ACUSHNET: PRIVACY NOTICE

Acushnet Company and its subsidiaries and its affiliates (collectively, “Acushnet”), respect your concerns about privacy. Unless otherwise indicated, all Acushnet brands, including but not limited to Titleist, FootJoy, Vokey, Scotty Cameron, Links & Kings, Pinnacle, KJUS, MyTPI, etc., (each referred to as a “Brand”), follow this Privacy Notice where published. You can find a list of Acushnet brands here.

This Privacy Notice describes the types of personal information we may obtain about you, including when you interact with our websites and mobile applications (collectively, “Online Services”), how we use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard personal information and how you can contact us about our privacy practices.

Information We Obtain

We may obtain certain personal information that you choose to submit to us through our Online Services, including:

● contact information, such as name, email and postal addresses, and phone number;
● login credentials when you create an account through our Online Services;
● payment card details, which are collected by our third-party payment processor on our behalf;
● gender and age or date of birth;
● information about products and services purchased, product sizes, measurements and customizations, interests and preferences, and experience with our products and services;
● professional information, such as your occupation and job title;
● information we obtain from third-party social media services if you choose to link to, create, or log into your account with us through these services;
● information we obtain about you when you apply for a job with us, such as your resume information, legal work eligibility status, citizenship status, information collected for diversity monitoring purposes, and other information about you; and
● other information you choose to provide, such as through communications with us.

In addition, if you are a user of TPI’s services, including but not limited to MyTPI.com and TPI’s software products (e.g., MyTPI App, MyTPI Pro App) (collectively, “TPI Services”) we may collect certain additional information, including:

● if you are a golf, fitness, or medical professional that is seeking to acquire TPI Certification (the “Certification”), we collect certain information about your Certification process, such as courses purchased, events attended, exam results, and Certifications obtained;
● if you are a TPI Certified Professional, after completing Certification, we will ask you for additional information to set up your Expert Profile, which may include your professional credentials and licenses, contact information, business address, photographs, and other personal information you wish to include in your Expert and publicly available profiles; and
● if you are a client of a TPI Certified Professional who uses the TPI Services, your TPI Certified Professional may send us your contact information to enable us to invite you to sign up. The TPI Certified Professional also may submit certain information about you to the TPI Services, such as photographs, videos, gender, height, weight, handedness, and assessment results.

If you are a client of a TPI Certified Professional, you and the TPI Certified Professional will enter into a separate contractual arrangement that does not involve TPI. TPI Certified Professionals operate independently from us, and their information practices are not subject to this Privacy Notice. We are not responsible for their privacy practices, including details on the information they may collect about you and how they use and share the information. Please contact your TPI Certified Professional directly for any questions about their privacy practices.

If you are a TPI Certified Professional that provides personal information about your clients to us, you are responsible for providing our Privacy Notice to any such clients.

Information We Obtain By Automated Means

When you visit our Online Services, we may obtain certain information by automated means, such as cookies, web beacons, web server logs, session replay and screen capture technology, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your IP address, unique device identifier, web browser characteristics, device characteristics, operating system, WiFi network identifiers and signals, language preferences, demographics (e.g., age range), city and country information, referring URLs, pages visited, clickstream data, and dates and times of visits. For additional information, please see our cookie policy on our Brand homepages.

We also may use session replay and screen capture technology to collect information on how you use and navigate our Online Services. This may include mouse movements, clicks, and how you scroll through the Online Services.

We may use these automated technologies on our Online Services to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Online Services; (3) tailor the Online Services around your preferences; (4) measure the usability of our Online Services and the effectiveness of our communications and marketing efforts; and (5) otherwise manage and enhance our products and services and help ensure they are working properly.

Your browser may tell you how to be notified when you receive certain types of cookies and automated technologies or how to restrict or disable certain types of cookies and automated technologies. Note, that without cookies, and other automated technologies, you may not be able to use all of the features of our Online Services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

How We Use The Information We Obtain

We may use the personal information we obtain about you to:

• provide our products and services, including our Online Services;
• establish and manage your account with us;
• verify your identity;
• process and fulfill transactions in connection with our products and services;
• communicate with you (including administrative notices and promotional communications about our products and services) and respond to your inquiries;
• manage and administer our marketing and promotional efforts, including special events and contests;
• personalize your experience with our products and services, including our Online Services;
• manage career opportunities with us, including for recruitment purposes, candidate screening and evaluation, and employee onboarding;
• establish and manage current and prospective business relationships;
• protect against and prevent fraud, unauthorized transactions, claims, and other liabilities;
• perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
• operate, evaluate, develop, and improve our business (including managing our products and services; developing new products and services; enhancing and improving our products and services; managing and evaluating our communications; analyzing our products and services; and performing accounting, auditing, and other internal functions);
• maintain and enhance the safety and security of our Online Services, products and services, and prevent misuse; and
• comply with and enforce applicable legal requirements, industry standards, and our policies and terms, including the terms and conditions governing our Online Services.

We also may use the information in other ways for which we provide specific notice at the time of collection.

Third-Party Analytics

We use third-party web analytics services on our Online Services, such as Google Analytics. We also may use third-party session replay and screen capture services that record users’ interactions with our Online Services. The service providers that administer these services use technologies such as cookies, web beacons, web server logs, session replay and screen capture technology, and similar automated technologies to help us analyze how visitors use our Online Services. The information we obtain through our Online Services may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://policies.google.com/technologies/partner-sites.

Interest-Based Advertising

On our Online Services, we may obtain information about your online activities to provide you with advertising about services tailored to your interests. This section of our Privacy Notice provides details and explains how to exercise your choices.

You may see our ads on other websites because we use third-party advertising services. Through such advertising services, we can target our messaging to users considering demographic data, users’ inferred interests, and browsing context. These services track your online activities over time and across multiple websites by collecting information through automated means, including through the use of cookies, web server logs, web beacons, and other similar technologies. The advertising services use this information to show you ads that may be tailored to your individual interests. The information that advertising services may collect includes data about your visits to websites that serve our advertisements, such as the pages or ads you view and the actions you take on the websites. This data collection takes place both on our Online Services and on third-party websites that participate in these advertising services. This process also helps us track the effectiveness of our marketing efforts.

Our Online Services are not designed to respond to “do not track” signals from browsers.

To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices or http://www.networkadvertising.org/choices/. In the EU or UK, please visit www.youronlinechoices.eu. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising purposes.

How We Share The Information We Obtain

We may share the information we obtain about you with our affiliates and subsidiaries. We also may share the information we obtain about you with professional services organizations (e.g., auditors, accountants, and law firms) and our service providers who perform services on our behalf. We do not authorize these service providers to retain, use, or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements.

If you are a TPI Certified Professional, we may share your Expert Profile on the TPI Services so potential clients can identify those TPI Certified Professionals whose services they would like to engage. If you are a client of a TPI Certified Professional, and you are using the TPI Services to interact with that TPI Certified Professional, your information may be accessible to your TPI Certified Professional.

In addition, we may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to transfer any personal information we have about you in connection with a prospective or actual sale, merger, transfer, or other reorganization of all or parts of our business or assets (including in the event of a merger, acquisition, joint venture, divestiture, restructuring, reorganization, dissolution, or liquidation).

Your Choices and Rights

We offer you certain choices in connection with the personal information we collect from you. If you have an account with us, you can update your profile information by logging into your account. You also can unsubscribe from our marketing emails by following the “unsubscribe” instructions in the emails.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called “California Consumer Privacy Statement” below.

If you are a Colorado resident, for more information about your privacy rights, please see the section of this Privacy Notice called “Colorado Consumer Privacy Statement” below.

If you are a Colorado, Connecticut, Utah or Virginia resident and you interact with us in an individual or household capacity (and not in a commercial or employment context), you may have the right to (1) request access to, correction of, or deletion of your personal information; (2) request that we provide you a copy of your personal information in a portable format; or (3) opt out of the sale of your personal information or the processing of your personal information for purposes of targeted advertising. To submit an access, correction or deletion request, or request a copy of your personal information in a portable format, please email us at privacypolicy@acushnetgolf.com or call us at (800) 436-6856. To opt out of the sale of your personal information, or the processing of your personal information for targeted advertising purposes, click here or use the Global Privacy Control signal (“GPC”). If you use the GPC, we will process it for your browser, but it will not apply outside of that browser to your device, account, or offline sales or sharing. After using the GPC, if you clear your cookies in your browser, you will need to use the GPC again for us to process your opt-out request for that browser. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Prior to fulfilling your access, correction or deletion request, we will take reasonable steps to verify your identity, including by verifying your email address or certain of your information in our records, such as recent order information (if applicable), name, phone number, and zip code. To submit an opt-out request as an authorized agent on behalf of an individual, please email us at privacypolicy@acushnetgolf.com.

You may appeal our decision with respect to a request you have submitted by contacting us at privacypolicy@acushnetgolf.com. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. If you choose to exercise any of these rights, you have the right to not receive discriminatory treatment by us.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children’s Privacy

Our Online Services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13.

Third-Party Links And Features

For your convenience and information, our Online Services may provide links to other online services, and may include third-party features such as apps, tools, widgets, and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties’ information practices.

Updates To Our Privacy Notice

This Privacy Notice may be updated periodically and to reflect changes in our personal information practices. We will post a notice on our Online Services to notify you of significant changes to our Privacy Notice and indicate at the top of the Privacy Notice when it was most recently updated.

How To Contact Us

If you have any questions about this Privacy Notice, please contact us at privacypolicy@acushnetgolf.com. You also can write to us at:

Legal Department
Acushnet Company
333 Bridge Street
Fairhaven, MA 02719
USA

CALIFORNIA CONSUMER PRIVACY STATEMENT

Last Updated: May 2, 2024

This California Consumer Privacy Statement supplements the Privacy Notice and applies solely to personal information collected about California consumers, such as our customers, visitors to our Online Services, job applicants, and representatives of business partners. This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the “Last Updated” date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, credit card number, debit card number, and other financial information, education, and medical information;
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender identity, gender expression, sexual orientation, medical condition, disability, citizenship status, and military and veteran status;
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements;
• Sensory Information: audio, electronic, visual, and similar information;
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information; and
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

We may use (and may have used during the 12-month period prior to the “Last Updated” date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA/CPRA:

• performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services;
• providing advertising and marketing services to you, except for cross-context behavioral advertising (which is addressed in the “Sale or Sharing of Personal Information” section of this Statement);
• auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us;
• helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
• debugging to identify and repair errors that impair existing intended functionality;
• undertaking internal research for technological development and demonstration; and
• undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Retention of Personal Information

We will retain your personal information for the period reasonably necessary to achieve the purposes described in our Privacy Notice and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

Sources of Personal Information

During the 12-month period prior to the “Last Updated” date of this Statement, we may have obtained personal information about you from the following categories of sources:

• directly from you, such as when you create an account on our Online Services;
• your devices, such as when you use our Online Services;
• our affiliates and subsidiaries;
• your friends, such as when someone uses the Tell-a-Friend feature;
• vendors who provide services on our behalf;
• business partners;
• your employer, if you are a representative of one of our business partners;
• online advertising companies;
• social networks;
• recruiting and talent agencies;
• job references, such as your employers; and
• data brokers, such as public databases, credit bureaus, credit reporting service providers, and background check services.

Sale or Sharing of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as online advertising services and social networks) to collect personal information via automated technologies on our Online Services for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services and social networks:

• Identifiers;
• Commercial Information;
• Online Activity; and• Inferences.
• Inferences.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the “Last Updated” date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the “Last Updated” date of this Statement, we may have disclosed personal information about you to government entities (e.g., in response to a request from law enforcement authorities) and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions or divestitures.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you, including the categories of personal information collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
• Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access, correction, deletion, or Shine the Light request, email us at privacypolicy@acushnetgolf.com or call us at (800) 436-6856. To opt out of the sale or sharing of your personal information, click here or use the Global Privacy Control signal (“GPC”). If you use the GPC, we will process it for your browser, but it will not apply outside of that browser to your device, account, or offline sales or sharing. After using the GPC, if you clear your cookies in your browser, you will need to use the GPC again for us to process your opt-out request for that browser. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction, or deletion of your personal information, we may require you to provide certain information in our records, such as: e-mail address, recent order information if applicable, name, phone number, and zip code. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, correction, deletion, or opt-out of sale or sharing request on your behalf, (a) we may require you to provide the authorized agent written permission to do so, and (b) for access, correction, and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacypolicy@acushnetgolf.com or call (800) 225-8500 if you have any questions about this Statement or our information practices, or to request this Statement in an alternative format.

COLORADO CONSUMER PRIVACY STATEMENT

Last Updated: May 2, 2024

This Colorado Privacy Notice supplements the information in our Privacy Notice above and applies solely to Colorado consumers. We adopt this Colorado Privacy Notice to comply with the Colorado Privacy Act (the “CPA”). This Colorado Privacy Notice uses certain terms that have the meanings given to them in the CPA.

Collection and Use of Personal Information

We may collect, use and share personal data as described in the chart below.

We also may share the personal data described above with government entities and third parties (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to lawful requests by government agencies, which may include lawful access by foreign courts, law enforcement and other government authorities in the jurisdictions in which we, our affiliates or our service providers operate; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss, or to protect the safety, property, or rights of Acushnet or of any third party; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We do not knowingly process personal information from children under the age of 13 or other sensitive data as defined in the CPA. We also do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined in the CPA. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Colorado Consumer Privacy Rights

For information about your privacy rights and how to submit a request, please see the “Your Choices and Rights” section of our Privacy Notice.