Privacy Policy

Last Updated: May 14, 2026

AVA Golf, Inc. (“AVA Golf,” “we,” “us,” or “our”) is committed to protecting the privacy of everyone who uses our products and services. This Privacy Policy describes how we collect, use, store, disclose, and protect personal information across all AVA Golf products and platforms, including:

The AVA Golf web application (ava.golf)
AVA Golf mobile applications (iOS and Android)
Email and waitlist communications
Third-party data integrations (Garmin, Arccos, USGA/GHIN, and others added over time)
APIs accessible by or from third parties
Social media interactions
Any other AVA Golf products, services, or channels that link to this Privacy Policy (collectively, the “Services”)

AVA Golf, Inc. is a Delaware C-corporation with offices at 169 Madison Ave #2003, New York, NY 10016. AVA Golf is a wholly-owned subsidiary of ParOne, Inc., a Delaware C-corporation (“ParOne”). ParOne and its affiliates and subsidiaries, including ParOne Holdings LLC, ParOne.dev LLC, ParOne App LLC, and GolfCentral TV, Inc., may have access to information collected under this Privacy Policy as described in Section 6.

This Privacy Policy applies to all users of the Services regardless of the device, platform, or method of access. Please read it carefully. By using the Services, you acknowledge that you have read and understood this Privacy Policy.

Questions or concerns? Contact us at privacy@ava.golf.

Information We Collect
How We Collect Information
- 2A. Third-Party Marketing, Analytics, and Tracking Tools
Third-Party Data Partner Integrations
How We Use Your Information
Technology, Machine Learning, and Video Recommendations
How We Share Your Information
Data Monetization and Aggregated Data
Advertising and Sponsorships
Data Retention
Data Security
Children’s Privacy (COPPA)
Your Privacy Rights
United States Residents — State-Specific Rights
European Union, United Kingdom, and Canadian Users
Third-Party Links and Services
Do Not Track Signals
Changes to This Privacy Policy
Referral Program
Contact Us

1. Information We Collect

AVA Golf collects a broad range of information in connection with your use of the Services. The core purpose of AVA Golf is to aggregate golf performance data from multiple sources in order to deliver Personalized Progression coaching and personalized insights. To accomplish that purpose effectively, we collect as much relevant data as you authorize us to collect.

1.1 Information You Provide Directly

Account registration data: Name, email address, username, password, date of birth, gender, dominant hand, home golf course, profile photo, and any other information you choose to provide during registration or account setup.
Golf profile data: Handicap Index, Handicap ID, club memberships, equipment inventory (clubs, balls, launch monitor), golfer preferences, skill level, and any other golf-related profile information you provide.
Payment and billing data: Payment instrument information necessary to process transactions. All payment data is processed and stored by our payment processor, Stripe, Inc. AVA Golf does not store full payment card numbers. See Stripe’s Privacy Policy.
Communications: Messages, emails, support tickets, feedback, survey responses, and any other information you provide when contacting us or participating in any AVA Golf communication channel.
User-generated content: Notes, coaching session records, goals, and any other content you voluntarily upload, submit, or create within the Services.

1.2 Golf Performance Data

The core data asset of AVA Golf is golf performance data. Depending on which integrations you authorize, this may include:

Scores, scorecards, and round history
Shot-by-shot data including club selection, shot type, result, and distance
GPS coordinates of shots taken during a round
Strokes gained statistics and other derived performance metrics
Handicap Index, Low Handicap Index, and 20-score history (via USGA/GHIN)
Launch monitor data (ball speed, club speed, spin rate, launch angle, carry distance)
Course information including course rating, slope rating, and course layout data
Practice session data and simulator round data
Any other golf performance, statistical, or activity data made available through authorized integrations or submitted directly by you

1.3 Device and Technical Data

When you access the Services through any device, browser, or application, we automatically collect:

IP address
Device type, model, and operating system
Browser type and version
Mobile device identifiers (IDFA, IDFV, Android Advertising ID)
App version and session data
Referring URLs and navigation paths
Date and time stamps of activity
Crash reports and diagnostic data
Network type and carrier (mobile)
Any other technical information automatically transmitted by your device or browser when accessing the Services

1.4 Location Data

When you connect a data provider for golf rounds, we may process:

Coarse location data (city/region level) for localized features such as course finding
Precise GPS location data from played rounds, where authorized by you and required for shot-tracking functionality

Location data is not collected by us and only processed when you have connected a partner that supplies GPS data.

If you interact with AVA Golf on social media platforms, or if you choose to authenticate or connect a social media account to the Services in the future, we may receive:

Public profile information (name, profile photo, username)
Email address associated with the account
Such other data as the social media provider makes available based on your settings

Social login functionality is currently planned but not yet available. When available, this policy will govern our handling of data received through such connections.

1.6 Data Received from Other Users or Third Parties

Golf instructors and coaches: If your coach uses AVA Golf, they may input session notes or observations linked to your profile, with your authorization.
Other platform users: Other golfers may share round data or challenge data that references your profile.
Marketing and analytics partners: We may receive anonymized or pseudonymized data from third-party analytics providers that we use to improve the Services.

1.7 Video Engagement Data

AVA Golf tracks how you interact with video content within the Services, including:

Videos viewed and watch history
Playback duration and completion rates
Replay and rewind activity
Video interactions (pauses, skips, speed adjustments)
Timestamps of specific in-video interactions
Playback quality and format selections
Full screen and inline viewing behavior
Video sharing, saving, and bookmarking activity
Chapter and segment navigation
Buffering events and stream performance data
Device and connection quality during playback
Any other video watching behavioral data generated by your interaction with video content within the Services

This data is used to power AVA Golf’s video recommendation engine, which uses machine learning to match specific instructional content to your identified performance gaps and learning patterns (see Section 5).

2. How We Collect Information

We collect information through the following mechanisms:

Direct collection: When you register, fill out forms, post scores, connect integrations, or otherwise interact with the Services.

Automatic collection: Through server logs, cookies, pixel tags, SDKs, and similar technologies embedded in our applications and websites.

Third-party API integrations: When you connect a third-party account or data partner (e.g., Garmin, Arccos, USGA/GHIN), that partner transmits data to AVA Golf on your behalf. See Section 3 for full details.

Cookies and tracking technologies: We use cookies, web beacons, and similar technologies to:

Maintain session state and authentication
Remember user preferences
Understand how users navigate the Services
Measure and analyze usage patterns

You may manage cookie preferences through your browser settings. Note that disabling cookies may affect the functionality of the Services.

2A. Third-Party Marketing, Analytics, and Tracking Tools

AVA Golf uses a number of third-party tools on its websites and applications that independently collect data about your interactions with the Services. This section discloses those tools, what they collect, and how you can manage your preferences.

2A.1 Email Marketing — Brevo (formerly Sendinblue)

AVA Golf uses Brevo to send both transactional emails (account confirmations, receipts, security alerts) and marketing communications (newsletters, product updates, promotional offers). When you receive an email from AVA Golf, Brevo may collect:

Whether you opened the email and when
Which links you clicked within the email
Your email client, device type, and approximate location at time of open
Unsubscribe and preference events

Brevo acts as a data processor on AVA Golf’s behalf. You may opt out of marketing emails at any time using the unsubscribe link in any email or by contacting privacy@ava.golf. You cannot opt out of transactional emails.

Brevo’s Privacy Policy: https://www.brevo.com/legal/privacypolicy/

2A.2 CRM and Marketing Automation — HubSpot

AVA Golf uses HubSpot for customer relationship management and, where integrated, marketing automation. HubSpot may collect data about your interactions with AVA Golf’s websites and communications, including:

Pages visited and time spent on each page
Form submissions and contact information you provide
Email engagement data (opens, clicks)
Device and browser information
IP address and approximate location

HubSpot may place cookies on your browser to track your activity across sessions. If you have provided AVA Golf with your contact information, HubSpot may associate your browsing activity with your contact record.

HubSpot’s Privacy Policy: https://legal.hubspot.com/privacy-policy

2A.3 Web and App Analytics — Google Analytics 4 (GA4)

AVA Golf uses Google Analytics 4 on both its websites (ava.golf) and mobile applications to understand how users interact with the Services. GA4 may collect:

Pages and screens viewed
Session duration and navigation paths
Events and interactions (button clicks, feature usage, video plays)
Device type, operating system, and browser
IP address (anonymized by default in GA4)
Approximate geographic location (derived from IP)
Referral source and acquisition channel

GA4 data is transmitted to and stored by Google LLC. Google may use this data in accordance with its own privacy policies. AVA Golf uses GA4 in a manner designed to minimize collection of personally identifiable information, including enabling IP anonymization.

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on or by managing your Google account’s ad personalization settings.

Google’s Privacy Policy: https://policies.google.com/privacy

2A.4 Additional Third-Party Tools

AVA Golf may use, or in the future may deploy, additional third-party tools for analytics, error monitoring, session recording, advertising, and user engagement. These may include tools such as:

Session recording and heatmap tools (e.g., FullStory) — which may record mouse movements, clicks, scrolling behavior, and on-screen interactions
Error and performance monitoring (e.g., Sentry, Datadog) — which collect crash reports, error logs, and performance diagnostics
Product analytics platforms (e.g., Mixpanel, Amplitude, Segment, Rudderstack) — which track feature usage, user flows, and retention metrics
First-party marketing tools (e.g., LinkedIn Insight Tag, Google Ads) — which may be used solely to market AVA Golf’s own products and services to prospective users on third-party platforms, using hashed or anonymized identifiers. These tools are not used to enable third-party sponsors or advertisers to target AVA Golf users.
Live chat and support tools (e.g., Intercom, Drift) — which collect messages, device information, and browsing context during support interactions

Where any of these tools are deployed, they will be disclosed in an updated version of this Privacy Policy. Each tool’s data collection is governed by its respective privacy policy. To the extent these tools use cookies or similar tracking technologies, you may manage your preferences through our cookie consent mechanism or your browser settings.

By continuing to use the Services, you acknowledge that AVA Golf may use third-party tools of the types described above, and that those tools may independently collect data about your interactions with the Services subject to their own privacy policies.

2A.5 Session Recording — Hotjar

AVA Golf uses Hotjar within the AVA Golf web application to understand how users interact with the product interface. Hotjar is deployed within the Services and is not loaded on AVA Golf’s marketing website. Hotjar may collect:

Mouse movements, clicks, taps, and scrolling behavior
On-screen interactions and navigation paths within the web application
Device type, operating system, and browser
IP address and approximate geographic location (derived from IP)

Hotjar acts as a data processor on AVA Golf’s behalf. Hotjar data is transmitted to and stored by Hotjar Ltd. and may be used in accordance with Hotjar’s own privacy policy and AVA Golf’s data processing agreement with Hotjar.

You may opt out of Hotjar tracking using Hotjar’s opt-out mechanism: https://www.hotjar.com/legal/compliance/opt-out.

Hotjar’s Privacy Policy: https://www.hotjar.com/legal/policies/privacy/

3. Third-Party Data Partner Integrations

AVA Golf’s core product depends on integrating data from multiple authorized partners. This section describes the data flows for each current partner. As AVA Golf adds additional data partners over time, this section will be updated to reflect those integrations. Each partner is an independent data controller with respect to data collected through their own platform — meaning each partner has its own privacy policy that governs data collected on their end. AVA Golf’s rights and obligations with respect to each partner’s data are governed by binding data sharing agreements with each partner.

3.1 Garmin International, Inc.

Effective Date of Integration: December 17, 2025

AVA Golf has entered into a Collaboration Agreement with Garmin International, Inc. (“Garmin”) to integrate Garmin’s Golf API. Under this integration, if you are a Garmin user and you authorize the connection, AVA Golf may receive the following data types, depending on the tier of access you authorize:

Scorecard data: Round scores, hole-by-hole results, and scorecard history
Shot Data (GPS): GPS-tracked shot locations, club used per shot, and on-course movement data collected during your round
Launch Monitor data: Ball speed, clubhead speed, spin rate, launch angle, and carry distance from Garmin launch monitor devices

Both AVA Golf and Garmin are independent controllers of data shared under this integration. Upon termination of the Garmin integration — whether by you disconnecting the integration, by AVA Golf, or by Garmin — AVA Golf is contractually required to return or destroy all Garmin Confidential Information in its possession, including your data transmitted under the integration, and to certify such destruction upon request.

Garmin’s Privacy Policy: https://www.garmin.com/en-US/privacy/app-privacy/

3.2 Arccos Golf LLC

AVA Golf has entered into an API License and Data Access Agreement with Arccos Golf LLC (“Arccos”). If you are an Arccos Caddie subscriber and you provide explicit written consent through the AVA Golf product for Arccos to share your data with AVA Golf, we may receive:

Personal details: Name, age, gender, dominant hand, email address, phone number, home golf course
Location and movement: GPS data from on-course activity, course movement during play, round duration
Performance data: Handicap, scores, shot-by-shot data, and statistical analysis derived from round data
Equipment: Data relating to your clubs, balls, and other equipment you use during play

Important restrictions regarding Arccos data:

AVA Golf receives Arccos data in a read-only capacity and cannot modify data on Arccos’s platform.
Arccos data is licensed to AVA Golf solely for the purpose of delivering services to you as the end user. AVA Golf may not sell, sublicense, or redistribute raw Arccos data to any third party.
AVA Golf accesses read-only performance statistics through the Arccos integration. Raw Arccos data is not stored within AVA Golf’s core systems. Anonymized, aggregated insights derived from user-authorized Arccos data connections are the property of AVA Golf.
If you disconnect your Arccos integration, or upon termination of AVA Golf’s agreement with Arccos for any reason, AVA Golf is contractually required to delete all Arccos-sourced data in its possession from all systems and certify that deletion. Anonymized or aggregated insights already incorporated into AVA Golf’s platform prior to termination are not subject to this deletion obligation.
You may withdraw your consent to Arccos data sharing at any time by disconnecting the Arccos integration within the AVA Golf product. AVA Golf will promptly transmit your withdrawal of consent to Arccos.

Both AVA Golf and Arccos are independent controllers of Shared Personal Data under applicable privacy laws including the GDPR.

Arccos’s Privacy Policy: https://www.arccosgolf.com/pages/privacy-policy

3.3 United States Golf Association (USGA) — World Handicap System (WHS)

Effective Date of Integration: December 15, 2025

AVA Golf participates in the USGA’s Golfer Product Access (GPA) Program, which enables AVA Golf to access the USGA’s Data Services Platform and World Handicap System™. If you are a USGA-registered golfer with an active Handicap Index and you provide affirmative consent, AVA Golf may access and display:

Your Handicap ID and current Handicap Index®
Your Low Handicap Index™ and Handicap Index history (last 12 months)
Your current 20-score history, including dates of play and course names
Your scoring record for the prior 24 months
Course Rating and Slope Rating information for courses you have played

Critical disclosure regarding USGA data:

By connecting your USGA/GHIN account and consenting to data sharing, you acknowledge and agree to the following:

Scoring data posted through AVA Golf becomes USGA property. Any scores posted through the AVA Golf product into the USGA Data Services Platform are incorporated into the USGA Master Data Set and become the sole property of the USGA.
The USGA shares your data broadly. The USGA reserves the right to share your handicap and scoring data with regional golf associations, member clubs, other golfers (limited), and USGA-approved technology providers, as set forth in the USGA Privacy Policy. AVA Golf has no control over how the USGA shares data once it has been incorporated into the Master Data Set.
USGA access is US-only. The USGA GPA Program is available only to users within the United States and its territories.
AVA Golf may not compute or issue a Handicap Index. Only the USGA may issue a Handicap Index. AVA Golf displays USGA-computed handicap data but does not calculate, issue, or distribute its own Handicap Index.

You may opt out of USGA data sharing at any time by disconnecting the USGA integration within the AVA Golf product. Upon your opt-out, AVA Golf will immediately notify the USGA in writing.

USGA’s Privacy Policy: https://www.usga.org/content/usga/home-page/usga-privacy-policy.html

3.4 Future Data Partners

AVA Golf intends to add additional data partners over time across the golf ecosystem. For each new partner integration, we will update this Privacy Policy and provide you with notice of any material changes to data collection practices. We will obtain your explicit consent before activating any new integration that shares your personal data with a new third-party partner.

4. How We Use Your Information

AVA Golf uses the information we collect for the following purposes:

To deliver the Services:

Creating and managing your account
Displaying your golf performance data, statistics, and history
Delivering Personalized Progression coaching and personalized insights through rules-based analysis of your performance data
Recommending specific instructional video content matched to your identified performance gaps
Enabling score posting and handicap integration
Syncing data from connected third-party integrations

To improve and develop the Services:

Analyzing usage patterns to identify product improvements
Conducting research and development on new features
Training and improving AVA Golf’s proprietary AI and machine learning models (see Section 5)
Debugging and resolving technical issues

To communicate with you:

Sending transactional messages (account confirmations, receipts, security alerts)
Sending product updates, newsletters, and marketing communications where you have opted in or where we have a legitimate interest to do so
Responding to support requests and inquiries

For security and fraud prevention:

Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity
Protecting the rights and property of AVA Golf, its partners, and its users
Enforcing our Terms of Service

For legal and compliance purposes:

Complying with applicable laws, regulations, legal process, and governmental requests
Enforcing our contractual obligations with data partners including Garmin, Arccos, and the USGA
Establishing, exercising, or defending legal claims

For business purposes:

Analyzing aggregate, de-identified data for internal analytics and business intelligence
Sharing or licensing aggregated, de-identified data with third parties (see Section 7)
Evaluating and completing business transactions (mergers, acquisitions, financing) as described in Section 6

5. Technology, Machine Learning, and Video Recommendations

This section describes how AVA Golf uses data processing technology — including rules-based analysis engines and machine learning — within the Services, and what that means for your data.

5.1 How AVA Golf Delivers Personalized Progression Coaching

AVA Golf’s coaching and insight engine is built on a deeply detailed, rules-based analysis system. Your golf performance data — including scores, shot patterns, strokes gained, and round history — is processed through structured analytical frameworks to identify specific strengths, weaknesses, and improvement opportunities in your game. This analysis does not rely on generative AI to produce coaching output; it reflects structured performance logic applied to your data.

5.2 Video Recommendation Engine

AVA Golf maintains a library of instructional video content. Each video in the library is weighted and tagged using machine learning models trained on content characteristics and user engagement patterns. When the rules-based analysis identifies a specific performance gap in your game, AVA Golf’s proprietary video recommendation model matches that gap to the most relevant instructional content in the library.

This matching process uses a proprietary model that AVA Golf develops, trains, and owns. Your video engagement data (see Section 1.7) and performance data are used as inputs to improve the accuracy of these recommendations over time.

5.3 Third-Party AI Service Providers

To support certain platform functions, AVA Golf may transmit data to one or more third-party AI and machine learning infrastructure providers. These providers may include, without limitation:

Google LLC (Gemini models and related AI infrastructure)
OpenAI, LLC
Anthropic, PBC
Amazon Web Services (AWS AI/ML services)
Other AI infrastructure providers we may engage over time

When your data is transmitted to these providers, it is processed solely to support the function for which it was submitted. Your data may be temporarily retained by these providers in accordance with their respective privacy policies and AVA Golf’s data processing agreements with them. AVA Golf takes commercially reasonable steps to ensure that data shared with AI providers is subject to appropriate data protection obligations and is not used for those providers’ own model training without restriction.

5.4 Proprietary Model Training

AVA Golf uses your golf performance data and video engagement data to train, validate, and improve AVA Golf’s own proprietary machine learning models, including the video recommendation engine described in Section 5.2. This is a core part of how AVA Golf builds a more accurate and personalized product over time.

Where we use your data for model training, we apply the following practices:

Training datasets are de-identified or pseudonymized to the extent technically feasible
Raw data received from Arccos under its API license is not used in model training
You may request that your data be excluded from future training datasets by contacting privacy@ava.golf. Note that exclusion from training does not affect data already incorporated into previously trained model weights in de-identified form.

AVA Golf does not sell your personal information in the traditional sense of exchanging identifiable data for money. However, we do share your information in the following circumstances:

6.1 Data Partners and Integrations

As described in Section 3, when you authorize an integration with a data partner such as Garmin, Arccos, or the USGA, data flows primarily from that partner into AVA Golf — AVA Golf pulls your authorized performance data from each partner’s platform for display and analysis within the Services. AVA Golf transmits data back to data partners only for limited purposes, specifically: authentication and identity verification, transmission of your consent grants or withdrawals, and score posting to the USGA Data Services Platform where you have authorized it. AVA Golf does not transmit your performance data or personal information to data partners beyond what is necessary for these purposes. Each partner is an independent data controller with respect to data on their own platform.

6.2 Service Providers

We share data with vendors and third-party service providers that perform services on our behalf, including:

Cloud infrastructure and hosting providers (e.g., Amazon Web Services)
Payment processors (Stripe, Inc.)
Analytics and monitoring services
Email delivery providers
Customer support tools
AI/ML service providers (see Section 5.2)

These providers are authorized to use your data only to perform services for AVA Golf and are bound by contractual data protection obligations.

6.3 Coaches and Golf Professionals

If you authorize a golf instructor or coach to access your AVA Golf profile, we will share your performance data and round history with that individual as directed by you. You control who has access to your data through your account settings.

6.4 Aggregated and De-Identified Data

We share aggregated, de-identified, or anonymized data with third parties as described in Section 7. Such data does not identify you individually.

6.5 ParOne, Inc. and Affiliated Entities

AVA Golf is a wholly-owned subsidiary of ParOne, Inc. We may share your information with ParOne and its affiliates and subsidiaries — including ParOne Holdings LLC, ParOne.dev LLC, ParOne App LLC, and GolfCentral TV, Inc. — for purposes consistent with this Privacy Policy, including shared infrastructure, internal analytics, business operations, and the development of related products and services. All ParOne entities that receive your data are subject to data handling obligations consistent with this Privacy Policy.

6.6 Business Transfers

If AVA Golf or ParOne is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your information may be transferred to the acquiring or successor entity. We will provide notice prior to your personal information being transferred and becoming subject to a different privacy policy.

6.7 Legal Compliance and Protection

We may disclose your information when we believe in good faith that disclosure is necessary or appropriate to:

Comply with applicable law, legal process, or governmental requests (including from law enforcement)
Enforce our Terms of Service or other agreements
Protect the rights, property, or safety of AVA Golf, our users, our data partners, or the public
Detect, prevent, or address fraud, security, or technical issues

6.8 Third-Party Partners and Commercial Arrangements

AVA Golf may share your information with third parties in connection with commercial partnerships, data licensing arrangements, and third-party service engagements as described in Section 7. By continuing to use the Services, you acknowledge and consent to data sharing practices consistent with this Privacy Policy, including sharing with third-party partners for the purposes described herein. Notwithstanding the foregoing, where applicable law requires explicit, freely given consent as a condition of data sharing — including under the GDPR and UK GDPR — AVA Golf will obtain that consent separately and will not rely on continued use of the Services as a substitute for such consent. If you do not consent to these practices, you may discontinue use of the Services and request deletion of your account as described in Section 12.

7. Data Monetization and Aggregated Data

AVA Golf may share, license, or sell aggregated, anonymized, or de-identified data derived from user activity with third parties. Such data does not identify you individually.

Third-party recipients of aggregated data may include:

Golf equipment manufacturers and brands
Golf courses and facilities
Golf industry research organizations
Media companies and publishers
Marketing and analytics firms
Investors and potential business partners (under appropriate confidentiality obligations)

Examples of aggregated data we may share or license:

Average strokes gained by club type across a user population
Most common shot patterns on specific holes or courses
Aggregate handicap trends over time across geographic regions
Equipment performance benchmarks at the population level

AVA Golf’s position is that aggregated, de-identified data that cannot be used to identify individual users does not constitute a “sale” of personal information under applicable privacy laws. However, to the extent that any applicable law treats such sharing as a sale or sharing for cross-context behavioral advertising, we will honor your rights under those laws as described in Section 13.

If you have concerns about how your data may contribute to aggregated datasets, you may contact us at privacy@ava.golf to request that your data be excluded from aggregated commercial datasets to the extent technically feasible.

8. Advertising and Sponsorships

AVA Golf does not sell access to its users’ personal information to advertisers, nor does AVA Golf allow third-party sponsors or advertisers to directly target users within the Services. Any sponsored content, brand integrations, or commercial placements within the Services are managed exclusively by AVA Golf. Sponsors and partners pay AVA Golf to reach our audience — they do not receive user data, targeting capabilities, or direct access to AVA Golf’s user base as part of any commercial arrangement.

AVA Golf may use aggregated, de-identified audience data internally to inform sponsorship pricing, placement decisions, and commercial partnerships. This data does not identify individual users and is not shared with sponsors in identifiable form.

We may engage in first-party marketing of our own products and services to you through email (where you have opted in or where permitted by law) and through our own owned and operated channels.

We reserve the right to introduce additional monetization features in the future. Any material changes to how advertising or sponsorships affect your personal data will be disclosed through an updated Privacy Policy with advance notice.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by law, contract, or legitimate business need, whichever is longer.

General retention principles:

Active account data: Retained for the life of your account plus a reasonable period following account closure to address any post-closure inquiries, disputes, or legal obligations.
Transaction records: Retained for a minimum of seven (7) years for tax and accounting purposes.
Golf performance data: Retained for the life of your account. Upon account deletion, personal identifiers are removed; de-identified performance data may be retained in aggregated form.
Partner integration data: Retention is subject to the requirements of the applicable data partner agreement. For Arccos data specifically, upon termination of the Arccos integration we are contractually required to delete all Arccos-sourced data from our systems and certify that deletion.
Legal hold: Data subject to an active legal hold, regulatory investigation, or litigation will be retained as required regardless of the above periods.
Proprietary model training: De-identified data incorporated into trained machine learning models may persist in the model itself; deletion requests cannot retroactively modify already-trained model weights.

You may request deletion of your personal information at any time as described in Section 12.

10. Data Security

AVA Golf implements and maintains administrative, physical, and technical safeguards designed to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction. These measures include:

Encryption of data in transit using TLS/SSL
Encryption of sensitive data at rest
Access controls and authentication requirements for internal systems
Regular security assessments and vulnerability management
Vendor security due diligence for service providers handling personal data
Security incident response procedures

AVA Golf complies with the security requirements of each data partner agreement, including those of Garmin, Arccos, and the USGA. In the event of a security incident affecting data received from a partner, we are contractually required to notify the relevant partner without undue delay and to cooperate in investigation and remediation.

No security measure is 100% effective. No electronic transmission or storage system can be guaranteed to be fully secure. While we work hard to protect your information, we cannot guarantee that unauthorized parties will never circumvent our security measures. You are responsible for maintaining the security of your account credentials.

Security incident notification: If we become aware of a security incident that affects your personal information, we will notify you and relevant authorities as required by applicable law.

11. Children’s Privacy (COPPA)

The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. If we become aware that we have inadvertently collected personal information from a child under 13 without verifiable parental consent, we will take immediate steps to delete that information from our systems.

If you believe that we may have collected information from a child under 13, please contact us immediately at privacy@ava.golf.

Parents and guardians who believe their child has provided personal information to AVA Golf may contact us to request review and deletion of that information.

Note: Golf is a family sport and we recognize that junior golfers may use the Services under parental supervision. We encourage parents to supervise their children’s use of the Services and to contact us with any questions about our data practices.

12. Your Privacy Rights

Regardless of where you are located, you have the following rights with respect to your personal information:

Right to Access: You may request a copy of the personal information we hold about you.

Right to Correction: You may request that we correct inaccurate or incomplete personal information.

Right to Deletion: You may request that we delete your personal information. Note that certain information may be retained as required by law, contract (including our data partner agreements), or legitimate business need.

Right to Portability: You may request that we provide your personal information in a structured, commonly used, machine-readable format.

Right to Opt Out of Marketing: You may opt out of receiving marketing communications from us at any time by using the unsubscribe link in any email or by contacting us at privacy@ava.golf. You cannot opt out of transactional or administrative communications related to your account.

Right to Disconnect Integrations: You may disconnect any third-party data integration (Garmin, Arccos, USGA, etc.) at any time through your account settings. Disconnection will terminate AVA Golf’s ongoing access to new data from that integration and trigger any applicable data deletion obligations described in Section 3.

Right to Withdraw Consent: Where we process your data based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, contact us at:

Email: privacy@ava.golf
Mail: AVA Golf, Inc., 169 Madison Ave #2003, New York, NY 10016, Attn: Privacy

We will respond to your request within the timeframes required by applicable law, and in any event within 45 days. We may need to verify your identity before processing your request. Notwithstanding the foregoing, residents of California and other states with applicable privacy laws that prescribe shorter response deadlines will receive responses within the timeframes required by their applicable state law.

13. United States Residents — State-Specific Rights

13.1 California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following additional rights:

Right to Know: You have the right to know the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting it, and the categories of third parties with whom we have shared it.

Right to Delete: Subject to certain exceptions, you have the right to request deletion of personal information we have collected from you.

Right to Correct: You have the right to request correction of inaccurate personal information.

Right to Opt Out of Sale or Sharing: AVA Golf does not sell your personal information, and does not share your personal information with third parties for cross-context behavioral advertising purposes. Accordingly, the CCPA/CPRA right to opt out of sale or sharing is not applicable to AVA Golf’s current data practices. If AVA Golf’s practices change in a way that triggers this right, we will update this Privacy Policy, provide advance notice, and implement a compliant opt-out mechanism before doing so.

Right to Limit Use of Sensitive Personal Information: To the extent we process sensitive personal information (as defined under CPRA), you have the right to limit our use of such information to purposes permitted under the CPRA.

Right Against Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Categories of personal information collected in the last 12 months: Identifiers (name, email, IP address), commercial information (payment records), geolocation data, Internet or other network activity (usage data, video engagement data), inferences drawn from personal information (Personalized Progression coaching recommendations, video recommendations), and golf performance data.

To submit a California privacy request, contact privacy@ava.golf or write to us at the address above. You may also designate an authorized agent to submit a request on your behalf.

Do Not Sell My Personal Information: AVA Golf does not sell personal information. AVA Golf does not share personal information with third parties for cross-context behavioral advertising. No “Do Not Sell or Share” link is required because these practices are not part of AVA Golf’s business model. If this changes, we will provide advance notice and implement all required opt-out mechanisms before doing so.

13.2 Other U.S. State Privacy Laws

Residents of Colorado, Connecticut, Virginia, Texas, and other states with comprehensive privacy laws may have similar rights to those described in Section 13.1, including rights to access, correct, delete, and port personal data, and to opt out of certain processing activities. To exercise these rights, contact privacy@ava.golf.

We will respond to verified consumer requests in accordance with the timelines and requirements of applicable state law.

14. European Union, United Kingdom, and Canadian Users

AVA Golf’s data partner agreements with both Garmin and Arccos explicitly reference and require compliance with the General Data Protection Regulation (GDPR) (EU 2016/679) and its UK equivalent (UK GDPR). AVA Golf’s Garmin agreement specifically cites the UK GDPR, the Data Protection Act 2018, EU GDPR, and the CCPA. To the extent AVA Golf processes personal data of individuals located in the European Union or the United Kingdom, we do so in compliance with applicable Data Protection Legislation.

Legal bases for processing (GDPR/UK GDPR):

Consent: Where you have given explicit consent to a specific processing activity (e.g., activating a third-party data integration, receiving marketing communications, model training).
Contract: Where processing is necessary to perform our contract with you (e.g., delivering the Services, processing payments).
Legitimate Interests: Where we have a legitimate interest in processing your data that is not overridden by your rights (e.g., improving our recommendation models, fraud prevention, internal analytics).
Legal Obligation: Where processing is necessary to comply with applicable law.

Data transfers: Where we transfer personal data outside the EEA or UK (e.g., to US-based service providers or AI providers), we implement appropriate safeguards including Standard Contractual Clauses (SCCs) or other transfer mechanisms recognized under applicable law.

Data subjects’ rights under GDPR/UK GDPR: In addition to the rights described in Section 12, EU and UK data subjects have the right to lodge a complaint with a supervisory authority. For UK residents, this is the Information Commissioner’s Office (ICO). For EU residents, the relevant supervisory authority in your member state. We encourage you to contact us first at privacy@ava.golf so we may work to resolve your concern directly.

14.2 Canadian Users (PIPEDA / Law 25)

For users located in Canada, we process personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. We rely on your consent (express or implied) as the basis for collecting, using, and disclosing personal information, and you may withdraw that consent at any time subject to legal and contractual restrictions. Quebec residents have additional rights under Law 25 (Law modernizing privacy legislation), including rights of access, rectification, and data portability.

15. Third-Party Links and Services

The Services may contain links to third-party websites, applications, or services that are not operated by AVA Golf. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access. AVA Golf is not responsible for the privacy practices of third parties.

16. Do Not Track Signals

Some browsers offer a “Do Not Track” (DNT) signal that you can enable to signal your preference that websites and applications not track your activity. AVA Golf does not currently respond to DNT signals because there is no uniform industry standard for how DNT signals should be interpreted and honored. We will continue to monitor developments in this area and update our practices accordingly.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Services. When we make material changes, we will:

Update the “Last Updated” date at the top of this policy
Notify you via email (to the address associated with your account) or through a prominent notice within the Services
Where required by law, obtain your renewed consent

Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you should discontinue your use of the Services and may request deletion of your account.

We maintain a version history of this Privacy Policy and will provide prior versions upon request to privacy@ava.golf.

18. Referral Program

When you visit AVA Golf using a referral link, we store a short referral code in your browser’s local storage (ava_ref). This code is an opaque 8-character identifier — it contains no personal data and does not identify you. It is used solely to credit the person who invited you when you complete the waitlist form, at which point it is removed from local storage.

19. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or AVA Golf’s data practices, please contact us:

AVA Golf, Inc.
Attn: Privacy
169 Madison Ave #2003
New York, NY 10016

Email: privacy@ava.golf

For data subject rights requests, security incidents, or urgent privacy matters, please include “PRIVACY REQUEST” or “SECURITY INCIDENT” in the subject line of your email.

For users located in the EU or UK who are not satisfied with our response, you have the right to lodge a complaint with your applicable data protection supervisory authority.

This Privacy Policy is effective as of the Last Updated date set forth above and supersedes all prior versions.

AVA Golf, Inc. is a Delaware corporation. This policy is governed by the laws of the State of New York, consistent with AVA Golf’s data partner agreements.