WORLD GOLF TOUR, INC. PRIVACY POLICY

Thank you for visiting World Golf Tour, Inc. dba WGT Sports' ("WGT") Internet web site and mobile application ("Site") located at the URL https://www.wgt.com/ (or m.wgt.com or www.worldgolftour.com or www.wgtsports.com). This Privacy Policy details certain policies implemented throughout WGT, a company having its principal place of business at 100 California Street, Ste 650, San Francisco, CA 94111, governing WGT's use of personally identifiable information about users of our Site and our services provided via this Site and through your use of WGT's services. If you access WGT services from a third-party social networking web site such as Facebook ("Social Site"), you may be required to also read and accept the Social Site's terms of service and privacy policy.

Summary of Key Points

  • Privacy Policy Updates: Changes to the Privacy Policy will be reflected at the end of this Privacy Policy under the Questions section, or as otherwise required by applicable law. Click here to learn more.

  • Information Collection and Use: We collect your contact information and user profile information (such as your avatar, interests, and other details you provide us) to create your game accounts and allow game play, enable user communications, provide support, deliver targeted advertising, provide in-game leader boards and promote in-game play achievements, as further detailed below. Click here to learn more.

  • Social Site Information Collection and Use: When you use any WGT service at a Social Site, we collect certain profile information about you from the Social Site related to your use of the services, such as your name or username, profile picture, location, gender, and birthday. You should review the Social Site's privacy policy and settings to understand and control the information you share with us. Click here to learn more.

  • Children's Privacy: We do not target or knowingly collect any personally identifiable information from children under the age of 13. Click here to learn more.

  • Aggregate Information: We collect information about Site visitors' interaction with our Site in the aggregate to understand how we can improve our Site and services. Click here to learn more.

  • Cookies: We use cookies and similar technologies to help provide our Site and offer you a more personalized user experience and market products and services to you. Click here to learn more.

  • Disclosure and Opt-In: We share personally identifiable information about you with third parties to perform the purposes for which the information is collected, complete transactions on your behalf, respond to requests, and fulfil other business and compliance purposes. Click here to learn more.

  • Security: We maintain appropriate technical, administrative, and physical security measures designed to protect your information. Click here to learn more.

  • Data Subject Rights: You have certain rights to request access, rectification, deletion, or other actions regarding your personally identifiable information where required by applicable law. Click here to learn more.

  • Cross-Border Data Transfers: We provide appropriate protections for cross-border transfers of your personally identifiable information where specified by law. Click here to learn more.

  • Other Issues: We provide other information in this Privacy Policy about: (i) the legal basis for our collection and processing of personally identifiable information, (ii) the consequences for not providing personally identifiable information, (iii) automated decision-making, (iv) do-not-track ("DNT") signals, (v) data retention, and (vi) links to third-party web sites. Click here to learn more.

  • Questions: If you have questions about this Privacy Policy, please contact us. Click here to learn more.

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, we update this Privacy Policy from time to time. When doing so, WGT will post its updated Privacy Policy on our Site located at https://m.wgt.com/privacy so you are always aware of what personally identifiable information we collect and how we use this information, and ask for your consent to the changes if required by applicable law. WGT encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.

Information Collection and Use

You can generally visit our Site without revealing all of the personally identifiable information about yourself detailed below. However, in certain sections of this Site (whether through a Social Site or directly), we invite you to register to use our services and enter a contest, contact us with questions or comments and request information. Due to the nature of some of these activities, we collect personally identifiable information, including your contact information such as your email address, username, password, player name, zip code, country, age and gender. We use your personally identifiable information to contact you to provide you with the services for which you have registered, enter you in contests for which you have registered, for internal marketing purposes, and to improve our products and services. If you use WGT's "tell a friend" or "send replay" features, we may ask you to submit your friend's email address and we will only use such email address to send the requested information or replay. When you provide us with your friend's email address, we assume that you have been authorized by your friend to do so.

If you are a registered user on our Site or services, we will send you transactional messages about your use of the Site and our services and you will not be able to opt-out of receiving these transactional messages. We also use your personally identifiable information to send you notices about products and services of ours that we think may interest you. At any time, you can request to discontinue receiving these marketing email communications from us about other products and services that we think may be of interest to you by clicking on the opt-out link in the email to "unsubscribe".

When you register with WGT (whether through a Social Site or directly), you create a public profile. The information you place into your public profile, such as your nickname and avatar, profile photo, gender, interests and hobbies, occupation, biographic details that you provide, links to your profiles on various Social Sites, details about the games you play and/or a WGT user ID number, created by WGT and used to identify your profile, are displayed publicly on the Site to enable you to connect with people on WGT. Other WGT users can view the public information associated with your related Social Site account. Your public profile information is used by WGT to help make the functionality of the Site available to you. Your profile information will be available in search results across the Site. This is primarily so your friends can find you and send a friend request through the Site. In some cases (e.g., posting to your wall), other WGT users will be able to supplement your profile. WGT does not disclose your birth date or email address.

When you use WGT (whether through a Social Site or directly), you also disclose your personally identifiable information when you form relationships, send messages, perform searches and queries, form teams, set up events, and otherwise transmit information through various channels. This information is generally retained by us so that you can connect to have the use of the information when you use the functionality of the Site, for instance, you can return to view prior messages you have sent or easily see your friend list.

If you play WGT games on your mobile device, such as smartphones, tablets and iPads, we collect your mobile device identifier, device type and IP address. We also collect other information associated with your device such as telephone number, country and other information that you have chosen to provide, such as user name, character name, geo-location (with your consent) or email address. With your consent, we also access your contacts to enable you to invite friends to join you in using the WGT services and playing a WGT game. Further, with your consent, we send push notifications to your mobile device, including game updates and other relevant messages. You can manage push notifications form the "options" or "settings" pages within the relevant game and/or from your mobile device's "settings" page. To learn more about how to control the collection of your certain information about the devices used to our services, please see the Cookies and Third-Party Advertising section below.

We may use information collected form you in the course of registering for or playing a WGT Game to create your game accounts and allow game play, to enable user communications as described above and to communicate with you about your use of a WGT Game, to provide support, to deliver targeted advertising, to provide in-game leader boards and promote in-game play achievement, to improve our services and to detect and prevent fraud and violations of the WGT Terms and Conditions.

You post User Content (as defined in the WGT Terms & Conditions) on the Site at your own risk. We cannot control the actions of other users, and we are not responsible for circumvention of any privacy settings or security measures contained on the Site. You understand and acknowledge that, even after removal, copies of User Content may remain viewable in cached and archived pages or if other users have copied or stored your User Content.

Social Site Information Collection and Use

When you use any WGT service at a Social Site, where WGT games are also referred to as "applications", you allow WGT to access certain information from your profile for that Social Site. The information you allow WGT to access varies by game and Social Site platform, and it is affected by the privacy settings you establish at the Social Site. You can control and find out more about these settings at the Social Site where you play our games. For example, WGT will access and store some or all of the following information, as allowed by you, the Social Site and your preferences: your first and last name; your profile picture or its URL; your user ID number, which is linked to publically available information such as name and profile photo; the user ID numbers for your friends that are also connected to our game(s); the login email you provided to that Social Site when you registered; your physical location and that of your access devices; your gender; and your birthday.

By playing a WGT game through a Social Site, you understand WGT will collect, store, and use, in accordance with this Privacy Policy, personally identifiable information that you have allowed the Social Site to provide to WGT through the Social Site Application Programming Interface ("API"). Your agreement takes place when you "accept" or "allow" (or similar terms) one of our applications on a Social Site.

To manage the information WGT receives about you from the Social Site where you play our games, you will need to follow the instructions at that Social Site for updating your information and changing your privacy settings.

Once WGT receives your information from a Social Site, that information is stored and used by WGT in accordance with this Privacy Policy, and you may access and update that information as described below.

Children's Privacy

WGT recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. This Site is not intended for children under the age of 13. WGT does not target its services or this Site to children under 13. WGT does not knowingly collect personally identifiable information from children under the age of 13. If WGT has actual knowledge that personally identifiable information about a person under the age of 13 has been collected without appropriate parental consent, then WGT will take the appropriate steps to delete such information.

Aggregate Information

The Site tracks the total number of visitors to our Site, the number of visitors to each page of our Site, pages visited per use, browser type, IP addresses, exit page, duration of use, operating system type, and we will analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We use such aggregate information to analyze trends, administer the Site, track users' movement, and gather broad demographic information for use and disclosure in aggregate form.

Cookies and Third-Party Advertising

We use small text files called cookies and related tracking technologies (collectively, "cookies") to improve overall Site experience. A cookie is a piece of data stored on the user's device or browser containing information about how the user interacts with our Site and services. We use cookies to provide the Site or services, gather information about your usage patterns when you navigate this Site or services in order to enhance your personalized experience, and to understand usage patterns to improve the Site and services. As detailed below, we also allow certain trusted partners to place cookies on our Site and services in order to provide personalized marketing to you.

Advertising

We use third-party advertising companies to place cookies on our Site and services in order serve ads when you visit our Site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this Site and our services and other web sites in order to provide advertisements about goods and services of interest to you. Specifically, advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria-for example, people aged 30-50 from a particular geographic area. WGT does not provide any personally identifiable information to the advertiser when you interact with or view a targeted advertisement.

Your choices

You can review your Internet browser settings, typically under the sections "Help" or "Internet Options" and use our cookie management tool (button below) to exercise choices you have for certain cookies, including for interest based advertising. If you disable or delete certain non-essential cookies, you might not be able to access or use important functions or features of this Site or services, and you may be required to re-enter your log-in details. Please note you may also still receive advertisements from the relevant ad serving company you opted out of, but the ads will not be tailored to your interests. For our mobile app please review your device settings or third-party tools available.

Cookie Settings


Offer walls

WGT games or their purchase pages may display an "offer wall" that is hosted by an offer wall provider. The offer wall allows third-party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These are not offers made by WGT. These offers will be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a web site hosted by WGT or partnering SNS. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your user ID number, will be shared with the offer wall provider. This identifier is used to ensure proper crediting of your account, prevent fraud or duplicate offers and to resolve any customer service inquiries that may arise. Once you complete an offer, you will then return to a WGT web site or game.

Disclosure and Opt-In

We share your personally identifiable information with service providers, such as email marketing service providers, for purposes of providing the Site and services to you, who we require to provide reasonable security for personally identifiable information and to only use your personally identifiable information on our behalf.

If you enter and/or have won a contest offered by us through the Site, we will collect your first and last name, mailing address, shipping address, tax identification number, date of birth, identity verification and, where applicable, your credit card or payment information, if we collect a fee from you. We will use such information to complete prize fulfillment and to comply with any applicable tax regulations and/or any obligations we have in connection with contests or services that we provide jointly with third parties.

If you are a contest winner, we provide your name to other users of our Site if they request a list of winners of a contest. We also disclose your personally identifiable information to our third-party service providers that assist us in providing services to you (such as our third-party co-location provider, contest administrator, or payment processor). These service providers will be obligated to use your personally identifiable information only to provide the services to us.

If you play or participate in our Major League Baseball game, we will share your personally identifiable information with MLB Advanced Media, L.P. MLB Advanced Media, L.P. will use your personally identifiable information in accordance with its then-current Privacy Policy available at mlb.com/privacy.

We offer contests or provide services jointly with third parties on the Site. You can tell when another company is involved in any contest or service provided on the Site, and, unless otherwise specified herein, only if you have expressly agreed to allow us to provide your personally identifiable information to our contest sponsors by clicking on the "Opt-In" button and opting-in, we share your personally identifiable information for their marketing use. If you do not want your information shared, you can choose not to allow the transfer of information to such third-party contest sponsors by not opting-in and not providing any information. Their use of your personally identifiable information will be subject to their privacy policies and terms of use and they may contact you with marketing messages. Notwithstanding the foregoing, if you register to participate in a challenge or tournament on the Site that is a benefit for a charity and you pay an entry fee and/or make a donation to that charity, you acknowledge and agree that we will provide all personally identifiable information you submit during registration to the charity so that they may communicate with you regarding the tax deductibility of any donation you make and generally about the activities of the charity. We will also share, or give permission to any such charity to share, your personally identifiable information with other sponsors of the challenge or tournament for purposes of prize fulfillment. Those communications will be subject to the privacy policy of the relevant charity. Please be aware that we cannot control the activities of third parties to whom we provide your personally identifiable information and as such, WGT cannot guarantee that such third parties adhere to the same privacy and security procedures as WGT.

When legally required or at WGT's discretion, WGT will cooperate with law enforcement agencies in any investigation of suspicious or alleged illegal activity on this Site or on the Internet. Additionally, your information, and the contents of your private online communications, will be accessed and disclosed (i) in response to legal process (for example, a court order, search warrant or subpoena); (ii) when we have a good faith belief that we are required to disclose the information in response to legal process; (iii) in other circumstances in which WGT believes the WGT games or web sites are being used in the commission of a crime (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction); (iv) when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; and (v) when necessary either to protect the rights or property of WGT including to enforce our Terms of Service, or for us to render the service you have requested.

We will not sell your personally identifiable information to any company or organization except we will transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which WGT participates or to a purchaser of all or substantially all of WGT's assets to which this Site relates.

Security

We employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. WGT will use password protection, encryption and other security measures to help prevent unauthorized access to your personally identifiable information. However, no security measure can guarantee against compromise. You also have an important role in protecting personally identifiable information. You should not share your usernames/email addresses and passwords with anyone, and you should not re-use passwords across more than one web site. If you have any reason to believe that your username/email or password have been compromised, please contact us as detailed below.

Data Subject Rights

Where required by applicable law, you have the right to obtain confirmation of the existence of certain personally identifiable information relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, obtain a copy, port, delete, or to block or withdraw consent to the processing of certain personally identifiable information (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below. Additionally, you have the right to object to our use of personally identifiable information for direct marketing and certain cookies at any time. Contact us below for more details. Please note that we need to retain certain personally identifiable information as required or permitted by applicable law.

Cross-Border Data Transfers

Our computer systems are currently based in the United States, so your personally identifiable information will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create a user account with the Site or otherwise provide us with personally identifiable information, as a visitor from outside the United States, where permitted by applicable law, by using the Site you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in other countries. We take steps to securely maintain personally identifiable information transferred to the US.

Other Issues

What is the legal basis of processing?

Some jurisdictions require an explanation of the legal basis for the collection and processing of personally identifiable information. We have several different legal grounds on which we collect and process personally identifiable information, including: (a) as necessary to perform a transaction (such as when we respond to your requests); (b) as necessary to comply with a legal obligation (such as when we use personally identifiable information for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally). With respect to legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personally identifiable information, such legitimate interests are the fulfilment of the processing purposes described in this Privacy Policy that are not necessary for the performance of a contract or for our compliance with a legal obligation to which we are subject.

What are the consequences of not providing personally identifiable information?

You are not required to provide all personally identifiable information identified in this Privacy Policy to use the Site or services, but certain functionality will not be available if you do not provide personally identifiable information. If you do not provide personally identifiable information, we may not be able to enter you into contests, respond to your requests, or provide you with marketing that we believe you would find valuable.

Do we engage in automated decision-making without human intervention?

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Does the Site honor do not track ("DNT") signals sent via browsers?

Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.

How long do we retain personally identifiable information?

We typically retain personally identifiable information related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For personally identifiable information that we collect and process for other purposes, we typically retain such personally identifiable information for no longer than for the period necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

Questions

If you have any questions regarding this Privacy Policy please contact us via email at: members@worldgolftour.com. You may also have a right to lodge a complaint with a supervisory authority.

This Privacy Policy was last updated: May 24, 2018

This Privacy Policy is effective as of: May 25, 2018

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