Website Privacy Policy – Canada

last updated: 11/30/2021

This is the privacy notice of Full Swing Golf, Inc. In this document, “we”, “our”, or “us” refer to Full
Swing Golf, Inc.

We are a California corporation registered in the United States of America. Our registered office
is located at 1905 Aston Avenue, Carlsbad, California 92008.
This privacy notice pertains to our collection, use, disclosure, and other processing activities with
regards to your personal information (as defined below) when you navigate or use our portfolio of
websites, products, and/or services located at fullswinggolf.com and related sub-domains.

INTRODUCTION
1. This is a notice to inform you of our policy about all personal information that we record,
receive, and collect about you. It sets out the conditions under which we may process any
personal information that we collect from you, or that you or other third parties provide to
us. It covers information that, alone or in combination with other information, could be used
to identify you (“personal information”). In the context of the law and this notice, “process”
means collect, store, transfer, use or otherwise act on information.
2. We take seriously the protection of your privacy. We understand that all visitors to our
website are entitled to know that their personal information will not be used for any purpose
unintended by them, and will not unlawfully fall into the hands of a third party.
3. We aim to preserve the confidentiality of all personal information you provide to us, and
hope that you reciprocate.
4. Our policy complies with US law accordingly implemented, including that required by the
EU General Data Protection Regulation (“GDPR”), as well as Canadian privacy laws.
However, depending on your geographic location, one or more of these laws may not
apply to our treatment of your personal information and, as a result, certain sections of
this Policy may not apply to it.
5. Citizens in the European Union have legal rights regarding how their personal information
is collected, used, and stored by website owners. The law requires us to tell EU citizens
about our rights and obligations to them in regards to the processing and control of their
personal data. We do this now, by requesting that EU citizens read the information
provided at www.knowyourprivacyrights.org.
6. Except as set out below, we do not share, or sell, or disclose to a third party, any
information collected through our website, unless we obtain your specific consent, or are
legally permitted or required to do so.

THE BASES ON WHICH WE PROCESS INFORMATION ABOUT YOU
GDPR, where applicable, requires us to determine under which of six defined bases we process
different categories of your personal information and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant, then we shall
immediately stop processing your data.
If the basis changes, then, if required by law, we shall notify you of the change and of any new
basis under which we have determined that we can continue to process your information.
Notwithstanding the foregoing, under Canadian privacy laws (as applicable), your consent
(implied or express, depending on the circumstances) is the only legal basis on which we can rely
to process your personal information, subject to certain specific exceptions provided under such
laws. One of those exceptions is found in cases where we are legally required to process your
personal information in a certain way. Consequently, the following Sections 1 and 3 do not apply
to you if you are located in Canada.

1. Information we process because we have a contractual obligation with you
This section is not applicable to you if you are located in Canada.
When you create an account on our website, buy a product or service from us, or otherwise agree
to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give
us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain the most
from using our website
We process this information on the basis that there is a contract between us, or that you have
requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class
information, for example, to monitor our performance with respect to a particular service we
provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated
by either party under the terms of the contract.

2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as
when you browse our website or ask us to provide you more information about our business,
including our products and services, you provide your consent to us to process information that
may be personal information.
Wherever required under applicable law, we aim to obtain your explicit consent to process this
information, for example, by asking you to agree to our use of cookies.
Sometimes, when permitted under applicable law, you might give your consent implicitly, such as
when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do
not use your information in any way that would identify you personally. We may aggregate it in a
general way and use it to provide class information, for example, to monitor the performance of a
page on our website.
If you have given us explicit consent to do so, we may from time to time pass your name and
contact information to selected associates whom we consider may provide services or products
you would find beneficial, including but not limited to our network of independent service providers
(sub-contractors).
We continue to process your information on this basis until you withdraw your consent or it can
be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us [email protected] However, if you
do so, you may not be able to use our website or our services further.

3. Information we process for the purposes of legitimate interests
This section is not applicable to you if you are located in Canada.
We may process information on the basis there is a legitimate interest, either to you or to us, of
doing so.
Where we process your information on this basis, we do after having considered:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round,
consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our official documents and
customer records
• responding to unsolicited communication from you to which we believe you would expect
a response protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage risk related to
our business
• protecting your interests where we believe we have a duty to do so

4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information to
comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if
they have the proper legal basis or authorization such as a search warrant or court order.
This may include your personal information.

PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT
5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied,
downloaded, or used by other people.
Examples include:
1.1. posting a message to our forum or comment form
1.2. tagging an image
1.3. clicking on an icon next to another visitor’s message to convey your agreement,
disagreement, or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every
person who might use it.
We do not specifically use this information, except to allow it to be displayed or shared.
Once your personal information has been publicly posted online, you should be aware that we
have no control over what any individual, third party may do with it. We accept no responsibility
for their actions at any time.
Depending on the privacy law(s) applicable to our processing of your personal information,
provided your request is reasonable and there is no legal basis for us to retain it, then at our
discretion, we may agree to your request to delete personal information that you have posted.
If applicable, you can make a request by contacting us at [email protected]

6. Complaints regarding content on our website
We attempt to moderate user-generated content, but we are not always able to do so as soon as
that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if the law requires us to do so, we will remove the content while we
investigate.
Free speech is a fundamental right, so we must make a judgment as to whose right will be
obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you
about it.

7. Information relating to your method of payment
Payment information is never taken by us, accessed by us, or transferred to us either through our
website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page hosted by Stripe Payment Solution,
or some other reputable payment service provider. The payment form may be branded to look
like a page on our website, but it is not controlled or hosted by us.

8. Information about your direct debit
When you agree to set up a direct debit arrangement, the information you give to us is passed to
our own bank for processing according to our instructions. We do not keep a copy.
We are registered under the direct debit guarantee scheme. This provides for the customer’s bank
to refund disputed payments without question, pending further investigation. Direct debits can
only be set up for payments to beneficiaries that are approved originators of direct debits. In order
to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved,
they are required to give indemnity guarantees through their banks.

9. Job application and employment
If you send us information in connection with a job application (such as your resume and cover
letter), we may keep it for up to 3 years in case we decide to contact you at a later date. We may
collect your application information indirectly through a third party service provider, and you
hereby consent to our collection of the personal information it contains through such provider.

10. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data
you have given to us in order to reply with the information you need, such as your name, address,
email address, phone number, and any personal information that your communications may
contain.
We record your request and our reply in order to increase the efficiency of our customer service
program. We keep personally identifiable information associated with your messages, such as
your name, email address, and phone number so as to be able to track our communications with
you to provide a high-quality service.

11. Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to
that other person some of the information contained in your complaint. We do this as infrequently
as possible, but it is a matter for our sole discretion as to whether we do give information, and if
we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level
of service we provide, but not in a way that could identify you or any other person.

12. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner,
which includes your name, contact information, including telephone number, business address,
and email address, and specifics of a given sale made to your business.
It allows us to recognize visitors that you have referred to us, and to credit to you commission due
for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.

USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU
VISIT OUR WEBSITE

13. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser
when you visit any website. They allow information gathered on one web page to be stored until
it is needed for use on another, allowing a website to provide you with a personalized experience
and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your
browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent
or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by
software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to activate our use of cookies
and any other technological tool that can be used to geolocalize or identify you, or to conduct
profiling. If you choose not to accept them, we shall not use them for your visit except to record
that you have not consented to their use for any other purpose.
If you choose not to activate cookies or other technologies described above, or you prevent their
use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
13.1. to track how you use our website
13.2. to record whether you have seen specific messages we display on our website
13.3. to keep you signed in our site
13.4. to record your answers to surveys and questionnaires on our site while you complete them
13.5. to record the conversation thread during a live chat with our support team
We provide more information about the cookies we use in our cookie policy, which can be
accessed at the following website address: https://www.fullswinggolf.com/cookie-policy/.

14. Personal identifiers from your browsing activity
Requests by your web browser to our servers for webpages and other content on our website are
recorded.
Subject to your activation of these functions in accordance with the previous section of this policy,
we may record information such as your geographical location, your Internet service provider and
your IP address. We also record information about the software you are using to browse our
website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website
and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could
be used to identify you personally, even if you are not signed in to our website.

15. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order
to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then, if
you have consented to the activation and our use of cookies and other technologies that enable
re-marketing, you may see advertisements for our products and services on other websites.
DISCLOSURE AND SHARING OF YOUR INFORMATION

16. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this
notice), we sometimes receive data that is indirectly made up from your personal information from
third parties whose services we use.

17. Third parties to which we may disclose your personal information
We may disclose your personal information to our third party service providers that are necessary
for us to operate our website, provide you with our online services or operate our business, such
as IT services providers, email distribution service providers, content management service
providers, and professional advisors.
In addition, third parties may advertise on our website. In doing so, those parties, their agents, or
other companies working for them may use technology that automatically collects information
about you when their advertisement is displayed on our website.
They may also use other technology, such as cookies or JavaScript, to personalize the content
of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly,
this privacy notice does not cover the information practices of these third parties.
We may also be required to give information to legal and/or governmental authorities if they so
request or if they have the proper legal basis or authorization, such as a search warrant or court
order.
Furthermore, if our organization undergoes a change in control, acquisition, merger,
reorganization, bankruptcy or asset sale, all personal information owned by us or in our control
may be transferred, sold, shared, or otherwise disclosed to the successor of the transaction.

18. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it
relates to clients or customers who instruct their credit card issuer to cancel payment to us without
having first provided an acceptable reason to us and given us the opportunity to refund their
money.

19. Data may be processed internationally
Our websites are hosted in the United States of America.
We use outsourced services in countries outside the European Union from time to time in other
aspects of our business.
Accordingly, data obtained within the United States of America or any other country could be
processed outside the European Union, Canada, or any other country in which you are located.
For example, some of the software our website uses may have been developed and may be
hosted in the United States of America or in France.

ACCESS TO YOUR OWN INFORMATION
20. Access to your personal information
20.1. At any time you may review or update personal information that we hold about you, by
signing in to your account on our website or by sending us a request at [email address].
20.2. To obtain a copy of any personal information we hold on you, you may send us a request
at [email protected]
20.3. After receiving the request, we will tell you when we expect to provide you with the
information, and whether we require any fee for providing it to you, as permitted under applicable
law.

21. Removal of your information
To the extent provided under applicable law, if you wish us to remove personally identifiable
information from our website, you may contact us at [email protected]
This may limit the service we can provide to you.

22. Verification of your information
When we receive any request to access, edit, or delete personal information we will first take
reasonable steps to verify your identity before granting you access or otherwise taking any action.
This is important to safeguard your personal information.

OTHER MATTERS
23. Use of site by children
23.1. We do not sell products or provide services for purchase by children, nor do we market to
children.
23.2. If you are under 18, you may use our website only with consent from a parent or guardian.

24. Security
We aim at using physical, administrative, organizational, and technical security measures to
protect the confidentiality and integrity of your personal information.
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to
encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by
looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
We have other measures in place to protect personal information, such as access controls to
enforce access to personal data on a need-to-know basis.
However, it is important to understand that we cannot guarantee the security of personal
information on the Internet and that you must also take precautions, such as not sharing your
credentials with anyone. You should keep in mind that no method of transmission over the
Internet, or method of electronic storage, is 100% secure.

25. How you can complain
25.1. If you are not happy with our privacy notice or privacy policy or if have any complaint then
you should tell us by email. Our address is [email protected]
25.2. If you are in any way dissatisfied about how we process your personal information, you have
a right to lodge a complaint to the competent governmental authority, depending on where you
are located. If you are located in the European Union, please visit https://www.eugdpr.org/ to
review information regarding the complaint process.

26. Retention period for personal information
Except as otherwise mentioned in this privacy notice, we keep your personal information only for
as long as required by us:
26.1. to provide you with the services you have requested or to accomplish any other purpose for
which we have collected your personal information, as applicable;
26.2. to comply with other applicable law, including for the period demanded by our tax authorities;
26.3. to support a claim or defense in court.
27. Review of this privacy policy
We may update this privacy notice from time to time as necessary, and we will change the date
of last update accordingly (at the beginning of this policy). The terms that apply to you are those
posted here on our website on the day you use our website. We advise you to print a copy for
your records.
If you have any question regarding our privacy notice, please contact us at [email address].