ANDREW GOLF PRIVACY POLICY

Last Revised on December 20, 2023

This Privacy Policy for Lothian Road WRX, Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s website (www.andrew.golf), the Andrew Golf app (“App”), services, tools and features (collectively, the “Services”).  For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.  

Please read this Privacy Policy carefully.  By using, accessing, or downloading any of the services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.  If you do not agree to this Privacy Policy, you may not use, access, or download any of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law.  If you do not agree to any updates to this Privacy Policy please do not access or continue to use the services.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources. 

Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

  1. Account and Registration. Users may access our App only if they register an Account with us. The personal information we collect as part of the Account creation process includes your first and last name, email, username, password, information to confirm you are old enough to use the Services and use the App, payment information for any in-app purchases or storage of funds in your Andrew Wallet (for example, your name and email associated with your payment account). We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.
  1. Prizes and Payments. We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prizes, which may include your email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.
  1. Feedback. We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), resumes provided, or other similar activities. This information may be used to enhance the Services or the App, to market to you or others, and to allow us to make appropriate hiring decisions if submitted for that purpose.
  1. Usage Data. We automatically collect information about your use of our Services and the App through cookies, local storage, analytics tools and other technologies, (“Tracking Technologies”) such as your device ID, location information, device name and model, operating system type, name and version, the length of time that you are using our Services and your activities within our Services ("Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.
  1. Interactions and Activities. We collect information about your activities in the App, such as Contests and wager activity, side bets activity, community interactions and time spent in the App and other factors. We may collect your geolocation information for purposes of using the App, and for our own due diligence and verification purposes. 

We may use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services.

We may obtain information about you from outside sources. Such information may include:

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 5 below for more information.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, improve and develop the Services and our product offerings, including as we describe in our Terms of Service, to enforce any applicable terms of service, to protect or defend the Services, our rights, and the rights of our users or others, and for the purpose of combatting fraud, or to otherwise operate our business. This Privacy Policy is integrated into and is expressly a part of the Terms of Service, to be interpreted in conjunction with such Terms. Any capitalized term not defined herein, shall have the meaning ascribed to it in the Terms of Service. 

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include: 

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, the Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly or not function at all. 

5. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or other online platforms operated by third parties. If you follow links to sites or interact with features (e.g., applications offered by third parties or social media widgets) not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions.  We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. 

6. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

7. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. 

8. European and California Users. 

  1. If you are a citizen of the European Union (“EU”) or the state of California, you may have some or all of the following rights with respect to our processing of your personal data:
  1. Updating Your Information. If you would like to update personal information that you have provided to us, you can do so by accessing your Account and editing your profile.
  2. Marketing Communications. You can opt-out of receiving marketing communications from us by clicking “unsubscribe” in any marketing email communications we send you, or by sending an email to info@andrew.golf. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.
  3. Additional Rights for the EEA and Certain Other Territories.If you reside in certain territories (such as the European Economic Area), you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with the GDPR. We may need to retain certain information for record-keeping purposes, legal purposes, and/or to complete transactions that you began prior to requesting any deletion. You can contact our Data Privacy and Protection office by sending an email to privacy@andrew.golf.
  4. Right Not to Provide Consent or to Withdraw Consent. We may seek to rely on your consent in order to process certain personal information and to render the Services. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect any actions based on consent before its withdrawal.
  5. Right of Access. You may have the right to access the personal information that we hold about you.
  6. Right of Erasure. In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
  7. Right to Object to Processing. You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.
  8. Right to Correct. You may have the right to require us to correct any inaccurate or incomplete personal information.
  9. Right to Restrict Processing. You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
  10. Exercise of Rights. If you would like to exercise any of the above rights, please contact privacy@andrew.golf so that we may consider your request under applicable law. To protect your privacy and security, we may take steps to verify your identity before complying with the request. You also have the right to lodge a complaint to your local data protection authority at: https://edpb.europa.eu/about-edpb/board/members_en

9. YOUR CHOICES

We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.

10. YOUR RIGHTS UNDER THE GDPR. 

In addition to the other disclosures in this Policy, we make the following express disclosures in accordance with the GDPR and hereby notify you of your rights: 

Right to Access: The right to be provided with a copy of your personal information (the right of access)

Right to Rectification: The right to require us to correct any mistakes in your personal information

Right to be Forgotten: The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object: The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation

11. TRANSFERRING PERSONAL INFORMATION OUT OF THE EEA.

To deliver Services to you and to enable your participation in the Contests, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

These transfers are subject to special rules under European and UK data protection law.

In general non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please contact us or our Data Protection Officer (see “How To Contact Us” below).

12. CALIFORNIA PRIVACY RIGHTS ADDENDUM

  1. This CALIFORNIA PRIVACY NOTICE (“Notice”) supplements our Privacy Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) but it applies to all of our users and players. 
  2. Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect: