Privacy Policy

BY USING OUR SERVICES, YOU ACKNOWLEDGE AND CONSENT TO THE COLLECTION, TRANSFER, STORAGE, DISCLOSURE, AND OTHER USES OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES.

At AceCam® Golf LLC ("AceCam," "we," "us," or "our"), we prioritize the privacy and security of your personal information. As the provider of the AceCam mobile application ("AceCam App") and associated services (collectively referred to as the "Services"), this Privacy Policy is designed to inform you about how we gather, utilize, share, and safeguard your information.

This Privacy Policy outlines the types of personal data we collect, the purposes for which we utilize that data, the methods of handling your information, and your rights related to your personal data. We are committed to compliance with applicable privacy laws and regulations, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

"Personal Data" refers to information that can identify you, either directly or indirectly, and may include personally identifiable information ("PII"), financial information, and any other details you voluntarily provide while using our Services.

We may update this Privacy Policy periodically. If we make significant changes, we will notify you by posting the revised policy on the AceCam App and our website. Changes will take effect as of the "Last Updated" date indicated at the end of this Privacy Policy. Continued use of our Services signifies your acceptance of the updated Privacy Policy.

At AceCam, we gather different types of information to provide and enhance our Services. This section details the categories of information we collect and how we obtain it.

Personal Data

When you register for an account or engage with our Services, you may be asked to provide certain personal information, including but not limited to:

• Name: To personalize your account, verify your identity, and display on leaderboards
• Phone Number: Your primary sign-in credential, used for OTP authentication, account management, and SMS communications
• Email Address: For communication, account verification, and updates (optional)
• Date of Birth: For age verification as required by law (must be 18 or older for real-money contests)
• Physical Address: For billing purposes, tax reporting, or where applicable
• Payment Information: Credit/debit card details processed through CyberSource (tokenized — we never store raw card numbers), and bank account details stored in Cliq's PCI-compliant vault
• AceCam Wallet Activity: Deposit, withdrawal, Entry Fee, Challenge Stake, Service Fee, and prize-payout transactions associated with your AceCam Wallet (as described in the AceCam Terms of Service)
• Golf Performance Data: Handicap index, scores, contest entries, and results

Usage Data

We automatically collect certain information about how you interact with our Services. This information may include:

• IP Address: To identify your device and provide location-based services
• Device Type: Such as mobile or desktop, including unique device identifiers
• Browser Type and Version: To optimize your experience with our Services
• Pages Visited: Information about the specific pages and features you access
• Time and Date of Visits: To analyze usage patterns and improve our Services
• Session Identifiers: A record of your activity within our Services for anonymous analytics

Information Collected from Third Parties

We may also obtain information about you from third parties, including identity verification providers and authentication services. This information may include:

• Profile information (e.g., username, profile picture) from Google OAuth sign-in
• Bank account holder name and account details from Plaid during bank linking
• Identity verification data from Plaid Layer during onboarding

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and collect information about your usage of our Services. Cookies are small text files placed on your device that help us recognize you and gather information about your preferences.

Types of Cookies We Use:

• Session Cookies: Temporary cookies that remain on your device until you leave our website or close the app. They help us remember your preferences during a single browsing session.
• Persistent Cookies: These cookies remain on your device for a specified period or until you manually delete them. They help us remember your preferences for future visits.

You can control cookie settings through your browser, but disabling cookies may limit your ability to use certain features of our Services.

It is your responsibility to provide and maintain accurate, current, and complete personal information when using AceCam's Services. You agree to promptly update any information you provide to ensure it remains accurate, complete, and up to date.

AceCam is not responsible for any issues, problems, or liabilities that may arise due to inaccurate, incomplete, or outdated information. We reserve the right to reject or delete any account or entry that we believe in good faith to be false, fraudulent, or inconsistent with this Privacy Policy.

At AceCam, we utilize the information we collect to provide, maintain, and enhance our Services, as well as to communicate effectively with you. The primary purposes for which we use your personal information include the following:

• We use your information to facilitate the creation of accounts, enable access to our Services, and manage your participation in contests and events. Personal data is essential for processing transactions, managing user accounts, and ensuring a smooth user experience.
• Your contact information is utilized to send notifications, updates, and promotional content related to our Services. We may respond to inquiries, provide customer support, and manage your account, which includes sending confirmations, invoices, and technical notices.
• To improve our Services, we analyze user behavior and preferences, allowing us to enhance functionality and develop new features.
• We may also use your information to comply with applicable laws and regulations, protect our rights and the rights of others, and prevent fraud or misuse of our Services.
• We may send you promotional materials and information about upcoming contests and special offers, provided you have given your consent to receive such communications.

Lastly, your personal information may be used as necessary to resolve disputes, enforce our agreements, and fulfill legal obligations.

Program Name: AceCam SMS Alerts

By providing your phone number, you consent to receive text messages from AceCam regarding contests, promotions, and updates related to our Services. These messages may include confirmations, notifications, and marketing content.

Cancellation:You can cancel the SMS service at any time by texting "STOP" to the short code. Upon sending "STOP," you will receive a confirmation message indicating that you have been unsubscribed.

Support:If you experience any issues with the messaging program, you can reply with the keyword "HELP" for assistance or contact us directly at support@acecamgolf.com.

Carrier Liability: Please note that carriers are not liable for delayed or undelivered messages.

Message and Data Rates: Standard message and data rates may apply for any messages sent to you from us and to us from you.

For full SMS messaging terms, see our SMS Messaging Terms.

At AceCam, we are committed to protecting your personal information. However, there are certain circumstances where we may share your information with third parties. We will not sell or rent your personal information to third parties for their own marketing purposes without your explicit consent.

With Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in operating our Services, conducting our business, or servicing you. These service providers are required to keep your information confidential and are prohibited from using it for any other purpose. Our service providers include:

• CyberSource: Payment card tokenization and processing
• Cliq (CashFlow): ACH payment processing and PCI-compliant bank account vault storage
• Plaid: Bank account authentication, identity verification, and balance checks
• Venmo (a service of PayPal, Inc.): Consumer-facing payment processing for AceCam Wallet funding and player payouts
• Twilio: SMS messaging delivery
• Resend: Email delivery
• Vercel: Application hosting and deployment
• Neon: Database hosting

For Legal Compliance

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This includes sharing information when we believe that disclosure is necessary to comply with legal obligations, protect our rights, or prevent fraud or abuse.

In Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business or assets, your personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

For Contests and Promotions

If you participate in contests or promotional events, we may share your information with sponsors or partners involved in the contest or promotion. Your participation may require sharing your name and other identifying information to fulfill prizes or recognition. Leaderboard data (username, scores) is displayed at participating golf courses and venues.

Aggregate and De-Identified Information

We may share aggregated or de-identified information that does not directly identify you. This information can be used for various purposes, including research, marketing, or analysis.

AceCam® Golf uses Plaid Technologies, Inc. ("Plaid") to connect your bank account to our platform. By using our bank linking features, you acknowledge and agree that the terms of Plaid's End User Privacy Policy govern Plaid's collection, use, and sharing of your financial data.

When you link your bank account through Plaid, Plaid may collect and process the following information:

• Bank account and routing numbers to facilitate ACH transactions
• Account holder name and identity information for ownership verification
• Account balance information for pre-deposit verification
• Bank login credentials (handled entirely within Plaid's secure environment — AceCam never sees or stores your bank login information)

You may revoke Plaid's access to your bank account at any time by removing your linked bank account from your AceCam account settings, or by contacting Plaid directly at plaid.com/legal.

All payments for AceCam® services are securely processed through trusted third-party providers:

• CyberSource: Handles credit and debit card transactions via tokenized Flex Microform — your full card number is never transmitted to or stored on our servers
• Cliq (CashFlow): Handles ACH bank transfers for deposits and cashouts. Bank account details are stored in Cliq's PCI-compliant vault — we store only masked account numbers
• Plaid: Authenticates bank account ownership and retrieves verified routing and account numbers during bank linking. Also provides pre-deposit balance checks.
• Venmo (a service of PayPal, Inc.): Provides an additional consumer-facing payment rail for AceCam Wallet funding (inbound deposits) and player payouts (outbound prize disbursements and withdrawals). Venmo's processing of your data is governed by Venmo's and PayPal's published Privacy Policies.

AceCam does not store or have access to your full payment card details. Bank credentials are transmitted from Plaid to Cliq's vault and are not stored in our database.

All fees and payments collected by AceCam are associated with real-world activity at participating physical golf courses: (i) Service Fees for AceCam's verification, video, and content services in connection with Host Course Contests and Player vs. Player AceCam Challenges; and (ii) Entry Fees and Challenge Stakes funded through the closed-loop AceCam Wallet for participation in AceCam-Operated Contests and AceCam Challenges. None of these payments are for digital goods or in-app content, and they are not subject to Apple In-App Purchase (IAP) or Google Play Billing requirements.

The active payment partners may be updated by AceCam from time to time as AceCam's payment infrastructure evolves. AceCam will update this Privacy Policy to reflect any material change to its payment partner roster.

At AceCam, we prioritize the security of your personal information and implement a variety of measures to protect it from unauthorized access, disclosure, alteration, and destruction.

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher, with HSTS enforced on all connections
• Encryption at Rest: Sensitive data is encrypted using AES-256-GCM. Our database provider (Neon) provides AES-256 encryption at rest for all stored data.
• Payment Security: Payment card data is tokenized via CyberSource and never stored on our servers. Bank account details are stored in PCI-compliant vaults operated by Cliq.
• Access Controls: We implement strict role-based access controls with least-privilege principles to limit access to personal information to only those who need it for legitimate business purposes.
• Security Headers: Our application enforces security headers including X-Frame-Options, X-Content-Type-Options, Strict-Transport-Security, and Referrer-Policy on every response.
• Vulnerability Scanning: We perform automated dependency vulnerability scanning and security audits as part of our development process.

While we take extensive precautions to protect your information, please be aware that no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

In the event of a data breach that affects your personal information, we will promptly notify you in accordance with applicable laws and regulations.

At AceCam, we are committed to retaining your personal information only for as long as necessary to fulfill the purposes for which it was collected, in accordance with applicable laws and regulations.

We retain your personal data for the following purposes:

• Service Provision: We keep your information as long as your account is active or as needed to provide you with our Services.
• Legal Obligations: Certain data may be retained for a longer period if required to comply with legal obligations, resolve disputes, or enforce our agreements. This may include information necessary for tax, accounting, or other legal requirements.
• Account Management: If you choose to close your account, we will retain your information for a reasonable period to ensure compliance with applicable laws and to respond to any legal inquiries or obligations.
• Aggregated Data: We may retain and use aggregated or de-identified information that does not directly identify you for analytical purposes, research, and service improvement.

When your personal information is no longer necessary for the purposes for which it was collected, or if you request its deletion and it is no longer required for legal or legitimate business purposes, we will take reasonable steps to securely delete or anonymize your data.

For detailed retention periods and our automated cleanup processes, see our Data Retention Policy.

AceCam integrates with various third-party services to enhance the functionality of our platform. The data collected by these services is governed by their respective privacy policies, and we encourage you to review those policies to understand how they handle your information.

User Consent: By using our Services, you consent to the sharing of your information with these third-party services as necessary to provide you with the features and functionality of AceCam. Please be aware that your interactions with these third-party services are subject to their terms of service and privacy policies.

Limitations of Responsibility: While we strive to work with reputable third parties, AceCam is not responsible for the privacy practices, content, or actions of these third-party services. We recommend that you exercise caution and review the privacy practices of any third-party services before providing them with your personal information.

At AceCam, we may transfer your personal information to countries outside of your home country, including the United States, where data protection laws may differ from those in your home country.

Data Transfer Information: By using our Services, you acknowledge and agree that your personal information may be transferred to and processed in a country outside of your home jurisdiction.

Legal Basis for Transfer: We take steps to ensure that any international transfers of personal data comply with applicable data protection laws. This may include entering into contractual agreements with third parties or relying on other lawful mechanisms to ensure your data is adequately protected.

User Rights: Regardless of where your data is processed, you retain all rights regarding your personal information as described in this Privacy Policy.

As a user of AceCam, you have certain rights concerning your personal information. We are committed to ensuring that you can exercise these rights in accordance with applicable data protection laws. The rights you may have include the following:

• Right to Access: You have the right to request copies of your personal information held by us. This allows you to know what data we have about you and how it is being used.
• Right to Correction: If you believe that any information we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Deletion: You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent.
• Right to Object: You have the right to object to the processing of your personal information in certain circumstances, including when we are processing your data for direct marketing purposes.
• Right to Restrict Processing: You can request that we restrict the processing of your personal information if you contest the accuracy of the data, if our processing is unlawful, or if you need us to retain your personal information for legal purposes.
• Right to Data Portability: You have the right to request that we transfer your personal information to you or to a third party in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: If you have provided consent for us to process your personal information, you have the right to withdraw that consent at any time. This will not affect the legality of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at privacy@acecamgolf.com. We may need to verify your identity before responding to your request, and we will aim to respond within a reasonable timeframe, typically within 30 days.

We may refuse to comply with requests that are unreasonably repetitive, require excessive technical effort, or jeopardize the privacy of others.

At AceCam, we are committed to ensuring that our practices regarding the collection, use, and protection of personal information comply with applicable laws and regulations.

Applicable Regulations: Our data protection practices adhere to various laws and regulations, including, but not limited to:

• The General Data Protection Regulation (GDPR) for users located in the European Union
• The California Consumer Privacy Act (CCPA) for residents of California, USA
• Any other applicable local, state, national, or international laws governing data protection and privacy

We regularly review and update our practices to ensure compliance with these regulations, including implementing necessary security measures, providing users with clear information about their rights, and responding to user requests regarding their personal information in accordance with the law.

At AceCam, we are committed to protecting the privacy of children. Our Services are not designed for children under the age of 18, and we do not knowingly collect personal information from children in this age group. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete that information promptly.

Real-money contest features require users to be 18 years or older, as specified in our Terms of Service and Rules of Play. Age verification is performed during onboarding.

In compliance with the Children's Online Privacy Protection Act (COPPA), we take measures to protect children's privacy, including limiting the collection of personal information to what is necessary, providing clear information about our practices, and never selling or sharing personal information collected from children with third parties.

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, we encourage you to reach out to us:

We aim to respond to all inquiries within 48 hours.

We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will revise the "Last Updated" date at the bottom of this Privacy Policy. We may also notify you through other means, such as by sending an email or providing a notice within our Services.

Your continued use of our Services after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide by and be bound by the modified policy.

If we make significant changes to this Privacy Policy that affect your rights, we will provide you with clear and prominent notice, such as via email or a notification within the Services.

• Terms of Service — Terms governing your use of AceCam® Golf
• Rules of Play — Contest rules and eligibility requirements
• Data Retention Policy — Detailed data retention periods and deletion procedures
• SMS Messaging Terms — Terms for SMS communications