Eagle

Eagle — Swing Analysis

Last updated 10 July 2026

This Privacy Notice for W185 Holdings LLC ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you: download and use our mobile application (Eagle — Swing Analysis), or any other application of ours that links to this Privacy Notice; or engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at eagleappcontact@gmail.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. This includes video recordings of your golf swing that you capture or upload, and data derived from those recordings. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions. We process video recordings of your golf swing and body-motion data derived from them, which may be considered biometric or otherwise sensitive information under certain laws. We process this information to provide the Services, and, where required by law, with your consent. We do not process information about your racial or ethnic origin, sexual orientation, or religious beliefs.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, including generating your swing analysis; to communicate with you; for security and fraud prevention; and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, such as cloud hosting and analytics providers who process data on our behalf. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at eagleappcontact@gmail.com. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

13. VIDEO, SWING, AND BIOMETRIC DATA

14. DO WE MAKE UPDATES TO THIS NOTICE?

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, including video recordings of your golf swing.

We collect personal information that you voluntarily provide to us when you register for the Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: names; email address; account credentials; and any information you choose to provide in connection with the Services.

Swing Videos and Swing Data. A core function of the Services is to record and analyze your golf swing. When you use the Services, we collect video and image recordings of your golf swing that you capture or upload ("Swing Videos"), together with data we derive from those recordings — including body-position, pose-estimation, motion, timing, and other measurements — and the swing analysis, scores, and metrics we generate ("Swing Data"). See the "VIDEO, SWING, AND BIOMETRIC DATA" section below for more detail.

Sensitive Information. Where necessary, with your consent or as otherwise permitted by applicable law, we process the Swing Videos and Swing Data described above, some of which may be considered biometric or otherwise sensitive information in certain jurisdictions. We do not process information about your racial or ethnic origin, sexual orientation, or religious beliefs.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Apple. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/data/en/app-store/.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

* Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, photo library/media storage, and other features, in order to capture and upload Swing Videos. If you wish to change our access or permissions, you may do so in your device's settings.

* Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.

* Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

* Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), and device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

* Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

* To deliver and facilitate delivery of services to the user. We may process your information, including your Swing Videos and Swing Data, to provide you with the requested service — namely, to generate and deliver your swing analysis, scores, and metrics.

* To improve and develop our Services. We may process your Swing Videos and Swing Data to maintain, improve, and develop the features, models, and algorithms that power the Services, including our computer-vision and analysis models. Where required by applicable law, we will rely on your consent for this processing, and you may withdraw that consent as described below.

* To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

* Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. Where we process Swing Videos and Swing Data that qualify as special-category (biometric) data under the GDPR/UK GDPR, we rely on your explicit consent. You can withdraw your consent at any time.

* Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

* Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

* Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way; for investigations and fraud detection and prevention; for business transactions provided certain conditions are met; if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim; for identifying injured, ill, or deceased persons and communicating with next of kin; if we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse; if it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province; if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records; if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced; if the collection is solely for journalistic, artistic, or literary purposes; or if the information is publicly available and is specified by the regulations. We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work — including hosting, storing, and processing your Swing Videos and Swing Data to generate your swing analysis. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows: Data Analytics Services; Cloud Computing and Storage Services; and Machine-Learning / AI Infrastructure Providers.

We also may need to share your personal information in the following situations:

* Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

* Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

* Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

We do not sell your Swing Videos, and we do not publicly share Swing Videos that identify you without your consent.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We keep your Swing Videos and Swing Data for as long as your account is active or as needed to provide the Services, and you may request deletion of your Swing Videos and account data at any time as described below.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at eagleappcontact@gmail.com.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information — including your consent to process biometric Swing Data — which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at eagleappcontact@gmail.com.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Connecticut, Colorado, Utah, Virginia, or certain other states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected. The table includes illustrative examples of each category.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: receiving help through our customer support channels; participation in customer surveys or contests; and facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

* Category A - Until a user requests we delete this information

* Category B - Until a user requests we delete this information

* Category E - Until a user requests we delete this information

* Category F - Until a user requests we delete this information

* Category H - Until a user requests we delete this information

* Category K - Until a user requests we delete this information

* Category L - Until a user requests we delete this information

Sources of Personal Information. Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information. Learn more about how we use your personal information in the section "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We may have disclosed the categories of personal information listed above to our service providers for a business or commercial purpose in the preceding twelve (12) months. The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights. You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: the right to know whether or not we are processing your personal data; the right to access your personal data; the right to correct inaccuracies in your personal data; the right to request the deletion of your personal data; the right to obtain a copy of the personal data you previously shared with us; the right to non-discrimination for exercising your rights; and the right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling"). Depending upon the state where you live, you may also have: the right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California); and the right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California).

How to Exercise Your Rights. To exercise these rights, you can contact us by emailing us at eagleappcontact@gmail.com, or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at eagleappcontact@gmail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

Illinois Biometric Information Privacy Act (BIPA) and similar laws. If you are a resident of Illinois or another state with a biometric privacy law (such as Texas or Washington), additional protections may apply to biometric information. See the "VIDEO, SWING, AND BIOMETRIC DATA" section below for details on what we collect, why, how long we retain it, and how we obtain your consent.

DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand. We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular to offer you the products or services that you want and to respond to or help with your requests. At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa. At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the Information Regulator (South Africa). General enquiries: enquiries@inforegulator.org.za. Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za.

VIDEO, SWING, AND BIOMETRIC DATA

Because the Services record and analyze your golf swing, we want to be clear about how we handle this information.

What we collect. When you use the Services, we collect and store the Swing Videos you record or upload and the Swing Data we derive from them, including body-position, pose-estimation, motion, and timing measurements and the analysis, scores, and metrics we generate.

Why we collect it. We use Swing Videos and Swing Data to (a) generate and deliver your swing analysis and related metrics; (b) operate, secure, and troubleshoot the Services; and (c) maintain, improve, and develop the features, models, and algorithms that power the Services.

De-identified and aggregated data. We may create de-identified or aggregated data from Swing Data. Such data does not identify you and may be used and retained by us for any lawful purpose, including product improvement and research, without restriction. Where we hold data in de-identified form, we will maintain and use it in de-identified form and will not attempt to re-identify it except as permitted by law.

Biometric information notice and consent. Depending on where you live, some Swing Data may be considered "biometric information" or "biometric identifiers" under laws such as the Illinois Biometric Information Privacy Act (BIPA) and comparable laws in Texas, Washington, and other jurisdictions, or "sensitive personal information" under the California Consumer Privacy Act (CCPA/CPRA) and other state laws. Where required by law, we will obtain your separate, informed consent before collecting or processing such information, and we will not sell or lease it. You may withdraw your consent at any time by contacting us, in which case we will stop the associated processing and delete the relevant information unless retention is required by law.

Retention. We retain Swing Videos and biometric Swing Data for as long as your account is active or as needed to provide the Services, and no longer than any period required by applicable biometric privacy law. Where a specific statutory deadline applies, we will permanently destroy such information within the timeframe that law requires. You may request deletion of your Swing Videos and biometric data at any time using the contact details below.

Your responsibilities. You are responsible for ensuring that any person appearing in a Swing Video has consented to being recorded and to having that recording processed and stored as described here, and for obtaining any consent that person's jurisdiction requires.

DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at eagleappcontact@gmail.com or contact us by post at:

W185 Holdings LLC United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email eagleappcontact@gmail.com.