TRACKMAN PRIVACY NOTICE

This Privacy Notice explains the personal data we collect from and about you, either directly or indirectly, and how we use it. The notice also covers the choices you can make about the data we collect and how you can control these choices. It applies to all Trackman products, applications, services, and websites. By using Trackman products and services, you agree to the use of your personal data as described in this Privacy Notice. Please read this Privacy Notice carefully to understand when you are providing personal data to us and how Trackman will use personal data provided.

Trackman has a data protection regime in place to oversee the effective and secure processing of personal data.

HOW TO CONTACT US

If you have any questions about the use of your personal data, please send us an email to privacy@trackman.com.

Trackman A/S, org. no (CVR) 27352677, having its registered address at Dr Neergaards Vej 15, DK-2970 Hørsholm, Denmark, is a data controller for the personal data we collect through the products and services subject to this privacy notice.

SITUATIONS WHERE PERSONAL DATA MAY BE COLLECTED

Trackman collects certain personal data in each of the following situations:

Website browsing

We collect information of IP addresses and information provided by cookies or similar technology. Furthermore, we may collect information of your name and email address, if you choose to provide this information to us voluntarily to receive further information about our products and services.

Enquiries through the Trackman CRM system

If you contact Trackman's CRM system via any of our websites, by telephone, email, social media, or other channels, we may collect information like your name and email address.

Purchase of a Trackman product

When you purchase a Trackman product, we collect information such as your name, billing and delivery address, EU VAT number (for businesses registered in the European Union), email address, and phone number.

Opening of Trackman account

When you create a Trackman account and become a registered user, we collect information like your name, email, and username. Furthermore, we may collect information about your home address, telephone number, gender, age, nationality, golf handicap, dexterity, golfer segment, and user category if you choose to register such information voluntarily.

Trackman profiles can be either public or private, depending on how much information you choose to share. A private profile will only show your full name, username, and potentially some highlevel statistics, which will allow others to find you and connect. A public profile will allow anyone to browse through your profile, seeing your aggregate stats and even review specific activities like a course round, game, or practice session.

Tournaments and competitions

If you participate in any tournaments or competitions facilitated by a Trackman product or service, your full name or player name will be visible on leaderboards. Leaderboards are available in the Trackman Golf app and through several other Trackman products and services.

Use of products and services by registered users (owners, including coaches and event/tournament organizers) and nonregistered users (players)

When Trackman products are used, we collect performance data, including but not limited to data parameters, video recordings, screencasts, reports, information on player visits, information on creation/cancellation and reactivation of subscriptions, information on downloaded certificates, progress data of lessons and courses, ball data parameters, lifetime stats, and achievements/badges depending on the specific Trackman product and/or service used.

Video recordings are not saved unless you voluntarily choose to have them saved. In tournaments, video recordings may be used for player recognition to limit cheating and ensure fair play, including to identify participants. Video recordings may in such instances be saved, if and to the extent necessary to fulfil such purposes. Generally, player recognition by video may be used in several scenarios to make the Trackman golf experience more enjoyable and effortless. One example is being able to prompt players with a warning if someone is about to hit another person’s ball. Another example is automatically tagging shots with correct player ID, if players move across different Trackman units (group lessons and similar).

If you use your Trackman product to collect data from your students, potential customers, and/or participants in events/tournaments, and/or otherwise make your Trackman product available to third parties, subject to any applicable limitations in Trackman’s general terms and conditions for sale and delivery of products and product-related services by Trackman and Trackman’s terms and conditions for the use of the account, it is your responsibility as an owner prior to commencement of any such use of the Trackman product to inform the relevant student/customer/participant of the content of this privacy notice; cf. Trackman’s terms and conditions for the use of account. You may not save video recordings of players unless you have obtained their express consent hereto. Upon completion of an event/tournament and/or training session by a player, Trackman may also share a link to this privacy notice to any student/participant, who has requested to receive a player report in connection with the training session/event/tournament.

If the standardized Trackman Combine test or a similar test is completed by any user (whether registered or not registered), the test results and the name of the player may automatically be published on Trackman’s electronic leaderboards. Any coach/event organizer who makes Trackman equipment available to students/participants in events are required to notify the student/participant of the publication of the test score and the player’s name on the leaderboard prior to the student/participant taking the Trackman Combine test; cf. Trackman’s terms and conditions for the use of account.

Users may enter information about their golf bag (e.g., types of clubs, specifications, and other related details) into their Trackman account, including so that Trackman may provide club suggestions. Trackman reserves the right to share this information with third parties, including partners and sponsors, to – subject to the user’s explicit consent hereto – provide users with tailored updates, offers, and other golf-related content. This information will be shared only after obtaining the player's consent where required by applicable laws.

Collection of functional data

In addition to the above, Trackman collects certain functional data related to the radar equipment and the IT-devices used in connection with the operation thereof, including but not limited to radar system information, GPS data, radar temperature, power on/off date, usage time, user ID, signup date, last shot date, IP address, network name, information of connected devices, login date, depending on the product and service used.

PURPOSE OF PROCESSING PERSONAL INFORMATION

The information we collect from you may be used in one or more of the following ways:

• To provide you with detailed and comprehensive data points on your current and historical performance within golf, whether for training and/or leisure purposes
• To personalize your experience
• To share your account information, which gives the ability to search for other users choosing a private profile view or full profile view depending on how much you choose to share.
• To continuously improve the Trackman equipment and software and the usability hereof
• To facilitate Trackman’s business operations and analysis in relation to the development of new products and/or services
• To ensure a safe and secure product
• To improve Trackman’s websites
• To improve customer support (your information helps us to more effectively respond to your customer service requests and support needs)
• To process orders and transactions
• To facilitate sharing and disclosure by you of the tracked data
• For documentation purposes in case of disputes
• For marketing and communication purposes

The email address you provide for order processing may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.

LAWFULNESS OF PROCESSING

In general, our processing of your personal data is based on Article 6(1)(b) of the General Data Protection Regulation pursuant to which your personal data may be processed, if necessary for our performance of a contract to which you are a party or in order for us to take steps at your request prior to entering into a contract.

Processing of your personal data may potentially also be carried out based on Article 6(1)(f) of the General Data Protection Regulation, if the processing is necessary for purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

INFORMATION SHARING

Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company outside Trackman for any reason whatsoever, without your consent, other than for the expressed purpose of delivering the purchased product or service requested. For example, we may ask for your consent for Trackman to provide your contact details and shot data from a specific driving range, retail store, indoor facility or similar public location you have visited – to the owners of that facility or thirdparty sponsor(s), in order to provide you with updates/offers covering golf related equipment, services, apparel or similar. Your name and/or username may also be included on overviews we provide or otherwise make available to facilities you have visited.

Notwithstanding the above, your name and performance in specific events/tournaments may be made available to Trackman's partners and the public (via leaderboards and similar) in connection with any competition organized by Trackman or involving the use of Trackman products and services. Further, we may exchange your information with other companies within the Trackman group to ensure that we provide you with an efficient and effective service.

We only share information with partners and suppliers if we are satisfied that they have sufficient measures in place to protect your information and only after having necessary privacy notices and/or data processing agreements in place.

DETAILS OF TRANSFERS TO THIRD COUNTRY AND SAFEGUARDS

Your personal data may be stored and processed on secure Microsoft cloud servers or other wellknown cloud service providers located in the United States of America or in the European Union.

RETENTION PERIODS

Customer data

Customer data, including performance data
Data is retained (a) whilst you maintain an account, service, or contract with Trackman and for a period of 24 months thereafter; or (b) until such an earlier point in time where you may request your data to be deleted. Once you request all data to be deleted, data will be removed from our backups within 12 months.

Performance data and functional data regarding the radar and/or IT-devices may be irreversibly anonymized at the end of the retention period and used for research and development purposes.

CRM data (Name, email address, mobile number, address)
Data is retained whilst you remain a customer or until such earlier point in time where you may request the data to be deleted. Once you request all data to be deleted, data will be removed from our backups within 12 months.

Noncustomer data

Name, email address, and/or telephone no.
Data is kept until you unsubscribe/request to be removed from the system. Once you unsubscribe or request to be removed from the system, data will be removed from our backups within 12 months.

Notwithstanding the above, Trackman may retain limited information after the end of the applicable retention period, if required by applicable law.

USE OF COOKIES

We use cookies. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with thirdparty service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

YOUR RIGHTS

You have certain rights under the applicable data protection laws, including the following rights under the EU General Data Protection Regulation

• The right to be informed via privacy notices such as this.
• The right of access to any personal information we hold about you. To request a copy of this information, you must make a subject access request in writing, either via a letter to Trackman A/S, Dr Neergaards Vej 15, DK-2970 Hørsholm, Denmark, attention: Privacy Officer, or via email to privacy@trackman.com. (to ensure that we can deal with your request you will need to include your current name and address, proof of identity, e.g., a copy of your driving license or passport). We do not charge for making a subject access request.
• The right of rectification, we must correct inaccurate or incomplete data within one month.
• The right to erasure. You have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal information.
• The right to restrict processing. You have the right to suppress processing. We can retain just enough information about you to ensure that the restriction is respected in the future.
• The right to withdraw your consent. You have the right at any time to withdraw any consent you may have provided for Trackman to process your personal data.
• The right to data portability. We can provide you with your personal data in a structured, commonly used, machinereadable form when asked.
• The right to object to processing for directs marketing purposes

You can read more about your rights in the guidance note on the rights of data subjects (in Danish: Vejledning om de registreredes rettigheder) prepared by the Danish Data Protection Agency and available at www.datatilsynet.dk

QUESTIONS AND COMPLAINTS

If you have any questions or wish to make a complaint, comment, or compliment about Trackman's processing of your personal information, please forward it to email: privacy@trackman.com.

If you are still dissatisfied, you may contact the Danish supervisory authority:

Datatilsynet
Borgergade 28, 5
DK-1300 Copenhagen K
Tel: 3319 3200
Fax: 3319 3218
E-mail: dt@datatilsynet.dk

CHANGES

If this privacy notice changes in any way, we will place an updated version hereof on this page. By regularly reviewing this page, you will ensure that you are always aware of what information we collect, how we use it, and under what circumstances, if any, we share it with others.