About our Privacy Policy

This document outlines the online privacy policy of Sugarloaf Golf, LLC (“Sugarloaf”), a Pro Shop Holdings, Inc. company, which governs the personal information gathered on the www.sugarloafsocialclub.com website, as well as its affiliated websites, social media profiles, any mobile applications, and other digital platforms (collectively, the “Site”). This Privacy Policy informs you about the kinds of information we may collect, how that information is used, with whom we share it, and how you can opt-out of a use or correct or change such information. In this Privacy Policy, any reference to “us”, “we”, or ourselves is a reference to Sugarloaf and its affiliates. In general, we process personal information for the purposes of running our business; complying with applicable laws; and protecting the Site, our business, and those who use the Site and/or transact business with us. We also process personal information as necessary to perform the services you request, such as sending you a newsletter or processing a purchase. Finally, some processing of your personal information may be subject to your consent (e.g. if you enter a sweepstakes). If you have any questions about our privacy policies, please contact us at privacy@proshop.inc. By providing your personal information to Sugarloaf, you signify your acceptance of the Site Terms of Use and agree that Sugarloaf may collect, use, and disclose your personal information as described in this Privacy Policy.

Scope

This Privacy Policy applies to everyone who interacts with us on our Site, customers who purchase any materials, newsletters or other communications from us, anyone who enters any promotions or competitions we may offer, anyone who interacts on social media with us and other online or offline offerings (together with any and all future online and offline offerings, the “Services”). Because this Privacy Policy covers a range of individuals and different types of relationships and interactions with us, not all aspects of this Privacy Policy will apply to you.

How We Use Your Information

By providing personally identifiable information to us, we are able to perform a number of business functions, such as providing products, services, or information you requested. Transactional Purposes. Sugarloaf will process personal information to fulfill requests for products, Services or information, including to: a. Respond to questions, comments, and other requests; b. Provide access to certain features of the Services; c. Personalize product recommendations; d. Communicate with you about logistical matters, including product deliveries and shipping; e. Conduct internal research and development; f. Review and respond to requests for customer support; and, g. Allow you to register for online profiles. Administrative Purposes. Sugarloaf will process personal information for administrative purposes, including to: a. Measure interest in our products and Services; b. Develop new products and Services; c. Ensure quality control; d. Send emails or text messages to the email address or telephone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, delivery updates, or system maintenance; e. Process payment(s) for products or services purchased; f. Process applications and transactions; g. Prevent potentially prohibited or illegal activities; h. Maintain and administer our Services; and, i. Enforce our Terms of Service Marketing. Sugarloaf will process personal information to provide you with marketing materials that may be of interest, including: a. To notify you about offers, products and Services that may be of interest or about which you have previously expressed an interest; b. For other purposes disclosed at the time that you provide personal information; c. Otherwise with your consent. You may contact us at any time to opt- out of the use of your personal information for marketing purposes. Research and Development. Sugarloaf will process personal information alone or in the aggregate with information obtained from other sources, in order to help us improve our existing products and Services or develop new products and Services. Anonymous and Aggregated Information. Sugarloaf uses personal information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, information about the computer or device from which you access the Services or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not personal information, and is thus not subject to this Privacy Policy. Shared Content. From time to time, we may offer referral services of features that allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services or purchase product from us. Other. Sugarloaf will process personal information for which we have a legitimate interest, such as fraud protection or compliance with legal obligations, or any other purpose disclosed to you at the time you provide personal information or with your consent.

Cookies, Pixels, and Similar Technologies

We (along with third parties that provide content, advertising or other functionality on our Services), may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services. Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and to recognize you across devices. You can find more information about the individual cookies we use on our Site and the purposes for which we use them in our Cookie Policy.

How We Share Your Information

We share information collected through the Services with the following categories of parties: a. Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust personal information include service providers for: (i) order fulfillment and warehousing; (ii) web hosting, analytics and related services; (iii) payment processing, fraud protection, and credit risk reduction; (iv) customer service activities such as inquiries and shipping; and (v) in connection with the provision of the Services. Sugarloaf’s policy is to execute appropriate contracts with service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements, and this Privacy Policy. b. Business Partners and Affiliates. We may share personal information with our business partners and affiliates (including, for clarity, other businesses that are part of the Pro Shop group) for our and their internal business purposes or to provide you with a product or service that you have requested or to suggest, market, promote or offer a product or service that you may be interested in based on data that we have collected, among other things. c. Marketing. Sugarloaf may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities on our Services (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected personal information (such as demographic information and past purchase history) we have collected with third party advertising partners. Advertising partners may use this information (and similar information collected from other companies) for purposes of delivering targeted advertisements to you when you visit non-Sugarloaf related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Service to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. d. Professional Advisors: We share personal data with our legal, financial, insurance and other advisors in connection with corporate transactions or in connection with the management of all or part of our business or operations. e. Legal Disclosure / Law Enforcement. We may access, preserve and disclose your personal information, other account information and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as, a court order or subpoena; (ii) to respond to your requests; (iii) to protect yours, ours or others’ rights, property or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) to comply with records retention policies; (vii) when we believe access, preservation, or disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (viii) if we, in good faith, believe that access, preservation, or disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order to allow them to identify users in connection with their investigation of unauthorized activities. f. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Sugarloaf will endeavor to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.

Managing Your personal information / Changing Marketing Preferences

We want to communicate with you only if you want to hear from us. You have the right to object to and opt-out of certain uses and disclosures of your personal information. Where you have consented to our processing of your personal information, you may withdraw that consent at any time and opt-out to further processing by contacting privacy@proshop.inc. Please note that even if you opt-out, we may still collect and use non-personal information regarding your activities on our Service and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as, to determine the effectiveness of the advertisements. a. Email. You can unsubscribe from email, text and phone communications at any time. If you would like to opt-out of receiving marketing via email, click the unsubscribe link on the footer of marketing emails. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Sugarloaf may continue to send you non promotional, service emails concerning your account, such as emails relating to purchases, billing and payment information, outstanding balance on your account, and other emails relating to your account and/or your use of the Site. b. Account. You may review, update, or modify your account information at any time by logging into your Sugarloaf account. You may also deactivate or delete your Sugarloaf account by emailing privacy@proshop.inc. c. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not override these settings or options. However, in order to access certain content, features, services, products, or benefits of the Services, you may be required to provide us with certain information, including some types of personally identifying information. If you do not wish to provide such information through the Service or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products, or benefits of the Site. d. Cookies and Similar Technologies. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs may not be effective on mobile interfaces. However, on many mobile devices, application users may opt-out of certain mobile advertisements via their device settings. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu/ or www.youradchoices.ca/, and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics https://tools.google.com/dlpage/gaoptout. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on third party websites that contain the AdChoices link, and that link to this Privacy Policy, may have been directed to you based on anonymous nonpersonal information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes. e. Rights of Access, Rectification, Erasure, and Restriction. Where permitted by applicable law, you may inquire as to whether Sugarloaf is processing personal information about you, request access to personal information, and ask that we correct, amend or delete your personal information where it is inaccurate or has been processed in violation of your rights under data privacy laws that apply in the country or state where you live. Where otherwise permitted by applicable law, you may send an email to privacy@proshop.inc or use any of the methods set out in this Privacy Policy to request access to, receive, seek rectification, or request erasure of personal information held about you by Sugarloaf. Please include your full name, email address associated with your account and a detailed description of your data request. Such requests will be processed in accordance with local laws. Although Sugarloaf will use good faith efforts to provide Individuals with access to their personal information, there may be circumstances in which we are unable to provide access, including but not limited to where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy, in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

Security & Retention

The security of your personally identifiable information is important to us and we are committed to handling such information carefully. We maintain physical, electronic and procedural safeguards to guard your personally identifiable information. We use secure socket layer technology to protect the security of your payment information and we encrypt your personally identifiable information when it is sent over the Internet. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you. You may have a legal right to receive this notice in writing. We retain personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. When we are no longer required to retain your personal information as described above, we will destroy, erase, or de-identify it in accordance with our data retention policies and applicable law. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold it.

Children’s Privacy

Our Services are not directed to children under the age of 16. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect personal information from children under the age of 16. If you learn that your child has provided us with personal information without your consent, you may alert us at privacy@proshop.inc. If we learn that we have collected personal information of a child under the age of 16, we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.

California Residents

California law requires us to disclose certain information related to our privacy practices, as set forth below. A. WHAT PERSONAL INFORMATION WE COLLECT The list below identifies the categories of personal information we have collected over the preceding 12-month period, as well as examples in each category. For more information about the personal information we collect, please see Section 2. Identifiers Name, email address, billing address, shipping address, phone number Commercial information Purchase history Geolocation data Internet protocol (IP) address, billing address, shipping address, Internet or other electronic network activity information IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences Financial, medical, or health information Payment information, such as credit card number Audio, electronic, visual, thermal, olfactory, or similar information Recordings of customer support calls Inferences drawn from any of the above information categories Inferences about the type of products you prefer; demographic and psychographic inferences The sources of the personal information we collect above include personal information that you directly provide to us (through the Services), personal information we receive from third party partners (for example, certain marketing, research or survey partners), and personal information that we generate internally. Please see Section 2 for additional details. B. HOW WE USE PERSONAL INFORMATION Please see Section 3 of the Privacy Policy. C. WHAT PERSONAL INFORMATION WE SHARE Please see Section 5 of the Privacy Policy for information on the personal information we share with third parties. In the last 12 months, we have disclosed all of the categories of personal information described in Section 2 for business purposes. For example, we may share your IP address with service providers that provide crash monitoring and site optimization services to us. California residents have the right to opt out of our disclosures of personal information that we have disclosed to third parties for valuable consideration. What is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information as we understand it. D. YOUR RIGHTS As a resident of California, you have certain rights, such as: a. Right to access personal information. You may be entitled to receive the specific pieces of your personal information we have collected in the 12 months preceding your request. b. Right to data portability. You may be entitled to receive a copy of your electronic personal information in a readily usable format. c. Right to know. You may be entitled to receive information regarding the categories of personal information we collected, the sources from which we collected personal information, the purposes for which we collected and shared personal information, the categories of personal information that we sold and the categories of third parties to whom the personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your request. d. Right to deletion. You may be entitled to request that we delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep such information, such as for our legitimate business purposes or as required to comply with applicable law. e. Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your personal information to third parties for monetary or other valuable consideration. As noted above, we do use trusted partners for interest based advertising. If you wish to opt out of our sharing of your personal information for such interest based advertising, you may do so by following the instructions in the “Cookies and Similar Technologies” discussion in section 6 above. You may freely exercise these rights without fear of being denied goods or services. If you are a California resident and would like to exercise one of your rights, please contact us at privacy@proshop.inc. Please note that California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We (or third parties we engage to assist us) may ask you to provide certain information to us in order for us to verify the request. In addition to these rights, pursuant to California’s “Shine the Light” law, California residents who share personal information with us have the right to request and obtain from us once per year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you would like to exercise this right, please contact us at privacy@proshop.inc.

Additional Topics

A. Payment Processors. When you make purchases through the Services, we process your payments via a third-party payment processor. In these instances, the third party application may collect certain financial information from you to process a payment on behalf of Sugarloaf, including your name, email address, address and other billing information, in which case the use and storage of your financial information is governed by the third party terms, conditions and privacy policies. If you apply for or otherwise take part in a financing offer through one of our financing partners, you will be asked to provide information to that financing partner, either directly or through the Services. The use of that information by the financing partner will be subject to the financing partner’s terms, conditions and privacy policies. Our treatment of any financial information that we may process on your behalf, or that we receive from our financing partners or payment processors, is subject to this Privacy Policy. For more information on our use of third party payment processors and financing partners, including the name(s) of the entities that we partner with, please email privacy@proshop.inc. B. International Data Transfers. You agree that all personal information collected via the Site may be transferred, processed and stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or on the servers of our service providers. By providing information to Sugarloaf, you explicitly consent to the storage of your personal information in these locations. C. Third-Party Sites and Services. The Service may contain links to other websites and other websites may reference or link to the Sugarloaf Site or other Services. These other domains and websites are not controlled by us, and we does not endorse or make any representations about third party websites or social media platforms. We encourage you to read the privacy policies of each and every website and application with which you interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. We do not control the use of cookies or the collection of information by these third parties, nor how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these third parties.

Updating this Privacy Policy

This We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time. You should check this page periodically for changes. Your continued use of this Site following the posting of changes to this Privacy Policy will be considered your consent to those changes. In the event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. Questions or Concerns If you have any feedback, questions, or concerns regarding privacy, please send us a detailed message to privacy@proshop.inc; we will make every effort to resolve your concerns. If you are a resident of a country that is not the United States, you may have the right to take any complaints or concerns you have about our compliance with this privacy policy to the appropriate supervisory authority which has jurisdiction over privacy rights in your country.