ParPro Privacy Policy

Version: 1.3.0 Effective Date: August 4, 2026 Last Updated: August 4, 2026

Material Changes in v1.3.0 (per docs/compliance/material-change-policy.md “balanced philosophy” — re-consent required because we are adding a new third-party category of disclosure):

§7.3 updated to describe Verifiable Parental Consent (VPC) via Kids Web Services (KWS), an Epic Games subsidiary, with three FTC-approved methods (Personal ID Register / Payment-Card Verification / Facial Age Estimation).
§7.4 Direct Notice to parents now includes KWS verification flow disclosure + AgeGraph cross-app reuse.
§7.10 (NEW) discloses the KWS Parent Verification third-party processor / independent-controller relationship and the AgeGraph cross-platform parent-verification network.
§3.2 (Service Providers) adds KWS to the third-party-vendor list.
Parents and guardians of existing consented minor users will receive a request to complete KWS Parent Verification after the KWS Parent Verification flow becomes available in production, upgrading the account’s consent record to a KWS-verified method. Existing consent remains valid while that upgrade is pending.

Pre-publication corrections (v1.3.0, prior to production release): contact addresses normalized to the canonical parpro.golf domain (legacy hyphenated domain removed), disclosure of jurisdiction-aware digital ages of consent and UK Children’s Code location consent added (§7.1, §7.9), the re-consent commitment above reworded to remove a fixed completion window, and the verification-first (blocked-until-approved) posture for newly created under-13 accounts added (§7.1, §7.3).

This Privacy Policy (“Policy”) explains how ParPro, LLC (“ParPro,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information and data when you access or use our mobile application, website, instructor portal, and related services (collectively, the “Service” or “Services”).

By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, you must not access or use the Service.

1. Information We Collect

ParPro collects several categories of information from and about users of our Service, including information by which you may be personally identified and information about your internet connection, equipment, and usage patterns.

1.1 Information You Provide Directly to Us

We collect information that you voluntarily provide to us when you register for an account, use the Service, communicate with us, or otherwise interact with the Service. This information includes, but is not limited to:

Account Registration Information:

Full name
Email address
Password (stored in encrypted form)
Date of birth
Phone number (optional)
Gender (optional)
Profile photograph (optional)
Golf handicap index (optional)
Home course or club affiliation (optional)

Instructor-Specific Information (applicable to users with instructor accounts):

Professional biography and credentials
Golf instruction certifications and qualifications (e.g., PGA, LPGA, USGTF)
Professional experience and background
Service offerings and specializations
Pricing and rate information
Calendar and availability settings
Stripe Connect account information for payment processing
Business taxpayer identification number (EIN or SSN)
Banking information for instructor payouts

Golf Performance and Activity Data:

Round scores and scorecards
Shot-by-shot tracking data
Club selection and distance data
Training session logs and practice activity
Performance goals and objectives
Personal notes, comments, and annotations
Statistical performance metrics
Uploaded media files (images and videos of swings, courses, or training)

Payment and Transaction Information:

Credit card or debit card information (processed and stored by third-party payment processors; ParPro does not directly store complete payment card numbers)
Billing address
Transaction history
Purchase history for Credits, subscriptions, and lesson bookings
Payment disputes and refund requests

Communications and Support:

Customer support inquiries and tickets
Email correspondence with ParPro or instructors
In-app messages and chat conversations, including direct messages, team messages, club messages, announcements, and group session chat
Reviews and ratings of instructors, courses, or training content
Posts, comments, and content shared in groups or social features
Survey responses and feedback

Club Portal Information (applicable to club administrators and members):

Club organization data (name, address, branding, course affiliations)
Club member roles and permissions
Club license/seat management data
Club billing and subscription data
Club event, tournament, and league data
Club course conditions updates
GHIN integration data (GHIN numbers, handicap sync records, posted scores)

Team Portal Information (applicable to coaches, administrators, and players):

Team organization data (name, sport level, school/organization affiliation)
Team member roles (head coach, assistant coach, admin, player, parent)
Player performance data shared with coaching staff
Recruiting pipeline data (prospect names, schools, contact info, status)
Team feed posts and interactions
Player profile cards and recruiting profiles
Parent/guardian contact information and consent records

1.2 Information Collected Automatically

When you access or use the Service, we and our third-party service providers automatically collect certain information about your device, usage patterns, and interactions with the Service:

Device and Technical Information:

Device type, model, and manufacturer
Operating system type and version
Mobile application version
Unique device identifiers (e.g., IDFA for iOS, Advertising ID for Android)
IP address
Browser type and version (for web-based access)
Screen resolution and device settings
Mobile network information and carrier

Usage and Analytics Data:

Features and pages accessed within the Service
Session duration and frequency of use
Navigation paths and click patterns
Search queries entered
Content viewed or interacted with
Time stamps of activities
Error logs and crash reports
Performance and diagnostic data

Location Information:

Precise GPS coordinates (with your permission) when creating rounds, tracking shots, or using location-based features
Course location data
Approximate geographic location derived from IP address
Location history for rounds played

Cookies and Tracking Technologies:

Session cookies for authentication and functionality
Persistent cookies for preferences and settings
Analytics cookies to understand usage patterns
Advertising cookies (if applicable)
Mobile analytics SDKs
Log files and server logs

1.3 Information from Third-Party Sources

We may receive information about you from third-party sources, including:

Social Media Platforms:

Profile information from connected social media accounts (e.g., Facebook, Google) if you choose to link your accounts or use social login features
Friends lists or contacts (with your permission)

Golf Course and Venue Data:

Course information, layouts, and details from third-party golf course databases (e.g., iGolf, Golf.API)
Tee time bookings or course check-ins (if integrated)

GHIN (Golf Handicap Information Network):

GHIN number and handicap index data synced via club integration
Scores posted to GHIN through the Platform
Handicap revision history received from GHIN

Calendar Integrations:

If you connect a calendar service (Google Calendar, Microsoft Outlook, etc.), we access event names, dates, times, and participant information for events related to the Service. Calendar data is used solely for scheduling and synchronization purposes.

Payment Platforms and App Stores:

Subscription status and transaction information from Apple App Store and Google Play Store
Payment processing information from Stripe
In-app purchase receipts and validation data

Analytics and Marketing Partners:

Aggregated demographic and interest data
Advertising campaign performance data
Attribution and conversion tracking information

2. How We Use Your Information

ParPro uses the information we collect for various business and operational purposes, including but not limited to the following:

2.1 To Provide, Operate, and Maintain the Service

Create and manage user accounts
Authenticate users and prevent unauthorized access
Process transactions, bookings, and payments
Deliver requested services, features, and functionality
Enable communication between users and instructors
Store and display your golf performance data and statistics
Generate performance analytics and insights
Facilitate group participation and social features
Provide customer support and respond to inquiries
Send transactional emails and in-app notifications related to your use of the Service

2.2 To Personalize and Improve User Experience

Customize content, recommendations, and features based on your preferences and usage patterns
Remember your settings, preferences, and login credentials
Provide relevant instructor recommendations
Suggest training content and drills based on your skill level and goals
Tailor marketing communications to your interests (with your consent)

2.3 To Analyze, Monitor, and Improve the Service

Conduct data analytics to understand user behavior and preferences
Monitor Service performance, reliability, and uptime
Identify and troubleshoot technical issues, bugs, and errors
Test new features and functionality
Conduct research and development to improve existing features
Optimize user interface and user experience design
Measure the effectiveness of marketing campaigns

2.4 To Ensure Security and Prevent Fraud

Detect, investigate, and prevent fraudulent transactions or activities
Monitor for security threats, unauthorized access, and policy violations
Enforce our Terms of Service and other policies
Verify user identity for security purposes
Protect the rights, property, and safety of ParPro, our users, and the public
Comply with legal obligations and respond to legal process

2.5 To Communicate with You

Send service-related announcements, updates, and notifications
Notify you of changes to the Service, Terms of Service, or Privacy Policy
Respond to your comments, questions, and customer support requests
Send you marketing communications about new features, promotions, and offers (with your consent and ability to opt-out)
Conduct surveys and request feedback
Send administrative messages and account-related information

2.6 For Business Operations and Legal Compliance

Process payments and maintain financial records
Generate invoices and receipts
Facilitate instructor payouts and earnings reports
Maintain accurate business records and archives
Comply with applicable laws, regulations, and legal obligations
Respond to lawful requests from government authorities
Enforce our legal rights and defend against legal claims
Facilitate corporate transactions such as mergers, acquisitions, or asset sales

2.7 For Aggregated and Anonymized Analytics

Create aggregated, de-identified, or anonymized data sets for statistical analysis
Generate industry reports and insights
Conduct market research
Share anonymized performance benchmarks and trends

You acknowledge and agree that aggregated and anonymized data is not considered personal information and may be used, shared, or retained by ParPro without restriction.

ParPro may share your information in the following circumstances:

3.1 With Other Users of the Service

Certain information may be visible to other users depending on your privacy settings and how you use the Service:

Leaderboards: Your name, scores, statistics, and performance data may appear on public leaderboards for competitions, tournaments, or groups you participate in
Groups: Your profile information, posts, comments, and shared content may be visible to other members of groups you join
Instructors: If you book lessons or work with an instructor, that instructor will have access to your profile information, contact details, performance data, and training progress
Reviews and Ratings: Reviews and ratings you post about instructors may be publicly visible or visible to other users considering that instructor
Club Administrators: If you are a member of a club, club administrators may have access to your name, contact information, membership status, performance data, and participation records within their club
Team Coaches and Staff: If you are a member of a team, coaches and authorized team staff may have access to your name, contact information, performance data, training progress, and recruiting profile data
Cross-Portal Visibility: If you participate in multiple roles on the Platform (e.g., mobile app user and team member), your performance data tracked in one context may be visible in other contexts where you have an active relationship. For example, round data tracked in the mobile app may be visible to your team coach through the Team Portal.
Parents and Guardians: If you are a minor, your parent or guardian may have access to your performance data, messages received, and activity logs through the Platform’s parent dashboard

3.2 With Service Providers and Business Partners

We share information with third-party service providers, vendors, and business partners who perform services on our behalf, including:

Payment Processors: Stripe, Apple, and Google for processing payments, subscriptions, and transactions
Cloud Hosting and Storage: Amazon Web Services (AWS), Google Cloud Platform, or similar providers for data hosting and storage
Analytics Providers: Google Analytics, Firebase Analytics, or similar services for usage analytics and performance monitoring
Customer Support Platforms: Zendesk, Intercom, or similar services for managing customer support tickets and communications
Email and Communication Services: SendGrid, Twilio, or similar services for sending transactional and marketing emails
Push Notification Services: Apple Push Notification Service (APNs) and Firebase Cloud Messaging (FCM)
Golf Course Data Providers: iGolf, Golf.API, or similar providers for course information and data
GHIN/USGA: Golf Handicap and Information Network for handicap index synchronization, score posting, and handicap verification (when enabled by your club)
Verifiable Parental Consent (VPC) Provider — Kids Web Services (KWS): Kids Web Services Ltd, a wholly-owned Epic Games subsidiary established in England and Wales, performs Verifiable Parental Consent on our behalf when a child under 13 enrolls in the Service. The relationship operates in two phases — a processor relationship for the initial email transmission and an independent-controller relationship once the parent interacts directly with the KWS Parent Gateway (including KWS’ AgeGraph cross-app pre-verified-parent network). For full disclosure of data shared, methods used, and parental rights, see §7.10.

These service providers are contractually obligated to use your information only for the purposes of providing services to us and are required to maintain the confidentiality and security of your information.

3.3 For Legal Compliance and Protection of Rights

We may disclose your information if we believe in good faith that such disclosure is necessary to:

Comply with applicable laws, regulations, or legal process (e.g., court orders, subpoenas, search warrants)
Respond to lawful requests from government authorities, law enforcement, or regulatory agencies
Enforce our Terms of Service, policies, or agreements
Protect the rights, property, safety, or security of ParPro, our users, or the public
Detect, prevent, or investigate fraud, security breaches, or illegal activities
Defend against legal claims or litigation

3.4 In Connection with Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity or successor organization. We will provide notice of such a transaction and any choices you may have regarding your information.

We may share your information with third parties when you explicitly consent to or request such sharing, such as when you choose to share content on social media or connect third-party applications to your account.

3.6 Aggregated and Anonymized Information

We may share aggregated, de-identified, or anonymized information that does not directly identify you with third parties for research, marketing, analytics, or other business purposes. Such information is not considered personal information under this Privacy Policy.

Important: ParPro does not sell your personal information to third parties for monetary consideration. We do not engage in the sale of personal information as defined by applicable privacy laws, including the California Consumer Privacy Act (CCPA).

4. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have certain rights and choices regarding your personal information.

4.1 Access and Update Your Information

You have the right to access and update your personal information at any time through the Service:

Account Settings: You can view and edit your profile information, contact details, and account preferences in the app settings
Contact Us: If you cannot access or update certain information through the app, you may contact us at support@parpro.golf to request access or corrections

4.2 Delete Your Account and Data

You have the right to request deletion of your account and personal information:

In-App Deletion: You can delete your account at any time through the account settings in the mobile application
Email Request: You can submit a deletion request by emailing support@parpro.golf with the subject line “Account Deletion Request”

Upon receiving a valid deletion request, we will delete or anonymize your personal information within thirty (30) days, except where we are required or permitted to retain certain information for legal, regulatory, tax, fraud prevention, or other legitimate business purposes.

Important Exceptions to Deletion:

Financial and transaction records may be retained for up to seven (7) years to comply with accounting, tax, and anti-money laundering requirements
Data necessary to resolve disputes, enforce agreements, or comply with legal obligations
Anonymized or aggregated data that does not identify you
Backup copies may persist in our systems for a limited time before being permanently deleted

4.3 Marketing Communications and Opt-Out

You have the right to opt-out of marketing communications:

Email Unsubscribe: Click the “unsubscribe” link at the bottom of any marketing email
Push Notifications: Disable push notifications through your device settings or the app settings
Email Preferences: Adjust your communication preferences in your account settings
Do Not Sell My Information: While we do not sell personal information, California residents may submit a “Do Not Sell” request at support@parpro.golf

Note that even if you opt-out of marketing communications, you will still receive transactional and service-related messages necessary for the operation of your account.

4.4 Control Location Data Collection

You can control location data collection through your device settings:

iOS Devices: Go to Settings > Privacy > Location Services and adjust permissions for the ParPro app
Android Devices: Go to Settings > Location > App Permissions and adjust permissions for the ParPro app

Disabling location services may limit certain features, such as automatic course detection and GPS shot tracking.

For web-based access to the Service:

Browser Settings: You can configure your browser to refuse cookies or alert you when cookies are being sent
Cookie Preference Center: Available on our website to manage cookie preferences

Note that disabling cookies may affect the functionality of the Service.

4.6 Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format:

Submit a data portability request to support@parpro.golf with the subject line “Data Portability Request”
We will provide your data within thirty (30) days in a portable format (e.g., CSV, JSON)

4.7 Object to Processing or Restrict Use

You may have the right to object to certain uses of your information or request that we restrict processing:

Contact us at support@parpro.golf to exercise these rights
We will evaluate your request in accordance with applicable law and our legitimate business interests

4.8 Non-Discrimination

You have the right to exercise your privacy rights without discrimination. We will not:

Deny you access to the Service
Charge you different prices or rates
Provide you with a different level or quality of service

solely because you exercised your privacy rights.

5. Data Security and Protection

ParPro takes the security of your personal information seriously and implements reasonable technical, administrative, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, and destruction.

5.1 Security Measures

Our security measures include, but are not limited to:

Encryption in Transit: All data transmitted between your device and our servers is encrypted using HTTPS/TLS protocols
Encryption at Rest: Sensitive data, including passwords and payment information, is encrypted when stored in our databases
Password Protection: User passwords are hashed using industry-standard cryptographic algorithms (bcrypt)
Access Controls: Role-based access controls limit employee and contractor access to personal information on a need-to-know basis
Authentication: Multi-factor authentication for administrative access to systems
Security Monitoring: Continuous monitoring for suspicious activity, unauthorized access attempts, and security threats
Vulnerability Management: Regular security assessments, penetration testing, and vulnerability scanning
Employee Training: All employees and contractors with access to personal information receive privacy and security training
Incident Response: Documented incident response procedures for security breaches and data incidents

5.2 Third-Party Security

We carefully select third-party service providers and require them to maintain appropriate security measures and comply with applicable data protection laws. However, we cannot guarantee the security practices of third parties.

5.3 Limitations and Your Responsibilities

No System is Completely Secure: Despite our security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.

Your Responsibility: You are responsible for:

Maintaining the confidentiality of your account credentials
Using a strong, unique password
Logging out of your account when using shared or public devices
Promptly notifying us of any unauthorized access or security breach at support@parpro.golf

Unauthorized Access: If you believe your account has been compromised, change your password immediately and contact us at support@parpro.golf.

6. Data Retention

ParPro retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

Active Account Data:

Retained while your account is active and for as long as needed to provide you with the Service

Deleted Account Data:

Most personal information is deleted within thirty (30) days of account deletion
Some data may be retained in backup systems for an additional sixty (60) days before permanent deletion

Financial and Transaction Records:

Retained for seven (7) years to comply with tax, accounting, and legal requirements
Includes invoices, receipts, payment records, instructor payouts, and transaction history

Customer Support Interactions:

Retained for two (2) years after resolution to improve service quality and handle follow-up inquiries

Legal and Compliance Records:

Retained as required by law, regulation, or legal process
Retained as necessary to establish, exercise, or defend legal claims

Communication Records:

Direct messages, team messages, club messages, and other in-app communications are retained for two (2) years from the date of sending
After the retention period, messages may be permanently deleted
Messages involved in active investigations, legal holds, or unresolved disputes may be retained beyond the standard retention period

Account Deletion and Reactivation:

Most personal information is deleted within thirty (30) days of account deletion
A ninety (90) day reactivation window is maintained during which your account data is preserved in a deactivated state. After this period, data is permanently deleted.
Some data may persist in backup systems for an additional sixty (60) days before permanent deletion

Anonymized and Aggregated Data:

May be retained indefinitely for analytics, research, and product development purposes
Cannot be used to identify you personally

6.2 Secure Deletion

When we delete personal information, we use secure deletion methods to ensure it cannot be reconstructed or recovered. Backup copies are overwritten in accordance with our data retention and deletion schedules.

7. Children’s Privacy

ParPro is committed to protecting the privacy of children. The following provisions comply with the Children’s Online Privacy Protection Act (COPPA), as amended by the FTC’s 2025 Final Rule (16 CFR Part 312, effective June 23, 2025), and applicable state laws.

7.1 Age Restrictions and Verification

Users must be at least thirteen (13) years old to create an individual account without parental consent
Users under thirteen (13) cannot use the Service on their own. An account for a child under thirteen (13) may be set up by a parent or guardian, or initiated through a team, club, league, or instructor enrollment — but in every case, creating the account triggers a verifiable-parental-consent request (see §7.3), and the child’s account remains blocked from use until the parent or guardian completes verification and approves the account
Users between thirteen (13) and eighteen (18) may use the Service with parental or guardian consent and supervision
Instructors must be at least eighteen (18) years old
The Platform performs age verification during account creation and organization enrollment. Users identified as under thirteen (13) are subject to enhanced protections as described below

Jurisdiction-Aware Digital Age of Consent. The age of thirteen (13) stated above is the default threshold under COPPA. Where the law of a user’s jurisdiction sets a higher digital age of consent — for example, European Union member states may, under Article 8 of the GDPR, set an age between thirteen (13) and sixteen (16) (such as sixteen (16) in Germany and fifteen (15) in France), while the United Kingdom applies thirteen (13) under the ICO’s Age Appropriate Design Code (“Children’s Code”) — ParPro applies the applicable local age when determining whether verifiable parental consent is required. Users below the applicable local age of consent are treated as children for all purposes of this Section 7.

7.2 Information Collected from Children Under 13

When a child under 13 is enrolled in the Service (through a team, club, or instructor group), we may collect the following categories of personal information with verifiable parental consent:

(a) Identifying Information: First and last name, date of birth, and parent/guardian email address
(b) Performance Data: Golf scores, statistics, handicap information, and training plan progress
© Communication Data: Messages sent through team or group communication features (subject to parental consent and monitoring)
(d) Participation Data: Team/club membership, event attendance, and practice participation records

We do not collect the following from children under 13:

Geolocation data (GPS tracking is disabled for minor accounts)
Financial information (all payments are processed through parent/guardian accounts)
Social media identifiers
Biometric data

Before collecting personal information from a child under 13, we obtain verifiable parental consent (“VPC”) through one or more of the following FTC-approved methods, all of which comply with 16 CFR Section 312.5(b):

(a) Stripe Card Transaction (stripe_card_transaction) — temporarily disabled pending implementation (returning in v3.7). When a parent pays for the child’s account via Stripe Checkout, the verified payment-card transaction is intended to itself constitute VPC; we will retain the Stripe payment_intent_id, customer_id, and last-four card digits as proof. Until this method is re-enabled, ParPro uses the KWS Parent Verification methods (b.i–b.iii) below for all parental-consent ceremonies.
(b) KWS Parent Verification (Kids Web Services, an Epic Games subsidiary; see §7.10 for full disclosure) — the parent is redirected to KWS’ Parent Gateway to complete verification through one of three FTC-approved sub-methods:
- (b.i) Personal ID Register (US: full name + last-four SSN + DOB + mailing address; Brazil: CPF + DOB; Mexico: full name + address + CURP) — KWS performs a real-time lookup against the country’s identity register.
- (b.ii) Payment-Card Verification (global) — parent provides credit/debit card details. A nominal transaction is processed: parents in the US are charged $0.50 USD which is refunded within 8-13 business days; parents outside the US have a small amount temporarily authorized and released within 30 business days. There is no net cost to the parent and no cost to ParPro.
- (b.iii) Facial Age Estimation (global, including Europe) — parent submits a selfie; KWS’ provider estimates age from facial features without requiring identity documents.
© Such other methods as may be approved by the FTC under 16 CFR Section 312.5(b).

Email-only verification is no longer used as a sole VPC method (effective v1.3.0) because ParPro discloses children’s personal information to third parties (instructors, leaderboards, payment processors, golf-data providers, KWS), which makes email-only insufficient under 16 CFR Section 312.5(b)(2)(viii).

Verification comes first. For every account created for a child under thirteen (13), the parental-verification request is initiated at account creation, and the child’s account remains blocked from use until the parent or guardian completes verification. If the parent or guardian explicitly declines the verification request, the account remains blocked and any previously recorded consent is revoked; if verification is never completed, the account is closed as described in §7.7 and the Children’s Data Retention Policy.

Consent is scoped to the activity. When a child’s account is created through a youth league, team, or similar enrollment, the initial parental consent covers participation in that group only. Parents and guardians may grant additional feature permissions (such as messaging, bookings, or public leaderboard visibility) individually, at any time, from the guardian dashboard — consistent with the data-minimization commitments in §7.6.

Separate Consent for Third-Party Disclosure. If a child’s personal information will be disclosed to a third party (such as a governing body, recruiting service, or analytics provider), we obtain separate parental consent for such disclosure, distinct from consent for data collection. We identify the third parties or categories of third parties to whom data may be disclosed at the time consent is requested. KWS is itself a third-party recipient and an independent controller of certain verification data, as fully described in §7.10.

7.4 Direct Notice to Parents

Before collecting personal information from a child under 13, we provide direct notice to the parent or guardian that includes:

(a) The types of personal information we collect from children
(b) How the information will be used (as described in this Privacy Policy)
© Whether the information will be disclosed to third parties, and if so, the names or categories of those third parties — including the KWS Parent Verification flow described in §7.10
(d) Our data retention practices for children’s information (see Section 7.7)
(e) That the parent may review the child’s information, request its deletion, and refuse to permit further collection or use
(f) Contact information for our children’s privacy inquiries: privacy@parpro.golf
(g) KWS Verification Disclosure (when KWS Parent Verification is the VPC method). Before redirecting the parent to the KWS Parent Gateway, we display an in-app explanation screen that itemizes:
- (g.i) what data ParPro will share with KWS (the parent’s email address only);
- (g.ii) what data KWS may collect directly from the parent (varies by sub-method: government-ID lookup data, payment-card details, or facial-image data);
- (g.iii) the temporary $0.50 USD card hold (US) or temp authorization (non-US) that the parent will see and the refund timing;
- (g.iv) that KWS will hash the parent’s verified email and add it to KWS’ “AgeGraph” cross-app pre-verified-parent network (see §7.10);
- (g.v) a link to the KWS Partner Privacy Policy governing KWS’ processing;
- (g.vi) the parent’s option to cancel and use the alternative Stripe-card-transaction method (when applicable to a paying-parent flow);
- (g.vii) acknowledgement of which version of this Privacy Policy is in effect at the time of consent (we record the direct_notice_version_id against each consent record so re-consent is automatically requested when this document is updated in a way that requires it under our Material Change Policy).

7.5 Parental Rights

Parents and legal guardians of children under 13 have the following rights:

(a) Right to Review: Parents may review all personal information collected from their child by accessing the guardian dashboard or contacting us at privacy@parpro.golf. We will respond to verified review requests within thirty (30) days.
(b) Right to Delete: Parents may request deletion of their child’s personal information at any time. Upon receiving a verified deletion request, we will delete the information within thirty (30) days, except where retention is required by law or for a legitimate purpose disclosed at the time of collection.
© Right to Refuse Further Collection: Parents may refuse to permit further collection or use of their child’s personal information. Exercising this right may result in the child’s inability to participate in certain features of the Service.
(d) Right to Revoke Consent: Parents may revoke previously granted consent at any time through the guardian dashboard or by contacting us at privacy@parpro.golf.
(e) No Retaliation: We will not condition a child’s participation in any activity on the parent consenting to the collection of more personal information than is reasonably necessary for that activity.

7.6 Data Minimization for Children

We collect only the personal information from children under 13 that is reasonably necessary for their participation in the specific activity for which consent was obtained. We do not condition participation on the disclosure of more personal information than is reasonably necessary. Features that are not essential to the child’s participation (such as social features, public profiles, and competitive leaderboards) may be restricted or disabled for children under 13.

7.7 Data Retention and Security for Children’s Information

(a) Retention: Personal information collected from children under 13 is retained only for as long as reasonably necessary to fulfill the purpose for which it was collected. We delete children’s personal information within thirty (30) days of account removal, organization departure, or upon verified parental request, whichever occurs first.
(b) Security Program: ParPro maintains a written information security program specifically designed to protect children’s personal information, including administrative, technical, and physical safeguards reasonably designed to protect the confidentiality, security, and integrity of such information. This program is reviewed and updated at least annually.
© Access Controls: Access to children’s personal information is limited to authorized personnel who require access for legitimate purposes, including coaches, team administrators, and club staff who have been granted access by the enrolling organization.

7.8 COPPA Compliance Statement

ParPro complies with the Children’s Online Privacy Protection Act (COPPA), as amended, including the FTC’s 2025 Final Rule. If we discover that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information as soon as reasonably practicable, and no later than within ten (10) business days of discovery. To report a concern about children’s privacy, contact us at privacy@parpro.golf.

7.9 Minors Aged 13-17

For users between the ages of thirteen (13) and seventeen (17), we implement the following additional protections:

Parental consent is recommended (and may be required by certain organizations or state laws)
Location tracking features are disabled for all users under 18
In addition, in accordance with the UK ICO’s Age Appropriate Design Code (“Children’s Code”), users located in the United Kingdom (both adults and minors) are asked to provide a per-session consent grant before any location-based feature processes their location
Public recruiting profiles for minor athletes require separate parental consent
Communication features between adults and minors are subject to monitoring and transparency measures as described in the applicable portal terms

7.10 KWS Parent Verification Service Disclosure

ParPro uses Kids Web Services Ltd (“KWS”), a wholly-owned subsidiary of Epic Games registered in England and Wales (Company Number 13351982; registered office: c/o Shepherd and Wedderburn LLP, 1-6 Lombard Street, London EC3V 9AA, United Kingdom; VAT number GB 452 1755 02), to conduct Verifiable Parental Consent under COPPA, GDPR-K, and equivalent international frameworks. This section is the third-party-disclosure notice required by 16 CFR § 312.4(d)(3) and 16 CFR § 312.5(b)(2)(viii).

(a) Why ParPro uses KWS. KWS is certified by two FTC-authorized COPPA Safe Harbor Programs — ESRB Privacy Certified and kidSAFE — and operates a multi-method verification service that satisfies 16 CFR § 312.5(b). Using KWS allows ParPro to offer parents a choice of FTC-approved verification methods (see §7.3) without parents having to navigate multiple flows, and provides ParPro with documented compliance under the certified Safe Harbor regimes.

(b) Two distinct processing relationships exist between ParPro and KWS (per the KWS Parent Verification Service Specific Terms dated 28 August 2025):

(b.i) ParPro-as-controller / KWS-as-processor (Processor Parent Verification Processing). When ParPro transmits the parent’s email address to KWS via API and instructs KWS to email a verification request to that address, ParPro is the data controller and KWS acts as our data processor. Under CCPA/CPRA, ParPro is the Business and KWS is our Service Provider for this processing. KWS uses this email solely on ParPro’s instructions.
(b.ii) KWS-as-independent-controller (Controller Parent Verification Processing). Once the parent interacts directly with the KWS Parent Gateway (entering verification details, completing the chosen method, and receiving the verification result), KWS is an independent controller. Under CCPA/CPRA, KWS is an independent Business for this processing. ParPro receives only the verification result (verified-or-not, method used, KWS transaction ID); ParPro does not receive the underlying ID, card, or biometric data the parent submitted to KWS.

© The AgeGraph (cross-app pre-verified-parent network). When a parent successfully verifies via KWS for ParPro, KWS hashes the parent’s email address and adds the hash, the verification method, the verification status, the timestamp, and the country in which the parent’s device was located to a database called the “AgeGraph”, alongside a KWS-generated transaction ID and any transaction IDs from KWS’ verification sub-providers (e.g., Stripe). KWS uses the AgeGraph to provide its services to other applications: a parent who has already verified via KWS for ParPro will not need to re-verify when they encounter a different KWS-using app that asks them to grant consent for a different child. The AgeGraph data described above is owned and controlled by KWS as an independent controller (KWS Data under the KWS Service Specific Terms). Parents can request information about AgeGraph data concerning them directly from KWS via https://parents.kidswebservices.com/.

(d) Data ParPro discloses to KWS: the parent’s email address (the parent provides this to ParPro, and ParPro transmits it to KWS via API to initiate verification).

(e) Data the parent discloses directly to KWS (varies by method chosen at the KWS Parent Gateway):

For the Personal ID Register method: full legal name, mailing address, last-four-digit SSN (US) / CPF (Brazil) / CURP (Mexico), date of birth.
For the Payment-Card Verification method: credit or debit card number, CVV, expiration date, and billing identifiers as required for the temporary nominal transaction. ParPro receives no portion of this data.
For the Facial Age Estimation method: a self-captured facial image (selfie) used by KWS’ provider to estimate adult-or-not age. ParPro receives no portion of this image.

(f) Verification result returned to ParPro: KWS returns to ParPro: a verified-or-not flag, the verification method used (one of kws_id_register, kws_payment_card, kws_facial_age_estimation), the KWS-generated transaction ID, and the verification timestamp. ParPro stores this in our parental_consent_requests table as proof of consent.

(g) Parent privacy rights vis-à-vis KWS. Because KWS is an independent controller for Controller Parent Verification Processing (including AgeGraph storage), parents must contact KWS directly to exercise rights of access, deletion, or restriction with respect to AgeGraph data. The KWS Partner Privacy Policy is available at https://www.kidswebservices.com/privacy. Parents may continue to exercise their COPPA rights with respect to ParPro’s records (the verification result + child PI we hold) by contacting privacy@parpro.golf as described in §7.5.

(h) International transfers. KWS is established in the United Kingdom. Parent data shared with KWS may be processed in the UK and EU. The KWS Data Processing Addendum incorporates UK and EU data-export safeguards (Standard Contractual Clauses where applicable). See §8 for ParPro’s broader international-transfer disclosures.

(i) Cost to parent. $0 net. The Payment-Card Verification method involves a temporary $0.50 USD hold (US) refunded within 8-13 business days, or a temp authorization (non-US) released within 30 business days. There is no charge to ParPro for any KWS verification.

(j) Liability allocation between ParPro and KWS. The contract with KWS is governed by English law and limits KWS’ aggregate liability to ParPro to one hundred pounds sterling (£100). KWS does not warrant the accuracy of any individual verification (i.e., KWS does not warrant that the verified person is in fact the parent or guardian of the specific ParPro child end-user, or that any particular method satisfies the law of any particular jurisdiction). ParPro retains full COPPA accountability to parents and end-users notwithstanding the use of KWS. Parents wishing to bring a complaint about ParPro’s COPPA practices should contact us at privacy@parpro.golf or, in the alternative, contact the FTC.

(k) Vendor change notice. KWS may, on 14 days’ notice to ParPro, introduce, test, or remove verification methods. ParPro will reflect any methods we choose to enable in §7.3 of this Policy and will re-issue Direct Notice to parents in advance of any change that constitutes a material change under our Material Change Policy.

8. International Data Transfers and Users

8.1 United States Operations

The Service is operated from the United States and is intended for use by individuals located within the United States. All data collected through the Service is transferred to, processed, and stored in the United States.

8.2 International Users

If you access or use the Service from outside the United States, you acknowledge and agree that:

Your personal information will be transferred to and processed in the United States
The United States may have data protection laws that differ from those in your country of residence
By using the Service, you consent to the transfer, processing, and storage of your information in the United States

8.3 European Economic Area (EEA) Users

If you are located in the European Economic Area (EEA), you may have additional rights under the General Data Protection Regulation (GDPR), including:

The right to access your personal data
The right to rectify inaccurate personal data
The right to erasure (“right to be forgotten”) in certain circumstances
The right to restrict processing in certain circumstances
The right to data portability
The right to object to processing based on legitimate interests
The right to withdraw consent at any time (where processing is based on consent)
The right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at privacy@parpro.golf. We will respond to your request in accordance with applicable law.

Legal Basis for Processing (GDPR):

Consent: For marketing communications and certain optional features
Contract Performance: To provide the Service and fulfill our contractual obligations
Legitimate Interests: For analytics, fraud prevention, and service improvement
Legal Obligations: To comply with applicable laws and regulations

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

9.1 Categories of Personal Information Collected

In the preceding twelve (12) months, ParPro has collected the following categories of personal information:

Identifiers: Name, email address, phone number, device IDs, IP address
Personal Records: Date of birth, billing address, payment information
Protected Classifications: Age, gender
Commercial Information: Purchase history, transaction records, subscription data
Internet Activity: Browsing history, search history, interactions with the Service
Geolocation Data: Precise location data (with consent), approximate location
Sensory Information: Photos and videos uploaded to the Service
Professional Information: (For instructors) Credentials, certifications, work history
Inferences: Preferences, skill level, interests derived from your activity

9.2 California Consumer Rights

As a California resident, you have the right to:

Right to Know:

Request disclosure of the categories and specific pieces of personal information we have collected about you
Request disclosure of the categories of sources from which we collected your personal information
Request disclosure of the business or commercial purposes for collecting or selling personal information
Request disclosure of the categories of third parties with whom we share personal information

Right to Delete:

Request deletion of your personal information, subject to certain exceptions

Right to Opt-Out of Sale:

Request to opt-out of the “sale” of your personal information (Note: ParPro does not sell personal information)

Right to Correct:

Request correction of inaccurate personal information

Right to Limit Use of Sensitive Personal Information:

Request limitation on the use of sensitive personal information

Right to Non-Discrimination:

Exercise your rights without discrimination in service or pricing

9.3 How to Exercise Your California Rights

To exercise your California privacy rights:

Email: Send a request to support@parpro.golf or privacy@parpro.golf with the subject line “California Privacy Request”
Specify: Clearly state which right you wish to exercise (e.g., Right to Know, Right to Delete)
Verification: We will verify your identity before processing your request by asking you to confirm your email address and account details

Response Timeline: We will respond to verifiable consumer requests within forty-five (45) days. If we require additional time (up to 90 days total), we will inform you of the reason and extension period.

Authorized Agents: You may designate an authorized agent to submit requests on your behalf. The agent must provide proof of authorization, and we may require you to verify your identity directly.

9.4 Do Not Sell My Personal Information

ParPro does not sell personal information as defined by the CCPA. We do not exchange personal information for monetary or other valuable consideration.

9.5 “Shine the Light” Law

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. ParPro does not share personal information with third parties for their own direct marketing purposes.

10. Additional State Privacy Rights

If you are a resident of a state with a comprehensive consumer privacy law, you may have additional rights beyond those described in Section 9 (California). These states include, but are not limited to: Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Delaware (DPDPA), Iowa (ICDPA), Nebraska (NDPA), New Hampshire (NHPA), New Jersey (NJDPA), Tennessee (TIPA), Minnesota (MCDPA), Maryland (MODPA), Indiana (INCDPA), Kentucky (KCDPA), and Rhode Island (RIDPA).

Depending on your state, your rights may include:

(a) The right to confirm whether we are processing your personal data
(b) The right to access your personal data
(d) The right to delete your personal data
(e) The right to obtain a copy of your personal data in a portable format
(f) The right to opt out of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects
(g) The right to appeal a denial of your privacy request

Maryland Residents (MODPA): ParPro does not process personal data of individuals under eighteen (18) for targeted advertising or sale, consistent with Maryland law.

Universal Opt-Out Signals: ParPro will honor Global Privacy Control (GPC) signals and other universal opt-out preference signals recognized under applicable state laws.

To exercise your state privacy rights, contact us at privacy@parpro.golf. We will verify your identity and respond within the timeframes required by your state’s law (typically 45 days).

11. Data Breach Notification

In the event of a data breach that compromises the security of your personal information, ParPro will:

(a) Investigate the breach and take steps to contain and remediate the incident
(b) Notify affected individuals in accordance with applicable state breach notification laws, including Alabama Code Section 8-38-1 et seq. (requiring notification within 45 days of discovery)
(d) Provide notice that includes: a description of the incident, the types of information involved, steps taken to address the breach, and steps individuals can take to protect themselves
(e) Notify organization administrators (club/team admins) of any security incident that may have compromised their organization’s data within seventy-two (72) hours of discovery

12. Automated Decision-Making

ParPro uses automated systems to generate performance analytics, recommendations, statistical calculations, and content moderation decisions. These automated systems:

(a) Generate strokes gained analysis, handicap calculations, and performance projections using industry-standard algorithms
(b) Provide instructor and training content recommendations based on your skill level, goals, and usage patterns
(d) Do not make consequential decisions about your account, membership, or access without human review

If you have questions about how automated systems affect your experience, contact us at support@parpro.golf.

13. Changes to This Privacy Policy

ParPro reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors.

10.1 Notification of Changes

If we make material changes to this Privacy Policy, we will notify you by:

Posting the updated Privacy Policy on our website and in the mobile application
Updating the “Last Updated” date at the top of this Privacy Policy
Sending an email notification to the email address associated with your account
Displaying an in-app notification or alert when you next access the Service

10.2 Acceptance of Changes

Your continued use of the Service after the effective date of any changes to this Privacy Policy constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must stop using the Service and may request deletion of your account.

10.3 Review Privacy Policy Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

14. Contact Us and Privacy Inquiries

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy or our privacy practices, please contact us:

14.1 General Privacy Inquiries

Email: privacy@parpro.golf Customer Support: support@parpro.golf Website: www.parpro.golf

14.2 Data Protection Officer

For privacy matters requiring escalation or formal response, you may contact our Data Protection Officer at:

Email: privacy@parpro.golf Subject Line: “Attention: Data Protection Officer”

14.3 Mailing Address

ParPro, LLC 500 23rd St. S. Birmingham, AL 35233

14.4 Response Time

We strive to respond to all privacy inquiries and requests within ten (10) business days. For formal data subject requests (e.g., CCPA, GDPR, state privacy laws), we will respond within the timeframes required by applicable law (typically 30-45 days).

15. Governing Law and Dispute Resolution

This Privacy Policy and any disputes arising out of or relating to this Privacy Policy or our privacy practices shall be governed by and construed in accordance with the laws of the State of Alabama, United States of America, without regard to its conflict of law principles.

Any disputes, claims, or controversies arising out of or relating to this Privacy Policy shall be subject to the dispute resolution and arbitration provisions set forth in our Terms of Service, which are incorporated herein by reference.

16. Severability

If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable while preserving its intent, or, if such modification is not possible, such provision shall be severed from this Privacy Policy. The validity, legality, and enforceability of the remaining provisions shall not be affected or impaired in any way.

17. Entire Agreement

This Privacy Policy, together with our Terms of Service and any other agreements expressly incorporated by reference, constitutes the entire agreement between you and ParPro regarding the collection, use, and disclosure of your personal information and supersedes all prior or contemporaneous understandings or agreements, whether written or oral, regarding such subject matter.

BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. YOU CONSENT TO THE COLLECTION, USE, DISCLOSURE, AND PROCESSING OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

ParPro, LLC Version 1.3.0 Effective Date: August 4, 2026 Last Updated: August 4, 2026

Privacy Policy