Contents
- Name and Contact Details of the Controller
- The Personal Data We Process
- How We Collect Your Personal Data
- Why We Process Your Personal Data
- To Whom We May Disclose Your Personal Data
- Cookies and Other Tracking Technologies
- Retention
- Third Country Data Transfers
- AI Training; Sensory Data
- Your Rights as a Data Subject
- Location-Specific Disclosures
- Updates to This Global Privacy Policy
- Contact Information
Viewlicity GmbH and its affiliates (referred to herein as "Viewlicity", "we", "us", or "our") treat data protection as a top priority and protect the information relating to an identified or identifiable individual ("Personal Data", the individual(s) referred to as "you" or "your").
This Global Privacy Policy applies to Personal Data we process when providing the "services" listed below:
- on Viewlicity websites operated by Viewlicity and its affiliates (each, a "website");
- through our other online services, such as online services that are part of your use of PuttView products, including the Ball Tracking Service, PuttView Books App, PuttView mobile app and other mobile applications we offer (collectively, "mobile apps") that we own, operate, or make available and that link to this Global Privacy Policy;
- when you purchase a product or services from us;
- through offline interactions (such as customer consultations and showroom demonstrations); and
- through other general inquiries we receive (including postal mail, electronic mail, telephone requests, and in person).
This Global Privacy Policy also applies to the processing of Personal Data relating to business partners, including suppliers and cooperation partners, in connection with our business relationships with them, as well as to individuals applying for employment with Viewlicity.
This Global Privacy Policy describes what Personal Data we process, how and why we process it, how and when we disclose it, and your privacy preferences, amongst other related information. Certain services may require you to agree to additional terms regarding our use of your Personal Data and those additional terms will apply to the Personal Data collected in that context. Any additional terms will be provided for your review prior to us processing data beyond that which is disclosed in this Global Privacy Policy.
For individuals in the United States: please refer to the appropriate "Regional disclosures" for additional details that may be relevant to you.
Name and Contact Details of the Controller
Entity: Viewlicity GmbH
Registered Office: Barnerstraße 14B, 22765 Hamburg, Germany
Email: [email protected]
THE PERSONAL DATA WE PROCESS
We process the following categories of Personal Data:
- Personal identification and contact data such as name, postal address, email address, date of birth, professional role / function, identity card.
- Account Information, including personal identification and contact data and other data such as account name, right-/lefthanded, handicap, user type (coach/player), and coach/player pairings.
- Usage Data such as data related to your use of the services, including mobile apps.
- Demographic Information such as sex, age, nationality, height, and weight, in each case subject to applicable laws.
- Financial Information such as bank account/credit card number used to pay for the services.
- Device Information such as hardware setup, device model, software version and other device characteristics, mobile app identifiers such as session ID and Customer ID, internet protocol address, cookie identification number, and information regarding consumer's interaction with our website. We use your IP address and/or country preference to approximate your location to provide you with a better experience when using our services. For more information, please review the Cookies and Other Tracking Technologies section.
- Photos, Videos, and Other Sensory Data such as pictures, videos, and sounds, including photos when using certain products and services.
- Location Information such as approximate location inferred from your IP address, country preference, or device settings, and, where you permit us to collect it, precise location information from your device, such as GPS, Bluetooth, Wi-Fi, or other geolocation data.
- Employment and Professional Information including personal identification and contact data and other data such as education, employment history, job title, university or school attended, diploma, other CV information, pay history, and income.
- Other Personal Data such as personal data disclosed in any additional terms that you receive related to the services you are using.
HOW WE COLLECT YOUR PERSONAL DATA
We collect Personal Data when you use the following services:
- Website. We collect Personal Data when you interact with our website's services which may include, but are not limited to, purchasing products, communicating with us or our chatbot that we provide, applying for a job, engaging with us on social media, or participating in a survey.
- Mobile Application. We collect Personal Data when you register and use the mobile apps, which includes creating and updating your account, providing support services to you, ensuring the mobile app is performing as expected, tracking session-specific details (e.g., improvement over time, session time stamps, use of the mobile app, and other putt training data) and providing the services.
- Device Usage. We collect Personal Data about how you access and use our products and services and to ensure our user training and Ball Tracking Service is functioning as intended.
- Other Sites and Third Parties. We may use separate websites and third-party service providers for the processing of transactions and for our service providers to assist us with other services that we have engaged them to perform, such as providing support services and marketing analytics.
- Other Sources. We may also collect Personal Data from information you provide to us or from other sources, such as public databases.
WHY WE PROCESS YOUR PERSONAL DATA
The following chart sets out (1) the purpose for which Personal Information may be collected and processed ("Purpose"), (2) a description of the processing activities associated with such Purpose, (3) the categories of personal data we process for such Purpose, and (4) the legal basis for processing such Personal Information ("Legal Basis").
| PURPOSE | DESCRIPTION OF PROCESSING | CATEGORIES OF DATA | LEGAL BASIS |
| Engage with you on our website | The processing associated with this Purpose includes responding to your inquiries and providing information requested, providing features available on our website to you. For more information on the processing by use of cookies and other tracking technologies, please review the respective section on such technologies below. | Device information; location information; usage data | Legitimate interest, for the purposes as described in the Purpose column. |
| Provide you with online services related to PuttView products, which include PuttView Indoor, the Ball Tracking Service, PuttView Books App, PuttView mobile App, and other services you request | The processing associated with this Purpose includes registering for PuttView products, including PuttView Indoor and mobile apps, using the associated services such as the Ball Tracking Service and mobile Apps, providing support services to you, and creating a profile about you in order to provide the individualized training you have requested. We will be unable to provide you with personalized training without tailoring the data specifically to you. | Account information; demographic information; financial information; photos, videos, and other sensory data; location information; usage data For the use of AI and of photos, videos, and other sensory data, please review the AI and sensory data section. | (1) Contractual obligations; or (2) where (1) above is not applicable, legitimate interests for the purposes as described in the Purpose column. |
| Operations and general business | The processing associated with this Purpose includes (1) communicating with customers, vendors and other business partners about offerings, contracts and payments and business cooperations; (2) processing data of customers, vendors and other business partners to manage the respective business relationship, including processing contact information in our customer and vendor relationship management system. | Account information; demographic information; financial information | (1) Contractual obligations and/or taking steps at your request prior to entering into a contract (as applicable); or where (1) above is not applicable, legitimate interests for the purposes as described in the Purpose column. |
| Marketing and surveys | The processing associated with this Purpose includes analysing user behaviour within our apps and services, identifying potential interest in our products and services, segmenting users based on their interactions, using location information, such as GPS location from the mobile app where enabled by the user, to identify and suggest nearby indoor golf facilities or other relevant locations where the Services may be used, and providing tailored marketing communications, promotions and offers. This also includes conducting surveys about the experience with our products and services. For more information on the processing by use of cookies and other tracking technologies, please review the respective section on such technologies below. | Account information; demographic information; location information; usage data | Consent, where required, including for access to precise device location or non-essential cookies. You may withdraw your consent at any time with effect for the future. Legitimate interests, where applicable, such as for general marketing, analytics, and improving the relevance of our services and communications for the purposes as described in the Purpose column. For more information on the legal basis for the use of cookies and other tracking technologies, please review the cookies and other tracking technologies section below. |
| Improving the quality, usability, and overall customer experience of our products and services | Processing for this Purpose includes analyzing how users interact with our apps and services, as well as assessing our customers' needs and preferences. | Demographic information; location information; usage data | Legitimate interests for the purposes as described in the Purpose column. |
| Marketing communication; sending newsletters to you | The processing associated with this Purpose includes contacting you directly by telephone or email (via newsletters or individual communications) to inform you about our products and services. | Personal identification and contact data; device information | Consent. You may withdraw your consent at any time with effect for the future. Upon receipt of your withdrawal, we may continue to store your contact details in order to demonstrate that consent was previously given, even after your data has been removed from our marketing database. The legal basis for retaining records of consent is (1) our compliance with legal obligations as derived from the principles of lawfulness and accountability; and (2) our legitimate interests to prove consent. Where our telephone contact relates to your commercial or self-employed professional activities and we may reasonably assume your presumed consent to receive such calls, the processing may also be based on our legitimate interests for the purpose as described in the Purpose column. Furthermore, we may contact you by email if we obtained your email address in connection with the sale of a product or service, use the address to inform you about our own similar products or services, you have not objected to such use, and we clearly informed you at the time the address was collected and each time it is used that you may object to its use at any time without incurring any costs other than the transmission costs according to the basic rates. Such processing is based on our legitimate interests for the purpose as described in the Purpose column. |
| Processing job applications | The processing associated with this Purpose includes your submission of your application data to us by email or other means. | Employment and professional information | We process the data for the purpose of conducting and managing the application process (processing necessary to take steps at the request of the data subject prior to entering into a contract). If you voluntarily provide us with special categories of personal data, such as health data, we will process such data on the basis of your explicit consent. You may withdraw your consent at any time with effect for the future. |
| Security and legal obligations | The processing associated with this Purpose includes detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity. | Account information; device information; photos, videos, and other sensory data; location information; usage data | Legitimate interests to protect against malicious activity Legal obligations relating to data protection and to report illegal activity and security incidents |
| Entering into merger and acquisitions (M&A) | The processing associated with this Purpose includes sharing data for the purposes of evaluating and conducting a potential merger, acquisition, or similar corporate transaction ("Due Diligence"), as well as transferring data to the acquiring entity following the completion of such transaction ("Closing"). | For Due Diligence: Personal identification and contact data and possibly other personal data (e.g. certain information about the scope and financials of our business relationship with you) of core business partners; Upon "Closing": All personal data required to continue the relevant PuttView business. The transfer of certain personal data may be subject to the customer's or business partners consent to a transfer of the business relationship. | Legitimate interests for the Purpose described in the Purpose column. |
| Exercise of rights or fulfilment of obligations | The processing associated with this Purpose includes the exercise of rights or fulfilment of obligations in judicial, administrative, or arbitration procedures | Account information; demographic information; financial information; photos, videos, and other sensory data; location information; usage data | (1) Processing is necessary for compliance with a legal obligation to which we are subject. (2) Where (1) above is not applicable: Legitimate interests for the purposes as described in the Purpose column. |
TO WHOM WE MAY DISCLOSE YOUR PERSONAL DATA
Subject to a legal basis as specified above, we may disclose Personal Data with the following third parties:
Viewlicity Affiliates. We disclose your Personal Data with our affiliates as necessary to communicate with you, provide you services, fulfill our contract with you, and to accomplish our business purposes.
Service Providers. We disclose Personal Data to third parties who perform services such as hosting our websites, providing our information technology systems, providing online communication and collaboration services (e.g. audio, video and web conferencing services), processing payments, conducting research and analytics, conducting financial, identity and other legal checks, and providing professional advice.
Partners. If you consent to non-essential cookies, we disclose Personal Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.
Government Authorities. We may disclose Personal Data to government authorities in accordance with applicable laws.
When you use our website or services, we process certain data from cookies, pixel tags, web beacons, and other technologies that store information on or access information from your device.
These technologies are used for a variety of purposes, including ensuring the technical operation and security of the website, providing requested functionalities, measuring and analysing website usage, improving user experience, and, where applicable, delivering personalised content and advertising.
Some of these technologies are strictly necessary for the operation of the website and the provision of services requested by the user. Such technologies are processed on the basis of our legitimate interests. Our legitimate interest lies in ensuring the technically correct, secure, and optimised provision of our website and services.
Where the use of cookies or similar technologies is not strictly necessary, they will only be used on the basis of your prior consent. You may withdraw your consent at any time with effect for the future.
You can configure your browser or device settings to manage or restrict the use of cookies and certain similar technologies. Please note, however, that disabling such technologies may affect the functionality and availability of certain features of our website and services.
RETENTION
We will retain your Personal Data for a reasonable period in order to fulfill the Purposes for which we collected it, unless a longer retention period is required or permitted by law.
The criteria used to determine our retention period includes:
- the length of time we have an ongoing relationship with you and provide the services to you;
- whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
- whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations); and
- whether you have revoked your consent or objected to use data for legitimate interests.
If you apply for employment and your application is unsuccessful, your data will be deleted no later than 6 months after completion of the application process, unless you have given us your consent to retain the data for a longer period. Such retention period is necessary to enable us, where required, to comply with our obligations to provide evidence under the German General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG).
THIRD COUNTRY DATA TRANSFERS
Personal Data may be transferred to recipients located in countries outside the European Union (EU) or the European Economic Area (EEA) ("third countries"). Such transfers will only take place where permitted under applicable data protection laws. Where the European Commission has not issued an adequacy decision for the respective third country, we ensure an appropriate level of data protection through suitable safeguards, such as the European Commission's Standard Contractual Clauses (SCCs), binding corporate rules, or other legally recognized transfer mechanisms. Further information regarding the safeguards implemented can be obtained upon request by contacting us at [email protected].
AI TRAINING; SENSORY DATA
Our services utilize certain AI tools to develop and improve our services and in connection with your use of the services. AI is used to detect patterns in user's data to provide an automated and objective evaluation system for putting skills and shortcomings. The results of this evaluation shall be used to offer the user personalized feedback. As described below, we do not use video footage from the mobile app or indoor systems for AI training or model improvement except with your consent.
Services may capture or process photos, videos, audio, or similar sensory data to provide product functionality, including local video recording in the mobile app and video-based ball tracking in indoor systems. Unless otherwise disclosed or separately agreed, mobile app videos are stored locally on the user's device and are not sent to our servers. Indoor system video footage is not retained after tracking data is generated. If you consent to share additional data, we will use indoor video footage for AI training or model improvement.
YOUR RIGHTS AS A DATA SUBJECT
You have the following rights regarding the processing of your Personal Data:
- Right to withdraw consent: Where we process your personal data based on your consent, you have the right to withdraw your consent at any time in accordance with Art. 7(3) GDPR. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right of access: Pursuant to Art. 15 GDPR, you have the right to obtain information about the personal data we process concerning you. In particular, you may request information regarding the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients to whom the data have been or will be disclosed, the envisaged retention period, the existence of rights to rectification, erasure, restriction of processing or objection, the right to lodge a complaint with a supervisory authority, the source of the data where it was not collected directly from you, and the existence of automated decision-making, including profiling, as well as meaningful information about the logic involved and the significance and envisaged consequences of such processing.
- Right to rectification: Pursuant to Art. 16 GDPR, you have the right to request the correction of inaccurate personal data and the completion of incomplete personal data without undue delay.
- Right to erasure: Pursuant to Art. 17 GDPR, you have the right to request the erasure of your personal data, unless processing is required for exercising the right of freedom of expression and information, compliance with a legal obligation, reasons of public interest, or the establishment, exercise or defence of legal claims.
- Right to restriction of processing: Pursuant to Art. 18 GDPR, you have the right to request the restriction of processing where you contest the accuracy of the personal data, where the processing is unlawful and you oppose erasure, where we no longer need the data but you require it for the establishment, exercise or defence of legal claims, or where you have objected to processing pursuant to Art. 21 GDPR.
- Right to data portability: Pursuant to Art. 20 GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller, or to have them transmitted directly where technically feasible.
- Right to object: Where your personal data are processed on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right to object to such processing at any time pursuant to Art. 21 GDPR on grounds relating to your particular situation.
To exercise any of the rights described above, please contact us at [email protected].
You also have the right to lodge a complaint with a competent data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection laws.
LOCATION-SPECIFIC DISCLOSURES
NOTICE TO USERS IN THE UNITED STATES (U.S.)
The disclosures in this section apply only to U.S. residents and is intended to supplement this privacy policy with information required by applicable U.S. state laws.
Below is a description of the categories of Personal Data, which references the categories in the above section "The Personal Data We Collect" we collected in the past 12 months, the categories of recipients of disclosures made for business purposes in the past 12 months, and the categories of recipients of disclosures made in the past 12 months that may be considered "sales" of personal information or "sharing" of personal information for cross-context behavioral advertising under U.S. state laws.
| Category of Information | Recipients of Disclosures for Business Purposes | Recipients of "Sales" or "Sharing" |
| Identifiers, such as Account Information |
|
|
| Commercial information, such as Financial Information |
| -NA- |
| Internet or other electronic network activity information, such as Device Information |
|
|
| Visual and audio information, such as Sensory Data |
| -NA- |
| Location Data |
| -NA- |
| Employment or Professional Information |
| -NA- |
| Inferences such as Usage Data |
|
|
| Sensitive personal information, such as Demographic Data |
| -NA- |
Your rights: If you are a U.S. resident, you have the following rights regarding your personal information:
- To request information about our processing of your Personal Data;
- To request access to and/or a copy of certain Personal Data we hold about you (including in a portable and/or machine-readable format);
- To update or correct your Personal Data;
- To request that we delete certain Personal Data we hold about you, subject to certain exceptions;
- To opt out of the "sale" of personal information, the "sharing" of personal information or "targeted advertising" (as these terms are defined under applicable laws);
- The right not to be discriminated against for exercising your rights; and
- The right to appeal our decision to deny your request, if applicable.
Opt out of "sales", "sharing", and "targeted advertising"
You may also opt out of "sales" of Personal Data to third parties, "sharing" of personal information for purposes of cross-context behavioral advertising, and "targeted advertising" by choosing to opt out of Cookies on our websites. Where required, we honor requests to opt out submitted via privacy preference signals recognized under applicable law, such as the Global Privacy Control ("GPC"). For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see Global Privacy Control — Take Control of Your Privacy.
UPDATES TO THIS GLOBAL PRIVACY POLICY
Any changes we make to this Global Privacy Policy will become effective upon posting. If we change our Global Privacy Policy, we will advise users of those changes through a general description at the top of this Privacy Policy and may also post these details to other places we deem appropriate. If we are legally permitted to do so, we may also email you.
CONTACT INFORMATION
If you have any questions about this Global Privacy Policy or have complaints about the processing of the Personal Information, please contact us at [email protected].
You may also contact us by postal mail at the following address:
Viewlicity GmbH
Barnerstraße 14B
22765 Hamburg, Germany
Phone: +49 40-63698063
Email: [email protected]
Viewlicity GmbH and its affiliates (referred to herein as "Viewlicity", "we", "us", or "our") treat data protection as a top priority and protect the information relating to an identified or identifiable individual ("Personal Data", the individual(s) referred to as "you" or "your").
This Global Privacy Policy applies to Personal Data we process when providing the "services" listed below:
- On Viewlicity websites operated by Viewlicity and its affiliates (each, a "website")
- Through our other online services, such as online services that are part of your use of PuttView products, including the Ball Tracking Service, PuttView Books App, PuttView mobile app and other mobile applications we offer (collectively, "mobile apps") that we own, operate, or make available and that link to this Global Privacy Policy
- When you purchase a product or services from us
- Through offline interactions (such as customer consultations and showroom demonstrations)
- Through other general inquiries we receive (including postal mail, electronic mail, telephone requests, and in person)
This Global Privacy Policy also applies to the processing of Personal Data relating to business partners, including suppliers and cooperation partners, in connection with our business relationships with them, as well as to individuals applying for employment with Viewlicity.
This Global Privacy Policy describes what Personal Data we process, how and why we process it, how and when we disclose it, and your privacy preferences, amongst other related information. Certain services may require you to agree to additional terms regarding our use of your Personal Data and those additional terms will apply to the Personal Data collected in that context. Any additional terms will be provided for your review prior to us processing data beyond that which is disclosed in this Global Privacy Policy.
For individuals in the United States: please refer to the appropriate "Regional disclosures" for additional details that may be relevant to you.
Name and Contact Details of the Controller
Entity: Viewlicity GmbH
Registered Office: Barnerstraße 14B, 22765 Hamburg, Germany
Email: [email protected]
THE PERSONAL DATA WE PROCESS
We process the following categories of Personal Data:
- Personal identification and contact data such as name, postal address, email address, date of birth, professional role / function, identity card.
- Account Information, including personal identification and contact data and other data such as account name, right-/lefthanded, handicap, user type (coach/player), and coach/player pairings.
- Usage Data such as data related to your use of the services, including mobile apps.
- Demographic Information such as sex, age, nationality, height, and weight, in each case subject to applicable laws.
- Financial Information such as bank account/credit card number used to pay for the services.
- Device Information such as hardware setup, device model, software version and other device characteristics, mobile app identifiers such as session ID and Customer ID, internet protocol address, cookie identification number, and information regarding consumer's interaction with our website. We use your IP address and/or country preference to approximate your location to provide you with a better experience when using our services. For more information, please review the Cookies and Other Tracking Technologies section.
- Photos, Videos, and Other Sensory Data such as pictures, videos, and sounds, including photos when using certain products and services.
- Location Information such as approximate location inferred from your IP address, country preference, or device settings, and, where you permit us to collect it, precise location information from your device, such as GPS, Bluetooth, Wi-Fi, or other geolocation data.
- Employment and Professional Information including personal identification and contact data and other data such as education, employment history, job title, university or school attended, diploma, other CV information, pay history, and income.
- Other Personal Data such as personal data disclosed in any additional terms that you receive related to the services you are using.
HOW WE COLLECT YOUR PERSONAL DATA
We collect Personal Data when you use the following services:
- Website. We collect Personal Data when you interact with our website's services which may include, but are not limited to, purchasing products, communicating with us or our chatbot that we provide, applying for a job, engaging with us on social media, or participating in a survey.
- Mobile Application. We collect Personal Data when you register and use the mobile apps, which includes creating and updating your account, providing support services to you, ensuring the mobile app is performing as expected, tracking session-specific details (e.g., improvement over time, session time stamps, use of the mobile app, and other putt training data) and providing the services.
- Device Usage. We collect Personal Data about how you access and use our products and services and to ensure our user training and Ball Tracking Service is functioning as intended.
- Other Sites and Third Parties. We may use separate websites and third-party service providers for the processing of transactions and for our service providers to assist us with other services that we have engaged them to perform, such as providing support services and marketing analytics.
- Other Sources. We may also collect Personal Data from information you provide to us or from other sources, such as public databases.
WHY WE PROCESS YOUR PERSONAL DATA
The following chart sets out (1) the purpose for which Personal Information may be collected and processed ("Purpose"), (2) a description of the processing activities associated with such Purpose, (3) the categories of personal data we process for such Purpose, and (4) the legal basis for processing such Personal Information ("Legal Basis").
| Purpose | Description of Processing | Categories of Data | Legal Basis |
| (1) Engage with you on our website | (2) The processing associated with this Purpose includes responding to your inquiries and providing information requested, providing features available on our website to you. For more information on the processing by use of cookies and other tracking technologies, please review the respective section on such technologies below. | (3) Device information; location information; usage data | (4) Legitimate interest, for the purposes as described in the Purpose column. |
| (1) Provide you with online services related to PuttView products, which include PuttView Indoor, the Ball Tracking Service, PuttView Books App, PuttView mobile App, and other services you request | (2) The processing associated with this Purpose includes registering for PuttView products, including PuttView Indoor and mobile apps, using the associated services such as the Ball Tracking Service and mobile Apps, providing support services to you, and creating a profile about you in order to provide the individualized training you have requested. We will be unable to provide you with personalized training without tailoring the data specifically to you. | (3) Account information; demographic information; financial information; photos, videos, and other sensory data; location information; usage data For the use of AI and of photos, videos, and other sensory data, please review the AI and sensory data section. | (4) (1) Contractual obligations; or (2) where (1) above is not applicable, legitimate interests for the purposes as described in the Purpose column. |
| (1) Operations and general business | (2) The processing associated with this Purpose includes (1) communicating with customers, vendors and other business partners about offerings, contracts and payments and business cooperations; (2) processing data of customers, vendors and other business partners to manage the respective business relationship, including processing contact information in our customer and vendor relationship management system. | (3) Account information; demographic information; financial information | (4) (1) Contractual obligations and/or taking steps at your request prior to entering into a contract (as applicable); or where (1) above is not applicable, legitimate interests for the purposes as described in the Purpose column. |
| (1) Marketing and surveys | (2) The processing associated with this Purpose includes analysing user behaviour within our apps and services, identifying potential interest in our products and services, segmenting users based on their interactions, using location information, such as GPS location from the mobile app where enabled by the user, to identify and suggest nearby indoor golf facilities or other relevant locations where the Services may be used, and providing tailored marketing communications, promotions and offers. This also includes conducting surveys about the experience with our products and services. For more information on the processing by use of cookies and other tracking technologies, please review the respective section on such technologies below. | (3) Account information; demographic information; location information; usage data | (4) Consent, where required, including for access to precise device location or non-essential cookies. You may withdraw your consent at any time with effect for the future. Legitimate interests, where applicable, such as for general marketing, analytics, and improving the relevance of our services and communications for the purposes as described in the Purpose column. For more information on the legal basis for the use of cookies and other tracking technologies, please review the cookies and other tracking technologies section below. |
| (1) Improving the quality, usability, and overall customer experience of our products and services | (2) Processing for this Purpose includes analyzing how users interact with our apps and services, as well as assessing our customers' needs and preferences. | (3) Demographic information; location information; usage data | (4) Legitimate interests for the purposes as described in the Purpose column. |
| (1) Marketing communication; sending newsletters to you | (2) The processing associated with this Purpose includes contacting you directly by telephone or email (via newsletters or individual communications) to inform you about our products and services. | (3) Personal identification and contact data; device information | (4) Consent. You may withdraw your consent at any time with effect for the future. Upon receipt of your withdrawal, we may continue to store your contact details in order to demonstrate that consent was previously given, even after your data has been removed from our marketing database. The legal basis for retaining records of consent is (1) our compliance with legal obligations as derived from the principles of lawfulness and accountability; and (2) our legitimate interests to prove consent. Where our telephone contact relates to your commercial or self-employed professional activities and we may reasonably assume your presumed consent to receive such calls, the processing may also be based on our legitimate interests for the purpose as described in the Purpose column. Furthermore, we may contact you by email if we obtained your email address in connection with the sale of a product or service, use the address to inform you about our own similar products or services, you have not objected to such use, and we clearly informed you at the time the address was collected and each time it is used that you may object to its use at any time without incurring any costs other than the transmission costs according to the basic rates. Such processing is based on our legitimate interests for the purpose as described in the Purpose column. |
| (1) Processing job applications | (2) The processing associated with this Purpose includes your submission of your application data to us by email or other means. | (3) Employment and professional information | (4) We process the data for the purpose of conducting and managing the application process (processing necessary to take steps at the request of the data subject prior to entering into a contract). If you voluntarily provide us with special categories of personal data, such as health data, we will process such data on the basis of your explicit consent. You may withdraw your consent at any time with effect for the future. |
| (1) Security and legal obligations | (2) The processing associated with this Purpose includes detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity. | (3) Account information; device information; photos, videos, and other sensory data; location information; usage data | (4) Legitimate interests to protect against malicious activity Legal obligations relating to data protection and to report illegal activity and security incidents |
| (1) Entering into merger and acquisitions (M&A) | (2) The processing associated with this Purpose includes sharing data for the purposes of evaluating and conducting a potential merger, acquisition, or similar corporate transaction ("Due Diligence"), as well as transferring data to the acquiring entity following the completion of such transaction ("Closing"). | (3) For Due Diligence: Personal identification and contact data and possibly other personal data (e.g. certain information about the scope and financials of our business relationship with you) of core business partners; Upon "Closing": All personal data required to continue the relevant PuttView business. The transfer of certain personal data may be subject to the customer's or business partners consent to a transfer of the business relationship. | (4) Legitimate interests for the Purpose described in the Purpose column. |
| (1) Exercise of rights or fulfilment of obligations | (2) The processing associated with this Purpose includes the exercise of rights or fulfilment of obligations in judicial, administrative, or arbitration procedures. | (3) Account information; demographic information; financial information; photos, videos, and other sensory data; location information; usage data | (4) (1) Processing is necessary for compliance with a legal obligation to which we are subject. (2) Where (1) above is not applicable: Legitimate interests for the purposes as described in the Purpose column. |
TO WHOM WE MAY DISCLOSE YOUR PERSONAL DATA
Subject to a legal basis as specified above, we may disclose Personal Data with the following third parties:
Viewlicity Affiliates. We disclose your Personal Data with our affiliates as necessary to communicate with you, provide you services, fulfill our contract with you, and to accomplish our business purposes.
Service Providers. We disclose Personal Data to third parties who perform services such as hosting our websites, providing our information technology systems, providing online communication and collaboration services (e.g. audio, video and web conferencing services), processing payments, conducting research and analytics, conducting financial, identity and other legal checks, and providing professional advice.
Partners. If you consent to non-essential cookies, we disclose Personal Data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered.
Government Authorities. We may disclose Personal Data to government authorities in accordance with applicable laws.
COOKIES AND OTHER TRACKING TECHNOLOGIES
When you use our website or services, we process certain data from cookies, pixel tags, web beacons, and other technologies that store information on or access information from your device.
These technologies are used for a variety of purposes, including ensuring the technical operation and security of the website, providing requested functionalities, measuring and analysing website usage, improving user experience, and, where applicable, delivering personalised content and advertising.
Some of these technologies are strictly necessary for the operation of the website and the provision of services requested by the user. Such technologies are processed on the basis of our legitimate interests. Our legitimate interest lies in ensuring the technically correct, secure, and optimised provision of our website and services.
Where the use of cookies or similar technologies is not strictly necessary, they will only be used on the basis of your prior consent. You may withdraw your consent at any time with effect for the future.
You can configure your browser or device settings to manage or restrict the use of cookies and certain similar technologies. Please note, however, that disabling such technologies may affect the functionality and availability of certain features of our website and services.
RETENTION
We will retain your Personal Data for a reasonable period in order to fulfill the Purposes for which we collected it, unless a longer retention period is required or permitted by law.
The criteria used to determine our retention period includes:
- The length of time we have an ongoing relationship with you and provide the services to you
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)
- Whether you have revoked your consent or objected to use data for legitimate interests
If you apply for employment and your application is unsuccessful, your data will be deleted no later than 6 months after completion of the application process, unless you have given us your consent to retain the data for a longer period. Such retention period is necessary to enable us, where required, to comply with our obligations to provide evidence under the German General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG).
THIRD COUNTRY DATA TRANSFERS
Personal Data may be transferred to recipients located in countries outside the European Union (EU) or the European Economic Area (EEA) ("third countries"). Such transfers will only take place where permitted under applicable data protection laws. Where the European Commission has not issued an adequacy decision for the respective third country, we ensure an appropriate level of data protection through suitable safeguards, such as the European Commission's Standard Contractual Clauses (SCCs), binding corporate rules, or other legally recognized transfer mechanisms. Further information regarding the safeguards implemented can be obtained upon request by contacting us at [email protected].
AI TRAINING; SENSORY DATA
Our services utilize certain AI tools to develop and improve our services and in connection with your use of the services. AI is used to detect patterns in user's data to provide an automated and objective evaluation system for putting skills and shortcomings. The results of this evaluation shall be used to offer the user personalized feedback. As described below, we do not use video footage from the mobile app or indoor systems for AI training or model improvement except with your consent.
Services may capture or process photos, videos, audio, or similar sensory data to provide product functionality, including local video recording in the mobile app and video-based ball tracking in indoor systems. Unless otherwise disclosed or separately agreed, mobile app videos are stored locally on the user's device and are not sent to our servers. Indoor system video footage is not retained after tracking data is generated. If you consent to share additional data, we will use indoor video footage for AI training or model improvement.
YOUR RIGHTS AS A DATA SUBJECT
You have the following rights regarding the processing of your Personal Data:
- Right to withdraw consent: Where we process your personal data based on your consent, you have the right to withdraw your consent at any time in accordance with Art. 7(3) GDPR. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right of access: Pursuant to Art. 15 GDPR, you have the right to obtain information about the personal data we process concerning you. In particular, you may request information regarding the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients to whom the data have been or will be disclosed, the envisaged retention period, the existence of rights to rectification, erasure, restriction of processing or objection, the right to lodge a complaint with a supervisory authority, the source of the data where it was not collected directly from you, and the existence of automated decision-making, including profiling, as well as meaningful information about the logic involved and the significance and envisaged consequences of such processing.
- Right to rectification: Pursuant to Art. 16 GDPR, you have the right to request the correction of inaccurate personal data and the completion of incomplete personal data without undue delay.
- Right to erasure: Pursuant to Art. 17 GDPR, you have the right to request the erasure of your personal data, unless processing is required for exercising the right of freedom of expression and information, compliance with a legal obligation, reasons of public interest, or the establishment, exercise or defence of legal claims.
- Right to restriction of processing: Pursuant to Art. 18 GDPR, you have the right to request the restriction of processing where you contest the accuracy of the personal data, where the processing is unlawful and you oppose erasure, where we no longer need the data but you require it for the establishment, exercise or defence of legal claims, or where you have objected to processing pursuant to Art. 21 GDPR.
- Right to data portability: Pursuant to Art. 20 GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller, or to have them transmitted directly where technically feasible.
- Right to object: Where your personal data are processed on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right to object to such processing at any time pursuant to Art. 21 GDPR on grounds relating to your particular situation.
To exercise any of the rights described above, please contact us at [email protected].
You also have the right to lodge a complaint with a competent data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection laws.
LOCATION-SPECIFIC DISCLOSURES
NOTICE TO USERS IN THE UNITED STATES (U.S.)
The disclosures in this section apply only to U.S. residents and is intended to supplement this privacy policy with information required by applicable U.S. state laws.
Below is a description of the categories of Personal Data, which references the categories in the above section "The Personal Data We Collect" we collected in the past 12 months, the categories of recipients of disclosures made for business purposes in the past 12 months, and the categories of recipients of disclosures made in the past 12 months that may be considered "sales" of personal information or "sharing" of personal information for cross-context behavioral advertising under U.S. state laws.
| Category of Information | Recipients of Disclosures for Business Purposes | Recipients of "Sales" or "Sharing" |
| Identifiers, such as Account Information |
|
|
| Commercial information, such as Financial Information |
| -NA- |
| Internet or other electronic network activity information, such as Device Information |
|
|
| Visual and audio information, such as Sensory Data |
| -NA- |
| Location Data |
| -NA- |
| Employment or Professional Information |
| -NA- |
| Inferences such as Usage Data |
|
|
| Sensitive personal information, such as Demographic Data |
| -NA- |
Your rights: If you are a U.S. resident, you have the following rights regarding your personal information:
- To request information about our processing of your Personal Data
- To request access to and/or a copy of certain Personal Data we hold about you (including in a portable and/or machine-readable format)
- To update or correct your Personal Data
- To request that we delete certain Personal Data we hold about you, subject to certain exceptions
- To opt out of the "sale" of personal information, the "sharing" of personal information or "targeted advertising" (as these terms are defined under applicable laws)
- The right not to be discriminated against for exercising your rights
- The right to appeal our decision to deny your request, if applicable
Opt out of "sales", "sharing", and "targeted advertising"
You may also opt out of "sales" of Personal Data to third parties, "sharing" of personal information for purposes of cross-context behavioral advertising, and "targeted advertising" by choosing to opt out of Cookies on our websites. Where required, we honor requests to opt out submitted via privacy preference signals recognized under applicable law, such as the Global Privacy Control ("GPC"). For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see Global Privacy Control — Take Control of Your Privacy.
UPDATES TO THIS GLOBAL PRIVACY POLICY
Any changes we make to this Global Privacy Policy will become effective upon posting. If we change our Global Privacy Policy, we will advise users of those changes through a general description at the top of this Privacy Policy and may also post these details to other places we deem appropriate. If we are legally permitted to do so, we may also email you.
CONTACT INFORMATION
If you have any questions about this Global Privacy Policy or have complaints about the processing of the Personal Information, please contact us at [email protected].
You may also contact us by postal mail at the following address:
Viewlicity GmbH
Barnerstraße 14B
22765 Hamburg, Germany
Phone: +49 40-63698063
Email: [email protected]