Porsche Golf Circle App

Privacy Notice

This privacy notice (“Privacy Notice”) describes the information that Porsche Sales & Marketplace, Inc. (“Porsche”) collects about you, how we use and share your information, and your choices when using the Porsche Golf Circle App (the “App”). Unless otherwise indicated, all references to “Porsche,” “we,” “us,” or “our” in this Privacy Notice means Porsche (as defined above).

Scope

This Privacy Notice applies to information collect about you by or on behalf of Porsche as set forth in the below “Information We Collect” section through the App.  This Privacy Notice does not apply to other Porsche mobile apps or websites, to any of our affiliates, other Porsche companies, or to Porsche dealers which are independent third parties. 

As used in this Privacy Notice, “Personal Information” means information that identifies or can reasonably be linked to a specific individual, such as name, address, e-mail address, phone number, driver’s license number, or credit card number. “Information” is collectively used herein to refer to both Personal Information and information that does not identify and cannot reasonably be linked to a specific individual. 

Links, Third-Party Websites, and Social Media Platforms

The App may contain links to the websites of other Porsche companies, Porsche dealers, or other third parties, as well as to social media platforms such as Facebook or Twitter (“Linked Sites”).  Porsche is not responsible and has no liability for the privacy policies or practices of Linked Sites.  We recommend that you review the privacy policies of each Linked Site you visit.  

Outside the U.S.

The App is for users located exclusively in the United States of America.  If you are located outside the United States, please do not use the App, as the information practices and the terms of this Privacy Notice may or may not comply with the laws of your jurisdiction.  By using the App, you consent to the use and disclosure of your information in accordance with this Privacy Notice and subject to the applicable laws of the United States. 

Information We Collect

Porsche and its third party service providers collect Information about you, including Personal Information you provide directly to us and Information we collect about you when you access and use the App. We also collect your Personal Information from third parties. We may combine any of the Information collected about you for the purposes described in this Privacy Notice.

Information You Provide Us.  We collect Personal Information when you register with and use the App.

· Registration and login: Registration takes place using your Porsche ID. If you do not have a Porsche ID yet, you can create a corresponding user account via the App. Please note that creation of a Porsche user account and use of a Porsche ID will be subject to the Porsche Digital Infrastructure Privacy Notice. As part of the registration process, your vehicle identification number will also be collected.

· Your user profile: You can supplement the information from your Porsche ID with further details to create an individual user profile. In particular, you can add the following information: profile picture, display name, location, handicap, home club and other golf clubs used. Your user profile can be accessed by us and other users and searched for the information it contains. If necessary, you can add further details and select which details should only be visible to you.  We may use the information from your user profile to supplement your customer data record if it is linked to your Porsche ID.

· Posting user content: You may post your own content such as comments and recommendations, photos and videos, and links, or distribute "Likes" for events, golf clubs and locations, or third-party user content, which will then be linked to your user profile. This user content can be accessed by us and the other users.

· Organization of events: The events themselves are created by us, other Porsche group companies, Porsche dealers or also by the users. If you participate in the events, your participation and possibly also your score may be published as part of the App and assigned to your user profile.

· Networking with other users: You can network with or follow other users in order to stay in contact with them or to be informed about their user content and events. In this respect, you can also tag and mention other users so that their user profile is linked to user content or events. In this sense, other users can also perform these functions with you or your user profile. In order to organize flights to play together and to exchange information about events, you can exchange messages with other users, which are then linked to your user profile.

· Location: You are able to look up golf courses worldwide and see which other community members have played there and what they recommend. The locations feature POI (Point of interest) gives users the possibility to find general information about the golf course as well as to write reviews and exchange recommendations with others. They will be able to post pictures and tag the corresponding location. An added value will be that if the user consents to sharing their geolocation, the feature can show them relevant results close to their area.  

Information Collected Automatically.

When you access the App, data relating to your terminal device and your use of the App is processed and stored, including in particular, technical data such as date and time of access, duration of the visit, type of end device, operating system used, functions used, amount of data sent, IP address and referrer URL. We process this data to ensure technical operation and to identify and eliminate malfunctions.

Cookies:   Cookies are small text files stored by your browser that allow us to learn more information about your visit or use of the App.  We may use cookies to remember your Personal Information, including your registration information, and to track your usage of the App over time. Most browsers automatically accept cookies.  Check the "Help" menu of your browser to learn how to change your cookie preferences if available.

Analytics Information:  We may use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the App.  These tools collect information sent by your mobile device, including the pages you visit and other information that assists us in improving the App. 

Device and Browsing Information:  We collect certain information about your device each time you access the App.  Servers may automatically record certain log file information such as your request, Internet Protocol (IP) address, MAC address, physical location data, browser or mobile operating system type, referring / exit pages and URLs, number of clicks and how you interact with Linked Sites, domain names, landing pages, pages viewed, and other such information.

Push Notifications.  We use a third-party, Google Firebase, as an authentication service and for sending you push notifications. The privacy policy for Google Firebase is located at https://www.firebase.com/terms/privacy-policy.html.

How We Use Your Information

We use your Information, including Personal Information, for a variety of business purposes, including:

· providing our products and services to you;

· communicating with you regarding Porsche, and its products and services;

· customizing your Porsche experience;

· creating and managing your registration for the App;

· responding to your inquiries, comments, or postings;

· improving and customizing the App;

· supplementing your customer profile in our records;

· internal operations such as enhancing our products and services, and the quality or safety    of the services or devices which we may own, control or provide;

· to conduct research and analysis including to develop and demonstrate technology;

· developing new products and services;

· marketing and advertising purposes;

· complying with legal obligations;

· enforcing our Terms and Conditions Use;

· protecting the security and integrity of our business, the App while using Personal Information as may be reasonably necessary and proportionate for these purposes;

· short-term, transient use including non-personalized advertising shown as part of your current interaction with us;

· auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with state privacy laws and other    standards; and

· debugging to identify and repair errors in our systems.

We retain Personal Information for the length of time needed to carry out the purposes outlined in this Privacy Notice and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We retain Personal Information to the extent necessary to manage our relationships with our customers, personalize and improve your overall customer experience, comply with our legal obligations (for example, if we are required to retain Personal Information to comply with applicable tax laws), resolve disputes, enforce our agreements, and as otherwise described in this Privacy Notice.

Your Choices In How We Use Your Information

By default, your personal contact information is not visible to other users. For better networking functionalities, you are able to change your personal settings to allow your approved contacts to see your contact information.  If you receive a contact request from another member, you may decline the member request and keep your contact information hidden from that member.

You may contact us as described in the below Contact Us section with any questions or concerns you may have about our privacy practices, including requests to update or correct your Personal Information. 

How We Disclose Your Information

We may disclose your Personal Information as follows:

• with third parties that provide a variety of services on our behalf, including the development, maintenance, and support of our App, communications, advertising and marketing research and analysis;
• with members of our affiliated group of companies for promotional or other purposes;
• to comply with law, a court order, or other legal process, or in connection with a legal investigation;
• as may be necessary to protect the rights and interests of  Porsche, its affiliates, and authorized Porsche dealers, and our and their respective employees, customers, visitors, users, or any other person or entity;
• to enforce any applicable terms and conditions and other agreements;
• in the event of a corporate transaction, such as a merger, reorganization, or acquisition, in which event your Personal Information may be transferred to the acquiring company;
• in aggregated or other non-personally identifiable form; and/or
• in accordance with your consent.

Additional Notice of State-Specific Privacy Information and Rights

This part of our Privacy Notice applies to consumers who reside in states that have enacted comprehensive consumer data privacy laws. 

Personal Information We Collect about Consumers

We describe the Personal Information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled “Information We Collect.” The information we collect and process includes the following:

• Identifiers such as name, address, e-mail address, phone number, password, Internet Protocol address, MAC address, title, golf handicap, golf club membership, personal profile text and photographs associated with user profiles. 
• The following categories of Personal Information described in California Civil Code § 1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” (2) vehicle identification numbers (VINs) (when linked to identified or identifiable persons), vehicle information such as model and year, vehicle registration information, and license plate numbers, (3) payment information such as payment card number or portion thereof, bank information, and payment amounts, (4) information you provide or that we record in connection with customer support calls or complaints, (5) demographic information such as birthdate, gender, language preference, and occupation, and (6) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in “Information We Collect” above.
• Characteristics of protected classifications under California or federal law, such as language preference and gender.
• Commercial information, including information about orders, purchases, or leases of, or interest you have expressed in, any of our products or services, registration information for any Porsche event or program, including Porsche driving experiences and the Porsche Travel Club, or web specials; and information you provide or submit to us when you participate in any event, program, contest, surveys, or other promotion that we may offer from time to time.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the App, other Porsche mobile apps, advertisements that we display on our mobile apps or on third party sites and apps, or Porsche pages or accounts on any third-party social media platforms such as Facebook or Twitter.
• Geolocation data relating to your computer or device when you interact with the App.
• Audio information from calls placed with customer service and accounting centers which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above. 
• Inferences drawn from (1) the information we collect when you use our apps, or our social media apps, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, or behavior.

· Sensitive Personal Information, such as precise geolocation data and contents of your communications and messages exchanged with users of the App.

We may collect and process Personal Information from sources that include Porsche vehicle buyers and lessees, Porsche dealers, our affiliates, Porsche clubs, and third-party marketing or analytics providers or providers of publicly available information.  For more information, please see “Information We Collect” and “Information Collected Automatically”.

We collect and use each category of the Personal Information above for the purposes described in “How We Use Your Information.” We do not process sensitive Personal Information for the purpose of inferring characteristics.

Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes

We disclose and have disclosed within the twelve (12) months preceding the effective date of this Privacy Notice the following category of Personal Information subject to this Privacy Notice to other businesses or third parties for monetary or other valuable consideration, cross-context behavioral advertising, or targeted advertising. 

· Identifiers and Inferences.  identifiers for individuals who visit our mobile app and the devices such individuals use to visit our mobile app, and data relating to usage of our app and inferences drawn from such usage data.  We disclose this information with third party vendors that provide analytics, social media, or digital advertising services to Porsche, and where applicable these vendors may use the information for their own purposes.

We disclose and have disclosed within the twelve (12) months preceding the effective date of this Privacy Notice Personal Information in all or substantially all of the categories identified in this Additional Notice of State-Specific Privacy Information and Rights for various business purposes.  For more information about the categories of Personal Information we have disclosed, the categories of entities with which we have disclosed this information, and the purposes for which we have disclosed the information, please see “How We Disclose Your Information.”

We do not disclose and have not disclosed within the twelve (12) months preceding the effective date of this Privacy Notice Personal Information of individuals we know to be under the age of 16 to other businesses or third parties for monetary or other valuable consideration or for cross-context behavioral advertising.

Your State-Specific Privacy Rights

If you are a resident of a state that has enacted a comprehensive consumer data privacy law you may have one or more of the following rights.  We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Right to Know Information regarding Personal Information. You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you.  Specifically, you have the right to request that we disclose the following to you, in each case subject to applicable law:

• whether we are processing Personal Information about you;
• the categories of Personal Information we have collected about you;
• the categories of sources from which the Personal Information is collected;
• our business or commercial purpose for collecting, sharing or selling Personal Information;
• the categories of third parties with whom we disclose Personal Information;
• the specific pieces of information we have collected about you;
• the categories of Personal Information about you, if any, that we have sold or shared and the categories of third parties to whom we have sold or shared the information, by category or categories of Personal Information for each category of third party to whom we sold or shared the Personal Information; and
• the categories of Personal Information about you that we disclosed for a business purpose and the categories of persons to whom we disclosed the information for a business purpose

Right to Deletion of Personal Information.  You have the right to request that we delete Personal Information that we have collected from or about you. Please note if you have requested a service that requires the use of your Personal Information, we may not be able to provide that service if you choose to delete your Personal Information. 

Right to Correct. You have the right to request that we correct inaccurate Personal Information that we have collected about you.

Right to Opt Out. You have the right to opt out of the disclosure of Personal Information about you to third parties for monetary or other valuable consideration or the sharing of Personal Information about you for cross-context behavioral advertising, targeted advertising and profiling in furtherance of decisions that produce legal or similarly significant effects. Please note that we do not process your Personal Information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects. To learn more about the choices you may have regarding Personal Information Porsche collects in connection with other services, please visit: Do Not Sell or Share My Personal Information.

The App cannot respond to opt-out preference signals that conform to the Global Privacy Control specification (“GPC”) because GPC is a browser-level technical specification that cannot forward your opt-out preferences to mobile applications. You can learn more generally about GPC by visiting https://globalprivacycontrol.org/.

Right to Non-Discrimination. We may not discriminate against you because of your exercise of any of the foregoing rights, including by:

· Denying you goods or services;

· Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

· Providing you a different level or quality of goods or services; or

· Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to Porsche by your Personal Information.

Right to Appeal. If we decline to take action on a request that you make in accordance with the foregoing to exercise the foregoing privacy rights, then you may appeal our decision by replying to our response to your request, emailing dataprivacy@porsche.us or calling 1-800-PORSCHE. Please use the reference ID associated with your request when you contact us so we can locate your records. 

Requests to Exercise Your Rights

You may request to exercise the foregoing rights by:

· Submitting a request through porsche.com/usa/privacy-policy/contact/

· Calling us toll-free at 1-800-PORSCHE. 

For requests made in connection with the Right to Know, Right to Delete and Right to Correct, please note we will process your request within 45 days (or the applicable statutory timeframe) after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. If your request involves us providing Personal Information to you, we may deliver the Personal Information to you through your account, if you maintain an account with Porsche, or, if not, electronically or by mail at your option.  If electronically, then we will deliver the information to you or, if you so request and by permitted by law, to another entity, in a portable and, to the extent technically feasible, in a structures, commonly used, machine-readable format that allows you to transmit the information from one entity to another without hindrance.

Agent Authorization

You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Even if you use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, and/or require you to verify your own identity.

Verification

We may require you to provide certain information, including contact information, to verify your identity before acting on your request to exercise your rights or granting you access to your information. We will only use this information to confirm your identity. In some cases we may need to collect additional information from you, and depending on the type of request we may use a third-party identity verification service to verify your identity. If we use a third-party identity verification service, our third-party identification verification service may ask you certain identity verification questions to match the information you provide with information that it has in its database.

Data Disclosure for Direct Marketing Purposes

California Civil Code Section § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us as specified below. To make such a request, please tell us your preference by contacting us as specified below.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

Accessibility

If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us at privacy@porsche.us.

How We Protect Your Information

We implement reasonable technical, administrative, and physical safeguards designed to keep your Personal Information secure.  We also request that our third-party service providers use appropriate security measures to protect your information from unauthorized access or use.  However, no data transmission is guaranteed as 100% secure.

Submissions and User Generated Content

Unless governed by separate terms identified at the time of submission, all suggestions, materials, remarks, or other intellectual property (e.g., ideas, experiences, and photos) you communicate or submit to us (“Submissions”) will be considered non-confidential and non-proprietary.  Porsche shall have no obligation of any kind with respect to such Submissions and shall be free to use and distribute Submissions for any purposes, without limitation of any kind.

The App and Social Media Pages allow you to post messages and submit content (e.g., comments, phots, blogs, postings, etc.; “User Generated Content”), which may include your Personal Information.  You are responsible for all actions resulting from any User Generated Content, including Personal Information, which you post on the App or Social Media Pages.  Please remember that any User Generated Content and Personal Information contained therein that you post becomes public information, and is not subject to this Privacy Notice, and Porsche is not responsible for the results of such postings.

Please see our Copyright Policy in the App’s Terms and Conditions of Use.

E-mail Security

"Phishing" is a scam designed to steal your Personal Information.  If you receive an e-mail that looks like it is from us asking you for your Personal Information, please notify us as provided below in the Contact Us section. 

Children’s Privacy

The App is not intended for use by children under 16. We do not knowingly collect Personal Information from children under the age of 16 without parental or guardian consent.  Please notify us as provided below in the Contact Us Section you believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it. 

Contact Us

If you have any questions or comments about this Privacy Notice or our privacy practices or any requests with respect to the Personal Information we collect about you, you may contact us at 1-800-PORSCHE, by sending an e-mail to contact@porschegolfcircle.com, or by mail in the United States to Porsche Sales & Marketplace, Inc., One Porsche Drive, Atlanta, Georgia 30354, Attn: Privacy/Legal Department.

Your Acceptance of Our Privacy Notice

By using the App, you signify your acceptance of this Privacy Notice, and you agree to adhere to the terms and conditions posted on our App under “Terms and Conditions.”  If you do not agree with the terms of this Privacy Notice, please do not access or use the App or submit any Personal Information to us.

Changes To This Privacy Notice  

Porsche reserves the right to modify this Privacy Notice at any time so you should review it frequently for changes. Your continued use of the App and/or provision of your Personal Information after such posting constitute your acceptance of such changes.  

Effective Date: August 2024

Copyright © 2024 Porsche Sales & Marketplace, Inc.