AVA Golf, Inc. (“AVA Golf™,” “we,” “us,” or “our”) is committed to protecting the privacy of everyone who uses our products and services. This Privacy Policy describes how we collect, use, store, disclose, and protect personal information across all AVA Golf™ products and platforms, including:
- The AVA Golf™ web application (avagolf.com)
- AVA Golf™ mobile applications (iOS and Android)
- Account sign-up, email, and newsletter communications
- Third-party data integrations (Garmin, Arccos, USGA/GHIN, and others added over time)
- APIs accessible by or from third parties
- Social media interactions
- Any other AVA Golf™ products, services, or channels that link to this Privacy Policy (collectively, the “Services”)
AVA Golf, Inc. is a Delaware C-corporation with offices at 169 Madison Ave #2003, New York, NY 10016. AVA Golf, Inc is a wholly-owned subsidiary of ParOne, Inc., a Delaware C-corporation (“ParOne”). ParOne and its affiliates and subsidiaries, including ParOne Holdings LLC, ParOne.dev LLC, ParOne App LLC, and GolfCentral TV, Inc., may have access to information collected under this Privacy Policy as described in Section 6.
This Privacy Policy applies to all users of the Services regardless of the device, platform, or method of access. Please read it carefully. By using the Services, you acknowledge that you have read and understood this Privacy Policy.
Questions or concerns? Contact us at privacy@avagolf.com.
Table of Contents
- Table of Contents
- 1. Information We Collect
- 2. How We Collect Information
- 2A. Third-Party Marketing, Analytics, and Tracking Tools
- 2A.1 Email Marketing — Brevo (formerly Sendinblue)
- 2A.2 CRM and Marketing Automation — HubSpot
- 2A.3 Web and App Analytics — Google Analytics 4 (GA4)
- 2A.4 Additional Third-Party Tools
- 2A.5 Session Recording and Heatmaps — Microsoft Clarity, Contentsquare, and Mouseflow
- 2A.6 Advertising Measurement — OpenAI Pixel
- 2A.7 Advertising Pixels — Meta and Reddit
- 3. Third-Party Data Partner Integrations
- 4. How We Use Your Information
- 5. Technology, Machine Learning, and Video Recommendations
- 6. How We Share Your Information
- 7. Data Monetization and Aggregated Data
- 8. Advertising and Sponsorships
- 9. Data Retention
- 10. Data Security
- 11. Children’s Privacy (COPPA)
- 12. Your Privacy Rights
- 13. United States Residents — State-Specific Rights
- 14. European Union, United Kingdom, and Canadian Users
- 15. Third-Party Links and Services
- 16. Do Not Track and Opt-Out Preference Signals
- 17. Changes to This Privacy Policy
- 18. Referral Program
- 19. Contact Us
1. Information We Collect
AVA Golf™ collects a broad range of information in connection with your use of the Services. The core purpose of AVA Golf™ is to aggregate golf performance data from multiple sources in order to deliver Personalized Progression coaching and personalized insights. To accomplish that purpose effectively, we collect as much relevant data as you authorize us to collect.
1.1 Information You Provide Directly
- Account registration data: Name, email address, username, password, date of birth, gender, dominant hand, home golf course, profile photo, and any other information you choose to provide during registration or account setup.
- Golf profile data: Handicap Index, Handicap ID, club memberships, equipment inventory (clubs, balls, launch monitor), golfer preferences, skill level, and any other golf-related profile information you provide.
- Payment and billing data: Payment instrument information necessary to process transactions. All payment data is processed and stored by our payment processor, Stripe, Inc. AVA Golf™ does not store full payment card numbers. See Stripe’s Privacy Policy.
- Communications: Messages, emails, support tickets, feedback, survey responses, and any other information you provide when contacting us or participating in any AVA Golf™ communication channel.
- User-generated content: Notes, coaching session records, goals, and any other content you voluntarily upload, submit, or create within the Services.
- Anonymous analysis submissions: You can ask for a one-off analysis from our public landing pages without creating an account at all. When you do, we collect the email address you give us and either the launch-monitor session file (CSV) you upload or the round-share link you paste. We use them to produce your report, to email it to you at that address, and — as described in Section 2A.1 — to create a contact record for that address. No AVA Golf™ account is created for you by a submission of this kind.
1.2 Golf Performance Data
The core data asset of AVA Golf™ is golf performance data. Depending on which integrations you authorize, this may include:
- Scores, scorecards, and round history
- Shot-by-shot data including club selection, shot type, result, and distance
- GPS coordinates of shots taken during a round
- Strokes gained statistics and other derived performance metrics
- Handicap Index, Low Handicap Index, and 20-score history (via USGA/GHIN)
- Launch monitor data (ball speed, club speed, spin rate, launch angle, carry distance)
- Course information including course rating, slope rating, and course layout data
- Practice session data and simulator round data
- Any other golf performance, statistical, or activity data made available through authorized integrations or submitted directly by you
1.3 Device and Technical Data
When you access the Services through any device, browser, or application, we automatically collect:
- IP address
- Device type, model, and operating system
- Browser type and version
- Mobile device identifiers (IDFA, IDFV, Android Advertising ID)
- App version and session data
- Referring URLs and navigation paths
- Date and time stamps of activity
- Crash reports and diagnostic data
- Network type and carrier (mobile)
- Any other technical information automatically transmitted by your device or browser when accessing the Services
1.4 Location Data
When you connect a data provider for golf rounds, we may process:
- Coarse location data (city/region level) for localized features such as course finding
- Precise GPS location data from played rounds, where authorized by you and required for shot-tracking functionality
Location data is not collected by us and only processed when you have connected a partner that supplies GPS data.
1.5 Social Media and Third-Party Platform Data
If you interact with AVA Golf™ on social media platforms, or if you choose to authenticate or connect a social media account to the Services in the future, we may receive:
- Public profile information (name, profile photo, username)
- Email address associated with the account
- Such other data as the social media provider makes available based on your settings
Social login functionality is currently planned but not yet available. When available, this policy will govern our handling of data received through such connections.
1.6 Data Received from Other Users or Third Parties
- Golf instructors and coaches: If your coach uses AVA Golf™, they may input session notes or observations linked to your profile, with your authorization.
- Other platform users: Other golfers may share round data or challenge data that references your profile.
- Marketing and analytics partners: We may receive anonymized or pseudonymized data from third-party analytics providers that we use to improve the Services.
1.7 Video Engagement Data
AVA Golf™ tracks how you interact with video content within the Services, including:
- Videos viewed and watch history
- Playback duration and completion rates
- Replay and rewind activity
- Video interactions (pauses, skips, speed adjustments)
- Timestamps of specific in-video interactions
- Playback quality and format selections
- Full screen and inline viewing behavior
- Video sharing, saving, and bookmarking activity
- Chapter and segment navigation
- Buffering events and stream performance data
- Device and connection quality during playback
- Any other video watching behavioral data generated by your interaction with video content within the Services
This data is used to power AVA Golf™‘s video recommendation engine, which uses machine learning to match specific instructional content to your identified performance gaps and learning patterns (see Section 5).
2. How We Collect Information
We collect information through the following mechanisms:
Direct collection: When you register, fill out forms, post scores, connect integrations, or otherwise interact with the Services.
Automatic collection: Through server logs, cookies, pixel tags, SDKs, and similar technologies embedded in our applications and websites.
Third-party API integrations: When you connect a third-party account or data partner (e.g., Garmin, Arccos, USGA/GHIN), that partner transmits data to AVA Golf™ on your behalf. See Section 3 for full details.
Cookies and tracking technologies: We use cookies, web beacons, and similar technologies to:
- Maintain session state and authentication
- Remember user preferences
- Understand how users navigate the Services
- Measure and analyze usage patterns
Managing your cookie preferences. AVA Golf™ presents a cookie consent banner on first visit that lets you accept or reject each category of non-essential cookie and tracking technology: Analytics and Marketing. Strictly necessary cookies (authentication, security, and core preferences) cannot be disabled because the Services do not function without them.
Where the default sits depends on where you are. In the European Economic Area, the United Kingdom and Switzerland, non-essential categories are denied by default: no analytics or marketing tag loads until you affirmatively accept that category. Everywhere else, including the United States, Analytics and Marketing are on by default and you may turn either off at any time, which is the opt-out model those laws are written around. In every region, a browser sending a Global Privacy Control signal is treated as opting out of Marketing before any advertising tag loads. You may change your choice at any time by selecting “Cookie preferences” or “Do Not Sell or Share My Personal Information” in the footer of any page, which reopens the same controls. Your choice is stored in your browser, so you will need to set it again on a different browser or device, or after clearing your site data.
The web application (app.avagolf.com). The consent banner described above is presented on the marketing website. The web application does not currently present it: the analytics and advertising tags described in Section 2A are loaded there, through the same tag manager, for every visitor; the application does not offer an in-product control for them; and a Global Privacy Control signal is not acted on there. A choice you make on avagolf.com is stored for that site and does not carry into the application. You may still exercise the opt-out, access and deletion rights described in Sections 13 and 14 — including the “Do Not Sell or Share My Personal Information” right — by writing to privacy@avagolf.com, and you may use your browser’s own cookie and tracking controls at any time.
You may additionally manage cookies through your browser settings. Note that disabling cookies may affect the functionality of the Services.
2A. Third-Party Marketing, Analytics, and Tracking Tools
AVA Golf™ uses a number of third-party tools on its websites and applications that independently collect data about your interactions with the Services. This section discloses those tools, what they collect, and how you can manage your preferences.
2A.1 Email Marketing — Brevo (formerly Sendinblue)
AVA Golf™ uses Brevo to send both transactional emails (account confirmations, receipts, security alerts) and marketing communications (newsletters, product updates, promotional offers). When you receive an email from AVA Golf™, Brevo may collect:
- Whether you opened the email and when
- Which links you clicked within the email
- Your email client, device type, and approximate location at time of open
- Unsubscribe and preference events
Anonymous analysis submissions create a Brevo contact. When you submit a launch-monitor file or a round-share link from one of our public analysis pages (Section 1.1), the report itself is sent to you through Brevo as a transactional email, and your email address is also written to Brevo as a contact record. That happens on every submission — including one whose analysis then fails and comes back to you as a failure notice — and it is independent of the cookie preferences you set on our website, because it is a record created from the address you typed in rather than anything tracked in your browser. It means you may subsequently receive marketing email from us. You can unsubscribe from any of it at any time using the link in any email, and you can ask us to delete the contact record entirely as described in Section 12.
Brevo acts as a data processor on AVA Golf™‘s behalf. You may opt out of marketing emails at any time using the unsubscribe link in any email or by contacting privacy@avagolf.com. You cannot opt out of transactional emails.
Brevo’s Privacy Policy: https://www.brevo.com/legal/privacypolicy/
2A.2 CRM and Marketing Automation — HubSpot
AVA Golf™ uses HubSpot for customer relationship management and, where integrated, marketing automation. HubSpot may collect data about your interactions with AVA Golf™‘s websites and communications, including:
- Pages visited and time spent on each page
- Form submissions and contact information you provide
- Email engagement data (opens, clicks)
- Device and browser information
- IP address and approximate location
HubSpot may place cookies on your browser to track your activity across sessions. If you have provided AVA Golf™ with your contact information, HubSpot may associate your browsing activity with your contact record.
HubSpot’s Privacy Policy: https://legal.hubspot.com/privacy-policy
2A.3 Web and App Analytics — Google Analytics 4 (GA4)
AVA Golf™ uses Google Analytics 4 on both its websites (avagolf.com) and mobile applications to understand how users interact with the Services. GA4 may collect:
- Pages and screens viewed
- Session duration and navigation paths
- Events and interactions (button clicks, feature usage, video plays)
- Device type, operating system, and browser
- IP address (anonymized by default in GA4)
- Approximate geographic location (derived from IP)
- Referral source and acquisition channel
GA4 data is transmitted to and stored by Google LLC. Google may use this data in accordance with its own privacy policies. AVA Golf™ uses GA4 in a manner designed to minimize collection of personally identifiable information, including enabling IP anonymization.
You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on or by managing your Google account’s ad personalization settings.
Google’s Privacy Policy: https://policies.google.com/privacy
2A.4 Additional Third-Party Tools
AVA Golf™ may use, or in the future may deploy, additional third-party tools for analytics, error monitoring, session recording, advertising, and user engagement. These may include tools such as:
- Session recording and heatmap tools (e.g., FullStory) — which may record mouse movements, clicks, scrolling behavior, and on-screen interactions
- Error and performance monitoring (e.g., Sentry, Datadog) — which collect crash reports, error logs, and performance diagnostics
- Product analytics platforms (e.g., Mixpanel, Amplitude, Segment, Rudderstack) — which track feature usage, user flows, and retention metrics
- Advertising measurement and first-party marketing tools (e.g., OpenAI Pixel, LinkedIn Insight Tag, Google Ads, Meta and Reddit pixels) — which are used to market AVA Golf™‘s own products and services to prospective users on third-party advertising platforms, and to measure which of AVA Golf™‘s own ads led to a sign-up or purchase. These tools do not enable third-party sponsors or advertisers to target AVA Golf™ users inside the Services. They do, however, transmit information about your activity — including online identifiers and, where the tool supports it, hashed contact details such as your email address, phone number, or name — outward to the advertising platform, which acts as an independent third party rather than as a processor on AVA Golf™‘s behalf. Hashing reduces but does not eliminate identifiability: a hashed email address is pseudonymized, not anonymous, and remains personal information under the GDPR and an identifier under the CCPA/CPRA. See Sections 2A.6 and 2A.7 for the specific tools currently deployed, and Section 13.1 for your right to opt out of this activity.
- Live chat and support tools (e.g., Intercom, Drift) — which collect messages, device information, and browsing context during support interactions
Where any of these tools are deployed, they will be disclosed in an updated version of this Privacy Policy. Each tool’s data collection is governed by its respective privacy policy. To the extent these tools use cookies or similar tracking technologies, you may manage your preferences through the cookie consent banner described in Section 2, reachable at any time from the footer of any page, or through your browser settings.
By continuing to use the Services, you acknowledge that AVA Golf™ may use third-party tools of the types described above, and that those tools may independently collect data about your interactions with the Services subject to their own privacy policies.
2A.5 Session Recording and Heatmaps — Microsoft Clarity, Contentsquare, and Mouseflow
AVA Golf™ uses three behavioural analytics tools to understand how visitors move through a page: Microsoft Clarity, operated by Microsoft Corporation; Contentsquare, operated by Contentsquare SAS; and Mouseflow, operated by Mouseflow ApS. All three are loaded through AVA Golf™‘s tag manager, which runs on both the marketing website (avagolf.com) and the web application (app.avagolf.com), so all three are active on both surfaces.
These tools go further than page-count analytics. Between them they may collect:
- Mouse movements, clicks, taps, scrolling, and rage- or dead-click signals
- A replayable recording of your session on the page, including navigation paths
- Heatmaps aggregated across many visitors
- Device type, operating system, browser, screen size
- IP address and approximate geographic location derived from it
- The content of the pages you viewed, excluding fields the tools are configured to mask
Session replay records more than a pixel does. A conversion pixel reports that something happened; a session recording reproduces what you did on the page. Treat the two as materially different in what they reveal about you, which is why they sit behind consent rather than being treated as strictly necessary.
Consent. All three follow the Analytics category in the cookie consent banner described in Section 2. In the European Economic Area, the United Kingdom and Switzerland that category is denied by default: until you affirmatively accept it, none of them loads and none of them records anything. Elsewhere, including the United States, it is on by default and they record until you turn the category off. You may withdraw consent, or turn the category off, at any time via “Cookie preferences” in the footer of any page.
Each of these providers acts as a data processor on AVA Golf™‘s behalf for this purpose, under its own terms and applicable data processing agreement. Data is transmitted to and stored by the respective provider.
Their privacy policies:
- Microsoft Clarity: https://privacy.microsoft.com/privacystatement
- Contentsquare: https://contentsquare.com/privacy-policy/
- Mouseflow: https://mouseflow.com/legal/privacy/ — opt out at https://mouseflow.com/opt-out/
2A.6 Advertising Measurement — OpenAI Pixel
AVA Golf™ uses the OpenAI Pixel (also referred to as oaiq), operated by OpenAI, LLC, to measure the results of AVA Golf™‘s own advertising. Its purpose is conversion measurement and campaign optimization: it tells us which of our ads led a visitor to sign up, so we can spend our advertising budget on the ones that work.
The OpenAI Pixel is deployed on both AVA Golf™‘s marketing website (avagolf.com), where it is loaded through AVA Golf™‘s tag manager under the Marketing category described in Section 2, and the AVA Golf™ web application (app.avagolf.com), which carries its own implementation. See Consent and how to opt out below.
What the pixel sends
- Page and conversion events. A page-load signal on the pages where it is active, and a
subscription_createdconversion event when a membership purchase completes. The conversion event includes the transaction amount and currency. - Advertising identifiers. A click identifier captured from the URL when you arrive from one of our ads, and a browser reference identifier generated by the pixel.
- Hashed contact details. OpenAI’s pixel supports a feature called automatic advanced matching. When it is active, the pixel reads contact details present in forms on the page and transmits them as SHA-256 hashes — specifically your email address, phone number, first name, and last name. AVA Golf™‘s account creation flow collects those details, as do forms on the marketing website that ask for a name or email address — for example the support request form and the newsletter signup. All of these are therefore within scope of this feature. Hashing is pseudonymization, not anonymization: hashed values remain personal information under the GDPR and identifiers under the CCPA/CPRA, and OpenAI may match them against its own records.
- Standard technical data. Your IP address, user agent, and the referring and current page URL, as with any request your browser makes to a third-party server.
Important: automatic advanced matching is configured from OpenAI’s own dashboard and delivered to the pixel as a remote setting at page load. It can therefore be enabled or disabled by OpenAI’s configuration without a change to AVA Golf™‘s code or a new deployment. This Privacy Policy describes the full capability of the tool rather than the state of a single setting at a single moment, so that the disclosure remains accurate however that setting is configured.
Cookies set by the pixel
| Cookie | Purpose | Retention |
|---|---|---|
__obref | Browser reference identifier used to associate a conversion with an ad click | 30 days |
__oaiq_consent | Records your consent state so the pixel knows whether it may operate | 30 days |
Where the data goes. Events are transmitted to bzr.openai.com, and the pixel’s configuration is retrieved from bzrcdn.openai.com. Both are operated by OpenAI, LLC in the United States.
OpenAI’s role. For this purpose OpenAI, LLC acts as an independent controller and a third party — not as a processor or service provider acting solely on AVA Golf™‘s instructions. OpenAI may use the data it receives for its own purposes, including advertising measurement and optimization across its own advertising platform, in accordance with its own privacy policy. This is a materially different role from the one described in Section 5.3, where OpenAI processes data as an AI inference provider on AVA Golf™‘s behalf. Two roles, two purposes, two sets of obligations.
Because of that role, the use of this pixel is a “share” of personal information for cross-context behavioral advertising purposes under the CCPA/CPRA, and it is a “sale” under the broad definitions used by several other U.S. state privacy laws. Your rights in relation to that activity, and how to exercise them, are described in Section 13.1.
Consent and how to opt out. On avagolf.com, the OpenAI Pixel follows the Marketing category in the cookie consent banner described in Section 2. In the European Economic Area, the United Kingdom and Switzerland that category is denied by default: until you affirmatively accept it, the pixel does not load and no event, identifier, or hashed contact detail is transmitted. Elsewhere, including the United States, it is on by default and the pixel loads until you turn the category off — except where your browser sends a Global Privacy Control signal, which opts you out before the pixel loads at all. You may withdraw that consent at any time by selecting “Cookie preferences” or “Do Not Sell or Share My Personal Information” in the footer of any page and turning the Marketing category off. Withdrawing consent stops further transmission; it does not by itself delete data already received by OpenAI, and you may contact us at privacy@avagolf.com for assistance with a deletion request directed to OpenAI.
OpenAI’s Privacy Policy: https://openai.com/policies/privacy-policy/
2A.7 Advertising Pixels — Meta and Reddit
In addition to the OpenAI Pixel described above, AVA Golf™ loads the Meta Pixel, operated by Meta Platforms, Inc., and the Reddit Pixel, operated by Reddit, Inc. The Meta Pixel is deployed on both the marketing website (avagolf.com) and the AVA Golf™ web application (app.avagolf.com), because a membership is completed in the application and an advertisement that led to one cannot otherwise be credited. The Reddit Pixel is loaded through the same tag manager and is therefore active on both surfaces as well. Both exist for the same narrow purpose: to measure which of AVA Golf™‘s own advertisements led a visitor to become a lead or a member, so that advertising budget can be directed at the ones that work.
What they send
- A page-load signal on the pages where they are active.
- A lead signal. The Meta Pixel additionally reports a
Leadevent when you click through from one of the device pages to start a membership. That event carries the brand and page context of the landing page you were on; it does not carry your email address. - Advertising identifiers. A click identifier captured from the URL when you arrive from one of our ads, and a browser identifier generated by the pixel.
- Standard technical data. Your IP address, user agent, and the referring and current page URL.
Cookies set by these pixels
| Cookie | Set by | Purpose |
|---|---|---|
_fbp | Meta | Browser identifier used to associate a conversion with an ad click |
_fbc | Meta | Stores the click identifier from a Meta advertisement |
_rdt_uuid | Browser identifier used for the same purpose on Reddit |
Their role. As with the OpenAI Pixel, Meta and Reddit act as independent third parties rather than as processors acting solely on AVA Golf™‘s instructions. Each may use what it receives for its own purposes under its own privacy policy. The use of these pixels is therefore also a “share” of personal information for cross-context behavioral advertising under the CCPA/CPRA, and a “sale” under the broader definitions used by several other U.S. state privacy laws. Section 13.1 describes how to opt out.
Consent. Both follow the Marketing category, which is the same category on either surface. In the European Economic Area, the United Kingdom and Switzerland it is denied by default, and until you accept it neither pixel is loaded and neither transmits anything. Elsewhere, including the United States, it is on by default and both load until you turn the category off or your browser sends a Global Privacy Control signal, which we honor before either pixel loads.
Their privacy policies: Meta — https://www.facebook.com/privacy/policy/ · Reddit — https://www.reddit.com/policies/privacy-policy
3. Third-Party Data Partner Integrations
AVA Golf™‘s core product depends on integrating data from multiple authorized partners. This section describes the data flows for each current partner. As AVA Golf™ adds additional data partners over time, this section will be updated to reflect those integrations. Each partner is an independent data controller with respect to data collected through their own platform — meaning each partner has its own privacy policy that governs data collected on their end. AVA Golf™‘s rights and obligations with respect to each partner’s data are governed by binding data sharing agreements with each partner.
3.1 Garmin International, Inc.
Effective Date of Integration: December 17, 2025
AVA Golf, Inc has entered into a Collaboration Agreement with Garmin International, Inc. (“Garmin”) to integrate Garmin’s Golf API. Under this integration, if you are a Garmin user and you authorize the connection, AVA Golf™ may receive the following data types, depending on the tier of access you authorize:
- Scorecard data: Round scores, hole-by-hole results, and scorecard history
- Shot Data (GPS): GPS-tracked shot locations, club used per shot, and on-course movement data collected during your round
- Launch Monitor data: Ball speed, clubhead speed, spin rate, launch angle, and carry distance from Garmin launch monitor devices
Both AVA Golf™ and Garmin are independent controllers of data shared under this integration. Upon termination of the Garmin integration — whether by you disconnecting the integration, by AVA Golf™, or by Garmin — AVA Golf™ is contractually required to return or destroy all Garmin Confidential Information in its possession, including your data transmitted under the integration, and to certify such destruction upon request.
Garmin’s Privacy Policy: https://www.garmin.com/en-US/privacy/app-privacy/
3.2 Arccos Golf LLC
AVA Golf™ has entered into an API License and Data Access Agreement with Arccos Golf LLC (“Arccos”). If you are an Arccos Caddie subscriber and you provide explicit written consent through the AVA Golf™ product for Arccos to share your data with AVA Golf™, we may receive:
- Personal details: Name, age, gender, dominant hand, email address, phone number, home golf course
- Location and movement: GPS data from on-course activity, course movement during play, round duration
- Performance data: Handicap, scores, shot-by-shot data, and statistical analysis derived from round data
- Equipment: Data relating to your clubs, balls, and other equipment you use during play
Important restrictions regarding Arccos data:
- AVA Golf™ receives Arccos data in a read-only capacity and cannot modify data on Arccos’s platform.
- Arccos data is licensed to AVA Golf™ solely for the purpose of delivering services to you as the end user. AVA Golf™ may not sell, sublicense, or redistribute raw Arccos data to any third party.
- AVA Golf™ accesses read-only performance statistics through the Arccos integration. Raw Arccos data is not stored within AVA Golf™‘s core systems. Anonymized, aggregated insights derived from user-authorized Arccos data connections are the property of AVA Golf™.
- If you disconnect your Arccos integration, or upon termination of AVA Golf™‘s agreement with Arccos for any reason, AVA Golf™ is contractually required to delete all Arccos-sourced data in its possession from all systems and certify that deletion. Anonymized or aggregated insights already incorporated into AVA Golf™‘s platform prior to termination are not subject to this deletion obligation.
- You may withdraw your consent to Arccos data sharing at any time by disconnecting the Arccos integration within the AVA Golf™ product. AVA Golf™ will promptly transmit your withdrawal of consent to Arccos.
Both AVA Golf™ and Arccos are independent controllers of Shared Personal Data under applicable privacy laws including the GDPR.
Arccos’s Privacy Policy: https://www.arccosgolf.com/pages/privacy-policy
3.3 United States Golf Association (USGA) — World Handicap System (WHS)
Effective Date of Integration: December 15, 2025
AVA Golf™ participates in the USGA’s Golfer Product Access (GPA) Program, which enables AVA Golf™ to access the USGA’s Data Services Platform and World Handicap System™. If you are a USGA-registered golfer with an active Handicap Index and you provide affirmative consent, AVA Golf™ may access and display:
- Your Handicap ID and current Handicap Index®
- Your Low Handicap Index™ and Handicap Index history (last 12 months)
- Your current 20-score history, including dates of play and course names
- Your scoring record for the prior 24 months
- Course Rating and Slope Rating information for courses you have played
Critical disclosure regarding USGA data:
By connecting your USGA/GHIN account and consenting to data sharing, you acknowledge and agree to the following:
-
Scoring data posted through AVA Golf™ becomes USGA property. Any scores posted through the AVA Golf™ product into the USGA Data Services Platform are incorporated into the USGA Master Data Set and become the sole property of the USGA.
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The USGA shares your data broadly. The USGA reserves the right to share your handicap and scoring data with regional golf associations, member clubs, other golfers (limited), and USGA-approved technology providers, as set forth in the USGA Privacy Policy. AVA Golf™ has no control over how the USGA shares data once it has been incorporated into the Master Data Set.
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USGA access is US-only. The USGA GPA Program is available only to users within the United States and its territories.
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AVA Golf™ may not compute or issue a Handicap Index. Only the USGA may issue a Handicap Index. AVA Golf™ displays USGA-computed handicap data but does not calculate, issue, or distribute its own Handicap Index.
You may opt out of USGA data sharing at any time by disconnecting the USGA integration within the AVA Golf™ product. Upon your opt-out, AVA Golf™ will immediately notify the USGA in writing.
USGA’s Privacy Policy: https://www.usga.org/content/usga/home-page/usga-privacy-policy.html
3.4 Future Data Partners
AVA Golf™ intends to add additional data partners over time across the golf ecosystem. For each new partner integration, we will update this Privacy Policy and provide you with notice of any material changes to data collection practices. We will obtain your explicit consent before activating any new integration that shares your personal data with a new third-party partner.
4. How We Use Your Information
AVA Golf™ uses the information we collect for the following purposes:
To deliver the Services:
- Creating and managing your account
- Displaying your golf performance data, statistics, and history
- Delivering Personalized Progression coaching and personalized insights through rules-based analysis of your performance data
- Recommending specific instructional video content matched to your identified performance gaps
- Enabling score posting and handicap integration
- Syncing data from connected third-party integrations
To improve and develop the Services:
- Analyzing usage patterns to identify product improvements
- Conducting research and development on new features
- Training and improving AVA Golf™‘s proprietary AI and machine learning models (see Section 5)
- Debugging and resolving technical issues
To communicate with you:
- Sending transactional messages (account confirmations, receipts, security alerts)
- Sending product updates, newsletters, and marketing communications where you have opted in or where we have a legitimate interest to do so
- Responding to support requests and inquiries
For security and fraud prevention:
- Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity
- Protecting the rights and property of AVA Golf™, its partners, and its users
- Enforcing our Terms of Service
For legal and compliance purposes:
- Complying with applicable laws, regulations, legal process, and governmental requests
- Enforcing our contractual obligations with data partners including Garmin, Arccos, and the USGA
- Establishing, exercising, or defending legal claims
For business purposes:
- Analyzing aggregate, de-identified data for internal analytics and business intelligence
- Sharing or licensing aggregated, de-identified data with third parties (see Section 7)
- Evaluating and completing business transactions (mergers, acquisitions, financing) as described in Section 6
5. Technology, Machine Learning, and Video Recommendations
This section describes how AVA Golf™ uses data processing technology — including rules-based analysis engines and machine learning — within the Services, and what that means for your data.
5.1 How AVA Golf™ Delivers Personalized Progression Coaching
AVA Golf™‘s coaching and insight engine is built on a deeply detailed, rules-based analysis system. Your golf performance data — including scores, shot patterns, strokes gained, and round history — is processed through structured analytical frameworks to identify specific strengths, weaknesses, and improvement opportunities in your game. This analysis does not rely on generative AI to produce coaching output; it reflects structured performance logic applied to your data.
5.2 Video Recommendation Engine
AVA Golf™ maintains a library of instructional video content. Each video in the library is weighted and tagged using machine learning models trained on content characteristics and user engagement patterns. When the rules-based analysis identifies a specific performance gap in your game, AVA Golf™‘s proprietary video recommendation model matches that gap to the most relevant instructional content in the library.
This matching process uses a proprietary model that AVA Golf™ develops, trains, and owns. Your video engagement data (see Section 1.7) and performance data are used as inputs to improve the accuracy of these recommendations over time.
5.3 Third-Party AI Service Providers
To support certain platform functions, AVA Golf™ may transmit data to one or more third-party AI and machine learning infrastructure providers. These providers may include, without limitation:
- Google LLC (Gemini models and related AI infrastructure)
- OpenAI, LLC — as an AI inference provider only. OpenAI, LLC also appears in this Privacy Policy in a second, unrelated role: as the operator of the OpenAI Pixel, an advertising measurement tool for which it acts as an independent third party rather than as a provider processing data on AVA Golf™‘s behalf. The two roles are separate — different data, different purpose, different legal basis — and the entries are not interchangeable. See Section 2A.6.
- Anthropic, PBC
- Amazon Web Services (AWS AI/ML services)
- Other AI infrastructure providers we may engage over time
When your data is transmitted to these providers, it is processed solely to support the function for which it was submitted. Your data may be temporarily retained by these providers in accordance with their respective privacy policies and AVA Golf™‘s data processing agreements with them. AVA Golf™ takes commercially reasonable steps to ensure that data shared with AI providers is subject to appropriate data protection obligations and is not used for those providers’ own model training without restriction.
5.4 Proprietary Model Training
AVA Golf™ uses your golf performance data and video engagement data to train, validate, and improve AVA Golf™‘s own proprietary machine learning models, including the video recommendation engine described in Section 5.2. This is a core part of how AVA Golf™ builds a more accurate and personalized product over time.
Where we use your data for model training, we apply the following practices:
- Training datasets are de-identified or pseudonymized to the extent technically feasible
- Raw data received from Arccos under its API license is not used in model training
- You may request that your data be excluded from future training datasets by contacting privacy@avagolf.com. Note that exclusion from training does not affect data already incorporated into previously trained model weights in de-identified form.
6. How We Share Your Information
AVA Golf™ does not sell your personal information in the traditional sense of exchanging identifiable data for money, and we do not sell or license your golf performance data to third parties. We do, however, share limited personal information with advertising platforms for the purpose of measuring our own advertising — an activity that meets the CCPA/CPRA definition of “sharing” for cross-context behavioral advertising and the broader definition of a “sale” used by several other U.S. state privacy laws, even though no money changes hands for your data. That activity is described in Sections 2A.6 and 2A.7, it requires your consent, and you can opt out of it at any time as described in Section 13.1.
Beyond that, we share your information in the following circumstances:
6.1 Data Partners and Integrations
As described in Section 3, when you authorize an integration with a data partner such as Garmin, Arccos, or the USGA, data flows primarily from that partner into AVA Golf™ — AVA Golf™ pulls your authorized performance data from each partner’s platform for display and analysis within the Services. AVA Golf™ transmits data back to data partners only for limited purposes, specifically: authentication and identity verification, transmission of your consent grants or withdrawals, and score posting to the USGA Data Services Platform where you have authorized it. AVA Golf™ does not transmit your performance data or personal information to data partners beyond what is necessary for these purposes. Each partner is an independent data controller with respect to data on their own platform.
6.2 Service Providers
We share data with vendors and third-party service providers that perform services on our behalf, including:
- Cloud infrastructure and hosting providers (e.g., Amazon Web Services)
- Payment processors (Stripe, Inc.)
- Analytics and monitoring services
- Email delivery providers
- Customer support tools
- AI/ML service providers (see Section 5.3)
These providers are authorized to use your data only to perform services for AVA Golf™ and are bound by contractual data protection obligations.
Not every recipient is a service provider. The advertising platforms described in Sections 2A.6 and 2A.7 (OpenAI, LLC in its capacity as operator of the OpenAI Pixel, together with Meta Platforms, Inc. and Reddit, Inc.) receive data as independent third parties, and may use what it receives for its own purposes under its own privacy policy. It is therefore not covered by the paragraph above, and the disclosure to it is a “share” rather than a disclosure to a processor. OpenAI, LLC appears in both categories for different data and different purposes: as a service provider for AI inference under Section 5.3, and as a third party for advertising measurement under Section 2A.6.
6.3 Coaches and Golf Professionals
If you authorize a golf instructor or coach to access your AVA Golf™ profile, we will share your performance data and round history with that individual as directed by you. You control who has access to your data through your account settings.
6.4 Aggregated and De-Identified Data
We share aggregated, de-identified, or anonymized data with third parties as described in Section 7. Such data does not identify you individually.
6.5 ParOne, Inc. and Affiliated Entities
AVA Golf, Inc is a wholly-owned subsidiary of ParOne, Inc. We may share your information with ParOne and its affiliates and subsidiaries — including ParOne Holdings LLC, ParOne.dev LLC, ParOne App LLC, and GolfCentral TV, Inc. — for purposes consistent with this Privacy Policy, including shared infrastructure, internal analytics, business operations, and the development of related products and services. All ParOne entities that receive your data are subject to data handling obligations consistent with this Privacy Policy.
6.6 Business Transfers
If AVA Golf™ or ParOne is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your information may be transferred to the acquiring or successor entity. We will provide notice prior to your personal information being transferred and becoming subject to a different privacy policy.
6.7 Legal Compliance and Protection
We may disclose your information when we believe in good faith that disclosure is necessary or appropriate to:
- Comply with applicable law, legal process, or governmental requests (including from law enforcement)
- Enforce our Terms of Service or other agreements
- Protect the rights, property, or safety of AVA Golf™, our users, our data partners, or the public
- Detect, prevent, or address fraud, security, or technical issues
6.8 Third-Party Partners and Commercial Arrangements
AVA Golf™ may share your information with third parties in connection with commercial partnerships, data licensing arrangements, and third-party service engagements as described in Section 7. By continuing to use the Services, you acknowledge and consent to data sharing practices consistent with this Privacy Policy, including sharing with third-party partners for the purposes described herein. Notwithstanding the foregoing, where applicable law requires explicit, freely given consent as a condition of data sharing — including under the GDPR and UK GDPR — AVA Golf™ will obtain that consent separately and will not rely on continued use of the Services as a substitute for such consent. If you do not consent to these practices, you may discontinue use of the Services and request deletion of your account as described in Section 12.
7. Data Monetization and Aggregated Data
AVA Golf™ may share, license, or sell aggregated, anonymized, or de-identified data derived from user activity with third parties. Such data does not identify you individually.
Third-party recipients of aggregated data may include:
- Golf equipment manufacturers and brands
- Golf courses and facilities
- Golf industry research organizations
- Media companies and publishers
- Marketing and analytics firms
- Investors and potential business partners (under appropriate confidentiality obligations)
Examples of aggregated data we may share or license:
- Average strokes gained by club type across a user population
- Most common shot patterns on specific holes or courses
- Aggregate handicap trends over time across geographic regions
- Equipment performance benchmarks at the population level
AVA Golf™‘s position is that aggregated, de-identified data that cannot be used to identify individual users does not constitute a “sale” of personal information under applicable privacy laws. However, to the extent that any applicable law treats such sharing as a sale or sharing for cross-context behavioral advertising, we will honor your rights under those laws as described in Section 13.
If you have concerns about how your data may contribute to aggregated datasets, you may contact us at privacy@avagolf.com to request that your data be excluded from aggregated commercial datasets to the extent technically feasible.
8. Advertising and Sponsorships
AVA Golf™ does not sell access to its users’ personal information to advertisers, nor does AVA Golf™ allow third-party sponsors or advertisers to directly target users within the Services. Any sponsored content, brand integrations, or commercial placements within the Services are managed exclusively by AVA Golf™. Sponsors and partners pay AVA Golf™ to reach our audience — they do not receive user data, targeting capabilities, or direct access to AVA Golf™‘s user base as part of any commercial arrangement.
AVA Golf™ may use aggregated, de-identified audience data internally to inform sponsorship pricing, placement decisions, and commercial partnerships. This data does not identify individual users and is not shared with sponsors in identifiable form.
Advertising inside the Services versus measuring our own ads outside them. The paragraphs above concern advertising directed at you within the Services, and they remain accurate: no third party buys the ability to target you inside AVA Golf™. Separately, AVA Golf™ advertises itself on other companies’ platforms — and to know which of those ads work, we send conversion signals outward to the advertising platform we bought the ad from. That outward flow does involve your personal information, it is a “share” for cross-context behavioral advertising under the CCPA/CPRA, and it is disclosed in full in Sections 2A.6 and 2A.7. It requires your consent and you can withdraw it at any time (Section 13.1). We state the distinction plainly here so that this section is not read as a denial of the activity described there.
We may engage in first-party marketing of our own products and services to you through email (where you have opted in or where permitted by law) and through our own owned and operated channels.
We reserve the right to introduce additional monetization features in the future. Any material changes to how advertising or sponsorships affect your personal data will be disclosed through an updated Privacy Policy with advance notice.
9. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by law, contract, or legitimate business need, whichever is longer.
General retention principles:
- Active account data: Retained for the life of your account plus a reasonable period following account closure to address any post-closure inquiries, disputes, or legal obligations.
- Transaction records: Retained for a minimum of seven (7) years for tax and accounting purposes.
- Golf performance data: Retained for the life of your account. Upon account deletion, personal identifiers are removed; de-identified performance data may be retained in aggregated form.
- Partner integration data: Retention is subject to the requirements of the applicable data partner agreement. For Arccos data specifically, upon termination of the Arccos integration we are contractually required to delete all Arccos-sourced data from our systems and certify that deletion.
- Anonymous analysis submissions: The link to a report produced from an anonymous submission expires thirty (30) days after the report is created, after which it no longer opens. A launch-monitor file uploaded through one of these pages is deleted from our storage on a thirty (30) day lifecycle. The email address itself is retained as a contact record until you unsubscribe or ask us to delete it.
- Legal hold: Data subject to an active legal hold, regulatory investigation, or litigation will be retained as required regardless of the above periods.
- Proprietary model training: De-identified data incorporated into trained machine learning models may persist in the model itself; deletion requests cannot retroactively modify already-trained model weights.
You may request deletion of your personal information at any time as described in Section 12.
10. Data Security
AVA Golf™ implements and maintains administrative, physical, and technical safeguards designed to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction. These measures include:
- Encryption of data in transit using TLS/SSL
- Encryption of sensitive data at rest
- Access controls and authentication requirements for internal systems
- Regular security assessments and vulnerability management
- Vendor security due diligence for service providers handling personal data
- Security incident response procedures
AVA Golf™ complies with the security requirements of each data partner agreement, including those of Garmin, Arccos, and the USGA. In the event of a security incident affecting data received from a partner, we are contractually required to notify the relevant partner without undue delay and to cooperate in investigation and remediation.
No security measure is 100% effective. No electronic transmission or storage system can be guaranteed to be fully secure. While we work hard to protect your information, we cannot guarantee that unauthorized parties will never circumvent our security measures. You are responsible for maintaining the security of your account credentials.
Security incident notification: If we become aware of a security incident that affects your personal information, we will notify you and relevant authorities as required by applicable law.
11. Children’s Privacy (COPPA)
The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. If we become aware that we have inadvertently collected personal information from a child under 13 without verifiable parental consent, we will take immediate steps to delete that information from our systems.
If you believe that we may have collected information from a child under 13, please contact us immediately at privacy@avagolf.com.
Parents and guardians who believe their child has provided personal information to AVA Golf™ may contact us to request review and deletion of that information.
Note: Golf is a family sport and we recognize that junior golfers may use the Services under parental supervision. We encourage parents to supervise their children’s use of the Services and to contact us with any questions about our data practices.
12. Your Privacy Rights
Regardless of where you are located, you have the following rights with respect to your personal information:
Right to Access: You may request a copy of the personal information we hold about you.
Right to Correction: You may request that we correct inaccurate or incomplete personal information.
Right to Deletion: You may request that we delete your personal information. Note that certain information may be retained as required by law, contract (including our data partner agreements), or legitimate business need.
Right to Portability: You may request that we provide your personal information in a structured, commonly used, machine-readable format.
Right to Opt Out of Marketing: You may opt out of receiving marketing communications from us at any time by using the unsubscribe link in any email or by contacting us at privacy@avagolf.com. You cannot opt out of transactional or administrative communications related to your account.
Right to Disconnect Integrations: You may disconnect any third-party data integration (Garmin, Arccos, USGA, etc.) at any time through your account settings. Disconnection will terminate AVA Golf™‘s ongoing access to new data from that integration and trigger any applicable data deletion obligations described in Section 3.
Right to Withdraw Consent: Where we process your data based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.
To exercise any of these rights, contact us at:
- Email: privacy@avagolf.com
- Mail: AVA Golf, Inc., 169 Madison Ave #2003, New York, NY 10016, Attn: Privacy
We will respond to your request within the timeframes required by applicable law, and in any event within 45 days. We may need to verify your identity before processing your request. Notwithstanding the foregoing, residents of California and other states with applicable privacy laws that prescribe shorter response deadlines will receive responses within the timeframes required by their applicable state law.
13. United States Residents — State-Specific Rights
13.1 California Residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following additional rights:
Right to Know: You have the right to know the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom we have shared it.
Right to Delete: Subject to certain exceptions, you have the right to request deletion of personal information we have collected from you.
Right to Correct: You have the right to request correction of inaccurate personal information.
Right to Opt Out of Sale or Sharing: AVA Golf™ does not sell your personal information for monetary consideration. AVA Golf™ does share personal information with third-party advertising platforms for cross-context behavioral advertising purposes, as described in Sections 2A.6 and 2A.7, in order to measure the results of AVA Golf™‘s own advertising. You have the right to opt out of that sharing at any time, and exercising it costs you nothing and changes nothing about your access to the Services.
A note on a previous version of this policy: until August 24, 2026 this section stated that AVA Golf™ did not share personal information for cross-context behavioral advertising and that the opt-out right was therefore not applicable. That statement was accurate when written. This policy has been updated, with the opt-out mechanism described below live at the same time, because the practice has changed.
How to opt out. Any of the following works, and each takes effect immediately:
- Select “Do Not Sell or Share My Personal Information” in the footer of any page and turn off the Marketing category.
- Select “Cookie preferences” in the footer and turn off the Marketing category — the same control, reached a different way.
- Decline the Marketing category, or select “Reject all”, when the cookie consent banner first appears. In the United States the Marketing category is on by default, so taking no action leaves it on: turn the category off, use the “Do Not Sell or Share My Personal Information” link in the footer, or enable Global Privacy Control in your browser, which we honor automatically before any advertising tag loads.
- Email privacy@avagolf.com, or have an authorized agent do so on your behalf.
Because the opt-out is stored in your browser, you will need to set it again on a different browser or device, or after clearing your site data.
Right to Limit Use of Sensitive Personal Information: To the extent we process sensitive personal information (as defined under CPRA), you have the right to limit our use of such information to purposes permitted under the CPRA.
Right Against Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
Categories of personal information collected in the last 12 months: Identifiers (name, email, IP address), commercial information (payment records), geolocation data, Internet or other network activity (usage data, video engagement data), inferences drawn from personal information (Personalized Progression coaching recommendations, video recommendations), and golf performance data.
Categories of personal information sold in the last 12 months: None. AVA Golf™ does not sell personal information for monetary consideration.
Categories of personal information shared for cross-context behavioral advertising in the last 12 months:
| Category | What is shared | Recipient | Purpose |
|---|---|---|---|
| Identifiers | Advertising click identifier, browser reference identifier, IP address, and — where automatic advanced matching is active — the SHA-256 hash of your email address, phone number, first name, and last name | OpenAI, LLC | Measuring which AVA Golf™ advertisement led to a sign-up, so campaigns can be optimized |
| Commercial information | That a membership purchase completed, with the transaction amount and currency | OpenAI, LLC | Same |
| Internet or other network activity | Page URL, referring URL, and user agent for the pages where the pixel is active | OpenAI, LLC | Same |
No other category of personal information is shared for advertising purposes. In particular, your golf performance data, round history, scores, coaching recommendations, and video engagement data are not shared with any advertising platform. Sharing occurs only where you have accepted the Marketing category, and Section 2A.6 describes the mechanism in full.
Sensitive personal information: AVA Golf™ does not use or disclose sensitive personal information for the purpose of inferring characteristics about you, and does not share sensitive personal information for cross-context behavioral advertising.
Retention. Data shared with the advertising platform is retained by that platform under its own retention policy, which AVA Golf™ does not control. See Section 9 for AVA Golf™‘s own retention practices.
To submit a California privacy request, contact privacy@avagolf.com or write to us at the address above. You may also designate an authorized agent to submit a request on your behalf.
Do Not Sell or Share My Personal Information: A “Do Not Sell or Share My Personal Information” link appears in the footer of every page of AVA Golf™‘s websites. Selecting it opens the privacy controls where you can turn off the Marketing category, which is the mechanism that stops the sharing described in Section 2A.6. No account, and no verification of your identity, is required to use it.
AVA Golf™ does not sell personal information for monetary consideration, so there is nothing to opt out of on the “sale” side; the link covers both because the CCPA/CPRA treats them as a single opt-out right.
We do not discriminate against anyone who exercises this right, and we do not treat an opt-out as a reason to degrade, limit, or price the Services differently.
13.2 Other U.S. State Privacy Laws
Residents of Colorado, Connecticut, Virginia, Texas, and other states with comprehensive privacy laws may have similar rights to those described in Section 13.1, including rights to access, correct, delete, and port personal data, and to opt out of certain processing activities. To exercise these rights, contact privacy@avagolf.com.
Targeted advertising and “sale” under other state laws. Several of these laws define a “sale” more broadly than California does — as a disclosure for any valuable consideration, not only for money — and separately grant a right to opt out of targeted advertising. The advertising measurement described in Section 2A.6 falls within those definitions. If you are a resident of one of these states, you have the right to opt out of it, and the same controls described in Section 13.1 serve that purpose: the “Do Not Sell or Share My Personal Information” link in the footer of any page, or the Marketing category in the cookie consent banner. As in California, the Marketing category is on by default outside the European Economic Area, the United Kingdom and Switzerland, so it is turning that category off — or sending a Global Privacy Control signal, which we honor automatically — that stops the processing.
We will respond to verified consumer requests in accordance with the timelines and requirements of applicable state law.
14. European Union, United Kingdom, and Canadian Users
14.1 GDPR and UK GDPR
AVA Golf™‘s data partner agreements with both Garmin and Arccos explicitly reference and require compliance with the General Data Protection Regulation (GDPR) (EU 2016/679) and its UK equivalent (UK GDPR). AVA Golf™‘s Garmin agreement specifically cites the UK GDPR, the Data Protection Act 2018, EU GDPR, and the CCPA. To the extent AVA Golf™ processes personal data of individuals located in the European Union or the United Kingdom, we do so in compliance with applicable Data Protection Legislation.
Legal bases for processing (GDPR/UK GDPR):
- Consent: Where you have given explicit consent to a specific processing activity (e.g., activating a third-party data integration, receiving marketing communications, model training, or the advertising and analytics cookies and tags described in Sections 2A and 2A.6). Consent is the sole lawful basis for the advertising measurement described in Section 2A.6 — we do not rely on legitimate interests for it. For visitors in the European Economic Area, the United Kingdom and Switzerland, consent is captured before the tag is loaded, not after: the Marketing category is denied by default there, and the pixel is not placed on your device and transmits nothing unless and until you accept that category. You may withdraw consent at any time, as easily as you gave it, using the footer link described in Section 13.1; withdrawal stops further processing but does not affect the lawfulness of processing carried out beforehand.
- Contract: Where processing is necessary to perform our contract with you (e.g., delivering the Services, processing payments).
- Legitimate Interests: Where we have a legitimate interest in processing your data that is not overridden by your rights (e.g., improving our recommendation models, fraud prevention, internal analytics).
- Legal Obligation: Where processing is necessary to comply with applicable law.
Data transfers: Where we transfer personal data outside the EEA or UK (e.g., to US-based service providers, AI providers, or the advertising platform described in Section 2A.6, whose endpoints are located in the United States), we implement appropriate safeguards including Standard Contractual Clauses (SCCs) or other transfer mechanisms recognized under applicable law.
Data subjects’ rights under GDPR/UK GDPR: In addition to the rights described in Section 12, EU and UK data subjects have the right to lodge a complaint with a supervisory authority. For UK residents, this is the Information Commissioner’s Office (ICO). For EU residents, the relevant supervisory authority in your member state. We encourage you to contact us first at privacy@avagolf.com so we may work to resolve your concern directly.
14.2 Canadian Users (PIPEDA / Law 25)
For users located in Canada, we process personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. We rely on your consent (express or implied) as the basis for collecting, using, and disclosing personal information, and you may withdraw that consent at any time subject to legal and contractual restrictions. Quebec residents have additional rights under Law 25 (Law modernizing privacy legislation), including rights of access, rectification, and data portability.
15. Third-Party Links and Services
The Services may contain links to third-party websites, applications, or services that are not operated by AVA Golf™. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access. AVA Golf™ is not responsible for the privacy practices of third parties.
16. Do Not Track and Opt-Out Preference Signals
Do Not Track (DNT). Some browsers offer a “Do Not Track” signal that you can enable to indicate a preference that websites and applications not track your activity. AVA Golf™ does not respond to DNT signals, because no uniform industry standard was ever adopted for how they should be interpreted and honored. Most browsers have since removed the setting. We will continue to monitor developments in this area.
Global Privacy Control (GPC). GPC is the successor to DNT, and unlike DNT it is a defined specification and is recognized by several U.S. state privacy laws as a valid opt-out preference signal. AVA Golf™ honors GPC. If your browser or a browser extension sends a GPC signal, AVA Golf™ treats it as an opt-out of the sharing of personal information for cross-context behavioral advertising and targeted advertising described in Sections 2A.6 and 13.1: the Marketing category is treated as denied, and advertising tags are not granted consent, regardless of any earlier choice recorded in that browser.
Because GPC is sent by your browser, it applies per browser and per device. It does not travel with your AVA Golf™ account, so a browser that does not send the signal will follow whatever choice you made in the cookie consent banner there.
Which control wins. If GPC is on, it takes precedence and advertising sharing does not occur — accepting the Marketing category in the banner will not override it. If GPC is off or unavailable, the choice you make in the banner governs; where you have made no choice, the regional default described in Section 2 applies.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Services. When we make material changes, we will:
- Update the “Last Updated” date at the top of this policy
- Notify you via email (to the address associated with your account) or through a prominent notice within the Services
- Where required by law, obtain your renewed consent
Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you should discontinue your use of the Services and may request deletion of your account.
We maintain a version history of this Privacy Policy and will provide prior versions upon request to privacy@avagolf.com.
18. Referral Program
When you visit AVA Golf™ using a referral link, we store a short referral code in your browser’s local storage (ava_ref). This code is an opaque 8-character identifier — it contains no personal data and does not identify you. It is used solely to credit the person who invited you when you sign up, at which point it is removed from local storage.
19. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or AVA Golf™‘s data practices, please contact us:
AVA Golf, Inc.
Attn: Privacy
169 Madison Ave #2003
New York, NY 10016
Email: privacy@avagolf.com
For data subject rights requests, security incidents, or urgent privacy matters, please include “PRIVACY REQUEST” or “SECURITY INCIDENT” in the subject line of your email.
For users located in the EU or UK who are not satisfied with our response, you have the right to lodge a complaint with your applicable data protection supervisory authority.
This Privacy Policy is effective as of the Last Updated date set forth above and supersedes all prior versions.
AVA Golf, Inc. is a Delaware corporation. This policy is governed by the laws of the State of New York, consistent with AVA Golf™‘s data partner agreements.