Last Updated: April 19, 2022
This Privacy Notice is designed to help you understand how Whoosh, Inc. (“Whoosh”, “we”, “our”, “us”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. HOW WE DISCLOSE YOUR INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
This Privacy Notice applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings, such as those that may provide for scheduling activities to play golf, racquet sports, fitness classes/sessions, aquatics, childcare, lessons, dining, club-specific events or other club-related services. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”
An Important Note: This Privacy Notice does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect the following personal information that you provide to us.
We may collect personal information automatically when you use our Services:
Our uses of these Technologies fall into the following general categories:
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
We may obtain information about you that can be readily available on public websites (such as LinkedIn), as well as from other sources, including through third-party services and organizations. For example, if you access our Services as an authorized user of a Whoosh customer (i.e., your employer or your golf course), the Whoosh customer may provide us with personal information about you that we use to service your account for the Whoosh customer. In addition, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. Also, our Services may offer various tools and functionalities that allow others to provide personal information about you through our referral service.
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfill our contract with you and provide you with our Services, such as:
We use your information for various administrative purposes, such as:
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we may market to you include email campaigns, text messages, phone calls, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
We also use your information for other purposes as requested by you or as permitted by applicable law.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
The categories of third parties with whom we may share your information are described below.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Whoosh has collected about them and whether Whoosh disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
|Category of Personal Information Collected by Us||Categories of Third Parties Personal Information is Disclosed to for a Business Purpose|
|Identifiers||· Other individuals you share or interact with · Service providers · Whoosh customers (authorized users only) · Advertising partners|
|Personal information categories listed in Cal. Civ. Code § 1798.80(e)||· Other individuals you share or interact with · Service providers · Whoosh customers (authorized users only)|
|Commercial information||· Other individuals you share or interact with · Service providers · Whoosh customers (authorized users only) · Advertising partners|
|Internet or other electronic network activity||· Individuals you share or interact with · Service providers · Whoosh customers (authorized users only) · Advertising partners|
|Geolocation data||· Individuals you share or interact with · Service providers · Whoosh customers (authorized users only)|
|Sensory data||· Individuals you share or interact with · Service providers · Whoosh customers (authorized users only)|
|Professional or employment-related information||· Individuals you share or interact with · Service providers · Whoosh customers (authorized users only)|
|Inferences drawn from other personal information to create a profile about a consumer||· Service providers · Advertising partners · Whoosh customers (authorized users only)|
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
Additional Privacy Rights for California Residents
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Whoosh does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.
If you are a California resident and would like to exercise any of your rights under the CCPA, please Contact Us as set forth below. We will process such requests in accordance with applicable laws.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
Protecting children’s privacy online is very important to us. Although our Services are designed for a general audience, we take steps to obtain the parent’s verifiable consent before collecting any information from a child, and we limit personal information collection and sharing to only what is necessary to support the internal operations of our Services.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent and either wish to review information collected from your child or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
Third-Party Services. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”) through the Services. Whoosh does not provide or control any aspect of the Third-Party Services and is not responsible for any compatibility issues, errors or bugs in the Services or Third-Party Services caused in whole or in part by the Third-Party Services or any update or upgrade thereto. We encourage our users to read the privacy policies of each Third-Party Service with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such Third-Party Services. Providing personal information to Third-Party Services is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
203 Flamingo Rd #336
Mill Valley, CA 94941
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