TRACKMAN PRIVACY NOTICE
This Privacy Notice explains the personal data we collect from and about you, either directly or indirectly, and how we use it. The notice also covers the choices you can make about the data we collect and how you can control these choices. It applies to all TrackMan products, applications, services, and websites. By using TrackMan products and services, you agree to the use of your personal data as described in this Privacy Notice. Please read this Privacy Notice carefully to understand when you are providing personal data to us and how TrackMan will use personal data provided.
TrackMan has a data protection regime in place to oversee the effective and secure processing of personal data.
HOW TO CONTACT US
If you have any questions about the use of your personal data, please send us an email to firstname.lastname@example.org.
TrackMan A/S, org. no (CVR) 27352677, having its registered address at Stubbeled 2, Gl. Holte, DK-2950 Vedbæk, Denmark, is a data controller for the personal data we collect through the products and services subject to this privacy notice.
SITUATIONS WHERE PERSONAL DATA MAY BE COLLECTED
TrackMan collects certain personal data in each of the following situations:
We collect information of IP addresses and information provided by cookies or similar technology. Furthermore, we may collect information of your name and email address, if you choose to provide this information to us voluntarily to receive further information about our products and services.
Enquiries through the TrackMan CRM system
If you contact 'TrackMan's CRM system via any of our websites, by telephone, email, social media, or other channels, we may collect information like your name and email address.
Purchase of a TrackMan product
When you purchase a TrackMan product, we collect information such as your name, billing and delivery address, EU VAT number (for businesses registered the European Union), email address, and phone number.
Opening of TrackMan account
When you create a TrackMan account and become a registered user, we collect information like your name, email, and username. Furthermore, we may collect information about your home address, telephone number, gender, age, nationality, golf handicap, dexterity, golfer segment, and user category if you choose to register such information voluntarily.
TrackMan profiles can be either public or private, depending on how much information you choose to share. A private profile will only show your full name, username, and potentially some highlevel statistics, which will allow others to find you and connect. A public profile will allow anyone to browse through your profile, seeing your aggregate stats and even review specific activities like a course round, game, or practice session.
Tournaments and competitions
If you participate in any Tournaments or Competitions facilitate by a TrackMan product or service, your full name or player name will be visible on leaderboards. Leaderboards are available in the TrackMan Golf app and through several other TrackMan products and services.
Use of products and services by registered users (owners, including coaches and event/tournament organizers) and nonregistered users (players)
When TrackMan products are used, we collect performance data, including but not limited to data parameters, video recordings, screencasts, reports, information on player visits, information on creation/cancellation and reactivation of subscriptions, information on downloaded certificates, progress data of lessons and courses, ball data parameters, lifetime stats, and achievements/badges depending on the specific TrackMan product and/or service used.
If you use your TrackMan product to collect data from your students, potential customers, and/or participants in events/tournaments and/or otherwise make your TrackMan product available to third parties, subject to any applicable limitations in 'TrackMan's general terms and conditions for sale and delivery of products and productrelated services by TrackMan and 'TrackMan's terms and conditions for the use of the account, it is your responsibility as an owner prior to commencement of any such use of the TrackMan product to inform the relevant student/customer/participant of the content of this privacy notice; cf. 'TrackMan's terms and conditions for the use of account (https://mytrackman.com/system/terms-and-conditions). Upon completion of an event/tournament and/or training session by a player, TrackMan may also share a link to this privacy notice to any student/participant, who has requested to receive a player report in connection with the training session/event/tournament.
If the standardized TrackMan Combine test or a similar test is completed by any user (whether registered or not registered), the test results and the name of the player may automatically be published on 'TrackMan's electronic leaderboards. Any coach/event organizer who makes TrackMan equipment available to students/participants in events are required to notify the student/participant of the publication of the test score and the 'player's name on the leaderboard prior to the student/participant taking the TrackMan Combine test; cf. 'TrackMan's terms and conditions for the use of account (https://mytrackman.com/system/terms-and-conditions).
Collection of functional data
In addition to the above, TrackMan collects certain functional data related to the radar equipment and the IT-devices used in connection with the operation thereof, including but not limited to radar system information, GPS data, radar temperature, power on/off date, usage time, user ID, signup date, last shot date, IP address, network name, information of connected devices, login date, depending on the product and service used.
PURPOSE OF PROCESSING PERSONAL INFORMATION
The information we collect from you may be used in one or more of the following ways:
- To provide you with detailed and comprehensive data points on your current and historical performance within golf, whether for training and/or leisure purposes;
- To personalize your experience;
- To share your account information, which gives the ability to search for other users choosing a private profile view or full profile view depending on how much you choose to share.
- To continuously improve the TrackMan equipment and software and the usability hereof;
- To facilitate 'TrackMan's business operations and analysis in relation to the development of new products and/or services;
- To ensure a safe and secure product;
- To improve our websites;
- To improve customer support (your information helps us to more effectively respond to your customer service requests and support needs);
- To process orders and transactions;
- To facilitate sharing and disclosure by you of the tracked data;
- For documentation purposes in case of disputes;
- For marketing and communication purposes.
The email address you provide for order processing may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.
LAWFULNESS OF PROCESSING
In general, our processing of your personal data is based on Article 6(1)(b) of the General Data Protection Regulation pursuant to which your personal data may be processed, if necessary for our performance of a contract to which you are a party or in order for us to take steps at your request prior to entering into a contract.
Processing of your personal data may potentially also be carried out based on Article 6(1)(f) of the General Data Protection Regulation, if the processing is necessary for purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company outside TrackMan for any reason whatsoever, without your consent, other than for the expressed purpose of delivering the purchased product or service requested. For example, we may ask for your consent for TrackMan to provide your contact details and shot data from a specific driving range, retail store, indoor facility or similar public location you have visited – to the owners of that facility or thirdparty sponsor(s), in order to provide you with updates/offers covering golfrelated equipment, services, apparel or similar.
Notwithstanding the above, your name and performance in specific events/tournaments may be made available to 'Trackman's partners and the public (via leaderboards and similar) in connection with any competition organized by TrackMan or involving the use of TrackMan products and services. Further, we may exchange your information with other companies within the TrackMan Group to ensure that we provide you with an efficient and effective service.
We only share information with partners and suppliers if we are satisfied that they have sufficient measures in place to protect your information and only after having necessary privacy notices and/or data processing agreements in place.
DETAILS OF TRANSFERS TO THIRD COUNTRY AND SAFEGUARDS
Your personal data may be stored and processed on secure Microsoft cloud servers or other wellknown cloud service providers located in the United States of America or in the European Union.
Customer data, including performance data
Data is retained (a) whilst you maintain an account, service, or contract with TrackMan and for a period of 24 months thereafter; or (b) until such an earlier point in time where you may request your data to be deleted. Once you request all data to be deleted, data will be removed from our backups within 12 months.
Performance data and functional data regarding the radar and/or IT-devices may be irreversibly anonymized at the end of the retention period and used for research and development purposes.
CRM data (Name, email address, mobile number, address)
Data is retained whilst you remain a customer or until such earlier point in time where you may request the data to be deleted. Once you request all data to be deleted, data will be removed from our backups within 12 months.
Name, email address, and/or telephone no.
Data is kept until you unsubscribe/request to be removed from the system. Once you unsubscribe or request to be removed from the system, data will be removed from our backups within 12 months.
Notwithstanding the above, TrackMan may retain limited information after the end of the applicable retention period, if required by applicable law.
You have certain rights under the applicable data protection laws, including the following rights under the EU General Data Protection Regulation
- The right to be informed via privacy notices such as this.
- The right of access to any personal information we hold about you. To request a copy of this information, you must make a subject access request in writing, either via a letter to TrackMan A/S, Stubbeled 2, 2950 Vedbæk, Denmark, attention: Privacy Officer, or via email to email@example.com. (to ensure that we can deal with your request you will need to include your current name and address, proof of identity, e.g., a copy of your driving license or passport). We do not charge for making a subject access request.
- The right of rectification, we must correct inaccurate or incomplete data within one month.
- The right to erasure. You have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal information.
- The right to restrict processing. You have the right to suppress processing. We can retain just enough information about you to ensure that the restriction is respected in the future.
- The right to withdraw your consent. You have the right at any time to withdraw any consent you may have provided for TrackMan to process your personal data.
- The right to data portability. We can provide you with your personal data in a structured, commonly used, machinereadable form when asked.
- The right to object to processing for directs marketing purposes
You can read more about your rights in the guidance note on the rights of data subjects (in Danish: Vejledning om de registreredes rettigheder) prepared by the Danish Data Protection Agency and available at www.datatilsynet.dk.
QUESTIONS AND COMPLAINTS
If you have any questions or wish to make a complaint, comment, or compliment about 'TrackMan's processing of your personal information, please forward it to email: firstname.lastname@example.org.
If you are still dissatisfied, you may contact the Danish supervisory authority:
If this privacy notice changes in any way, we will place an updated version hereof on this page. By regularly reviewing this page, you will ensure that you are always aware of what information we collect, how we use it, and under what circumstances, if any, we share it with others.