Homestretch Golf
Golf pari-mutuels reimagined

Privacy Policy For California Residents


HOMESTRETCH GOLF PRIVACY POLICY FOR CALIFORNIA RESIDENTS

(Last Modified and Effective On: December 3, 2021)

This Homestretch Golf Privacy Policy for California Residents supplements the Homestretch Golf  Privacy Policy (this “Policy”) and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

  1. Information We Collect: The Homestretch Golf Web Application (which is hereinafter referred to as the “Web App”) collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not include:

1.1 Publicly available information from government records;

1.2. Deidentified or aggregated consumer information;

  1. Categories of Personal Information: In particular, the Web App has collected the following categories of Personal Information from consumers within the last 12 months: 

Category

Examples

Collected

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

Yes

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

Geolocation data

Physical location or movements. 

Yes

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

Professional or employment-related information

Current or past job history or performance evaluations.

No

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. §1232g, 34 C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

No

Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

  1. Sources of Personal Information: The Web App obtains the categories of Personal Information listed above from the following categories of sources:

3.1. Directly from you: For example, from forms you complete or products and services you purchase; and/or

3.2. Indirectly from you: For example, from observing your actions on the Web App.

  1. Uses of Personal Information: We may use or disclose the Personal Information we collect for one or more of the following purposes:

4.1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;

4.2. To provide, support, personalize, and develop our Website, products, and services;

4.3. To create, maintain, customize, and secure your account with us;

4.4 To process your requests, purchases, transactions, and payments and prevent transactional fraud.;

4.5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;

4.6. To help maintain the safety, security, and integrity of the Web App, our products and services, databases and other technology assets, and business;

4.7. For testing, research, analysis, and product development, including to develop and improve the Web App and our products and services;

4.8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

4.9. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

4.10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

  1. Notice of Collection of Use of Personal Information: We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
  1. Sharing Personal Information: We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding 12 months, we have not disclosed Personal Information for a business purpose. We do not sell Personal Information. Specifically, in the preceding twelve months, we have not sold the following categories of Personal Information.

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales

Identifiers

None

None

California Customer Records Personal Information categories

None

None

Protected classification characteristics under California or federal law

None

None

Commercial information

None

None

Biometric information

None

None

Internet or other similar network activity

None

None

Geolocation data

None

None

Sensory data

None

None

Professional or employment-related information

None

None

Non-public education information

None

None

Inferences drawn from other Personal Information

None

None

  1. Your Rights and Choices: The CCPA provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

7.1. Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “Right to Know”). Once we receive your request and confirm your identity, we will disclose to you:

7.1.1. The categories of Personal Information we collected about you;

7.1.2. The categories of sources for the Personal Information we collected about you;

7.1.3. Our business or commercial purpose for collecting or selling that Personal Information;

7.1.4. The categories of third parties with whom we share that Personal Information;

7.1.5. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (A) sales, identifying the Personal Information categories that each category of recipient purchased; and (B) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained; and

7.1.8. The specific pieces of Personal Information we collected about you (also called a data portability request).

  1. Right to Delete: You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions (the “Right to Delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us to:

8.1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, or otherwise perform our contract with you;

8.2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

8.3. Debug products to identify and repair errors that impair existing intended functionality;

8.4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

8.5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 and the following sections);

8.6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

8.7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

8.8. Comply with a legal obligation; and/or

8.9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  1. Information to be Deleted: We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
  1. Exercising Your Rights to Know or Delete: To exercise your Right to Know or Right to Delete described above, please contact us at the email address located at the bottom of this page. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. You may also make a request to know or delete on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

10.1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

10.2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  1. Response Timing and Contents: We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact us via the information provided at homestretchgolf.com/#contact-us. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  1. Personal Information Sales Opt-Out and Opt-In Rights: If you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). We do not sell the Personal Information of consumers we actually know are less than 16 years old. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the Right to Opt-Out, please contact us at the email address located at the bottom of this page. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by contacting us at the email address located at the bottom of this page.
  1. Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

13.1. Deny you goods or services;

13.2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

13.3. Provide you a different level or quality of goods or services; or

13.4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  1. Financial Incentives: Notwithstanding Section 13, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
  1. CCPA Rights Request Metrics: Metrics regarding the consumer rights requests we received from all individuals from January 1, 2020 to December 31, 2020 appear in the following chart:

    

Request Type

Received

Granted (in whole or in part)

Denied

Average Days to Respond

Requests to Know

0

Not Applicable

Not Applicable

Not Applicable

Requests to Delete

0

Not Applicable

Not Applicable

Not Applicable

Requests to Opt-Out of Personal Information Sales

0

Not Applicable

Not Applicable

Not Applicable

  1. Other California Privacy Rights: California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of the Web App and similar platforms who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at the email address located at the bottom of this page.
  1. Changes to Our Privacy Policy: We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Web App and update the notice’s effective date. Your continued use of the Web App following the posting of changes constitutes your acceptance of such changes.
  1. To ask questions or comment about this Policy and our privacy practices or to make any request hereunder, contact us at: Info@HomestretchGolf.com.