Privacy Policy

PRIVACY NOTICE

Last Updated: [February 3, 2025]

 

Welcome to the PGA Shop — an online store and in-person retail store operation run by Legends Global Merchandise, LLC (together with its affiliated companies, “Legends,” “we,” “us,” or “our”) for all of your PGA gear. When you purchase from the PGA Shop, you provide personal data to Legends and to The Professional Golfers Association of America (together with its affiliated companies, the “PGA”).

Legends uses your personal data to allow you to administer your online and offline relationship with Legends, comply with Legends legal obligations, provide you with Legends and PGA products and services, and send you marketing.

This privacy notice explains how Legends collects, uses, discloses, and otherwise processes personal data in connection with the online PGA Shop at  https://shop.pga.com/  (the "PGA Shop") and in-person PGA retail store.

Legends may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may apply to you.

PGA processes your personal data under its own privacy policy.

What Does This Notice Cover?

This privacy notice describes how Legends collects and uses your personal data when you browse or make a purchase from the PGA Shop, correspond with Legends, follow us or otherwise interact with us on social media platforms, or attend venues or premises at which we operate.

It also describes your privacy and data protection rights, including where applicable the right to object to some of Legends' processing. More information about your rights and how to exercise them is in the Your Privacy Choices section below.

This privacy notice does not address Legends’ privacy practices relating to Legends job applicants, employees, and other employment-related individuals. It also does not address our use of data that is not subject to applicable data protection laws (such as anonymized data), or our privacy practices relating to our corporate site (Legends.net) or representatives of our partners (both of which are addressed in Legends Corporate Privacy Policy). This privacy notice is also not a contract and does not create legal rights or obligations not otherwise provided by law.

Legends Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” sometimes referred to as a “service provider,” processes personal data on behalf of a controller and is subject to the controller’s instructions.

This privacy notice describes Legends' privacy practices where we act as a controller in respect of our processing of personal data in connection with providing the PGA Shop. This privacy notice does not cover or address Legends' processing of personal data in our capacity as a processor or service provider on behalf of PGA and we recommend you refer to the PGA Privacy Policy for information on how they process personal data. Any requests relating to personal data processed on behalf of PGA in our capacity as a processor should be directed to the PGA and will typically be handled directly by the PGA (see their Privacy Policy, linked above).

If you access the PGA Shop or otherwise interact with us from the European Economic Area, United Kingdom, or Switzerland, please see the Who is Responsible for Your Personal Data section of our Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures set out below, for more information about the legal entity operating as the controller of your personal data.

Personal Data We Collect

Personal Data You Provide to Legends

We collect and process personal data about you that you provide directly to us when you interact with us, our websites and apps, and when you make purchases.

The categories of personal data we collect depend on how you interact with us and the PGA Shop. For example, you may provide us with your personal data directly when you communicate with us (such as by email or phone), report a problem or request support with the PGA Shop, buy merchandise from us online or from a PGA retail store, participate in contests, promotions, sweepstakes, or customer service surveys, or sign up for an account, fill out forms, or otherwise engage with the PGA Shop.

This includes:

Category	Details
Account Information	Your name, username and password for your account on the PGA Shop, gender, and age/date of birth.
Contact Information	Your home address, email address and phone number, and social media usernames.
Communications Between You and Us	Details of any communications you may make to us, including through customer messages sent through forms, emails, or other contact information we make available, including call recordings where permissible.
Purchase Details	Your purchase, payment, and delivery details, including items purchased, billing and delivery addresses and payment card details. We use third-party payment providers, including Stripe, to process payments made to us. To view Stripe’s privacy policy, please click here.
Product Returns and Complaints	Details of any requests to return products, the reason for the return (including any faults) and refunds processed.
Communication Preferences	Your preferences in receiving marketing information from us, and your communication preferences.
Market Research Information	Information collected in the course of carrying out market research, including your responses to surveys.
Engagement Information	Information you provide or that we create when you engage in competitions or feedback, including entries to events, contests or promotions and feedback and ratings you provide relating to the PGA Shop or its products.

Personal Data We Receive from Third Parties

Sometimes, we receive information about you from third parties. In particular:

●  Social Media Sites: If you interact with us on social media, such as if you "follow" us, "tag" us or participate in an online event, community or form that we operate on the relevant social media platform, we may access information about you and your profile on that social media platform that you choose to share in accordance with your settings.

●  PGA: We work closely with PGA and may receive information from them to help us tailor your services, ensure you have access to certain services or goods you are entitled to or to allow us to send you appropriate direct marketing.

●  Advertisers, Influencers, and Publishers: We advertise on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us regarding our advertising efforts. For example, we may obtain information about whether an advertisement on a third-party's services led to a purchase through the PGA Shop.

●  Service Providers: Our service providers that perform services on our behalf, such as analytics and surveys, collect personal data and often share some or all this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.

●  Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

Personal Data We Receive or Generate Automatically

We also collect the following personal data automatically when you browse or otherwise interact with the PGA Shop online:

Category	Details
Information About Your Device and Network	This may include the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
Information About the Way You Use the PGA Shop and Interact With Us	This may include the site from which you came, the site to which you are going when you leave the PGA Shop, how frequently you access the PGA Shop, whether you open emails or click the links contained in emails, whether you access the PGA Shop from multiple devices, and other browsing behavior and actions you take on the PGA Shop (such as the pages you visit, the content you view, the communications you have through the PGA Shop, and the content, links and ads you interact with). We and PGA employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on the PGA Shop, which may record your mouse movements, scrolling, clicks, and keystroke activity on the PGA Shop and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with the PGA Shop or engage in communication features we provide.
Information About Your Location	This may include a general geographic location that our third-party providers (including PGA and their partners) or we may derive from your IP address.

We may use the above information to operate the PGA Shop, enhance and personalize your user experience, to monitor and improve the PGA Shop, offer communications features, and enhance the effectiveness of our products, services, offers, communications, and customer service.

We may also use this information to (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the PGA Shop; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and other patterns on the PGA Shop website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

We typically collect this information through the use of a variety of our own and our third-party partners’ (including PGA’s and their partners’) automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies.

For additional details about the cookies we and PGA use on the PGA Shop and to adjust your preferences about those cookies, please visit our Cookie Policy and the “Do Not Sell My Personal Information” link in the footer of the PGA Shop website.

Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources. We may share a common account identifier (such as a hashed email address or user ID) with third-party advertising partners to help link the personal data we, and our third-party partners, collect about the same person and target advertising to that individual on a third-party website or platform.

We also generate or collect information about you ourselves without your input. We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

How Legends Uses Your Personal Data

We use personal data that we collect to:

−      Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the services requested, and to process transactions;

−      Fulfill the shipment of the goods and services you order;

−     Manage the PGA Shop, our organization, and their day-to-day operations;

−      Request you provide us feedback about the PGA Shop and our product and service offerings;

−      Market PGA products and services to you, including through email and social media;

−      Administer, improve, and personalize the PGA Shop and our products and services, including by recognizing you and remembering your information when you return to the PGA Shop;

−      Develop, operate, improve, maintain, protect, and provide the features and functionality of the PGA Shop and our products and services;

−      Identify and analyze how you use our PGA Shop and products and services;

−      Infer additional information about you fromusing the PGA Shop and our products and services, such as your interests.

−      Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this privacy notice;

−      Conduct research and analytics on our customer and user base, the PGA Shop, and our products and services; 

−      Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;

−      Test, enhance, update, and monitor the PGA Shop and our products or services, or diagnose or fix technology problems;

−      Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;

−      Defend, protect, or enforce our rights or applicable contracts and agreements (including the PGA Shop  Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;

−      Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Legends, PGA, and others;

−      Facilitate business transactions and reorganizations impacting the structure of our business;

−      Comply with contractual and legal obligations and requirements;

−      Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

If you access the PGA Shop or otherwise interact with us from the European Economic Area, United Kingdom, or Switzerland, additional information about how we use your personal data and the lawful basis we rely on is set out in the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures set out below.

Legends Disclosure of Personal Data

Legends may disclose or otherwise make available personal data in the following ways:

−      To the PGA: We share personal data with PGA, as required under our contract. PGA will use your personal data for business and commercial purposes, such as to market events, sell tickets, and engage in other marketing activities. Please refer to the PGA  privacy policy for more information.

−     To Marketing Providers: We coordinate and share personal data with our marketing providers to advertise and communicate with you about the PGA Shop and the related products and services we make available.

−     To Ad Networks and Advertising Partners: We and PGA work with third-party ad networks and advertising partners to deliver advertising and personalized content on the PGA Shop, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit the PGA Shop and other services through cookies and related technologies. This information is used to provide and inform targeted advertising and advertising-related services such as reporting, attribution, analytics, and market research.

−     To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or access personal data while performing services on our behalf.

−     To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction, including, for example, payment processing services.

−     In Connection with a Business Transaction or Reorganization:We may participate in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during the negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.

−     To Facilitate Legal Obligations and Rights:We may disclose personal data to third parties, such as legal advisors and law enforcement:

o   in connection with the establishment, exercise, or defense of legal claims;

o   to comply with laws or to respond to lawful requests and legal process;

o   to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;

o   to detect, suppress, or prevent fraud;

o   to reduce credit risk and collect debts owed to us;

o   to protect the health and safety of us, our customers, or any person; or

o   as otherwise required by applicable law.

If you access the PGA Shop or otherwise interact with us from the European Economic Area, United Kingdom, or Switzerland, additional information about how we share your personal data is set out in the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures set out below.

Your Privacy Choices

The following privacy choices are made available to all individuals with whom Legends interacts. You may also have additional choices or rights regarding your personal data depending on your location or residency. Please refer to Legends Region-Specific Disclosures below for information about additional privacy choices that may be available to you.

Automatic Data Collection Preferences

We provide you the ability to adjust your preferences regarding our use of automatic data collection technologies on the PGA Shop. Please visit the “Do Not Sell My Personal Information” link in the footer of the PGA Shop to adjust your preferences regarding certain automatic data collection technologies on the PGA Shop for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the PGA Shop). Your preferences on the PGA Shop do not apply to automatic data collection technologies PGA may use on its own websites.

If you are in the European Economic Area, United Kingdom or Switzerland, unless these technologies are strictly necessary to provide the PGA Shop or certain functionalities of the PGA Shop that you request, we will only use use these technologies to the extent you give us your consent to do so. You can withdraw your consent at any time by visiting the “Do Not Sell My Personal Information” link in the website footer and adjusting your preferences.

You may also be able to utilize third-party tools and features to further restrict the use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using the PGA Shop, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies, or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Targeted Advertising Preferences

The data Legends and PGA and our and their third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. You can control what personal data we collect for targeted advertising by adjusting your cookie preferences, as set out in the Automatic Data Collection Preferences section above.

You may also be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

−   Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.

−   Digital Advertising Alliance: The  Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at  https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by third parties that participate in the Digital Advertising Alliance’s self-regulatory program.

−    European Interactive Digital Advertising Alliance: The European Interactive Digital Advertising Alliance similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at  https://www.youronlinechoices.eu to opt out of browser-based targeted advertising carried out by third parties that participate in the European Interactive Digital Advertising Alliance’s program.

−    Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by third parties that participate in the Network Advertising Initiative’s self-regulatory program.

−    Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or PGA or on our or PGA-related services. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We and PGA are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about their use of the PGA Shop, including for analytics and fraud prevention and any other purpose permitted under the applicable advertising industry program.

Modifying or Deleting Your Personal Data

If you have an online account with us, you have the ability to modify or delete certain information in your account (e.g., your contact information) through the “settings” option provided on the PGA Shop website. If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at dataprivacy@legends.net. We may not be able to modify or delete your personal data in all circumstances.

Partner-Specific Preferences

Certain of Legends and PGA’s third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:

−    Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with the PGA Shop (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us and PGA. For example, many mobile devices allow you to change your device permissions to prevent products and services from accessing certain types of information from your device, and many social media platforms allow you to change your platform permissions to prevent products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

−    Google Analytics: Google Analytics allows us and PGA to understand better how PGA Shop customers interact with the PGA Shop. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We and PGA may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable the PGA Shop to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the PGA Shop. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/?ref=help-center.

Children’s Personal Data

The PGA Shop and our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 16. If an individual is under the age of 16, they should not use the PGA Shop or our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 16, we will promptly delete that personal data.

Retention of Personal Data

Legends collects, stores, and uses your personal data as long as you remain a customer and in compliance with our legal obligations to retain certain types of data, such as for tax purposes and legitimate business interests. We review our retention periods for personal data on a regular basis.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Therefore, we retain personal data for as long as you continue to use the PGA Shop and our services for the purposes explained in the section above. When you discontinue the use of the PGA Shop and our services, we will retain your personal data for as long as necessary to comply with our legal obligations, to resolve disputes, and defend claims, as well as for any additional internal business purposes. We will retain any other personal data supplied during the duration of your contract with us in relation to the PGA Shop and our services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or anonymize the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

If you are a California resident, additional information about how long we retain your personal data is set out in the Additional California-Specific Disclosures set out below.

If you access the PGA Shop or otherwise interact with us from the European Economic Area, United Kingdom, or Switzerland, additional information about how long we retain your personal data is set out in the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures set out below.

Third-Party Websites and Services

The PGA Shop, newsletters, email updates, and other communications from us may, from time to time, include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this privacy notice, this privacy notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

−    European Economic Area, United Kingdom or Switzerland: If you are in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please click here for additional European-specific privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.

−    United States: If you are a resident of the United States, please click here for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

Updates to This Privacy Notice

We may update this privacy notice from time to time. When we make changes to this privacy notice, we will change the date at the beginning of this privacy notice. If we make material changes to this privacy notice, we will notify individuals by email to their registered email address, by prominent posting on the PGA Shop, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this privacy notice or other privacy-related matters, please send an email to dataprivacy@legends.net  or contact us at:

Legends Global Merchandise, LLC
Attn: Legends Data Privacy Office
61 Broadway, Suite 2400
New York, NY 10060

ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of certain states in the United States. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read the privacy notice (linked above).

Nevada Residents

If you are a resident of Nevada, please note Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please email dataprivacy@legends.net.

California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia Residents

If you are a resident of the states of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia in the United States, the following supplementary disclosures apply to you.

Personal Data Disclosures, Sales, and Targeted Advertising

We disclose all of the categories of personal data we collect to the categories of recipients outlined in the Our Disclosure of Personal Data section of our Privacy Notice.

Our disclosure or making available of contact information, commercial information, information about how you use the PGA Shop and interact with us, and inferences about your interests and preferences to ad networks and advertising partners (directly or through PGA) may qualify as the sale of personal data or the sharing or processing of personal data to display advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

Please note we do not collect personal data of individuals we know to be less than 16 years of age. As a result, we do not sell or share such information for targeted advertising purposes.

Sensitive Personal Data

The payment card information you provide directly to our third-party payment providers may be classified as “sensitive” under certain privacy laws. However, we do not directly collect or process this potentially sensitive personal data.

Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Automated Decision-Making and Profiling

We do not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.

Your Additional U.S. Privacy Choices

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

−    Right to Know: The right to confirm whether we are processing personal data about you and, for residents of California and Oregon only, to obtain certain personalized details about the personal data we have collected about you, including:

o   The categories of personal data collected;

o   The categories of sources of the personal data;

o   The purposes for which the personal data were collected;

o   The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed (or, for Oregon residents only, a list of the specific third parties to whom personal data have been disclosed);

o   The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and

o   The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.

−    Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

−    Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.

−    Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.

−    Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties, including the right to opt-out of the disclosure of personal data to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.

−    Right to Deletion: The right to have us delete personal data we maintain about you.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by:

●     Completing our online form found here; or

●     Calling our toll-free U.S. telephone number: +1 (888) 590-0006.

To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, please visit the “Do Not Sell My Personal Information” link in the footer of the PGA Shop website and adjust your preferences accordingly. If you are visiting the PGA Shop with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the PGA Shop and your preferences on the PGA Shop do not apply to automatic data collection technologies PGA may use on its own websites. In addition, you can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting  https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Notice to further exercise control over automatic data collection technologies.

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we must verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we may require requests to include your order number and/or email address or a single-use 6-digit code.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems or where you are not a resident of one of the eligible states.

Submitting Authorized Agent Requests

In certain circumstances, you can use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you can appeal our decision in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request or emailing us at  dataprivacy@legends.net.

Additional California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

California law requires we provide privacy disclosures to you by reference to the enumerated categories of personal data set forth under the California Consumer Privacy Act. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in our Privacy Notice:

Personal data	How long we retain it	How we use it
Identifiers, such as name, unique personal identifiers, customer number, email address, or account name.	Until the later of the date you close your account on the PGA Shop and 6 years from your last purchase on the PGA Shop.	We use this information to set up and authenticate your account on the PGA Shop.
		We use this information to personalize the products displayed to you on the PGA Shop when you log in to your account.
		We use this information to fulfil your product orders when you make a purchase on the PGA Shop.
		We use this information to provide customer support and responses to any queries you submit to us in relation to the products you have purchased.
Customer records, such as address or telephone number, purchase, payment, and delivery details, including items purchased, billing and delivery addresses and payment card details, the details of any requests to return products, the reason for the return (including any faults) and refunds processed.	6 years from the date of purchase, return or complaint.	We use this information to fulfil your product orders when you make a purchase on the PGA Shop.
		We use this information to send you service-related communications, such as order and dispatch confirmations.
		We use this information to tailor how the PGA Shop is displayed to you, such as listing products that are similar to your past purchases or would be of interest to you in a more prominent position.
		We use this information to respond to your queries and comments and to help us identify errors or problems with the PGA Shop and our products so that we can fix and improve them.
		We use this information to process any returns of the products you purchase through the PGA Shop.
		We use this information to identify commonly occurring faults in our products and inform how we can improve the products available on the PGA Shop.
Commercial information, such as purchasing and order interests, history, and tendencies.	6 years from the date of purchase.	We use this information to fulfil your product orders when you make a purchase on the PGA Shop.
		We use this information to send you service-related communications, such as order and dispatch confirmations.
		We use this information to respond to your queries and comments and to help us identify errors or problems with the PGA Shop and our products so that we can fix and improve them.
Sensory information, such as recordings of any communications between you and Legends (where permitted by law).	One year from the date we receive the communication, unless longer retention is required in connection with pursuing or defending legal claims.	We use this information to respond to your queries and comments and to help us identify errors or problems with PGA Shop and our products so that we can fix and improve them.
Other Personal Data, such as communications preferences, entries to events, sweepstakes, contests, and promotions, comments and content in response to surveys, and any other inquiries, requests, or comments you choose to send us or post on social media.	Communications preferences are retained unless youopt out of receiving all communications.   Personal data included in entries to events, sweepstakes, contests, promotions, comments and content in response to surveys is retained for 6 years after the sweepstakes, contest, promotion or survey.   Social media information is retained for as long as you maintain an account on the relevant social media platform.	We use this information to inform our product development, improvement and marketing campaigns.
		We use this to ensure we communicate with you in accordance with your preferences.
		We use this information to respond to your social media comments or posts that are addressed to us or reference us.
		We use this information to inform our social media marketing strategy, including choosing and creating the content that we post to our social media pages.
Inferences, such as predictions about interests and preferences and related information.	Until completion of the relevant market research campaign.	We use this information to inform our product development, improvement and marketing campaigns.
		We use this information to conduct research and analytics on our customer and user base, the PGA Shop, and our products and services.

 

We disclose the categories of personal data above as described in the Personal Data Disclosures, Sales, and Targeted Advertising section of these Additional United States Privacy Disclosures.

For more information about what personal data we collect and how we use it, please see the Our Collection and Use of Personal Data section of our Privacy Notice. For more information about how long we retain personal data, please see the Retention of Personal Data section of our Privacy Notice

Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures

Who is responsible for your personal data

Legends Hospitality, LLC is the controller of the personal data we collect and use as described in the Privacy Notice in connection with the operation of the PGA Shop. This means we determine and are responsible for how your personal data is used.

If you have any questions or requests in connection with these European Disclosures or other privacy-related matters, please send an email to dataprivacy@legends.net.

Additional information about personal data that we collect and how we use it

Personal data you provide to us

Personal data	How we use it	Lawful basis we rely on
Account information:your name, username and password for your account on the PGA Shop, as well as your gender and age/date of birth.	We use this to set up and authenticate your account on the PGA Shop.	The processing is necessary for the performance of a contract (namely our Terms of Service).
	We use this information to personalize the products displayed to you on the PGA Shop when you log in to your account.	The processing is necessary for our legitimate interests, namely tailoring the PGA Shop to the user's account.
Contact information:your home address, email address and phone number.	We use this information to fulfil your product orders when you make a purchase on the PGA Shop.	The processing is necessary for the performance of a contract, or to take steps prior to the performance of a contract (namely our Terms of Service).
	We use this information to send you service-related communications, such as order and dispatch confirmations.	The processing is necessary for the performance of a contract, or to take steps prior to the performance of a contract (namely our Terms of Service).
	We use this information to respond to any queries you submit to us about the PGA Shop or the products available through the PGA Shop.	The processing is necessary for our legitimate interests, namely responding to customer queries and providing customer support.
Communications between you and us:details of any communications you may make to us, including through customer messages sent through forms, emails, or other contact information we make available, including call recordings where permissible.	We use this information to respond to your queries and comments and to help us identify errors or problems with the PGA Shop and our products so that we can fix and improve them.	The processing is necessary for our legitimate interests, namely administering the PGA Shop, addressing user queries and comments, and to help us improve the PGA Shop.
Purchase Details:your purchase, payment, and delivery details, including items purchased, billing and delivery addresses and payment card details.	We use this information to fulfil the product orders you place through the PGA Shop.	The processing is necessary for the performance of a contract (namely our Terms of Service).
	We use this information to process any returns of the products you purchase through the PGA Shop.	The processing is necessary for the performance of a contract (namely our Terms of Service).
	We use this information to provide customer support and responses to any queries you submit to us in relation to the products you have purchased.	The processing is necessary for our legitimate interests, namely responding to customer queries and providing customer support.
	We use this information to tailor how the PGA Shop is displayed to you, such as listing products that are similar to your past purchases or would be of interest to you in a more prominent position.	The processing is necessary for our legitimate interests, namely tailoring the PGA Shop to make it more relevant to the individual user's interests.
	We use this information to tailor the advertising we display to you and the electronic marketing messages we send to you in accordance with your preferences.	The processing is necessary for our legitimate interests, namely informing our direct marketing.
Product returns and complaints:Details of any requests to return products, the reason for the return (including any faults) and refunds processed.	We use this information to process any returns of the products you purchase through the PGA Shop.	The processing is necessary for the performance of a contract (namely our Terms of Service).
	We use this information to identify commonly occurring faults in our products and inform how we can improve the products available on the PGA Shop.	The processing is necessary for our legitimate interests, namely informing our product improvement.
Communication preferences: your preferences in receiving marketing information from us, and your communication preferences.	We use this information to ensure that we only send you marketing communications you have consented to.	The processing is necessary for a legal obligation to which we are subject.
	We use this information to ensure we communicate with you in accordance with your preferences.	The processing is necessary for our legitimate interests, namely ensuring we comply with communications preferences.
Market Research Information: Information collected in the course of carrying out market research, including your responses to surveys.	We use this information to inform our product development, improvement and marketing campaigns.	The processing is necessary for our legitimate interests, namely to inform product development, improvement and marketing.
Engagement Information: Information you provide or that we create when you engage in competitions or feedback, including entries to events, contests or promotions and feedback and ratings you provide relating to the PGA Shop or its products.	We use this information to inform our product development, improvement and marketing campaigns.	The processing is necessary for our legitimate interests, namely to inform product development, improvement and marketing.

 

Personal data we collect from social media

Personal data	How we use it	Legal basis we rely on
How you have interacted with us, such as any posts addressed to us or in which you tagged us, or if you have "liked" one of our posts.	We use this information to respond to your comments or posts that are addressed to us or reference us.	The processing is necessary for our legitimate interests, namely promoting the PGA Shop.
	We use this information to inform our social media marketing strategy, including choosing and creating the content that we post to our social media pages.	The processing is necessary for our legitimate interests, namely informing our social media marketing strategy.
The personal data you make public on the social media network in accordance with your settings, such as your profile name and picture.	We use this information to respond to your comments or posts that are addressed to us or reference us.	The processing is necessary for our legitimate interests, namely promoting the PGA Shop.
	We use this information to inform our social media marketing strategy, including choosing and creating the content that we post to our social media pages.	The processing is necessary for our legitimate interests, namely informing our social media marketing strategy.

 

Personal data we collect automatically

Personal data	How we use it	Legal basis we rely on
Information About Your Device and Network: This may include the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.	We use this information to operate the PGA Shop and present it to you in the correct format for your device.	The processing is necessary for the performance of a contract with you.
	We use this information to identify and prevent suspicious or fraudulent use of the PGA Shop.	The processing is necessary for our legitimate interests, namely ensuring the security of the PGA Shop.
	We use this information to analyse the performance of the PGA Shop to identify errors and ways in which we can improve the PGA Shop.	We will only use your personal data in this way if you have given us your consent to do so.
	We and our advertising partners use this information to serve you targeted advertising on other websites and platforms that you visit, and to identify how effective those advertisements are.	We will only use your personal data in this way if you have given us your consent to do so.
Information About the Way You Use the PGA Shop and Interact With Us:This may include the site from which you came, the site to which you are going when you leave the PGA Shop, how frequently you access the PGA Shop, whether you open emails or click the links contained in emails, whether you access the PGA Shop from multiple devices, and other browsing behavior and actions you take on the PGA Shop (such as the pages you visit, the content you view, the communications you have through the PGA Shop, and the content, links and ads you interact with). We and PGA employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on the PGA Shop, which may record your mouse movements, scrolling, clicks, and keystroke activity on the PGA Shop and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with the PGA Shop or engage in communication features we provide.	We use this information to operate the PGA Shop and present it to you in the correct format for your device.	The processing is necessary for the performance of a contract with you.
	We use this information to identify and prevent suspicious or fraudulent use of the PGA Shop.	The processing is necessary for our legitimate interests, namely ensuring the security of the PGA Shop.
	We use this information to analyse the performance of the PGA Shop to identify errors and ways in which we can improve the PGA Shop.	We will only use your personal data in this way if you have given us your consent to do so.
	We and our advertising partners use this information to serve you targeted advertising on other websites and platforms that you visit, and to identify how effective those advertisements are.	We will only use your personal data in this way if you have given us your consent to do so.
Information About Your Location:This may include a general geographic location that our third-party providers (including PGA and their partners) or we may derive from your IP address.	We use this information to ensure the PGA Shop is presented in accordance with requirements under applicable law (such as cookie consent requirements) relevant to the country you are in.	The processing is necessary for compliance with a legal obligation to which we are subject.
	We use this information to present the PGA Shop in the language and currency of the country you are in.	The processing is necessary for our legitimate interests, namely presenting the PGA Shop in the appropriate language and currency.
	We use this information to identify and prevent suspicious or fraudulent use of the PGA Shop.	The processing is necessary for our legitimate interests, namely ensuring the security of the PGA Shop.
	We and our advertising partners use this information to serve you targeted advertising on other websites and platforms that you visit, and to identify how effective those advertisements are.	We will only use your personal data in this way if you have given us your consent to do so.

 

Additional information about how we share your personal data

How we may share personal data	Lawful basis we rely on
PGA: We share personal data with PGA, as required under our contract. PGA will use your personal data for business and commercial purposes, such as to market events, sell tickets, and engage in other marketing activities. Please refer to the PGA Privacy Policy for more information.	The processing is necessary for our and PGA's legitimate interests, namely coordinating and informing each of our marketing efforts.
Marketing Providers:We coordinate and share personal data with our marketing providers to advertise and communicate with you about the PGA Shop and the related products and services we make available.	These companies process personal data as processors on our instructions
Ad Networks and Advertising Partners: We and PGA work with third-party ad networks and advertising partners to deliver advertising and personalized content on the PGA Shop, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit the PGA Shop and other services through cookies and related technologies. This information is used to provide and inform targeted advertising and advertising-related services such as reporting, attribution, analytics, and market research.	We will only share your personal data with these recipients to the extent you give us your consent to do so.
Service Providers:We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or access personal data while performing services on our behalf.	These companies process personal data as processors on our instructions
Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction, including, for example, payment processing services.	The processing is necessary for the performance of a contract (namely our Terms of Service)
Companies within the same group as us.These are companies that are owned by us or under common ownership with us who may use your personal data to provide and administer intragroup services.	These companies either process personal data as processors on our instructions, or the processing is necessary for our legitimate interests, namely procurement and administration of intragroup services.
Advisors, such as legal advisors or accountants.These third-party vendors and other service providers perform services for us or on our behalf.	The lawful basis we rely on for these transfers is that the processing is necessary for our legitimate interests, namely obtaining legal, accounting and other professional advice.
Purchasers and third parties in connection with a business transaction.Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business. These recipients will use your personal data to review and assess a potential transaction to purchase our business or assets.	The lawful basis we rely on for these transfers is that they are necessary for our and the purchaser's legitimate interests, namely to conduct due diligence on our business and assets in connection with a potential acquisition.
Law enforcement, regulators and other parties for legal reasons.We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and / or (iii) exercise or protect the rights, property or personal safety of Legends or others. These recipients will use your personal data in the performance of their regulatory or law enforcement role, or to advise us in connection with a potential claim or regulatory enforcement action.	The lawful basis we rely on for sharing personal data with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or, where there is no applicable legal obligation to share this data, that the sharing is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.

 

Additional information about how long we keep your personal data

Personal data	How long we keep it
Account information	For as long as you have an account on the PGA Shop.
Contact information	Until the later of the date you close your account on the PGA Shop and 6 years from your last purchase on the PGA Shop.
Communications between you and us	One year from the date we receive the communication, unless longer retention is required in connection with pursuing or defending legal claims.
Purchase details	6 years from the date of purchase.
Product returns and complaints	6 years from the date of the return or complaint.
Communication preferences	Until you opt out of receiving communications from us.
Market research information	Until completion of the relevant market research campaign.
Engagement information	6 years after the completion of the relevant competition, event, contest or promotion.
Information collected through social media	For as long as you maintain an account on the relevant social media platform.

 

International transfers

The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. We will ensure that these international transfers of your personal data are made pursuant to appropriate safeguards, such as:

●   ensuring that the personal data is only transferred to countries or recipients recognised by the UK Secretary of State or the European Commission (as applicable) as offering an equivalent level of protection as compared to the level of protection in the country you are located ("Adequacy"); or

●   the transfer is to a third party who uses appropriate safeguards in respect of the processing in question, included but not limited to the UK or EU standard contractual clauses, which are recognised as offering adequate protection for the rights and freedoms of data subjects, as adopted by the UK Secretary of State or the European Commission (as applicable) ("Standard Contractual Clauses").

We may transfer your personal data to, or store your personal data in, the following countries:

Country	Appropriate Safeguard
United States	Standard Contractual Clauses Adequacy (for recipients certified to the EU-U.S. Data Privacy Framework and UK Extension)
European Economic Area	Adequacy (for data subjects in the UK)
UK	Adequacy (for data subjects in the EEA)

We will take appropriate steps to ensure that your personal data is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed.

If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy notice.

Privacy rights

If you are resident in the UK, EEA or Switzerland, in accordance with applicable privacy law you have the following rights in respect of your personal data that we hold:

·       Right of access. You have the right to obtain:

(i)              confirmation of whether, and where, we are processing your personal data;

(ii)             information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;

(iii)            information about the categories of recipients with whom we may share your personal data; and

(iv)           a copy of the personal data we hold about you.

·       Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

·       Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.

·       Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.

·       Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

·       Right to withdraw consent. Where we rely on your consent for processing your personal data, you have the right to withdraw your consent. Withdrawal of your consent will not affect the lawfulness of the processing of your personal data before you withdrew your consent.

You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy notice.

We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.

Privacy wrongs

You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, your local data protection authority is the Information Commissioner's Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/. If you are in the European Economic Area, you can find your local Data Protection Authority at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. If you are in Switzerland, information about how to contact the Federal Data Protection and Information Commissioner is available at https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html