information beyond what is necessary to provide the Services (for example, account credentials and payment information). We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law, and we do not "sell" or "share" it as those terms are defined by California law.

3. How We Use Information

We use the information we collect for purposes including to:

• Operate, maintain, provide, and improve the Services;
• Create and manage your account, and produce Fair Play Scores, reports, and related indicators from the data your club provides;
• Provide and deliver the products, subscriptions, and services you request or purchase;
• Process transactions and send related information, including confirmations, invoices, and renewal notices;
• Provide customer service and technical support, and respond to your comments, questions, and requests;
• Send technical notices, updates, security alerts, and administrative messages;
• Communicate about products, services, offers, promotions, and events;
• Send account summaries and updates, such as new reports and changes in member review status;
• Personalize your experience and deliver content and features matched to your needs;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Detect, investigate, and prevent fraud, abuse, security incidents, and other harmful or unlawful activity;
• Comply with legal obligations and enforce our Terms of Use; and
• Carry out any other purpose described to you at the time the information was collected.

4. How We Share Information

We do not sell your personal information for money. We may disclose information as described below:

• Service providers: with vendors and partners who perform services for us, such as hosting, payment processing, analytics, email delivery, and customer support, under contractual obligations to protect your information and use it only as directed.
• Within your club: scores, handicap information, Fair Play Scores, and related review activity may be visible to other authorized users at your club, such as committee members and club administrators, consistent with the purpose of the Services and your club's settings.
• Golf clubs, associations, and event partners: where necessary to provide the Services, administer club accounts, or support tournaments and events your club runs.
• Legal and safety: when we believe disclosure is necessary to comply with law, legal process, or a governmental request, to enforce our agreements, or to protect the rights, property, or safety of the Company, our users, or others.
• Business transfers: in connection with, or during negotiations of, a merger, acquisition, financing, reorganization, or sale of all or a portion of our assets, in which case personal information may be among the transferred assets. You acknowledge and consent that such transfers may occur and that an acquirer may continue to process personal information as set forth in this Policy.
• With your consent: or at your direction, including when you choose to share content through social media.

We may also use and disclose aggregated or de-identified information, which cannot reasonably be used to identify you, for any purpose permitted by law.

5. Your Privacy Rights

5.1 Marketing Communications

You may opt out of promotional communications at any time by following the unsubscribe instructions in the email, or by adjusting the settings in your account. Even if you opt out of promotional messages, we may still send you administrative or transactional communications, such as updates to our Terms or this Policy and messages about your account.

5.2 California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, provides you with the following rights, subject to certain exceptions:

• Right to know: to request the categories and specific pieces of personal information we have collected about you, the sources, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
• Right to delete: to request deletion of personal information we have collected from you.
• Right to correct: to request correction of inaccurate personal information we maintain about you.
• Right to opt out: to opt out of the "sale" or "sharing" of your personal information. We do not sell or share personal information as those terms are defined by California law.
• Right to limit: to limit the use and disclosure of sensitive personal information to permitted purposes.
• Right to non-discrimination: we will not discriminate against you for exercising any of your rights.

To exercise these rights, contact us using the information in Section 12, or through any request mechanism we make available on the Services. We will verify your request by matching information you provide with information in our records; we may request additional information for verification. You may use an authorized agent to submit a request, subject to proof of authorization. We will respond within the timeframes required by law.

Shine the Light. California Civil Code Section 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at the address in Section 12.

5.3 Access, Update, and Deletion

You may access and update certain account information at any time through your account settings. You may also request that we delete your account and associated personal information, subject to information we are required or permitted to retain under applicable law.

6. Additional Information for Users in the European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the following additional information applies to our processing of your personal data under the EU General Data Protection Regulation (GDPR) and the UK GDPR. In the event of any conflict with other provisions of this Policy, this Section controls for such users.

6.1 Data Controller

Tournament Index, LLC is the controller responsible for your personal data. You can contact us using the details in Section 12.

6.2 Legal Bases for Processing

We process your personal data only where we have a valid legal basis to do so, including:

• Performance of a contract: to provide the Services you request, administer your account and subscription, and fulfill our agreement with you.
• Legitimate interests: to operate, secure, and improve the Services, prevent fraud and abuse, and communicate with you, provided these interests are not overridden by your rights and freedoms.
• Consent: where required, such as for certain marketing communications or optional features. You may withdraw your consent at any time.
• Legal obligation: to comply with applicable laws, regulations, and legal process.

6.3 Your Rights Under the GDPR

Subject to applicable law, you have the right to:

• Access a copy of the personal data we hold about you;
• Request rectification of inaccurate or incomplete personal data;
• Request erasure of your personal data (the "right to be forgotten");
• Restrict or object to our processing of your personal data;
• Request data portability, to receive your data in a structured, commonly used, machine-readable format;
• Withdraw consent at any time where processing is based on consent; and
• Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

To exercise any of these rights, contact us using the information in Section 12. We will respond within the timeframes required by law and will not charge a fee except as permitted by law.

6.4 International Data Transfers

We are based in the United States, and your personal data may be transferred to, stored in, and processed in the United States or other countries that may not provide the same level of data protection as your jurisdiction. Where we transfer personal data out of the EEA, the United Kingdom, or Switzerland, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), to protect your information.

6.5 Complaints

If you believe our processing of your personal data infringes applicable law, you have the right to lodge a complaint with your local data protection supervisory authority. We would appreciate the opportunity to address your concerns before you do so, so please consider contacting us first.

7. Data Retention

We retain personal information for as long as necessary to provide the Services, maintain your club's scoring and review records, comply with our legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we will delete, anonymize, or de-identify it in accordance with our retention practices and applicable law.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and secure the Services, remember your preferences, analyze usage, and improve your experience. We may use both persistent cookies (which remain until you delete them) and session cookies (which expire when you close your browser). Most browsers accept cookies by default; you can set your browser to remove or reject cookies, though doing so may limit the functionality of the Services.

Do Not Track. Some browsers offer a "Do Not Track" signal. Because there is not yet a common industry standard for interpreting these signals, the Services do not currently respond to them. We will treat recognized opt-out preference signals as valid requests to opt out where required by law.

9. Third-Party Sites and Social Media

The Services may contain links to, or integrations with, third-party websites, platforms, and social media. We do not control these third parties, and their inclusion does not imply our endorsement. This Policy does not apply to information you provide to, or that is collected by, these third parties, and we encourage you to review their privacy policies. You assume all risks associated with following links to third-party sites.

10. Children's Privacy

The Services are intended for users who are eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will take reasonable steps to delete it. If you believe a minor has provided us with personal information, please contact us using the information in Section 12.

11. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and for taking reasonable precautions to protect your information. If you have reason to believe your account is no longer secure, please contact us immediately.

12. Contact Us

If you have questions or requests regarding this Policy or our privacy practices, please contact us:

Tournament Index, LLC
1701 El Nido #25, Diablo, CA 94528
Email: support@tournamentindex.com