Privacy Policy
Last updated: July 17, 2024
When you use our services or visit our websites, you are choosing to trust us with some of your personal information. We appreciate your trust, and we will work hard to continue to deserve it. This Privacy Policy (“Privacy Policy“) describes how The Fairway Lounge and its current and future parents, subsidiaries and affiliates, including The Fairway Lounge and all related and affiliated entities (collectively “The Fairway Lounge,” “we,” “us,” or “our“), may collect, use, and share your personal information, and the choices you have with respect to your personal information, in connection with the platform (the “Platform“), which is available through the The Fairway Lounge app and our websites located at www.thefairwaylounge.com and any other websites operated by The Fairway Lounge that link to this Privacy Policy (each, a “Site“). The Platform provides individual end users (“Users“) with the ability to access material, information, and content (collectively, “Content“), and our related services, social media pages, and email and other electronic communications (collectively, “Services“) (the Content and Services are incorporated into the Platform for purposes of this Privacy Policy). In some cases, region-specific terms may apply to you, which are indicated in the section headings below.
The Fairway Lounge reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Platform, or other means as may be required by applicable law. In all cases, your continued use of the Platform following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices.
This Privacy Policy covers the following topics:
PERSONAL INFORMATION WE COLLECT
HOW WE USE PERSONAL INFORMATION
HOW WE SHARE PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
NOTICE TO CALIFORNIA RESIDENTS
PERSONAL INFORMATION WE COLLECT
Personal Information Collected. We want you to understand the types of personal information that we may collect about you. The personal information we collect, and how we use it, depends largely upon how you use our Platform, and may include the following categories of personal information. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
- Contact Information, such as your name, email address, phone number, city, state, and zip code, social media handle, and signature.
- Professional Information if you inquire about advertising with us, such as company name, email address, and phone number.
- Demographic Information, such as date of birth, age, gender, education, special needs information, household income, occupation, home ownership, marital status, military or veteran status, or number of children.
- Marketing Information, such as viewing interests and habits based on Content and Services accessed by you on or through the Site (e.g., viewing history, habits, and preferences, title selections, streams, downloads, and demographics), and details about how you engage with our communications.
- Online Activity Information, such as the website you visited before browsing to the Platform, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Browser & Device Information used to access our Platform, such as unique identifiers, browser type and settings, device type and settings, operating system, and mobile network information including carrier name and phone number. We also collect personal information about the interaction of your browsers and devices with our Platform, including IP address, crash reports, system activity, and general location information such as city, state, or geographic area.
- Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us. We and our service provider may also record or monitor any call or chat you have with us for quality control or training purposes, or to enforce our rights.
Sources of Personal Information. We obtain personal information from a variety of sources, including the following sources:
- Personal Information You Provide. The Fairway Lounge collects personal information when you voluntarily submit it to us, including through offline interactions, such as when you fill out a form on the Site, sign one of our petitions, call customer service, or communicate with us.
- Personal Information Automatically Collected. The Fairway Lounge, our service providers, our advertising partners, and Authorized TV Providers may automatically log information about you, your computer, or mobile device, and your activity over time on our Platform and other sites and online services, such as the online activity information and device information listed above. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, which may include the following:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Platform, and remember your preferences.
- Session replay technologies, which are third-party software used to record a video replay of Users’ interactions with the Site. The video replay may include Users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We may use these replays for research and development purposes, such as to help us troubleshoot problems with the Site, understand how Users interact with and use the Site, and identify areas for improvement.
Personal Information Obtained from Third Parties. In some circumstances, we may collect personal information about you from third party or publicly available sources, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, publicly available sources, or data licensors or providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
Referrals. Users of our Platform may have the opportunity to refer to us colleagues, friends, or other contacts and share their contact information and other personal information. Please do not provide us with someone’s personal information unless you have their permission to do so.
HOW WE USE PERSONAL INFORMATION
The Fairway Lounge’s primary purpose in collecting personal information is to provide the Content and Services and to operate our business. We also use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.
To Provide the Platform. We may use personal information to operate our business. For example, we use personal information to:
- improve and personalize your experience on or with the Platform;
- verify your identity for authentication and security purposes, or determine your eligibility for offers and promotions;
- communicate with you, including responding to any of your requests, feedback, or questions;
- provide maintenance and support; and
- fulfill any other purpose for which you provide personal information.
Research and Development. We use personal information for research and development purposes, including to study and improve the features and functionality of our Platform and our business, understand and analyze the usage trends and preferences of our Users, and develop and improve our Content and Services. We may also collect personal information, such as your name, email, and signature, in response to a petition. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you or your device, whether directly or indirectly. We will maintain and use any de-identified data without attempting to reidentify the data. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes.
Direct Marketing. We may send you The Fairway Lounge-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below.
To Display Advertisements. We partner with advertising partners and other third parties that collect information (including the online activity information and device information described above in the section called “Personal Information Automatically Collected”) across various channels, including offline and online, to help us advertise our Platform and for purposes of displaying advertisements on the Platform or elsewhere online and delivering more relevant advertising to you. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Platform or your activity elsewhere online. Our partners may use your information to recognize you across different channels and platforms, including but not limited to, computers and mobile devices, over time for advertising (including addressable TV), analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. To learn more about your choices in connection with advertisements, please see “Advertising Choices” within the “YOUR CHOICES” section below.
To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Platform and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
HOW WE SHARE PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, we may share your personal information with the following entities or persons:
Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.
Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, maintenance services, database management, analytics, fraud protection, marketing, finances, and other purposes.
Advertising Partners. We may share your personal information with our partners and sponsors to send you information about products, events, and services you may like. We may also share usage information about our Platform, including searches and viewing information with Authorized TV Providers and our partners and sponsors for online advertisement purposes, including for the purposes described in the “To Display Advertisements” section above.
Other Users of the Platform and the Public. You may be able to submit content to the Platform (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), or may choose to sign one of our petitions, and we may identify you by displaying information such as your name or social media handle along with the content you submit. We do not control how other Users or third parties use any personal information that you make available to other users or the public.
Professional Advisors. We may share personal information with persons, companies, or professional firms providing The Fairway Lounge with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Authorities and Others for Compliance, Fraud Protection, and Safety. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”
Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
YOUR CHOICES
You can make the following choices regarding your personal information:
Review and Request Changes to Your Personal Information. The accuracy of the personal information we have about you is very important. You may request that we correct your information by contacting us. Note that we may keep historical information in our backup files as permitted by law.
Email Communications. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails. Please note that certain emails may be necessary for the operation of our Platform, such as to deliver notifications directly to you through the Platform. You will continue to receive these emails, even if you unsubscribe from our marketing communications.
Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Analytics. The Site may use Google Analytics to help us analyze how the Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.
Advertising Choices. If you wish to minimize the amount of interest-based advertising you receive (as described in the “To Display Advertisements”), you may block third-party cookies in your browser settings, use browser plug-ins/extensions, and use your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Users of AltitudeNOW may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.
Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Site currently does not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
SECURITY OF PERSONAL INFORMATION
We build security into our Platform to protect your information. Our Platform is built with reasonable security features designed to protect personal information. The insights we gain from maintaining our Platform help us detect and block certain security threats.
We exercise reasonable care in providing secure transmission of personal information from your devices to our servers. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
CHILDREN’S PRIVACY
Our Platform is not directed to people who are under 16 years old. We do not knowingly collect personal information from children under 13 years of age. Individuals under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children under the age of 13, please contact us immediately.
LINKS TO WEBSITES AND APPS
Our Platform may contain links to other websites and apps not operated or owned by us. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third-party websites and apps. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps. We encourage you to read the privacy policies of the other websites and online services you use.
DATA TRANSFERS
The Fairway Lounge is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.
NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents and supplements the practices described in this Privacy Policy. It describes how we collect, use, sell, share, and retain personal information of California residents, and their rights with respect to their personal information. For purposes of this section “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended (the “CCPA“), but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
Personal Information Collected and Purposes of Collection and Use. The list below summarizes the personal information we collect, or have collected in the 12 months preceding the last updated date of this Privacy Policy, by reference to the categories specified in the CCPA. Examples in the list refer to the types of personal information described in the section titled “PERSONAL INFORMATION WE COLLECT.”
- Identifiers, such as Contact Information and Referral information.
- Customer Records, such as Marketing Information and Communications.
- Protected Classifications, such as Demographic Information.
- Commercial Information, such as Marketing Information.
- Internet or Network Activity, such as Online Activity Information and Browser & Device Information.
- Audio, Electronic, Visual, or Similar Information, such as recorded customer service calls and chats.
- Professional Information.
- Inferences, such as inferences drawn from the personal information identified above to create a profile reflecting your preferences, characteristics, behavior.
We may collect these categories of personal information as described in the section titled “Sources of Personal Information.”
The purposes, including the specific business and commercial purposes, for which we collect and use these categories of personal information are described in the section titled “HOW WE USE PERSONAL INFORMATION.”
To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Platform, detect security incidences and prevent fraud, and to verify and maintain the quality of the Platform). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
Personal Information Disclosed for a Business Purpose, “Sold,” or “Shared.” Each of the categories of personal information listed above may have been disclosed for business purposes in the preceding 12 months to any of the third parties set forth in this Privacy Policy under the section titled “HOW WE SHARE PERSONAL INFORMATION.”
The CCPA defines a “sale” of personal information to mean when a business discloses a California resident’s personal information to a third party for monetary or other valuable consideration. Where a business discloses personal information for purposes of cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA.
In the 12 months preceding the last updated date of this Privacy Policy, we have “sold” or “shared” Internet or Network Activity to Advertising Partners for purposes of advertising our Platform (including tracking the success of our advertising campaigns) and measuring activity on the Platform as further described in this Privacy Policy under the section titled “HOW WE SHARE PERSONAL INFORMATION.” We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
Retention of Personal Information. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your California Privacy Rights. As a California resident, in addition to the choices described elsewhere in this Privacy Policy, you have the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Right to Know/Access. You can request the following information about how we have collected and used your personal information:
- the categories of personal information we collected;
- the categories of sources from which we collected personal information;
- the business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information;
- the categories of third parties with whom we disclose personal information; and
- a copy of the personal information that we collected about you.
- Right to Delete. You can request that we delete the personal information we collected from you.
- Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
- Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information, you can opt-out.
- Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
How to Exercise Your Rights. You may exercise the rights described above as follows:
- Know/Access, Delete, or Correct. You may exercise these California privacy rights by calling us toll free at 1-833-534-0521 or by clicking here: Your Privacy Choices.
- Opt-Out of Sales/Sharing. You can request to opt-out out of the “sale” or “sharing” of your personal information by clicking here: Your Privacy Choices or broadcasting the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit our Platform from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences and/or rebroadcast the GPC signal.
If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know/access, delete, and correct. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request.
Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests to know/access, delete, and correct within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
in the manner described in the section titled, “To Display Advertisements,” as further detailed in the table below. For a description of the categories of third parties mentioned in the table, see the section titled, “HOW WE SHARE PERSONAL INFORMATION.” To exercise your right to opt out of targeted advertising, see “How to Exercise Your Colorado Privacy Rights” below.
HOW TO CONTACT US
If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at [email protected].
