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Privacy Notice

Our Privacy Notice has been updated and has an Effective Date of March 31, 2024.

This privacy notice (“Privacy Notice”) applies to our physical locations, including our on-site kiosks (“Locations”), our websites (“Website(s)”), mobile applications, including the Topgolf application, Toptracer Range application, World Golf Tour (“WGT”), and Shankstars (“Application(s)”), and other Topgolf products and services, including “Toptracer Coach”, “Toptracer Range Management System”, and “Toptracer Range” (collectively the “Topgolf Offerings”), owned and operated by Topgolf International Inc., and its subsidiaries and affiliates (collectively “Topgolf,” “we,” "our," or “us”). Topgolf is a subsidiary of Topgolf Callaway Brands Corp. which owns several brands and companies, (collectively, the “Topgolf Callaway Brands Family of Companies”). You can see the brands and companies included in Topgolf Callaway Brands Family of Companies here.

Please review this Privacy Notice and any of our applicable Terms and Conditions carefully. To the extent legally permitted, your use of the Topgolf Offerings, including any purchase of any products or services, signifies you have read, understood, and agree to this Privacy Notice and Terms and Conditions.

1. Personal, Sensitive, and Non-Personal Data We Collect and How We Use and Disclose It

 

We collect data from you directly, automatically when you visit or use the Topgolf Offerings and through cookies and other technologies, and sometimes from third parties. Some of this data may be considered "personal information" or "personal data," some of which may be considered "sensitive," under various applicable laws. We consider data that identifies you as a specific, identified individual to be personal data (such as your name, phone number, email address, etc.), and we treat additional data, including IP addresses and cookie identifiers, as "personal data" where required by applicable law.

Note that we may de-identify or pseudonymize personal data so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function commonly known as a "hash." We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized data as non-personal to the fullest extent allowed by applicable law. If we combine data that we consider to be non-personal with personal data, we will treat that combined data as personal data under this Privacy Notice.

The following chart sets out the category of personal data collected ("Category"), the purposes for which the data is collected ("A. Purposes"), the categories of third parties to whom the data may be disclosed for a business purpose ("B. Disclosed To"), and the categories of third parties to whom the data may be sold for monetary value or other valuable consideration or shared for cross context behavioral advertising/targeted advertising ("C. Sold/Shared To").

Please also see Section 2, Additional Details About Our Data Practices below the chart for additional information on certain types of personal data collection and use.

Category of Data A. Purposes for Collection; B. Categories of Third Parties the Data is Disclosed To C. Third Parties to Whom the Data is Sold/Shared for Targeted Advertising

Contact Information
This may include your first and last name, phone numbers, email address, and billing and shipping addresses. This may also include your social media handle. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments, as well as if you choose to participate in Toptracer Coach; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and at any golf facility operated by a third party ("TTR Operators") at which Toptracer Range is installed ("TTR Facilities") as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; administer your participation in sweepstakes and promotions; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, partner companies, corporate affiliates, and third party partners online and offline; provide you with information about new products or services, events at our Locations or TTR Facilities , events that Topgolf sponsors (such as contests, sweepstakes and surveys); analyze customer behaviors and trends, conduct research and analysis, and measure the effectiveness of our online and offline marketing efforts, and develop products, services and marketing programs; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, advertisements, and offers to you, both on our Topgolf Offerings and elsewhere online and offline, and enhance your experience at our Topgolf Offerings; identify your preferences; (4) Administrative: To verify your identity; recognize you across the Topgolf Offerings and your devices; communicate with you regarding your use of the Topgolf Offerings, content, or features and, in our discretion, updates to our policies; conduct sales auditing; (5) Employment Related Purposes: To facilitate your job search; process your employment application; prepare related governmental and internal statistics reports; (6) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (7) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (8) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (9) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (10) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Other Users; (2) Third party Advertising and Analytics Providers: Such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development; (3) Data Brokers; (4) Third party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (5) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (6) Social Media Platiorms; (7) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (8) Order Fulfillment Vendors: Such as payment processors, fulfillment centers, delivery services, order tracking vendors; (9) Communication Services Providers: Such as email delivery vendors; (10) Customer Service Providers: Such as call centers; (11) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (12) Topgolf Callaway Brands Family of Companies; (13) Golf coaches with whom you interact via Toptracer Coach; (14) TTR Operators; (15) Security Vendors; (16) Third parties in the course of a business transition; (17) Third parties to whom you agree or direct us to share your data; (18) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third party Advertising and Analytics Providers; (2) Third party Business Partners; (3) Data Brokers; (4) Social Media Platiorms; (5) Topgolf Callaway Brands Family of Companies.

Payment Information
This may include your credit or debit card number, expiration date, and other payment data. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration and managing your account; participate in golf lessons, leagues, and tournaments; book or participate in events at our Locations or TTR Facilities; provide customer service; (2) Administrative: To conduct sales auditing; (3) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (4) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (5) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (6) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Order Fulfillment Vendors: Such as payment processors; (2) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (3) Security Vendors; (4) Customer Service Providers: Such as call centers; (5) Government Agencies and Law Enforcement/Where Required By Law: Including third parties in connection with a court or other legal proceeding; (6) Third parties in connection in the course of a business transition; (7) Third parties whom you agree or direct us to share your data; (8) Other service providers who solely use your data to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: This category of data is not sold or shared for targeted advertising.

Transaction Information
This may include data about the products and services you purchased and considered; your returns, exchanges, and cancellations; when you ordered or received the products and services; and sweepstake or contest participation. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments, as well as if you choose to participate in Toptracer Coach; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; administer your participation in sweepstakes and promotions; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, partner companies, corporate affiliates, and third party partners online and offline; analyze customer behaviors and trends, conduct research and analysis, and measure the effectiveness of our online and offline marketing efforts, and develop products, services and marketing programs; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, advertisements, and offers to you, both on our Topgolf Offerings and elsewhere online and offline, and enhance your experience at our Topgolf Offerings; identify your preferences; (4) Administrative: To verify your identity; recognize you across the Topgolf Offerings and your devices; communicate with you regarding your use of the Topgolf Offerings, content, or features and, in our discretion, updates to our policies; conduct sales auditing; (5) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (6) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (7) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (8) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (9) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Third party Advertising and Analytics Providers: Such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development; (2) Third party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (3) Data Brokers; (4) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (5) Social Media Platiorms; (6) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (7) Order Fulfillment Vendors: Such as payment processors, fulfillment centers, delivery services, order tracking vendors); (8) Communication Services Providers: Such as email delivery vendors; (9) Customer Service Providers: Such as call centers and live and automated chat vendors; (10) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding); (11) Topgolf Callaway Brands Family of Companies; (12) Golf coaches with whom you interact via Toptracer Coach; (13) TTR Operators; (14) Security Vendors; (15) Third parties in the course of a business transition; (16) Third parties to whom you agree or direct us to share your data; (17) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third party Advertising and Analytics Providers; (2) Third party Business Partners; (3) Data Brokers; (3) Social Media Platiorms; (4) Topgolf Callaway Brands Family of Companies.

Device ID/Interaction Information
This may include details about the device you use the access the Topgolf Offerings, such as IP address, mobile device ID, other unique ID, device model, operating system version, device date and time, mobile network information, approximate location A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; administer your participation in sweepstakes and promotions; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, partner companies, corporate affiliates, and third party partners online and offline; provide you with information about new information, the site or advertisement that referred you to our Website. products or services, events at our Locations or TTR Facilities, events that Topgolf sponsors (such as contests, sweepstakes and surveys); analyze customer behaviors and trends, conduct research and analysis, and measure the effectiveness of our online and offline marketing efforts, and develop products, services and marketing programs; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, advertisements, and offers to you, both on our Topgolf Offerings and elsewhere online and offline, and enhance your experience at our Topgolf Offerings; identify your preferences; (4) Administrative: To verify your identity; recognize you across the Topgolf Offerings and your devices; communicate with you regarding your use of the Topgolf Offerings, content, or features and, in our discretion, updates to our policies; conduct sales auditing; (5) Employment Related Purposes: To facilitate your job search; process your employment application; (6) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (7) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect ours or others' rights or assets; (8) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (9) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (10) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Third party Advertising and Analytics Providers: Such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development; (2) Social Media Platiorms; (3) Data Brokers; (4) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (5) Communication Services Providers: Such as email delivery vendors; (6) Customer Service Providers: Such as call centers and live and automated chat vendors; (7) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (8) Topgolf Callaway Brands Family of Companies; (9) Security Vendors; (10) Third parties in the course of a business transition; (11) Third parties to whom you agree or direct us to share your data; (12) Other service providers who use your data solely to provide services to us or to you C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third party Advertising and Analytics Providers; (2) Social Media Platiorms; (3) Data Brokers; (4) Topgolf Callaway Brands Family of Companies.

User Account Information
This may include information such as username, password, security questions and answers, and setings. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, partner companies, corporate affiliates, and third party partners online and offline; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, advertisements, and offers to you, both on our Topgolf Offerings and elsewhere online and offline, and enhance your experience at our Topgolf Offerings; identify your preferences; (4) Administrative: To verify your identity; recognize you across the Topgolf Offerings and your devices; communicate with you regarding your use of the Topgolf Offerings, content, or features and, in our discretion, updates to our policies; conduct sales auditing; (5) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; (6) Personalization: To understand your preferences and tailor content, both on our Topgolf Offerings and elsewhere online; (7) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights or assets; (8) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (9) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (10) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers); (2) Security Vendors; (3) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with a court or other legal proceeding; (4) Topgolf Callaway Brands Family of Companies; (5) Third parties in connection with a business transition; (6) Third parties to whom you agree or direct us to share your data; (7) Other service providers who solely use your data to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: This category of data is not sold or shared for targeted advertising.

Information About Your Interests, Preferences, and Performance
This may include information derived from interactions with the Topgolf Offerings, including your searches or your posts to a community forum; your gameplay performance at Topgolf Offerings; and your participation in a market research request. This could include information about your lifestyle, golf game, and buying preferences. A. Purposes for Collection: (1) Provide You Services: To provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments, as well as if you choose to participate in Toptracer Coach; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, partner companies, corporate affiliates, and third party partners online and offline; provide you with information about new products or services, events at our Locations or TTR Facilities, events that Topgolf sponsors (such as contests, sweepstakes and surveys); analyze customer behaviors and trends, conduct research and analysis, and measure the effectiveness of our online and offline marketing efforts, and develop products, services and marketing programs; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, advertisements, and offers to you, both on our Topgolf Offerings and elsewhere online and offline, and enhance your experience at our Topgolf Offerings; identify your preferences; (4) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (5) Employment Related Purposes: If submited in connection with your job application, to facilitate your job search; process your employment application; prepare related governmental and internal statistics reports; (6) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (7) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (8) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (9) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Third party Advertising and Analytics Partners: Such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development; (2) Third party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (3) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (4) Social Media Platiorms; (5) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (6) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (7) Topgolf Callaway Brands Family of Companies; (8) Golf coaches with whom you interact via Toptracer Coach; (9) TTR Operators; (10) Security Vendors; (11) Third parties in the course of a business transition; (12) Third parties to whom you agree or direct us to share your data; (13) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third party Advertising and Analytics Providers; (2) Third party Business Partners; (3) Data Brokers; (4) Social Media Platiorms; (5) Topgolf Callaway Brands Family of Companies.

Demographic Data
This may include your age, date of birth, sex and/or gender, marital status zip code. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments, as well as if you choose to participate in Toptracer Coach; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; administer your participation in sweepstakes and promotions; (2) Advertising Activities and Marketing Messages: To send you offers and promotions from us, our advertisers, and third party partners online and offline; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, recommendations, and offers to you, both on our Topgolf Offerings and elsewhere online; identify your preferences; (4) Administrative: To verify your identity; recognize you across the Topgolf Offerings and your devices; communicate with you regarding your use of the Topgolf Offerings, content, or features and, in our discretion, updates to our policies; conduct sales auditing; (5) Employment Related Purposes: If submited in connection with your job application, to facilitate your job search; process your employment application; prepare related governmental and internal statistics reports; (6) Internal Business Purposes: To operate and improve the Topgolf Offerings, our products, and our services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (7) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (8) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (9) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (10) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Third party Advertising and Analytics Providers: Such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development; (2) Third Party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (3) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (4) Data Brokers; (5) Social Media Platiorms; (6) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (7) Customer Service Providers: Such as call centers and live chat vendors; (8) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (9) Topgolf Callaway Brands Family of Companies; (10) Golf coaches with whom you interact via Toptracer Coach; (11) TTR Operators; (12) Security Vendors; (13) Third parties in the course of a business transition; (14) Third parties to whom you agree or direct us to share your data; (15) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third Party Advertising and Analytics Providers; (2) Third Party Business Partners; (3) Data Brokers; (4) Social Media Platiorms; (5) Topgolf Callaway Brands Family of Companies.

Government Identification
Such as your social security number or other governmentissued ID A. Purposes for Collection: (1) Administrative: To verify your identity and age; (2) Employment Related Purposes: If submited in connection with your job application, to facilitate your job search; process your employment application; prepare related governmental and internal statistics reports; (3) Internal Business Purposes: To comply with legal obligations to process your application; detect and troubleshoot problems, fraud, and criminal activity; (4) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights or assets; (5) Security: To protect the integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (6) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (7) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (3) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (4) Topgolf Callaway Brands Family of Companies; (5) Security Vendors; (6) Third parties in the course of a business transition; (7) Third parties to whom you agree or direct us to share your data; (8) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: This category of data is not sold or shared for targeted advertising.

Precise/Specific Location Data
Such as your longitude/latitude coordinates from a global positioning system (GPS). A. Purposes for Collection: (1) Provide You Services: To estimate travel times and to locate a Topgolf Location near you; identify your nearest TTR Facility; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including identifying your location when participating in gameplay using our Applications; (2) Advertising Activities and Marketing Messages: To send you offers and provide special in-app features when visiting a Topgolf Location; (3) Personalization: To tailor and personalize the Topgolf Offerings, including our content, recommendations, and offers to you, both on our Topgolf Offerings and elsewhere online; identify your preferences; (3) Internal Business Purposes: To operate and improve the Topgolf Offerings and our products and services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (4) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (5) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; s (6) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (7) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Other Users; (2) Third Party Advertising and Analytics Partners: Such as analytics companies, affiliated marketing partners or unaffiliated third parties who are joint marketing and licensing partners or whose products or services are integrated in our Topgolf Offerings; (3) Third Party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (4) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (5) Social Media Platiorms; (6) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (7) Order Fulfillment Vendors: Such as payment processors, fulfillment centers, delivery services, order tracking vendors; (8) Communication Services Providers: Such as email delivery vendors; (9) Customer Service Providers: Such as call centers and live and automated chat vendors; (10) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (11) Topgolf Callaway Brands Family of Companies; (12) TTR Operators; (13) Security Vendors; (14) Third parties in the course of a business transition; (15) Third parties to whom you agree or direct us to share your data; (16) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third Party Advertising and Analytics Providers; (2) Third Party Business Partners; (3) Social Media Platiorms; (4) Topgolf Callaway Brands Family of Companies.

Photo/Video Data and Other User Generated Content
This may include videos captured in through our onpremises security cameras; your profile picture; images, audio recordings, video recordings, or text that you submit in connection with product reviews, survey responses, customer service interactions, or your resume and cover leter. A. Purposes for Collection: (1) Provide You Services: To process transactions and fulfill your orders; provide the Topgolf Offerings to you and allow you to participate in our games, features, and services, including registration, managing your account, and making a reservation; participate in golf lessons, leagues, and tournaments, as well as if you choose to participate in Toptracer Coach; book or participate in events at our Locations or TTR Facilities; display a member's first and last name or username on leaderboards at Locations and TTR Facilities as well as on any digital platiorm such as our online Topgolf Offerings (including the Toptracer Range application) and Social Sites and tracking your performance against other participants when you participate in gameplay; play on a Toptracer Range at a TTR Facility; provide customer service; communicate with you, such as responding to your questions, complaints, or comments and collecting your feedback; administer your participation in sweepstakes and promotions; (2) Internal Business Purposes: To operate and improve the Topgolf Offerings and our products and services; detect and troubleshoot problems, fraud, and criminal activity; analyze trends and usage paterns; market research; (3) Employment Related Purposes: If submited in connection with your job application, to facilitate your job search; process your employment application; prepare related governmental and internal statistics reports; (4) Legal: To resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation of public safety maters or investigations into claims of intellectual property infringement; fulfill regulatory reporting obligations; protect our or others' rights/assets; (5) Security: To protect integrity of the Topgolf Offerings; to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies; to protect health and safety of our users or the general public; (6) Business Transitions: In connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence; (7) Other Purposes as Disclosed at the time of collection or with your consent. B. Categories of Third Parties the Data Is Disclosed to: (1) Other Users; (2) Third Party Advertising and Analytics Partners: Such as analytics companies, affiliated marketing partners or unaffiliated third parties who are joint marketing and licensing partners or whose products or services are integrated in our Topgolf Offerings; (3) Third Party Business Partners: Unaffiliated parties that are joint marketing and licensing partners or distributors of Toptracer Range; (4) Technology Systems Service Providers: Such as webhosts, database hosts, cloud computing providers, sotiware-as-a-service providers, and technology maintenance and repair vendors; (5) Social Media Platiorms; (6) Sweepstakes/Contest Partners: Such as TTR Operators, administrators, other prize providers, prize fulfillment vendors, and sponsors/partners of the sweepstake/contest; (7) Order Fulfillment Vendors: Such as payment processors, fulfillment centers, delivery services, order tracking vendors; (8) Communication Services Providers: Such as email delivery vendors; (9) Customer Service Providers: Such as call centers and live and automated chat vendors; (10) Government Agencies and Law Enforcement/Where Required by Law: Including third parties in connection with a court or other legal proceeding; (11) Topgolf Callaway Brands Family of Companies; (12) Golf coaches with whom you interact via Toptracer Coach; (13) Security Vendors; (14) Third parties in the course of a business transition; (15) Third parties to whom you agree or direct us to share your data; (16) Other service providers who use your data solely to provide services to us or to you. C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: (1) Third Party Advertising and Analytics Providers; (2) Third Party Business Partners; (3) Social Media Platiorms; (4) Topgolf Callaway Brands Family of Companies.

 

2. Additional Details About Our Data Practices

 

a. Data Collected Automatically: Device ID/Interaction Information. When you interact with us through the Topgolf Offerings online, we and our third party business partners automatically collect and/or store certain information about your device when you visit or interact with the Topgolf Offerings ("Device ID/Information") and information about your activity on those Topgolf Offerings. This Device ID/Information may be stored and/or accessed from your computer, tablet, mobile device, or other device whenever you visit or interact with the Topgolf Offerings. Device ID/Information may include, but is not limited to: • Your IP address, mobile device identifier and other unique identifier • Device information, including device model, operating system version, device date and time, mobile network information • Approximate location of your device, which may be collected or inferred through other data we collect, such as IP address • How you use and interact with the Topgolf Offerings, including your search terms, pages you visit, content you view, videos you watch, your preferences and any other information you provide through chat or community forum features or submit through online forms Precise and Approximate Location Data. We may collect specific data about your location from your device. This may include your precise location. We may collect this using different types of technologies, including GPS and Wi-Fi. If you use our mobile app, we may also access your device's location data in the background. You may be able to turn off the collection of location data through your device settings. However, please note that we may still be able to collect or infer your approximate location through other data we collect, such as IP address. In addition, some mobile service providers may also provide us or our third party service providers with data regarding the physical location of the device used to access the Topgolf Offerings. Device ID/Interaction Information may be collected through the use of the following technologies: Cookies and Local Storage. The online Topgolf Offerings use cookies and related technologies ("Cookies") to enhance the browsing and usage experience on our online Topgolf Offerings. "Cookies" are small files or records that are placed on a visitor's device or browser (by a third party or us) to collect data about your activities on our online Topgolf Offerings. Cookies may be used for many purposes by us and third parties, such as: • To speed up navigation and provide you with custom-tailored content. • To remember the information you gave to us, so you do not have to re-enter it each time you visit the online Topgolf Offerings. • To monitor the effectiveness of certain marketing email campaigns. • To monitor the total number of visitors, pages viewed, and banners served on our online Topgolf Offerings. • To enforce limitations on downloads described for online coupons and other similar offers. • To automatically collect Device ID/Information. • To enable features. • To serve behavioral based advertisements. • For analytics. • To market our products and services to you. • As detailed below, we also allow certain partners to place Cookies on our online Topgolf Offerings to provide personalized marketing to you. You can find more information about Cookies and how they work at allaboutcookies.org. Certain Browsers or Browser Add-Ons. Certain browsers or browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to Cookies, and some of the content included on the online Topgolf Offerings may make use of this local storage. Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our online Topgolf Offerings and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a website or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the online Topgolf Offerings, to monitor how users navigate the online Topgolf Offerings, to count how many emails that were sent were actually opened, or to count how many particular links were actually viewed. Embedded Scripts. An embedded script is programming code that is designed to collect data about your interactions with the online Topgolf Offerings, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the online Topgolf Offerings and is deactivated or deleted thereatier. Data Collection from Mobile Devices. We use embedded scripts and the tools provided in Sotiware Development Kits ("SDKs") to collect data through mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. SDKs are sotiware packages that contain a set of tools that can be used to help build applications and implement new features in existing apps including those that collect information from your device. Session Replay Technology. Topgolf may record through session replay technology your interactions with the Topgolf Offerings, such as what pages you visit on the Topgolf Offerings, how long you visit those pages, the links you click, your mouse movements, keystroke or scrolling activity or information you provide to us. These tools may also record information when you interact with the Topgolf Offerings, such as by engaging in chat features or forum discussions. If collected, we will use this data for our internal business purposes, such as for website analytics, to improve the Topgolf Offerings and our products and services, and to address functionality issues. In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, online functionality, and operational purposes. b. Data We Receive or Collect from Third Parties. In General. We may also receive data about you from third parties, including other users who add you to a reservation, your coach in "Toptracer Coach", third party business partners (including companies that assist us with online advertising and analytics), and data providers. For example, if you are on another website and agree to receive data from Topgolf, that website will forward your data to us so that we may contact you. We may also supplement the data we collect with outside records from third parties — such as public databases, publicly available social media pages, joint marketing partners, and third parties who enhance the data we have about you for various purposes, such as to provide you with information, services, or products, to tailor our content and the offers we show you, or to enhance our products and services. If you are an existing user of any Topgolf Offering, or later become a user of any Topgolf Offering, we may combine the data we receive from you with data about you from other sources to beter understand your interests and preferences and beter market our products and services to you. We may combine the data we receive from third parties with data we collect through the Topgolf Offerings. In those cases, we will apply this Privacy Notice to the combined data. The data collected and stored by the third party is subject solely to the third party's privacy practices. Forward to a Friend Features and Data You Provide About Others. The Topgolf Offerings may give you the opportunity to forward information to a friend to facilitate your visit to one of our Locations. If you send a friend a communication with the assistance of the Topgolf Offerings, the data you or they provide is used to facilitate the visit to our Locations and is not used for any other marketing purpose, unless we obtain consent from that person. If you otherwise disclose any personal data relating to other people to us, you represent that you have the authority to do so and permit us to use the data in accordance with this Privacy Notice. On-Premises Security Camera Data Collection. If you visit one of our Locations or other offline Topgolf Offerings, we may also collect data about you through our on-premises security cameras for security, loss prevention, employee safety, investigations, and other legitimate video surveillance purposes. Social Site Information Collection and Use. The online Topgolf Offerings may permit you to interact with a third party social media site ("Social Site"), for example, by including a button allowing you to link to a third party platform (such as Instagram or TikTok) or interacting with you through your social media account ("Social Site Features"). When you access a Social Site through our online Topgolf Offerings or use or access any of our products and services or communicate with us by way of a Social Site, including Social Sites where you can play our electronic games, both we and the Social Site may have access to certain data about you and your use of the online Topgolf Offerings and the Social Sites. The Social Sites may collect data about your visit to the online Topgolf Offerings through Social Site Features we have integrated into the Topgolf Offerings. The personal data you allow us to access varies by game and Social Site, and it is affected by the privacy settings you establish at the Social Site. You can control and find out more about these settings at the Social Site where you play our games or otherwise access our content or interact with us. For example, we may access and store some or all of the following data, as allowed by you, the Social Site, and your preferences; your first and last name; your profile picture or its URL; your user ID number, which is linked to publicly available personal data such as name and profile photo; the user ID numbers for your friends that are also connected to us or our game(s); and the login email you provided to that Social Site when you registered. Note that through the Social Site Features, these Social Sites may be able to collect certain data about your visits to the online Topgolf Offerings regardless of whether or not you affirmatively interact with the Social Site Features and whether or not you are logged into (or have) an account with the Social Site. If you use the Social Site Features, your interaction and personal data may be publicly disclosed on the Social Site. By accessing our products and services or otherwise communicating with us through a Social Site, you understand we will collect, store, and use, in accordance with this Privacy Notice the personal data that you have allowed the Social Site to provide to us, or that we collect through the Social Site, including through an Application Programming Interface ("API"). To manage the personal data we receive about you from the Social Site where you play our games or interact with us, you will need to follow the instructions at that Social Site for updating your personal data and changing your privacy settings. Once we receive your personal data from a Social Site, that personal data is stored and used by us as set out in this Privacy Notice, and you may access and update that personal data as described below. c. Data You Provide Directly. We may ask you to provide data to use when you use the Topgolf Offerings. User Generated Content and Public Postings. The Topgolf Offerings may provide you the opportunity to register and participate in posting content publicly in forums, through interactive features such as leaderboards at Locations and TTR Facilities as well as on any digital platform such as our online Topgolf Offerings (including the Toptracer App) and Social Sites. Those forums may ask you to create an account, may allow you to submit or post photographs, questions, comments, reviews, or other content (collectively "User Content"). If you participate in these features, certain data will be made available to other users or the public. For example, your participation in the leaderboards at Locations and TTR Facilities will allow Topgolf to display the information you provide, including personal data, on the leaderboards at Topgolf Offerings. organize certain submissions (such as images you upload) into public or private albums Sweepstakes, Contests, & Promotions. We may, with our third party partners, offer sweepstakes, contests, or other promotions (any of which, a "Promotion") that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal data may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfilment, as required by law, or as permited by the Promotion's terms or official rules (such as on a winner's list). If you decide to enter a Promotion that is co-sponsored by a third party partner, the personal data that you provide will be shared with us and with them. Their use of your personal data in this context is not governed by this Privacy Notice. Promotions may also include contests or other promotions conducted by TTR Operators or at TTR Facilities– for example a closest-the-pin contest at your local range ("TTR Operator Promotions"). While TTR Operator Promotions are facilitated by the Toptracer Range system, they are solely arranged and promoted by TTR Operators, not by Topgolf. TTR Operator Promotions are subject to the terms of entry set by the TTR Operator, which may include additional uses of your personal data, and you should read these carefully before participating. If you enter a TTR Operator Promotion, your personal data will be shared with the TTR Operator in connection with the administration of such TTR Operator Promotion, including in connection with winner selection, prize fulfilment, as required by law, or as permited by the TTR Operator's terms of entry (such as on a winner's list). The TTR Operator's use of your personal data in this context is not governed by this Privacy Notice. Employment Applications. If you apply for a job through our Topgolf Offerings, we or our Service Provider(s) may ask you to provide self-identifying information such as your veteran status, gender, ethnicity, education information, eligibility to work in the United States, and work history in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints. Please note that we may utilize a careers portal that is operated by a third party, in which case, your registration and use of the careers portal may be subject to the third party's privacy practices as disclosed on the portal. Photos and Videos. We allow you to post photos and videos on the Topgolf Offerings or to submit them to us as described in the chart above. Applicable laws and regulations may vary with respect to whether such materials are considered to be biometric information. For clarity, we do not create a record of facial geometry from your photos or videos and do not use your photos or videos for the purposes of facial recognition, facial surveillance, or otherwise as a biometric identifier. Please note, however, that to the extent that you post your photos or videos publicly on our Topgolf Offerings, or we share – as described elsewhere in this Privacy Notice – such materials with third parties who are permited to use these materials in accordance with their own privacy policies, we do not control the actions of third parties, and their use of your photos or videos may differ from ours. d. Data We Disclose to Third Parties. We may share non-personal data that we collect, such as certain Device ID/Interaction Information, aggregate user statistics, and hashed or otherwise deidentified or pseudonymized data (including email addresses), with third parties in our discretion as permited by law, including for targeted advertising purposes. In addition to the specific situations discussed elsewhere in this Privacy Notice, we share personal data as disclosed at the time you provide it, with your consent, and in the situations described below. Topgolf Callaway Brands Family of Companies. Topgolf is a member of the Topgolf Callaway Brands Family of Companies. Topgolf shares data across the Topgolf Callaway Brands Family of Companies for internal business, analytical, operational, and marketing purposes. Service Providers. We use service providers and sub-processors ("Service Providers") to provide services to us or on our or your behalf, such as payment processing, customer relationship management, scheduling bookings (e.g., events, reservations, and golf lessons), food and beverage, information technology, employment application tracking, communications, and insurance. We give these Service Providers access to your personal data (or allow them to collect data from or about you) so that they can provide these services. Unaffiliated Third Parties and Otherwise at Your Request or with Your Consent. We may ask if you would like us to share your data with unaffiliated third parties who are not described elsewhere in this Privacy Notice and we may permit partner companies and other third parties to collect your data directly from you, with your permission. We do not share your personal data with third parties for those third parties' direct marketing purposes unless you consent (opt-in or opt-out) to such sharing. For example, you may be presented with an opportunity to receive marketing offers from a third party or you may engage with a Social Site platform or other third party application or feature, through which data about you is shared. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. We do not sell or rent for monetary compensation to third parties any of the personal data that you provide to us through the Topgolf Offerings or authorize any of our Service Providers to sell or rent any such personal data for monetary compensation, and we do not authorize any of our Service Providers to make independent use of your personal data for their own purposes, including but not limited to direct marketing. Aggregated data about customers utilizing the Topgolf Offerings, in surveys or otherwise providing data to Topgolf will be utilized by Topgolf and/or Service Providers in connection with research, benchmarking and other like uses related to general usage analytics. TTR Operators. When you visit TTR Facilities, the TTR Operators may share certain data about you with us (as described above) and we may also share certain data with the TTR Operator. This occurs, in part, through the Toptracer App and the Toptracer Range Management System. TTR Operators often utilize the Toptracer Range Management System, which aggregates and presents data related to the operation of TTR Facilities, to support customer relations management and various business operations and activations (e.g., the configuration of leaderboards). The data we share with the TTR Operator may include your personal data, which the TTR Operator may use for the purposes of directly sending you communications and promotional materials regarding their services, or through the Topgolf Offerings. Please note that we are not responsible for the privacy practices of TTR Operators and the personal data you disclose to TTR Operators is subject to their privacy practices. TTR Operators and TTR Facilities are not owned or operated by Topgolf Offerings. Toptracer Coach. Individuals who participate in our coaching platform ("Toptracer Coach") join an interactive coaching experience where coaches create custom lesson plans tailored to each unique student. If you choose to participate in Toptracer Coach, your designated coach will have access to certain personal data, including your name, email address, account and profile information, performance data, and Toptracer Range usage data (including locations and dates/times) to provide them with an objective view of your current skillset, allowing your coach to follow-up on your performance, set new goals, and assist you with reaching your objectives. Business Transfers and Transitions. In case of a transfer or sale of some or all our business or assets, bankruptcy, or merger, or other corporate transaction (including, without limitation during the negotiation stage and in the course of any due diligence process), we may transfer or assign your personal data to those involved in such a transfer or sale of business or assets, which you agree that we may do without your further consent. Government Agencies and Legal Reasons. We may transfer and disclose your personal data (i) in response to subpoenas, warrants, court orders, or in connection with any legal process, or to comply with relevant laws or (ii) at the request of governmental authorities conducting an investigation. In addition, notwithstanding any term to the contrary in this Privacy Notice, we reserve the right to use and disclose your personal data to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Terms and Conditions or other applicable policies.

 

3. Third Party Advertising & Analytics/Privacy Controls (Ad and Cookie Notice)

 

We use third party advertising companies, ad agencies, analytics providers, and network advertisers to target and serve ads when you visit our online Topgolf Offerings and elsewhere online and offline, and to provide us with data regarding use of our Topgolf Offerings and effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including Cookies), and they may otherwise collect or have access to certain data about your use of the Topgolf Offerings. Some of these companies may collect personal data over time when you visit and/or access the online Topgolf Offerings or other online websites and services. We also use third party partners or technologies to collect information to help us improve your user experience, monitor and improve the effectiveness of the Topgolf Offerings, and to facilitate communications and customer service. We may share data, typically data that has been aggregated, pseudonymized or de-identified, Device ID/Information, and location data with third party advertising companies, analytics providers, and other third parties for these purposes. If you would like to opt-out of third party advertising and analytics, there are a variety of tools available to you: • Our Tools. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please adjust your settings by clicking the link in the footer titled "Manage Cookie Preferences". Certain jurisdictions provide their residents further rights, if you are a resident of such a jurisdiction, please see Section 12, Jurisdiction-Specific Rights below regarding additional rights you may have. • Do Not Track. Please note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services that you visit. When you choose to turn on the "Do Not Track" settings in your browser, your browser will send a signal to websites, analytics providers, advertisements networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about and to set up "Do Not Track", please visit https://allaboutdnt.com. • Global Privacy Control. Global Privacy Control ("GPC") is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with respect to third party online tracking. To find out more about and to set up GPC, please visit https://globalprivacycontrol.org/#about. • NAI/DAA Opt-Out. We use a variety of third parties to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA"). You may wish to visit https://optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interestbased advertising. You may also want to visit https://optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. Note that these are cookie-based opt-outs. If you disable your Cookies or upgrade your browser after opting out, or if you use different devices or browsers, you will need to indicate your opt-out choices across those other devices and browsers. European Union and United Kingdom residents, please refer to the European Digital Advertising Alliance ("EDAA") choice page by going to https://www.youronlinechoices.com/. Australian and South Korean residents, please refer to DAA's choice page by going to https://youradchoices.com/control. Mobile devices may contain settings that allow you to disable tracking advertising and analytics. In addition, the digital advertising industry has provided the ability for mobile users to register their intent not to receive targeted advertising at https://aboutads.info/appchoices. • Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze data about use of the Topgolf Offerings and provide other report. This service may also collect data regarding the use of other websites, apps, and online services. You can learn about Google's practices by going to https://google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online. Your opt-out choices are browser and device specific; if you disable your cookies or upgrade your browser atier opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers. When you visit the Topgolf Offerings, read our emails, or otherwise engage with us through a computer or mobile device, we automatically collect information you provide to us and information about how you access and use the Topgolf Offerings and the device you use. For example, we collect information about the pages you visit, links you click on, videos you watch, purchase or browsing information, as well as information you provide when you engage in chat or community forum features on the Topgolf Offerings. We may use third party vendors or technologies to collect this information. Typically, this information is collected through the following methods or technologies: • Cookies. Cookies are small data files that download onto your computer or other device when you visit the Website or otherwise access our online content on certain websites. Cookies may be used for many purposes. We use both session cookies (which are deleted when you close your browser) and persistent cookies (which remain on your computer or other device atier the browser has been closed). To learn more, visit htps://allaboutcookies.org or htps://www.youronlinechoices.eu. • Web Beacons. Small graphic images or other web programming code called web beacons (also known as "pixel tags," "1x1 GIFs," or "clear GIFs" may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons and similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed. • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Topgolf Offerings, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is only active while you are connected to the Topgolf Offerings and is deactivated or deleted thereafter. • Session Replay Technology. We may record your interactions with the Topgolf Offerings' user interfaces, including what pages you visit on our Websites and how long you visit those pages, the links you click, and your path through our Websites. We capture this for analytics purposes, solely for our internal business purposes, to improve the Topgolf Offerings and our products and services as well as to address functionality issues. • Other. APIs, mobile software development kits (SDKs) and similar technology or tools. All of the information collected automatically through these tools allows us to enhance and personalize your user experience and to monitor and improve the effectiveness of the Topgolf Offerings, offers, advertising, communications and customer service. We may also use the information collected automatically through the Topgolf Offerings in order to: • analyze user traffic to the Topgolf Offerings and usage trends to understand more about the demographics and behaviors of our players; • recognize past players and remember preferences; • store your password if you are registered; • integrate with third-party social media websites; • facilitate your purchases; • serve you with advertising content in which we think you will be interested; • understand the effectiveness of our advertisements and conduct research regarding the usefulness of certain advertisements to you; • prevent you from seeing the same advertisements too many times; • combine information we have collected about you from multiple sources; and • better understand our audience, our players, users of the Topgolf Offerings, and their respective interests. We and our partners display interest-based advertising using information gathered about you over time across multiple websites or other platforms (including websites and apps). Third parties, including advertising and analytics companies, set their own cookies and similar tracking technologies on the Topgolf Offerings. We and third parties might link information automatically through cookies and other tracking technologies to your name or email address or other information, including past purchases made offline or online. Interest-based advertising or "online behavioral advertising" includes ads served to you after you leave our website, encouraging you to return. They also include ads we think are relevant based on your browsing habits or online activities. These ads might be served on third-party websites or on apps. They might also be served in emails. We might serve these ads, or third parties may serve ads. They might be about our products or services or other companies' products or services.

 

4. Your Choices About the Data We Collect

 

Marketing Messages from Us. You may opt-out of marketing communications as set forth below. • Email. You may unsubscribe from marketing emails we send you through the opt-out mechanism included in each such email. Note, however, that we reserve the right to send you certain communications relating to your use of our products or services, notices of changes to this Privacy Notice or other terms, or similar administrative and transactional messages. • Text Messages. Personal data obtained from you in connection with a SMS/text message service may include your mobile phone number, your carrier's name, the date, time and content of your messages, and other information you provide to us as part of this service. You can unsubscribe at any time by texting "STOP" to the number provided in the SMS/text message. A SMS/text message will be sent confirming your removal. We reserve the right to remove subscribers from our messaging database. For more info, text "HELP" to the number provided in the SMS/text message. • Push Notifications. Topgolf Offerings, a TTR Operator, or TTR Operator Promotion partner may send promotional and non-promotional push notifications or alerts to your mobile device. You can elect to stop receiving those messages at any time by changing the notification settings on your mobile device. Data Privacy Choices. • Updating and Deleting Your personal data. Some of our online Topgolf Offerings may allow you to modify or delete your account profile. Note that we may keep some personal data as permitted by law. • Other Privacy Rights. You may have additional specific rights depending on where you are a resident, please see Section 12, Jurisdiction-Specific Rights below.

 

5. Links to Other Websites and Online Services

 

The online Topgolf Offerings may provide links to websites, gaming platforms, and online services operated by third parties. These third parties use their own cookies and other tracking technologies on your device, and they may independently collect personal data from you. We assume no responsibility for third parties or their privacy practices. This Privacy Notice applies only to our Topgolf Offerings.

 

6. Children's Privacy

 

Except as noted in Section 12(c), Notice to European Economic Area/United Kingdom Residents, our Websites and Applications are directed to persons who are at least thirteen (13) years of age, and we do not knowingly collect any personal data from children younger than the age of thirteen (13) years. If a parent or guardian is made aware that a child under the age of thirteen (13) years has provided us with personal data through any point of contact, please call us toll-free at +1 (833) 554-0955 or write to us at the contact details below (see Section 11, Contact Us), and we will delete the personal data. If we have actual knowledge that personal data about a person younger than the age of thirteen (13) years has been collected without parental/guardian consent, then we will take the appropriate steps to delete such personal data.

 

7. Security of Your Personal Data

 

Although we cannot guarantee that there will never be a security problem (no system, data transmission over the Internet, wireless transmission, or electronic storage of data can be guaranteed to be 100% secure), we have in place commercially reasonable security measures to guard against the loss or misuse of personal data collected through the Topgolf Offerings. However, we cannot guarantee or warrant the security of any data you disclose or transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. In the event that we are required by law to inform you of a breach to your personal data, we may notify you electronically, in writing, or by telephone, if permitted to do so by applicable law. You use the Topgolf Offerings and provide us with data at your own initiative and risk.

 

8. Retention and Destruction of Your Personal Data

 

For personal data that we collect and process, we typically keep such personal data for as long as necessary to fulfill the purposes for which it was collected or for which you subsequently authorize it and otherwise to carry out the purposes described in this Privacy Notice, and as otherwise permitted by applicable law or needed to address tax, corporate, compliance, litigation, insurance claims, and other legal rights and obligations. Data that has been anonymized and aggregated is not personal data, and we will keep such data in accordance with our retention policy.

 

9. Consent to Cross-Border Transfers of Data

 

Topgolf is headquartered in the United States. If you use a Topgolf Offering outside of the United States, and provide us with data, you acknowledge and agree that your personal data may be processed for the purposes identified in this Privacy Notice. Please be aware that data that we collect will be transferred to and processed in the United States and other jurisdictions. By using the Topgolf Offerings outside of the United States, you specifically consent to our collection, processing, storage, or transfer of your personal data in the United States and other jurisdictions, including in countries where data protection standards may differ from those in the country where you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States and other countries may request to access your personal data in accordance with the laws of that jurisdiction.

 

10. Changes In Our Privacy Notice

 

To the extent allowed by applicable law, Topgolf reserves the right to change our Privacy Notice at any time without prior notice. Topgolf will notify of material changes by posting the changed or modified Privacy Notice by revising the "Last Updated" date at the top of this Privacy Notice. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Notice unless otherwise specified. Your continued use of the Topgolf Offerings after the effective date of the revised Privacy Notice will constitute your consent to those changes to the fullest extent allowed by applicable law. However, Topgolf will provide notice and obtain your consent (opt-in or opt-out) if required by applicable law. Note that you may need to consent to the revised Privacy Notice in order to continue to use the Topgolf Offerings.

 

11. Contact Us

 

If you have any questions regarding this Privacy Notice or you wish to exercise any of your data subject rights, you can contact us at the following mailing address: Topgolf International, Inc. Attn: Privacy Team 8750 N. Central Expressway, Suite 1200 Dallas, TX 75231 Controllers by Country Country Company Address Sweden Topgolf Sweden AB (EU/EEA Representative) Svärdvägen, 3A, SE-182 33 Danderyd, Sweden Japan Topgolf Japan GK c/o Baker & McKenzie, Ark Hills Sengokuyama Mori Twr. 28F, 1- 9-10 Roppongi, Minato-ku, Tokyo United Kingdom Topgolf Limited (UK Representative) Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA United Kingdom Topgolf Group Limited Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA United Kingdom World Golf System Group Limited Unit 8 Shepperton Business Park, Govett Avenue, Shepperton TW17 8BA United States of America Topgolf International inc. N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 United States of America Topgolf USA LLC N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 United States of America Topgolf Pro LLC N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 United States of America Topgolf Payroll Services LLC N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 United States of America Topgolf Media Services LLC N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231 United States of America World Golf Tour LLC N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231

 

12. Jurisdiction-Specific Rights

 

Residents of certain jurisdictions may have the ability to exercise additional rights and choices regarding their personal data. We will take reasonable steps to accommodate your request but may need to verify your identity before doing so. If you are a resident of a jurisdiction with specific rights, please see additional information below. a. U.S. States i. Colorado, Connecticut, Utah, and Virginia. We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Virginia, Colorado, Connecticut, and Utah have certain privacy rights with respect to this data, as described below. If you are a Consumer residing in one these states (as defined in each state's respective law) and would like to exercise your applicable rights, please complete this form or call (833) 554-0955. o Access Your Data/Data Portability (CO, CT, UT, VA Residents) - To confirm whether we are processing your personal data and request to access such data, please complete the form. This includes to obtain a copy of the personal data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability. o Delete Your Data (CO, CT, UT, VA Residents) – Request to delete your personal data. o Correct Your Data (CO, CT, VA Residents) – Correct the personal data we hold about you. o Opt-Out of Targeted Advertising – Topgolf engages in online advertising practices (and certain analytics or similar activities) that may be considered "targeted advertising" under these states' laws. To disable sharing through cookies set by third parties that may be considered targeted advertising under such laws, please adjust your settings by clicking the link in the footer titled "Manage Cookie Preferences". Please also review Section 3, Third party Advertising &Analytics/Privacy Controls above for information on industry tools and device settings that may be available to you. o Opt-Out of Sales of Your Personal Data – Topgolf may sell your data as defined by CO and CT. To opt-out of the sales of your personal data please complete this form. o Right to Appeal (CO, CT, VA Residents) - If, for any reason, you would like to appeal our decision relating to your request and you are a resident of Colorado, Connecticut, or Virginia, you have the right to submit an appeal and can do so by submitting this form. Please include your full name, the basis for your appeal, and any additional information to consider. o Sensitive Data – If you are a Virginia, Colorado, or Connecticut resident, we will obtain your consent to the processing of any Sensitive Data (as defined by the applicable state law) we collect. If you are a resident of Utah, we will notify you at or before the time of collection of Sensitive Data (as defined by Utah law) and provide you with an opportunity to opt-out of the processing. ii. Nevada. Nevada S.B. 220 provides consumers with the ability to opt out of the sale of their personal data. We do not sell your personal data as defined in S.B. 220. However, you may still submit an opt-out request, and if our practices were to change in the future, we would honor your request. If you are a Nevada resident and would like to opt out of the sale of your covered information, your request must be submitted by calling toll-free at (833) 554- 0955 or writing to us at the following mailing address: Topgolf, Attn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. Your request must include your full name, street address, city, state, zip code, and a valid email address so that we can contact you if needed regarding your request. If you previously provided a phone number, including it will assist us in making sure we identify you as someone who wants to opt out. You may be required to take reasonable steps as we determine from time to time to verify your identity and/or the authenticity of your request. iii. California. If you are a California resident, please see Section 13, our Notice To California Residents for additional information about your privacy rights and how to exercise them. b. Notice to Australian Residents. If you are a resident of Australia, the following information applies. Identity and Contact Information – The Topgolf Offerings are owned and operated by Topgolf International Inc. and our address is N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. If you have any questions, concerns, or comments about the Topgolf Offerings, please reach out by calling +1 (833) 554-0955 or writing to us at the following mailing address: Topgolf, Atn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. Likely Overseas Disclosure – Personal data we collect may be disclosed to overseas recipients that are located in the United States or any other country in which we or our subcontractors maintain facilities. We rely on your consent to facilitate this disclosure in the United States and other jurisdictions, where laws regarding processing of personal data may be less stringent than the Australian Privacy Principles. In certain cases, we may rely on appropriate safeguards such as standard contractual clauses as a basis for the overseas disclosure. Your Rights to Access and Correct Your Personal Data - You have the right to access and correct inaccuracies in your personal data in our custody and control, subject to certain exceptions prescribed by law. You may request access and corrections of inaccuracies in your personal data we have in our custody or control by writing to us at the following mailing address: Topgolf, Atn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records. Third Party Advertising. As discussed above, we work with certain third party advertising companies in connection with our online advertising and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. Please refer to EDAA's choice page at htps://www.youronlinechoices.com to learn more about your choices related to advertising with respect to participating EDAA member companies. Complaints and Resolving Concerns - If you have any questions or comments about this Privacy Notice or if you otherwise have a question or complaint about the manner in which we or our service providers treat your personal data, you may contact us by writing to us at the following mailing address: Topgolf, Atn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. You may also obtain further information about your privacy rights from the Office of the Australian Information Commissioner (OAIC) at htps://www.oaic.gov.au. OAIC has authority to investigate complaints and claims for compensation in appropriate cases. c. Notice To European Economic Area/United Kingdom Residents If you are a resident of the European Union ("EU"), other European Economic Area ("EEA") countries, or of the United Kingdom ("UK"), the following information applies. Purposes of processing and legal basis for processing: We process personal data for the purposes and on the following legal bases listed below: Context Types of Data Primary Purpose for Collection and Use of Data Account Registration We collect your name, gender, age, and contact information when you create an account at our Topgolf Offerings. We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account-related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. Cookies and First Party Tracking We use cookies and clear GIFs. "Cookies" are small pieces of information that a website sends to a computer's hard drive while a website is viewed. We have a legitimate interest in making our online Topgolf Offerings operate efficiently. Cookies and Third party Tracking We participate in behaviorbased advertising, this means that a third party uses technology (e.g., a cookie) to We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics. collect information about your use of our online Topgolf Offerings so that they can provide advertising about products and services tailored to your interests on our online Topgolf Offerings, or on other websites. Demographic Information We collect personal data, such as your age, gender or location. We have a legitimate interest in understanding our users and providing tailored services. Geolocation Information We may collect geolocation data based on your use of the Topgolf Offerings. We have a legitimate interest in understanding the location of our users. Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We have a legitimate interest in understanding how you interact with our communications to you. Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. We use information about current employees to perform our responsibilities as an employer. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations. Feedback/Support If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues. Game Activity When you participate in gameplay at one of our Locations or TTR Facilities or through the online Topgolf Offerings or when playing Toptracer Range we will collect We have a legitimate interest in keeping track of your performance in games to effectively deliver our services to you. information necessary to track your performance against other participants. Golf Lessons and Leagues We collect your information when you sign up for golf lessons or leagues at one of our Locations or TTR Facilities. We have a legitimate interest in communicating with you regarding your golf lessons or league participation. Coaching If you as a player use our online coaching Topgolf Offering ("Toptracer Coach"), we will use your name and e-mail address to manage your invitation and your account information and game activity to track your performance against set goals, assignments and targets. Your performance information will also be shared with your designated coach to allow the coach to follow-up on your performance, set new goals and coach you. We have a legitimate interest to effectively deliver our services to you. Incident Reporting If there is a circumstance in which an incident takes place at one of our Locations, we may collect information from you to ensure the incident is properly recorded and remedied. We have a legitimate interest in resolving any incidents that take place at our various Locations. Mailing List When you sign up for one of our mailing lists, we collect your email address or postal address. We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. Mobile Devices We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Websites, Applications, or when visiting one of our Locations or TTR Facilities. We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. Order Placement We may collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order. We use your information to perform our obligations to provide you with products or services. Partner Promotion We may collect information that you provide as part of a cobranded promotion with another company. We have a legitimate interest in fulfilling our promotions. Reservations We collect your information that you provide in order to make a reservation at one of our Locations. We have a legitimate interest in facilitating your ability to make advance reservations to one of our Locations. Surveys When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party's privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions and collecting information relevant to our organization. Sweepstakes or Contests When you participate in a sweepstakes or contest, (including a TTR Operator Promotion) we collect information about you which includes contact information to notify you if you are selected. We have a legitimate interest in operating or facilitating the sweepstakes or contests. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. Ticketing Information When you purchase tickets to one of our events, such as a special event at one of our Locations, admission to one of our camps/academies, or a musical performance, we collect information about you to process the transaction, which includes your contact information and credit card information. We have a legitimate interest in fulfilling your ticket purchase order. Online Topgolf Offering Interactions We use technology to monitor how you interact with our online Topgolf Offerings. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. We have a legitimate interest in understanding how you interact with our online Topgolf Offerings to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. Web Logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our online Topgolf Offerings. Among other things, it helps us understand which of our services is the most popular. Although the table above describes our primary purposes in collecting your personal data, in many situations we have more than one purpose. For example, if you complete an online purchase, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information atier your transaction is complete so that we can quickly and easily respond to any questions about your purchase. As a result, our collection and processing of your personal data is based in different contexts upon your consent, our need to perform a contract, our obligations, and rights under law, and/or our legitimate interest in conducting our business. For these processing activities, we require our Service Providers to provide technical and organizational security measures and to only use your personal data on our behalf if they are a processor or a sub-processor. For more information on our use of Service Providers, including a current list of authorized sub-processors, please contact us at the contact details set out below (see Section 11, Contact Us). In some cases, third parties may be a controller in their own right (for example, if you choose to participate in TTR Operator Promotions, third party promotions, contests/sweepstakes, surveys, or click through to a third party website from the online Topgolf Offerings). Third party controllers are responsible for the processing of your personal data, and you should carefully review their privacy notice and policies before providing your personal data. Controllers Whenever dealing with one of the Topgolf corporate affiliates, the controller of your personal data will be the entity that decides how and why your personal data is used. For the purposes of data protection laws, Topgolf and its corporate affiliates are "joint controllers" for the processing of your personal data described in this Privacy Notice. This means that Topgolf and its corporate affiliates work together to decide why and how your personal data is processed. Depending on the reason for the sharing of your personal data, corporate affiliates may be a joint controller with Topgolf or other corporate affiliates, a controller in their own right, or a processor. For more information on how corporate affiliates process your personal data please contact us at the contact details set out above (see Section 11, Contact Us). Regarding data processing within the framework of Topgolf's and its corporate affiliates' internal administration and joint procedures through centralized systems, Topgolf and its corporate affiliates are jointly responsible as joint controllers and controllers in their own right. The joint processes particularly pertain to the operation and use of jointly used databases, platiorms, and IT systems. With respect to the joint processes, Topgolf and its corporate affiliates jointly determine the purposes and means of processing. Topgolf and its corporate affiliates use a shared IT services and infrastructure and has legitimate (joint) interests as per Recital 48 of GDPR in group-wide data organization and administration including the exchange of personal data for internal administrative purposes such as to ensure compliance and a consistent approach to compliance within the Topgolf Group. In an agreement on joint controllership under Article 26 GDPR, Topgolf and its corporate affiliates have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfills which data protection obligations. In particular, it was determined how an appropriate level of security and your rights as a data subject can be ensured, how the information duties under data protection law can be fulfilled jointly, and how potential data protection incidents can be monitored. This also includes ensuring that reporting and notification obligations are fulfilled. We do not perform all processing of your personal data as joint controllers. Topgolf makes decisions about certain processing of your personal data independently of other corporate affiliates, for which Topgolf is solely responsible. Similarly, Topgolf's corporate affiliates make decisions for certain processing of your personal data independently of Topgolf, for which such corporate affiliates are solely responsible and controllers in their own right when processing your personal data independently. Topgolf is your central contact point. You can also assert your rights regarding the processing of personal data in joint controllership by other corporate affiliates. Should you contact us, Topgolf will coordinate the response in accordance with the aforementioned agreement pursuant to Article 26 GDPR in order to respond to your inquiry and to guarantee your rights as a data subject. International Transfers • Shared Services. Topgolf and its corporate affiliates are part of a single group of companies who have a legitimate interest in sharing personal data under Recital 48 of GDPR. As such your personal data is transferred to the United States where certain of our IT systems are located. • Global Offerings. As we offer the ability to play and benefit from services at the Topgolf Offerings globally (including Locations and Toptracer Range), we will transfer your personal data within Topgolf's corporate affiliates for the purposes of fulfilling your contract with us, providing the benefits of global membership, and/or facilitating gameplay at the Topgolf Offerings. • Business Operations. personal data we collect from you may be transferred to, stored by, or accessed by our corporate affiliates and our and their Service Providers. We transfer personal data for the purposes of fulfilling your contract with us, in our legitimate interests, and, if needed, with your consent. Topgolf and its corporate affiliates and our and their Service Providers may be located outside of the UK/EEA/EU and may not benefit from an adequacy decision issued by the relevant data protection authorities regarding protection afforded to personal data in that country. Details of the specific countries that do benefit from an adequacy decision may be found here. We will only transfer your personal data outside of the UK/EEA/EU based on an adequacy decision or an appropriate safeguard such as standard contractual clauses or if a derogation or other lawful basis exists. Where required we have put in place additional safeguards. For more information on the basis on which we transfer personal data outside of the UK/EEA/EU, you may contact us at the contact details set out above (see Section 11, Contact Us). Your Choices and Rights Under the UK and EU General Data Protection Regulation ("GDPR") and Data Protection Act, you have the following rights. • Access. You may have the right to access, review, obtain a copy or port certain personal data, for example to verify its existence, content, origin or accuracy. Please note that we are not always able to provide the personal data or take the action that you have requested. We may refuse to provide personal data based on a number of lawful exemptions. • Update. Moved? Changed your name, email, address, or phone number? It is important that the personal data we hold about you is accurate and up to date. With certain Topgolf Offerings, you may also be able to directly update your personal data on the bay player or account management screens. • Deletion. You may have the right to request deletion of certain personal data. We may refuse to delete personal data if we have a need to keep personal data to meet our statutory obligations, dispute resolution, troubleshooting, and other valid legal or business reasons. We may in our discretion anonymize your personal data in which case it is no longer personal data. • Revocation of Consent. You may have the right to block or withdraw consent to the processing of certain personal data (without affecting the lawfulness of processing based on consent before its withdrawal). If you revoke your consent for the processing of personal data, we may no longer be able to provide you our products or services. We may retain personal data in respect of which you are revoked consent to meet our statutory obligations, dispute resolution, troubleshooting, and other valid legal or business reasons. We may in our discretion anonymize your personal data in which case it is no longer personal data. • Portability. You have the right, in certain circumstances, to request that we provide your Personal Data to you in a format that can be transferred to another entity. • Restrict Processing. You have the right, in certain circumstances, to request that we limit our processing of your Personal Data if you are contesting the accuracy of your personal data; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing. • Object. You may object to our processing if we are processing your personal data based on legitimate interests, use your personal data for direct marketing, or process your personal data for purposes of scientific or historical research and statistics. You can optout at any time from receiving direct marketing from us. You can do so by clicking the unsubscribe link at the botom of any email you receive from us, by submiting a request as set out in Section 11, Contact Us, above or by writing to Topgolf (or the relevant corporate affiliate) at the address in Section 11. If you do opt-out of receiving promotional and marketing messages, we can still contact you regarding your membership, such as your status and activity updates, survey requests in respect of products and services we have provided to you atier you have visited our Locations (if permited under applicable law), booked confirmations, or to respond to your inquiries or complaints, and similar communications. • Cookies. You can review your Internet browser setings, typically under the sections "Help" or "Internet Options," and use our cookie setings by clicking the link in the footer titled "Manage Cookie Preferences" to exercise choices you have for certain cookies, including for interest-based advertising. If you disable or delete certain non-essential cookies, you might not be able to access or use important functions or features of this Website or services, and you may have to re-enter your log-in details. Please note you may also still receive advertisements from the relevant ad serving company you opted out of, but the ads will not be tailored to your interests. For our Applications (if available), please review your device setings or third party tools available. Please note, if you elect to exercise one of your choices listed above, you will not receive discriminatory treatment by us for exercising your privacy rights that are conferred upon you by law. If you need to exercise any of your rights, please contact us at the contact details set out above (see Section 11, Contact Us). To process your request, we may need to ask you for additional information or personal data to correctly find you in our systems. If you are an authorized agent acting on behalf of an individual, you must atach a completed authorized agent designation form or power of atorney indicating that you have the authority to act on behalf of the individual in respect of whom the rights are being exercised and if you are business, proof of your business registration evidencing that you are authorized to conduct business in the relevant country. We will respond to your request in the time periods permited by applicable law. We may charge a reasonable fee if we receive multiple requests for the same personal data or if your request in manifestly unfounded. Automated Decision-making For residents of the UK and the EEA, we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you. Third Party Advertising As discussed above, we work with certain third party advertising companies in connection with our online advertising and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. The EDAA has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with participating EDAA member companies available for UK and EU residents at htps://www.youronlinechoices.com/. Users Younger Than Age 16 Our Websites and Applications are directed to persons in the EEA who are at least sixteen (16) years of age, and we do not knowingly collect any personal data from children in the EEA younger than the age of sixteen (16) years. If a parent or guardian in the EEA is made aware that a child under the age of sixteen (16) years has provided us with personal data through any point of contact, please call us at +1 (833) 554- 0955 or write to us at the contact details above, and we will delete the personal data. If we have actual knowledge that personal data about a person in the EEA younger than the age of sixteen (16) years has been collected without parental/guardian consent, then we will take the appropriate steps to delete such personal data. Right to Lodge a Complaint EU and UK residents have the right to lodge a complaint about our data collection and processing actions with the Information Commissioner's Office ("ICO") in UK and the relevant national supervisory authority where you reside in the EU, if you believe we have not resolved your concerns. Contact details for UK's ICO are available here. Contact details for national supervisory authorities in the EU are available here. d. Notice To South Korean Residents Certain specific privacy rights apply to you if you are a South Korean resident. These are set out in the following sections. Details of third parties with whom we share your information If you are a South Korean resident, you may request information from us about how we may share certain categories of your personal data with third parties. We may provide third parties with personal data as set forth below: Third party Recipients / Location Contact Information for Personal Data Related Inquiries Personal Data Collected, Purposes, and Retention Method of Transfer Authorize.net / United States CyberSource Corporation P.O. Box 8999 San Francisco, CA 94128 ATTN: Data Use and Privacy Office Fax: (650) 286- 6547 OR CyberSource Limited P.O. Box 3073 Reading RG1 9YB United Kingdom ATTN: Compliance Officer Fax: +44 (0)118 990 7301 Authorize.net is a payment processor Service Provider. Your registration information will be processed for the period necessary to fulfill the purposes outlined in this Privacy Notice and in accordance with applicable law. Data transfer agreement. Amazon.com, Inc. / United States Customer Service PO Box 81226 Seatle, WA 98108- 1226, United States Amazon.com, Inc. is a cloud Service Provider. Your general personal data will be processed by Amazon.com, Inc. for storage purposes for the period necessary to fulfill the purposes outlined in this Privacy Notice and in accordance with applicable law. Data transfer agreement. Transfer of Information Overseas Our computer systems are currently based in the United States, so at the time the personal data detailed above is collected and processed for the above-mentioned purposes; it is maintained by us in the United States. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including the Act on Promotion of Information and Communications Network Utilization and Information Protection of the Republic of Korea. Collection of Opinions and Handling of Complaints If you have any questions regarding this Privacy Notice, you may raise your questions with us as detailed above (see Section 11, Contact Us).

 

13. Notice to California Residents

 

This California Privacy Notice is effective as of the Effective Date. This California Privacy Notice supplements the information contained in Topgolf's Privacy Notice and applies only to California residents. This California Privacy Notice sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Consumer Privacy Act of 2018 ("CCPA"), the California Privacy Rights Act of 2020 ("CPRA"), and any implementing regulations adopted thereunder. Any terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA, CPRA, and the associated regulations, unless otherwise defined. EXERCISING YOUR CALIFORNIA ACCESS, DELETION, AND DO NOT SELL RIGHTS If you are a California Consumer, you have the right to request: (1) that we disclose to you what personal information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of personal information we have collected about you ("Right to Know"); (2) that we delete the personal information we collect about you ("Right to Delete"); (3) that we correct inaccurate personal information we hold about you ("Right to Correct"), (4) to opt-out from the sharing of your personal information to a third party for cross-context behavioral advertising (i.e., targeted advertising) ("Right to Opt-Out of Sharing"), and (5) to opt-out from the sale of their personal information ("Right to Opt-Out of Sale"), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below. In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We cannot respond to your request if we cannot verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity. Verifying Your Requests We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. When you exercise your Right to Know, Right to Delete, or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submiting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request. Agents If you are an authorized representative submiting a request on a user's behalf, please complete the applicable request per the instructions below. You may also make a request on behalf of your minor child. We will follow up to request a signed, writen permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The writen permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of atorney under Probate Code sections 4000-4465. In either case, please also indicate the nature of your request. The consumer's identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer's behalf, we may deny the request. Requests to Know California Consumers have the right to know what information we have collected about them (the categories and the specific pieces of information). If you are a California Consumer and would like to exercise your Right to Know, please submit your request by completing this form or by calling us toll-free at (833) 554-0955. In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Requests to Delete California Consumers have the right to request that we delete personal information we have collected from them. If you are a California Consumer and would like to exercise your Right to Delete, please submit your request by completing this form or by calling us toll-free at (833) 554-0955. Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted. Right to Correct Inaccurate Information California Consumers have the right to request that we correct inaccurate information we hold about them. If you are a California Consumer and would like to exercise your Right to Correct, please submit your request by completing this form or by calling us toll-free at (833) 554-0955. Do Not Sell or Share Right to Opt-Out Of Sharing California Consumers have the right to opt-out of the sharing of their personal information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. Topgolf additionally shares your personal information with its corporate affiliates which may be considered "sharing" under the CCPA and CPRA. If you are a California Consumer and would like exercise your Right to Opt-Out of Sharing, please submit your request by completing this form. Right to Opt-Out of Sale California Consumers have the right to opt-out of the sale of their personal information. Topgolf shares your personal information with its corporate affiliates which may be considered "sales" under the CCPA and CPRA. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale, please submit your request by completing this form. Other Important Information for Do Not Sell or Share Topgolf engages in online advertising practices (and certain analytics or similar activities), which may be considered a "sale" or "share" for cross-context behavioral advertising under the CCPA and CPRA. To disable sharing through Cookies set by 3rd parties that may be considered "sales" or "sharing" under the CCPA and CPRA, please click on the link in the footer titled "Manage Cookie Preferences". In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies. Right to Limit the Use and Disclosure of Sensitive Personal Information Under the CPRA Regulations, a business must only provide the Right to Limit the Use and Disclosure of sensitive personal information when such use is not collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Topgolf's use and disclosure of sensitive personal information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer this right at this time. Data Retention We will retain all categories of personal information described in this California Privacy Notice as set forth above in Section 8, Retention and Destruction of Your Personal Data of this Privacy Notice. Users Younger than Age 16 Topgolf does not knowingly Sell or Share personal information of users younger than 16 years of age. Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights California consumers have the right not to receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising any of your CCPA and CPRA rights. Notice of Financial Incentive Under California regulation, certain programs we offer that provide benefits to consumers may be considered financial incentive programs. We may collect personal information from you in connection with these programs, for example contact information (name, email address, residential address) and certain commercial information for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to beter serve you, and to fulfill your requests associated with the program. To opt into the programs, you may need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with that applicable program. Please also see the terms of the program you are joining for additional description of the program and any additional requirements. Participation in our programs is voluntarily, and you can withdraw at any time. To the extent that we provide a program that may be considered a financial incentive because the program is directly or reasonably related the collection, deletion or sale or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program. In addition to the below, we may collect and/or use additional types of information and will do so atier providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA. PERSONAL INFORMATION WE COLLECT The personal information we collect about you will depend upon how you use the Topgolf Offerings or otherwise interact with us. Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information and will do so atier providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA. Category of Personal Information Collected Categories of Sources from which the Information was Collected Business or Commercial Purpose(s) for which Information is Collected Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared Identifiers This category includes information such as name, contact information, and online or device identifiers. We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Cookies and tracking technologies Social Sites Applicants for employment We may use this type of information: To allow you to participate in the Topgolf Offerings, and features we offer To respond to your requests (e.g., support, feedback) To develop and improve our products, services, and marketing programs We may disclose this type of information to: Other users The Topgolf Callaway Brands Family of Companies Service Providers Third parties who deliver our communications Internet service providers Social Sites The Topgolf Callaway Brands Family of Companies. Third party advertising, analytics, and other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners To communicate with you and tailor content, ads, and offers In connection with your purchases and for customer service To operate and protect our Topgolf Offerings To display your first and last name and/or username on leaderboards at Topgolf Offerings and Social Sites To process payments To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or Payment processors and financial institutions Third parties we partner with for contests, sweepstakes, or promotions Third party advertising and analytics companies Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or request that we share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) "share" under CCPA and CPRA under certain circumstances. the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice Any categories of "personal information" described in subdivision (e) of Section 1798.140 This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as "personal" under this California law. We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Cookies and tracking technologies Social Sites Applicants for employment Third party business partners, such as data analytics providers, advertising networks, or joint We may use this type of information: To allow you to participate in the Topgolf Offerings and features we offer To respond to your requests (e.g., support, feedback) To develop and improve our products, services, and marketing programs To communicate with you and tailor content, ads, offers In connection with your We may disclose this type of information to: Other users The Topgolf Callaway Brands Family of Companies Service Providers Internet service providers Social Sites Payment processors and financial institutions Third parties we partner with for contests, sweepstakes, or promotions Third party advertising and The Topgolf Callaway Brands Family of Companies. Third party advertising, analytics, and other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. marketing partners purchases and for customer service To operate and protect our Topgolf Offerings to display your first and last name and/or username on leaderboards at our Topgolf Offerings and Social Sites To process payments To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise analytics companies Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or request that we share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) with your consent or as consistent with this Privacy Notice Characteristics of protected classifications under California or federal law This category includes information such as age, sex (including gender), national origin, citizenship, and marital status. We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Applicants for employment We may use this type of information for job applicants: For prospective employees, background screening to assess applications for employment To process your employment application and prepare related governmental and internal statistics reports For consumers, we may use this type of information to perform market research that allows Topgolf to beter understand its demographic market We may disclose this type of information to: The Topgolf Callaway Brands Family of Companies Service Providers Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or request that we share your information with them Other third parties (including government or regulatory agencies) as required by law or in connection with court proceedings (such as pursuant to The Topgolf Callaway Brands Family of Companies For other purposes described to you at the time of collection or otherwise consistent with this Privacy Notice subpoenas or court orders) Commercial information This category includes, for example, payment information you provide for goods, services, customer service records, and information about the products you have purchased. We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Third party business partners, such as data analytics providers or joint marketing partners We may use this type of information: To allow you to participate in the Topgolf Offerings and features we offer In connection with your purchases and for customer service To communicate with you and tailor content, ads, offers To operate and protect our Topgolf Offerings To process payments To comply with the law and protect We may disclose this type of information to: The Topgolf Callaway Brands Family of Companies Social Sites Service Providers Third parties we partner with for contests, sweepstakes, or promotions Third party advertising and analytics companies Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated The Topgolf Callaway Brands Family of Companies Third party advertising, analytics, and other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice companies when you agree to or direct us to share your information with them Payment processors and financial institutions Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) Internet or other electronic network activity information This category includes information about the web browser and operating system you are using, the website or ad that referred you to the Topgolf Offerings, areas of the Topgolf Offerings that you visited, and terms entered into a search engine that led you to We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Cookies and tracking technologies Social Sites Third party business partners, such as data We may use this type of information: To allow you to participate in the online Topgolf Offerings and features we offer To develop and improve our products, services, and marketing programs to operate and protect our online Topgolf Offerings We may disclose this type of information to: The Topgolf Callaway Brands Family of Companies Internet service providers Social Sites Service Providers Third party advertising and analytics companies The Topgolf Callaway Brands Family of Companies Third party advertising, analytics, and other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or the Topgolf Offerings analytics providers or advertising networks To communicate with you and tailor content, ads, offers To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice Third parties who may acquire your information as a result of a merger acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders). "share" under CCPA and CPRA under certain circumstances. Geolocation data This is specific location, e.g., longitude/latitude coordinates from a global We may collect this type of information from: Consumers We may use this type of information: To allow you to participate in the Topgolf Offerings and We may disclose this type of information to: Other users The Topgolf Callaway Brands Family of Companies Third party advertising, analytics, and positioning system (GPS). The Topgolf Callaway Brands Family of Companies Cookies and tracking technologies features we offer To communicate with you and tailor content, ads, offers To operate and protect the Topgolf Offerings To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice. The Topgolf Callaway Brands Family of Companies Service Providers Third party advertising and analytics companies Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. Audio, electronic, visual, thermal, olfactory, or similar information This category includes, for example, images, video, or audio recordings. We may collect this type of information from: Consumers The Topgolf Callaway Brands Family of Companies Applicants for employment Social Sites We may use this type of information: To allow you to participate in the Topgolf Offerings and features we offer To operate and protect the Topgolf Offerings To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice. We may disclose this type of information to: Other users The Topgolf Callaway Brands Family of Companies Service Providers Social Sites Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) The Topgolf Callaway Brands Family of Companies Third party advertising, analytics, and other marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. Professional or employmentrelated information This category includes job applications and current and/or past employers. We may collect this type of information from: Applicants for employment We may use this type of information: To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice We may disclose this type of information to: The Topgolf Callaway Brands Family of Companies Service Providers Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) The Topgolf Callaway Brands Family of Companies Education Information We may collect this type of We may use this type of information: We may disclose this type of information to: The Topgolf Callaway This category includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99) information from: Applicants for employment To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice. The Topgolf Callaway Brands Family of Companies Service Providers Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) Brands Family of Companies Inferences drawn from any of the information identified above to create a profile about a consumer We may collect this type of information from: Consumers We may use this type of information: To allow you to participate in the online Topgolf We may disclose this type of information to: The Topgolf The Topgolf Callaway Brands Family of Companies Third party advertising, analytics, and These inferences may relate to your perceived interests, preferences, characteristics, or behavior. The Topgolf Callaway Brands Family of Companies Cookies and tracking technologies Social Sites Applicants for employment Third party business partners, such as data analytics providers, advertising networks, or joint marketing partners Offerings and features we offer To develop and improve our products, services, and marketing programs To communicate with you and tailor content, ads, and offers to operate and protect our online Topgolf Offerings To operate and protect the Topgolf Offerings To process your employment application and prepare related governmental and internal statistics reports To comply with the law and protect us, our consumers or the general public Callaway Brands Family of Companies Service Providers Third parties we partner with for contests, sweepstakes, or promotions Social Sites Third party advertising and analytics companies Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition Third parties or affiliated companies when you agree to or direct us to share your information with them Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to other marketing business partners may have access to this data, including to beter serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under CCPA and CPRA under certain circumstances. For other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Notice subpoenas or court orders) Contact for More Information You can contact us for more information by writing to us at Topgolf, Atn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. b. Other California Privacy Rights California Civil Code Section 1798.83 permits residents of California to request certain details about how their personal information has been shared during the calendar year with third parties for those third parties' own direct marketing purposes, unless the business permits California residents to opt in to, or opt out of, this type of sharing. Topgolf qualifies for this alternative option. As noted above, we will not share personal information about you with third parties for their own direct marketing purposes without first offering you choice (opt-in or opt-out). If you are a California resident and have questions about our practices with respect to sharing personal information with third parties for their direct marketing purposes and your ability to exercise choice, please submit your request by calling toll-free at (833) 554-0955 or writing to us at the following mailing address: Topgolf, Atn: Privacy Team, 8750 N. Central Expressway, Suite 1200 Dallas, U.S.A. TX 75231. You must put the statement "Your California Privacy Rights" at the top of your leter. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or for those notices which do not have complete information.

 

14. Washington and Nevada Consumer Health Data Privacy Notice

 

This Washington and Nevada Consumer Health Data Privacy Notice is effective as of the Effective Date.

This Consumer Health Data Privacy Notice (the “Consumer Health Notice”) applies to residents of Washington State and Nevada and individuals whose Consumer Health Data (as defined below) is collected in Washington State and Nevada by us through any of our Websites or the related content, products, services, platforms and other functionality offered on or through the Topgolf Offerings.

This Consumer Health Notice supplements the Privacy Notice set forth above and explains how we use and disclose your Consumer Health Data. This Consumer Health Notice does not address privacy practices relating to Topgolf job applicants, employees, or other personnel. Please note that this Consumer Health Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law. Changes to this Consumer Health Notice will be made according to the process described in Section 10, Changes in our Privacy Notice, above.

a. Our Collection and Use of Consumer Health Data

The term “Consumer Health Data” as used in this Consumer Health Notice means any personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Washington My Health My Data Act or the Nevada Consumer Health Data Privacy Law (collectively, the “Laws”). The data we collect depends on the context of your interactions with us and, in most cases, is information that you decide to share with us. Consumer Health Data does not include information that is considered deidentified under the Laws. Examples of Consumer Health Data that Topgolf may collect include:

• Information you share about your health-related conditions, symptoms, experiences, diagnoses, accessibility requirements, testing, or treatments.
• Golf performance information, including swing data.

We may process Consumer Health Data that we collect from you by methods including, but not limited to, collecting, using, storing, organizing, combining, erasing, filtering, and transmitting data in accordance with this Consumer Health Notice.

With your permission, we may process and/or use Consumer Health Data that we collect from you to deliver the Topgolf Offerings to you, including for the following purposes:
• To fit you for products.
• To provide accessible accommodations.
• To provide emergency services if applicable.
• To create anonymous, aggregated, or de-identified data.

b. Sources of Consumer Health Data

The Consumer Health Data we collect depends on the context of your interactions with the Topgolf Offerings and, in most cases, is information that you decide to share with us.

c. Our Disclosure of Consumer Health Data

We may share the categories of Consumer Health Data set forth above with the following third parties:
• Service Providers: We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the operation of our Websites and the Topgolf Offerings.
• Business Transactions: We may take part in or be involved with a business transaction, such as a merger. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction but, to the extent permitted by applicable law, we will only disclose Consumer Health Data upon the third party agreeing to the same or stronger protections for your Consumer Health Data than are set forth in this Consumer Health Notice.
• Legal Obligations and Rights: We may disclose Consumer Health Data to third parties: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.
• With Your Consent: We may disclose Consumer Health Data about you to certain other third parties or publicly with your consent or at your direction.

d. Your Privacy Rights

The Laws provide the following rights with respect to Consumer Health Data we collect about you:
• Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
• Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.
• Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.

To exercise any of the privacy rights set forth above or to review or request changes to data, please submit a request by clicking “Your Privacy Choices” in the footer of our Website.

Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including, but not limited to, your email address and phone number.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.

If your request to exercise a right under the Laws is denied, you may appeal that decision by contacting us. If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable attorney general:
• Washington: www.atg.wa.gov/file-complaint
• Nevada: ag.nv.gov/Complaints/File_Complaint/