PRIVACY POLICY

Effective Date: 2007 Last Update: 23/06/2021

Data Controller:

Acushnet Europe Ltd
Caxton Road
St. Ives, Cambridgeshire, PE27 3LU
United Kingdom

CONTENTS

1. THIS PRIVACY POLICY APPLIES TO OUR WEBSITES DESIGNED FOR USE IN THE EUROPEAN UNION
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. PURPOSES AND LEGAL BASES OF PROCESSING YOUR PERSONAL DATA
4. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA
5. YOUR RIGHTS AND OPTIONS

THIS PRIVACY POLICY APPLIES TO OUR WEBSITES DESIGNED FOR USE IN THE EUROPEAN UNION.

This Privacy Policy describes how we treat personal data on our websites designed for use in the European Union and the United Kingdom, including Titleist.co.uk, Titleist.de, Titleist.com.fr, Titleist.ie, Titleist.se, Footjoy.co.uk, Footjoy.de, Footjoy.com.fr, Footjoy.ie, Footjoy.se, and Footjoy.eu. If you are accessing our websites from the European Union or the United Kingdom, and nevertheless choose to use our websites designed for use in other regions of the world (e.g. our United States websites), the Privacy Policy found on those websites will apply to your use; we urge you to visit the websites intended for use in your country.

In this Privacy Policy, you can read about the various ways we collect, use, disclose or otherwise process your personal data. We also describe ways you can manage what personal data you share with us. From time to time we may change our privacy policies, but we will not reduce your rights. If you have provided us with your email address, we will notify you of any material changes to our website Privacy Policy as required by law. We will also post an updated copy on our website and indicate at the top of the Privacy Policy when it was most recently updated.

The transmission of information via the Internet is not 100% secure. We encourage you to use caution when using the Internet. This includes keeping your passwords confidential and not sharing your passwords. We urge you to take care when providing information in public areas of the website, which any website visitor can view.

CATEGORIES OF PERSONAL DATA WE COLLECT

We collect technical information.

We may collect technical information related to you through cookies and other similar tracking technologies. We collect, for example, information about the browser you are using, the operating system and the IP address of your devices to connect to the Internet. For more information about how you can control cookies, the types of personal data we collect through cookies and the third party tracking tools we use, please read our Cookie Policy.

We collect other information from and about you.

We collect contact information directly from you. For example, if you choose to create an account on our website, we collect your name, user name or similar identifier and email address. We also may collect your phone number, mailing address, gender, and product specifications and preferences if you choose to provide them. We will let you know whether that particular type of personal data is required or optional. If you choose to connect to your social media accounts via our websites, those third parties may provide us with your personal data if you provided it to the social media platform in accordance with the third parties’ policies. Please refer to the privacy policies of any social media platforms you connect to through our websites for information about providing your personal data on those platforms.

If you would like to place an order for a product or schedule an appointment on one of our websites, we will ask you for certain required personal data in order to fulfill your order or schedule your appointment.

We collect information you voluntarily submit or post, for example, in a blog entry or comment, including in a public space on our website, or if you complete a survey, which may include your gender, date of birth or postal code.

If you fill out a “Contact Us” form on our websites, you will provide your first name, last name, phone number, email address, country, and details of your question or comment.

If you sign up to our website’s mailing list or newsletter to receive offers and updates from us, you will provide your email address.

If you contact us, we may ask you for certain information in order to respond to your questions or customer service needs. The information we may request could include your gender and your postal code. You may choose not to share this information, though our ability to assist you may depend on you providing certain personal data to look up your order, account, etc.

Generally, when we request your personal data, we will let you know whether this particular type of personal data is required or optional. In most cases, an asterisk (*) indicates required information. You may choose to provide additional information within fields that are not required.

Where we need to collect personal data by law or in order to carry out your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you.

PURPOSES AND LEGAL BASES OF PROCESSING YOUR PERSONAL DATA

We use personal data for the purposes as disclosed and described here. We may process your data on the various bases of i) your consent, ii) performing a contract with you, iii) meeting our legal or statutory obligations, or iv) our legitimate interests to improve our products and services. We have provided more information about how these legal bases apply below.

Where we have a contract with you, we process your personal data as necessary to perform our contractual relationship with you, provide our products and services and manage our customer relationship. For example, where you make a purchase or request a service, we will process your personal data to facilitate this.

We use your personal data to present and administer our websites and conduct related internal operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes. We use your personal data for these purposes because we have a legitimate business interest in improving our products and services. Wherever technically possible, we will use anonymised data to meet business needs.

We use your personal data to respond to your requests or questions and to administer our customer relationship with you. For example, we may use your personal data to respond to your feedback. We may also use your personal data to notify you if you win a contest or make a purchase. We use your personal data for these purposes because we have a legitimate business interest in providing our products and services.

We may also use the personal data to protect us against and prevent fraud, enforce our rights, claims (e.g., billing or money collections), and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by a law that applies to us.

We use personal data to improve our website, products and services and our customer relationship with you and your experiences on the websites you use. We might use your personal data to customise your experience with us, such as using your purchase history to cater certain communications and product recommendations. We may use your personal data in combination with other users’ personal data in aggregated ways to evaluate business trends and improve our website. This aggregated data does not identify any specific person. We use your personal data for these purposes because we have a legitimate business interest in providing and improving our products and services.

We use personal data for security purposes. We use your personal data to protect our company, our employees, our customers, and our platforms and apps and other operations, our property and rights. We use your personal data for these purposes because we have a legitimate business interest in ensuring the protection of our employees, customers, systems and premises.

If you have separately provided consent to receive marketing communications from us, we send you e-mail marketing messages, which may include requests for feedback about our products or our relationship. If you are an existing customer of our products and services, we may use your personal data specified above, except credit card information, for marketing our own, similar products and services by e-mail, if you have not objected to such use. For example, where permitted by applicable law, we may provide you with information about new products and special offers, serve you ads about products and offers and may tell you about new features or updates, or make recommendations or suggestions to you. We may use your personal data to measure or understand the effectiveness of the advertising we serve to you.

We may also contact you about this Privacy Policy and to notify you about changes.

DISCLOSURE OF PERSONAL DATA

Where permitted by applicable law, we will share your personal data within the Acushnet family of companies and brands, which means our subsidiaries, our ultimate parent company and its subsidiaries and affiliates, for the purposes set out in the previous section above and to engage in the activities described in this Privacy Policy. Our brands include Titleist, FootJoy, Scotty Cameron, Vokey Wedges, and Links & Kings. Our related companies are listed here and are updated from time to time: https://www.sec.gov/Archives/edgar/data/1672013/000155837018001635/golf-20171231ex211e46df7.htm

We also share personal data with third parties.

Where permitted by applicable law, we will share personal data with third parties who perform services on our behalf for the business purposes or activities described in this Privacy Policy. For example, we may share personal data with vendors who provide marketing services for us as well as analytics and search engine providers that assist us with website improvement and optimisation. We may also share personal data with companies that help us operate our platforms or run a promotion. We may also share personal data with companies that help us fulfill customer requests.

We may share personal data with third parties if we think we have to in order to comply with the law, a court or administrative order or to protect ourselves. For example, we will share personal data where legally required to do so in order to respond to a court order or subpoena, including our legal advisors and auditors. We may share personal data where legally required to do so in order to respond to government agency, public or law enforcement authority or investigatory body requests. We may share personal data if we are investigating potential fraud. This may include fraud we think has happened during a promotion. If you are the winner of a contest, with your consent, we will also share your personal data with anyone who requests a winners' list.

We may share your personal data with a successor to all or part of our business. For example, if part of our business is sold we may include customer information (including personal data) as part of that transaction.

We link to third party platforms or services we don't control.

Our websites contain links to other platforms that we do not own or operate. We provide these links as a mere convenience to our users, but these are not intended as an endorsement or referral to the linked sites or services, and we are not responsible for the content of these sites and cannot monitor such sites fully and permanently for possible breaches of the law. The linked sites and services are subject to their separate and independent privacy statements, notices and terms and the collection and use of your personal data will be subject to the privacy policies of the third party and not this Privacy Policy. We are not responsible for the content or privacy practices of other platforms or services. We encourage our users to be aware when they leave our website. Read the privacy statements of other platforms carefully. This Privacy Policy applies solely to inform you about the personal data collected by our websites.

RETENTION OF YOUR PERSONAL DATA

We store your personal data for various periods of time.

We typically keep the personal data we collect for the duration of our relationship with you, plus a reasonable period in order to take into account the applicable legal retention requirement or statute of limitation periods, or otherwise as required for our business purposes described above.

INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

We transfer personal data to third countries.

Where permitted by applicable law, your personal data will be transferred for the purposes and to the recipients noted in this Privacy Policy, which may involve transfers to third countries outside the European Economic Area (EEA) and the United Kingdom, including the United States that may not afford the same level of protection as those in your country. However, when transferring your personal data to these countries, we will protect the data as described below.

Intra-Group

Where permitted to do so by applicable law, we share your data within the Acushnet family of companies, which means our subsidiaries, our ultimate parent company and its subsidiaries and affiliates that are located in the United States of America and other third countries outside the EEA and the United Kingdom, where they have offices. The transfer of your personal data outside the EEA or the United Kingdom takes place on the basis of our data transfer agreement(s), which is/are based on the standard data protection clauses adopted by the European Commission or otherwise in accordance with applicable laws.

Third Parties

Some of the third parties with whom we share your personal data are also located outside the EEA or the United Kingdom. Transfers to third parties located in third countries outside the EEA or the United Kingdom take place using a data transfer mechanism which is acceptable under the applicable data protection laws, such as the EU Standard Contractual Clauses (see here) and Binding Corporate Rules (see here). Please contact us at privacypolicy@acushnetgolf.com, if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.

YOUR RIGHTS AND OPTIONS

These rights apply to you under certain conditions only if you are visiting our website from the EU or UK, or where applicable EU or UK data protection laws so provide that you have the following rights:

i) Access your personal data from us and receive a copy;

ii) Correct your personal data if it is inaccurate or incomplete;

iii) Restrict processing of your personal data;

iv) Erase your personal data under certain circumstances;

v) Object to our processing of your data on grounds relating to your particular situation, where we use that information based on our legitimate interest; and

vi) Receive, in a structured, commonly used and machine-readable format, your personal data you have provided to us based on your consent or a contract to which you are party. You have the right to have this information transmitted to another company, where it is technically feasible.

You can also object at any time to the processing of your personal data for marketing purposes. If you object to our use of your personal data for direct marketing purposes, please email us at privacypolicy@acushnetgolf.com. You can also specifically opt out of receiving our marketing emails. To stop receiving our promotional emails follow the instructions in any promotional email you get from us.

Please note that even if you object to your use of personal data for direct marketing purposes or more specifically opt out of receiving our marketing emails, we will still send you, where permitted by applicable law, transactional messages in relation to products or services that you have purchased from us. These include responses to your questions and information about a product or service you have purchased from us.

You also have the right to lodge a complaint with a supervisory authority, in particular in the UK or EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.

You have the option to freely withhold or withdraw (with future effect) your previously provided consent to the processing of your personal data at any time without any adverse consequences.

If you have any questions about this policy or want exercise any of the abovementioned rights, please email us at privacypolicy@acushnetgolf.com.

You can also write to us at our contact address:

Acushnet Europe Ltd
Caxton Road
St. Ives, Cambridgeshire, PE27 3LU
United Kingdom
Attention: Director, Group Finance & Operations

Or

Acushnet Company
333 Bridge Street
Fairhaven, MA 02719
USA
Attention: Legal Department