PRIVACY POLICY
Parsons Xtreme Golf - Privacy Notice
Last updated and Effective Date: August 2nd, 2022



Parsons Xtreme Golf, LLC, and our Affiliates ("PXG", "we", "us", or "our") is committed to maintaining your confidence and trust as it relates to the privacy of your information. Please read below and learn how we collect, use and share your information.


1. INFORMATION WE COLLECT

2. HOW WE USE YOUR PERSONAL INFORMATION

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

4. OUR PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION

5. THIRD-PARTY LINKS

6. CHILDREN

7. CROSS-BORDER TRANSFERS

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

9. YOUR RIGHTS AND CHOICES

10. SAFEGUARDING YOUR PERSONAL INFORMATION

11. CHANGES TO THIS PRIVACY NOTICE

12. QUERIES OR COMPLAINTS

13. OUR CONTACT DETAILS

14. GDPR EUROPEAN REPRESENTATIVE




1. THE INFORMATION WE COLLECT

Information You Provide To Us: We, or our service providers (acting on our behalf), may collect "Personal Information" (which is information that, on its own or when combined with other information, can be used to identify you) that you provide to us either in the capacity of a business owner or employee ("Business Customer") or as an individual customer of PXG ("Individual Customer").For example, the Personal Information we collect in the course of providing the Services to you depends on how you engage with our Services:


Ordering through PXG.com ("Website Order")

  • identifiers like contact details (first and last name; email address; telephone number(s); and postal address);
  • commercial information, like measurements taken by you (if ordering direct through our e-commerce site); and
  • any Personal Information you include in correspondence with us about the Services.

Ordering through PXG Fitters ("Fitter Order")

  • identifiers like contact details (first and last name; email address; telephone number(s); and postal address);
  • correspondence directly with PXG Fitter(s);
  • commercial information, like club fitting measurements taken by PXG Fitter(s) to provide you with the Services; and
  • any Personal Information you include in correspondence with us about the Services.

Ordering on-site at a Golf Club ("Club Order")

  • identifiers like contact details (first and last name; email address; telephone number(s); and postal address);
  • commercial information, like:
    • club fitting measurements taken by a Golf Club employee or contractor;
    • membership details of the Golf Club; and
  • any Personal Information you include in correspondence with us about the Services.

Applying for credit from PXG as a Business Customer ("Credit Application")
When you make a Credit Application, we may receive and use international business data ("IBD") about your company. In some cases, IBD may include commercial information that is personal information about you, such as:

  • financial information about you, including information about your mortgage(s), credit card(s), overdraft(s), loan(s) or other;
  • your previous business address(es);
  • your credit history; and
  • any other results of the credit report that has been compiled about your company by the credit reference agency.

Applying for a job (“Job Application”)

  • identifiers like contact details (first and last name; email address; telephone number(s); and postal address)
  • demographic information such as your age
  • professional or employment related information

Entering into an employment relationship (“Employees”)

  • identifiers like contact details (first and last name; email address; telephone number(s); and postal address);
  • demographic information such as your age
  • professional or employment related information
  • government issued identification (Social Security Number, driver’s license number, or state issued identification number)

Information Collected Automatically: Whenever you visit or interact with the Site, we, as well as our third-party service providers, may use a variety of technologies that automatically or passively collect information about how you access and use the Site. This may include internet or other electronic network activity information such as:

  • Your IP address or other unique identifier for the computer, mobile phone, tablet or other device you use to access the Site;
  • Your device type;
  • Your location;
  • The type of browser software and operating system you are using; and
  • The web page(s) you have accessed, and the time you accessed them.

Collecting this information enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. We use this information for our internal analytics purposes, to improve the quality and relevance of our Site to our visitors, and for advertising purposes.

Cookies: In our Site and emails, we and third parties may collect certain information by automated means such as cookies, web beacons, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, other device information, Internet connection information, as well as details about your interactions with our Sites and emails (for example, the URL of the third-party website from which you came, the pages on our Site that you visit, and the links you click on in our websites).
We and third parties may use these automated means to read or write information on your devices, such as in various types of cookies and other browser-based or plugin-based local storage (such as HTML5 storage or Flash-based storage), or to collect pieces of information that together may uniquely identify your device.
Cookies and local storage are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from your devices for the purposes described in this Privacy Notice, such as to recognize the devices, to improve your use of our website and services, for cybersecurity, to prevent fraud, to provide services, and for record-keeping, analytics, and marketing, depending on the context of collection.
These technologies help us:

  • Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
  • Remember your settings on the pages you visit so that we can display your preferred content the next time you visit.
  • Display personalized content.
  • Perform analytics, measure traffic and usage trends, and better understand the demographics of our users.
  • Diagnose and fix technology problems.
  • Plan for and enhance our business.

Also, in some cases, we assist with the collection of information by advertising services provided by third parties. The ad services may track your online activities over time by collecting information through automated means such as cookies, and they may use this information to show you ads that are tailored to your individual interests or characteristics and/or based on your prior visits to certain sites or apps, or other information we or they know, infer, or have collected from the users like you.
For example, we and these services may use different types of cookies, other automated technology, and data to:

  • Recognize users and their devices.
  • Inform, optimize, and serve ads.
  • Report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).

You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page from each browser. Google also allows you to install a Google Analytics Opt-out Browser Add-on for each browser.
Additional choice mechanisms for some of our partners are described at the links below:

In addition, you may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. Some browsers offer similar settings for HTML5 local storage, and Flash storage can be managed as described here. However, if you block or otherwise reject our cookies, local storage, JavaScript or other technologies, certain websites (including some of our own websites) may not function properly.
If you replace, change, or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.
Please visit your mobile device manufacturer's website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system.

Information from Third Parties: From time to time, we may receive Personal Information about you from third party sources.


For example, we partner with shipping companies such as FedEx. These are third-party service providers we use to deliver products to you, and as such we may collect information from them about your order so that we can ensure our products are delivered effectively, accurately and safely. We also receive personal information from our corporate affiliates including, among others, PXG UK Ltd., PXG Fitters, Golf Clubs (our “Affiliates”) and from our customers (such as when a customer provides us with the contact details of its employee responsible for purchasing, or when a customer makes a referral).

2. HOW WE USE YOUR PERSONAL INFORMATION
We use the Personal Information we collect about and from you:

  • To build and deliver your PXG products and provide you with the Services;
  • To enable us to run the Site. For example, we may use your Personal information: to complete and fulfil any purchases or requests for products or Services; to respond to your questions and requests; to communicate with you about changes to any PXG policy or notice; and to improve the Site and keep it secure;
  • To carry out promotional activities, including email marketing, social media campaigns and prize promotions, to help develop our business.
  • If you have made a Credit Application, to run a credit check on your company for the purposes of determining whether to extend credit your company;
  • To personalize your PXG experience, including: to tailor content, advertisements, and offers we serve you; and for market research and statistical analysis;
  • To comply with our legal obligations, to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
  • To help us to administer the Site and fix problems;
  • For internal analytics, research, and reports regarding use of our Services; and
  • To verify your identity and for fraud detection and prevention.

We may aggregate and/or de-identify information collected through the Services. We may use or disclose aggregated or de-identified data for any purpose. To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.


3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may share your Personal Information with the third parties set out below in the following circumstances:

  • Group companies and third-party service providers: We instruct our Affiliates, other companies and individuals to perform activities on our behalf. Examples may include sharing details with professionals who may assist in taking your measurements so that we can deliver the Services, sending email, analyzing data, data storage, providing marketing assistance, compiling credit reports and providing customer service.
  • Business Partners: We may share your Personal Information with our business partners, including Golf Clubs, where this is necessary to provide you with the products or Services you have requested.
  • Business Transfers: We may disclose your information in the event that we undergo organizational restructuring (e.g., establish a subsidiary or merge with another entity). In such transactions (including in contemplation of such transactions, e.g., due diligence) your Personal Information may be disclosed. If any of our assets are sold or transferred to a third party, or otherwise involved in such a transaction, your Personal Information would likely be one of the transferred business assets.
  • Competent law enforcement bodies, regulatory, government agencies, court or other third party: We may transfer and disclose your Personal Information to third parties to comply with a legal obligation and legal process, to enforce this Privacy Policy, our Terms of Use or other applicable policies or agreement, to investigate potential violations, possible fraud, or to help investigate or fix any security or technical issues relating to the Site, or to respond to an emergency; or otherwise to protect the rights, property, safety and security of PXG, third parties, visitors to our Site, or the public, consistent with applicable law.
  • Consent: We may disclose your Personal Information to any third parties based on your consent to do so.

Some jurisdictions require that organizations state whether the following categories of personal information are collected, or disclosed to third parties. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Note that we do not sell personal information in exchange for money or other valuable consideration, although we do share personal information in some contexts with third parties for the purpose of targeted advertising.

Categories of Personal Information We Collect

To Whom We Disclose Personal Information for a Business Purpose

To Whom We Share for Targeted Advertising

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

· Affiliates or subsidiaries

· Business partners

· Data analytics providers

· Government entities, as may be needed to comply with law or prevent illegal activity

· Internet service providers

· Other Service Providers

· Professional services organizations, this may include auditors and law firms

· Advertising networks

Characteristics of protected classifications – this may include age.

· Affiliates or subsidiaries

· Government entities, as may be needed to comply with law or prevent illegal activity

· Professional services organizations, this may include auditors and law firms

· Other Service Providers

We do not this information for targeted advertising purposes.

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Affiliates or subsidiaries

· Government entities, as may be needed to comply with law or prevent illegal activity

· Professional services organizations, this may include auditors and law firms

· Other Service Providers

· Advertising networks

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

· Affiliates or subsidiaries

· Government entities, as may be needed to comply with law or prevent illegal activity

· Professional services organizations, this may include auditors and law firms

· Other Service Providers

· Advertising networks

Audio, electronic, visual, thermal, olfactory, or similar information. Among this group we collect electronic information when provided.

· Affiliates or subsidiaries

· Government entities, as may be needed to comply with law or prevent illegal activity

· Professional services organizations, this may include auditors and law firms

· Other Service Providers

We do not share this information for targeted advertising purposes.

Inferences drawn from any of the information listed above

· Affiliates or subsidiaries

· Government entities, as may be needed to comply with law or prevent illegal activity

· Professional services organizations, this may include auditors and law firms

· Other Service Providers

We do not share this information for targeted advertising purposes.

In some jurisdictions we are required to disclose categories of sensitive personal information (as defined under those laws) that we collect:

Categories of Sensitive Personal Information We Collect

Purposes for which it is collected

Is information sold or shared for the purpose of cross-context behavioral advertising

Social security, driver’s license, state identification card, or passport number.

· Required by law from employees

· Eligibility for employment

· Business travel

No

Racial or ethnic origin, religious or philosophical beliefs, or union membership.

· We collect demographic information in order to meet our labor and employment related legal obligations

No

Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication

· We monitor the work-related email accounts of our employees.

No

Health

· We collect health information to meet our obligations to our employees.

No


4. OUR PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION

The follow provides examples of the type of information that we collect and our purpose for processing that information.

Type of data

How we use your information

Basis for processing

Contact details, measurements, correspondence (if any), payment details

To build and deliver your PXG products and provide you with the Services

Performance of a contract

Contact details, correspondence

To respond to your questions and requests

It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business

Contact details, measurements, correspondence (if any), payment details

To complete and fulfil any purchases or requests for products or Services

Performance of a contract

Contact details

To send you promotional materials and other materials that may be of interest to you, including information about us, our products and services, events or general promotions

Consent


Please note that you can unsubscribe or opt-out from receiving these communications at any time by clicking the “unsubscribe” link in the email

Contact details, social media details (if applicable)

To carry out competitions and prize promotions

Performance of a contract

Contact details

To communicate with you about changes to any PXG policy or notice

It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you

Contact details, technical and usage data

To improve the Site and keep it secure

It is in our legitimate interests to continually monitor and improve our services and your experience of the Site and to ensure network security

Technical and usage data

To personalize your PXG experience, including: to tailor content, advertisements, and offers we serve you; and for market research and statistical analysis

Consent

Location data

To direct you to your closest PXG location.

Consent (if using geo-location data). Otherwise, such processing is in our legitimate interests to help our customers find our retailers.

Contact details, correspondence, technical and usage data

To comply with our legal obligations, to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others

Compliance with a legal obligation or legitimate interests to protect our business and enforce our terms

Technical and usage data, correspondence

To help us to administer the Site and fix problems

Compliance with a legal obligation or legitimate interests to ensure our Site is functioning for our customers

Technical and usage data

To analyze trends, and to track your web page movements in order to keep the Site fresh and interesting for you

Consent

Note that in some countries our legitimate interest may arise by obtaining your express or implied consent.

5. THIRD-PARTY LINKS
The Site may contain links to other sites and applications that we are not responsible for such as Facebook, Instagram, and Twitter. We do not control, recommend or endorse these other sites. These other sites may also collect Personal Information about you, and they may have their own privacy policies. We recommend that you review the privacy policy of any site that you access through our Site.

6. CHILDREN
This Site is a general audience website and is not designed for or directed at children. As such, we do not knowingly process Personal Information from or about children under 16 years of age. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will take reasonable steps to delete such information from our records. We will also delete Personal Information from a child under the age of 16 upon request of the child or the child’s legal guardian.

7. CROSS-BORDER TRANSFERS
We are a global company with headquarters in the United States, and the Affiliates and third parties with whom we share the personal data as described in this Privacy Policy are located in the United States and elsewhere in the world, including countries where privacy laws may not provide as much protection as your country. PXG complies with legal requirements for protecting the movement of data across borders, including where appropriate through the use of European Commission and United Kingdom approved Standard Contractual Clauses. For more information about the mechanisms that PXG uses to transfer specific data across borders, or to obtain a copy of our standard contractual clauses, please contact us.

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will hold your Personal Information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Where we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

9. YOUR RIGHTS AND CHOICES
In some jurisdictions you may have a right to:

  • Obtain a copy of your personal information held in our possession (or explanation of the categories of personal information that we collect and disclose), and in some cases to receive it in a structured commonly used and machine readable format, or have it transmitted to a third party in such form.
  • Update, correct or delete your information
  • Opt-out of the processing of your personal information for direct marketing purposes
  • Obtain confirmation of whether we hold your personal information and how we are processing it;
  • Object to the processing of your information;
  • Withdraw consent previously provided for the processing of the information. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Please note that not all of the above rights are absolute and we may refuse to comply with your request where exceptions apply under applicable law.

If you make any of the above requests, we may require that you provide us with information to confirm your identity before addressing your request. At a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, that may include verifying your name, email address, and other details.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests, or provide them with a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.” If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority. Note that we do not discriminate against individuals that exercise statutorily conferred data privacy rights.

 

10. SAFEGUARDING YOUR PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

11. CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

12. QUERIES OR COMPLAINTS
If you have any questions or concerns about this Privacy Notice, this Site, or about our use of your Personal Information, please contact us using the contact details set out below.

13. OUR CONTACT DETAILS
If you wish to contact us, you may do so using the following contact details:

Email: privacy@pxg.com.
Phone: 1.833.479.0175
Webform: SUBMIT A PRIVACY INFORMATION REQUEST

Address: PXG
Attn: Privacy Manager

15690 N 83rd Way

Scottsdale, Arizona 85260


14. GDPR EUROPEAN REPRESENTATIVE

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), PXG UK Limited has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

EDPO’s Webform: https://edpo.com/gdpr-data-request/

EDPO’s Address: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Parsons Xtreme Golf, LLC, whose contact information is above, is a data controller of:

  • Personal Information collected on pxg.com (such as in a Website Order);
  • Personal Information collected on Fitter Orders and Club Orders placed within the U.S.;
  • Personal Information collected through Fitter Orders and Club Orders placed within the UK (and in this case, PXG UK Limited, located at CO/Fieldfisher Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R3TT, is also a controller of the data);
  • Personal Information collected through Fitter Orders and Club Orders placed within Canada (and in this case, PXG Canada Limited, located at Suite 2300, Bentall 5, 550 Burrard Street, Vancouver, BC V6C 2B5K, is also a controller of the data);
  • Personal Information collected through Fitter Orders and Club Orders placed within Japan (In this case, PXG Japan GK, located at 9F Nakano Sunplaza, 1-1 Nakano 4-chome, Nakano-ku, Tokyo, Japan is also a controller and joint user of the data. The shared information includes all of the types of Personal Information described in this Privacy Policy, and it is shared between this Japanese entity and Parsons Xtreme Golf, LLC for all of the purposes described in this Privacy Policy. Parsons Xtreme Golf, LLC is responsible for the two companies’ joint use of personal information.)
  • Personally identifiable IBD collected in connection with a Credit Application made as part of a negotiation to become a business partner of any PXG entity.

If you place an order from outside the U.S., UK or Canada, the data controller will be the third-party distributor or retailer with whom you place the order.