Privacy Policy

Effective Date: January 1, 2020   Last Update: January 1, 2020
Thank you for visiting the privacy policy page of Roger Cleveland Golf Company, Inc. ("Cleveland Golf"). The purpose of this privacy policy is to provide consumers with a comprehensive description of Cleveland Golf’s online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of consumers regarding their personal information. Cleveland Golf takes privacy seriously, and wants you to feel comfortable using our website atWWW.CLEVELANDGOLF.COM, WWW.SRIXON.COM, WWW.XXIOUSA.COM and/or US.DUNLOPSPORTS.COM  (our "Site") and providing your personal information to us, whether online or offline. This page describes our online and offline privacy policy ("Privacy Policy"), which applies to our Site. By visiting our Site, or providing personal information to us (whether or not via our Site), you are accepting the practices described in this Privacy Policy, as well as our TERMS OF USE. By registering your Cleveland Golf products or otherwise using our Site in any way, you are further confirming your acceptance of this Privacy Policy and our TERMS OF USE. If you do not agree to this Privacy Policy or our TERMS OF USE, please do not use or visit our Site, and do not disclose any personal information to us, either online or offline.

ACCESSIBILITY TO CONSUMERS WITH DISABILITIES
Cleveland Golf seeks to make this Privacy Policy and any Notices contained in this Privacy Policy accessible to consumers with disabilities. If you are unable, due to a disability, to access this Privacy Policy or any Notices it contains, including the Notice at Collection of Personal Information, and Opt-out Notice below, we encourage you to contact us, either via our toll free number at (800) 999-6263, our Live Chat link, or email Support@ClevelandGolf.com to inform us how to provide you with our Privacy Policy or any Notices it contains in an alternative format that is accessible to you.

CHANGES TO PRIVACY POLICY
If we change this Privacy Policy, we will notify you by posting the revised privacy policy on our Site. It is your responsibility to periodically revisit our Site to be aware of any changes to this Privacy Policy. We may, in our sole discretion, also notify you of changes to this Privacy Policy by sending you an email notification to the email address that you provided to us. It is your responsibility to provide us with your current email address. If we revise our Privacy Policy to broaden our use of your personal information, you may contact us at the address below to request that we either refrain from using your personal information or destroy your personal information.

COLLECTION OF PERSONAL INFORMATION
Each time you register a Cleveland Golf product, enter to win a contest, register for a newsletter, send us an email, call us, send us regular mail, or otherwise contact us or transmit information via our Site, Cleveland Golf may obtain and collect personally identifiable contact information including (but not limited to) your name, email address, mailing address, and telephone number. You may also provide us with information that, when combined with personally identifiable information, provides us with a better idea of who you are, including but not limited to, your gender, birthday, marital status, IP address, credit card information, and education level (collectively with the personally identifiable information, "personal information"). For California residents, the term “personal information” as used in this Privacy Policy is intended to be consistent with the definition of that term under the California Consumer Privacy Act of 2018 (“CCPA”). Generally, you can browse our Site without telling us who you are or revealing any personal information about yourself. Once you give us any of your personal information, however, via any method of communication, you will no longer be anonymous to us. If you choose to use our services, we may require you to provide contact and identity information, and other personal information as indicated on the forms throughout our Site. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature.

USE OF PERSONAL INFORMATION
Cleveland Golf may use and share with others your personal information:

  • If you choose to Contact Us through the Site, or via telephone, email, or regular mail, we may ask you for personal information such as your name, address, phone number, or e-mail address so that we can respond to your questions or comments.
  • To enable us to generally respond to you, or to process, validate and verify requests and/or purchase orders;
  • To fulfill any of your requests;
  • To send information to you about additional goods or services;
  • To compile and/or distribute aggregated information about our website users and usage patterns;
  • To provide useful information to our website designers for developing new features and services;
  • To tailor your experience on our websites, e.g., showing content that we believe may interest you or altering the content based on your personal preferences; and
  • In any way we deem advisable, not prohibited by law, to provide better goods or services to our customers.

Cleveland Golf may share personal information within our family of related companies and businesses, including Sumitomo Rubber Industries, Ltd., its subsidiaries and affiliates, and Dunlop Sports Americas. Cleveland Golf may also use personal information for any marketing and survey purpose on behalf of itself and its affiliates. Cleveland Golf may disclose personal information to third party agents and independent contractors that help us conduct our marketing and survey efforts. In addition, Cleveland Golf may disclose personal information to certain of its business partners in connection with marketing efforts, including but not limited to direct marketing. Cleveland Golf may also disclose personal information to its affiliates for their marketing and survey efforts.
Additionally, Cleveland Golf will use or disclose your personal information under the following circumstances: (1) in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; (2) in the event you violate or breach an agreement with Cleveland Golf; (3) we believe you will harm the property or rights of Cleveland Golf or those of Cleveland Golf's other customers, (4) we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Cleveland Golf's terms of use, or as otherwise required by law, or (5) personal information may also be shared with or sold to any successor to, or purchaser of, part or all of the assets of Cleveland Golf.

NOTICE AT COLLECTION OF PERSONAL INFORMATION UNDER CALIFORNIA LAW
If you are a California resident, under the California Consumer Privacy Act of 2018 (“CCPA”), you have the right to know, at or before the time of collection of your personal information, the categories of personal information to be collected from you and the purposes for which the categories of personal information will be used. This section of our Privacy Policy, as well as any online links to this notice on our homepage or elsewhere, shall constitute such notice. Below is a list of the categories of personal information about California residents that may be collected and the business or commercial purposes for which it will be used:

Category of Personal Information Collected

Commercial Purpose for which Personal Information Collected

Personally identifiable information, such as real name; postal address; phone number; email address; account name/number; characteristics; Internet information; social security number; encrypted credit card information; IP information; occupation; employer; gender; date of birth; handedness; golf handicap; playing characteristics; personal golf club information; banking information, e-commerce payment gateways

Communication, for example, with customers; taking and filling orders; awarding prizes; to support credit application review process; cardholder payment data and ecommerce needs; to run credit reports; to gather information about and communicate with consumer test subjects for testing our products; verifying order fulfillment for retail sites; for accounts payable: to make payments

Employee personal information, such as, in addition to above, bank information; insurance information; passport information; signatures; employment information, education, passport information

Employee contact, notifications for alarm access, CA-OSHA recordable incident reporting; for 1099 tax purposes; payroll; hiring; and benefits; evaluating job applicants and new hires

 

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD UNDER CALIFORNIA LAW
If you are a California resident, under the CCPA, you have the right to request what personal information we collect, use, disclose, and sell. Currently, Cleveland Golf does not sell any personal information of consumers.
To make a request to know what personal information Cleveland Golf collects about you, you may use either of the following designated methods: (1) call our toll-free number at (800) 999-6263; or (2) submit a verifiable consumer request using the following link to an online request form. Upon receipt of a request via our toll-free number or a fully completed online request form, Cleveland Golf will verify your request, which may involve asking you to provide additional information to us. Such verification may use a third party verification service, or may require you to access, and re-authenticate yourself via, a password-protected account.

Download form, Attachment A

The table below lists the categories of consumers’ personal information Cleveland Golf has collected about consumers in the preceding 12 months, the categories of sources from which that information was collected, the commercial purpose for which the information was collected, and the categories of third parties with whom we shared personal information:

Category of Personal Information Collected

Sources from which Information Collected

Commercial Purpose for which Information Collected

Categories of Third Parties with Whom Personal Information Shared

Personally identifiable information, such as real name; postal address; phone number; email address; account name/number; characteristics; Internet information; social security number; encrypted credit card information; IP information; occupation; employer; gender; date of birth; handedness; golf handicap; playing characteristics; personal golf club information; banking information, e-commerce payment gateways

B2B & B2C customers, independent contractors, night janitors, vendors, job applicants, contest and sweepstakes entrants, anyone requesting payment, retail locations and consumers participating in e-commerce sales,

Communication, for example, with customers; taking and filling orders; awarding prizes; to support credit application review process; cardholder payment data and ecommerce needs; to run credit reports; to gather information about and communicate with consumer test subjects for testing our products; verifying order fulfillment for retail sites; for accounts payable: to make payments; B2B user requesting access to our B2B site; B2C user to indicate orders fulfilled for retail sites

 

Employee personal information, such as, in addition to above, bank information; insurance information; passport information; signatures; employment information, education, passport information

Employees and job applicants

Employee contact, notifications for alarm access, CA-OSHA recordable incident reporting; for 1099 tax purposes; payroll; hiring; and benefits; evaluating job applicants and new hires

 



Cleveland Golf has disclosed to third parties consumer personal information for a business or commercial purpose during the past 12 months. Below is a list of categories of personal information disclosed for a business or commercial purpose to third parties during the past 12 months:

Category of Personal Information Disclosed

Commercial Purpose for which Personal Information Disclosed

Personally identifiable information has not, to our knowledge, been disclosed to third parties during the past 12 months. We reserve the right to do so, however, under any of the Commercial Purposes set forth in this table.

(1) in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; (2) in the event you violate or breach an agreement with Cleveland Golf; (3) we believe you will harm the property or rights of Cleveland Golf or those of Cleveland Golf's other customers, (4) we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Cleveland Golf's terms of use, or as otherwise required by law, or (5) personal information may also be shared with or sold to any successor to, or purchaser of, part or all of the assets of Cleveland Golf.



RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION UNDER CALIFORNIA LAW
We do all we can in order to protect personal information we collect from being compromised by cyber theft and other nefarious activities, for example by employing firewalls, secure servers, limited users and limited access, and log-in credentials for system access. Nevertheless, no system can ever be made 100% secure from cyber theft activities. If you are a California resident, you have the right under the CCPA to request the deletion of personal information collected or maintained by Cleveland Golf.
To make a request to delete personal information Cleveland Golf collects about you, you may use either of the following designated methods: (1) call our toll-free number at (800) 999-6263; or (2) submit a verifiable consumer request using the following link to an online request form. Upon receipt of a request via our toll-free number or a fully completed online request form, Cleveland Golf will verify your request, which may involve asking you to provide additional information to us. Such verification may use a third party verification service, or may require you to access, and re-authenticate yourself via, a password-protected account. Either before or after your request to delete is verified, we will ask you to separately confirm that you want your personal information deleted.

NOTICE OF RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION UNDER CALIFORNIA LAW
SHOULD CLEVELAND GOLF DETERMINE TO SELL ANY PERSONAL INFORMATION, AND YOU ARE A CALIFORNIA RESIDENT, YOU HAVE A RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION BY US.
Cleveland Golf has not sold any consumer personal information during the past 12 months, and will not sell personal information without further notice. Cleveland Golf will not sell the personal information of minors under 16 years of age without affirmative authorization.

RIGHT TO NON-DISCRIMINATION UNDER CALIFORNIA LAW
California residents have a right, under the CCPA, not to receive discriminatory treatment by Cleveland Golf for the exercise of privacy rights conferred by the CCPA.

DESIGNATION OF AUTHORIZED AGENT UNDER CALIFORNIA LAW
California residents have a right, under the CCPA, to designate an authorized agent to make a request under the CCPA on the consumer’s behalf. In order to make such a designation, Cleveland Golf requires the consumer to appoint the authorized agent via a financial power of attorney that meets the requirements of the California Probate Code, Section 4401.

COOKIES
"Cookies" are a feature on your browser software. If enabled, cookies may store small amounts of data on your computer about your visit to our Site. Cookies assist us in tracking which of our features appeals to you and what content you may have viewed on previous visits. When you visit our Site again, cookies can enable us to customize our content according to your preferences. We may use cookies to: keep track of the number of return visits to our Site; accumulate and report aggregate, statistical information on website usage; deliver specific content to you based on your interests or viewing history; save your password for ease of access to our Site. You can disable cookies, although, if you do, our Site may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set.

IP ADDRESSES
We automatically track certain information based on your behavior on our Site. We may use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on our Site or not), which URL you next go to (whether this URL is on our Site or not), your computer browser information, and your IP address. Your Internet Protocol ("IP") is a unique Internet "address"; which is assigned to you by your Internet Service Provider ("ISP"). For local area network ("LAN"), DSL, or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by Web servers, collecting information about a user's traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages.

COMPUTER PROFILES
Cleveland Golf may also collect and accumulate other anonymous data which will help us understand and analyze the Internet experience of our visitors. For instance, Cleveland Golf may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement. Unless you provide us with personally identifiable information, we will not use such visitor data to identify you.

SECURITY
Your information may be stored and processed in the United States or any other country in which Cleveland Golf or its affiliates, subsidiaries or agents maintain facilities, and by using our Site, you consent to any such transfer of information outside of your country. Cleveland Golf abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.
We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, including encryption, and "firewalls." We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company. However, perfect security does not exist on the Internet.

CONTACT INFORMATION
If you have any questions or concerns about the Privacy Policy for this Site or its implementation, whether online or offline, you may contact us here. You may also contact us by mail at:
Cleveland Golf Company, Inc.
5601 Skylab Road
Huntington Beach, CA 92647
USA

or

By email: support@clevelandgolf.com
By telephone: (800) 999-6263
By fax: (714) 889-5891

*Email No Thanks

XXIO Eleven