CALIFORNIA CONSUMER PRIVACY ACT PERSONAL INFORMATION POLICY

Effective: January 1, 2020

1. Purpose and Scope

This CCPA Personal Information Policy (“Policy”) provides guidance to Club Champion LLC (“Club Champion,” “our,” “we” or “us”); its subsidiaries, and all of their respective staff members, employees, consultants, contractors, distributors, temporary workers, suppliers, agents, representatives, partners, and all personnel affiliated with such third parties (“Covered Persons”) on the management of Personal Information (as defined below) Processed (as defined below) by or on behalf of Club Champion, in accordance with the California Consumer Privacy Act (the “CCPA”). This Policy describes how Personal Information must be collected, handled, and stored to meet Club Champion’s data protection standards, and to comply with the CCPA. The purpose of this Policy is to ensure fair and transparent Processing of Personal Information.

Club Champion’s policy is to respect and protect Personal Information collected or maintained by or on behalf of Club Champion. All Personal Information must be Processed in a lawful, fair, and transparent manner and it is Club Champion’s duty to ensure the security and confidentiality of such Personal Information at all times. This Policy covers all Personal Information obtained from Club Champion’s customers and other California Residents (defined below) for which Club Champion collects Personal Information.

Covered Persons can contact the Club Champion Marketing Department at This email address is being protected from spambots. You need JavaScript enabled to view it. or (888) 340-7820 with questions about this Policy. Verifiable Personal Information Requests (defined below) and requests for further information should be directed to the Club Champion Marketing Team.

2. DEFINITIONS

Capitalized terms used but not defined in this Section 2 have the meanings given elsewhere in this Policy. In this Policy, unless stated otherwise:

“California Consumer Privacy Act” or “CCPA” means the California Consumer Privacy Act of 2018.

“California Resident” means a natural person who is a California resident, as defined in section 1798.140(g) of the CCPA.

“Verifiable Personal Information Request” means a California Resident request that a business disclose or delete Personal Information that it has about the California Resident pursuant to CCPA sections
1798.100, 1798.105, 1798.110, or 1798.115.

“Data Incident” means a breach of Club Champion’s security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information on systems managed
by or otherwise controlled by Club Champion. “Data Incidents” does not include unsuccessful attempts or activities that do not compromise the security of Personal Information, including unsuccessful log-in
attempts, pings, port scans, denial‐of‐service attacks, and other network attacks on firewalls or networked systems.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California
Resident or household. (See Appendix A for examples of Personal Information.)

“Information Security Policy” means Club Champion’s internal information security policy.

“Process” means any operation or set of operations that are performed on Personal Information or on sets of Personal Information, whether or not by automated means.

“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its
shareholders or other owners, that Processes information on behalf of a business and to which the business discloses a California Resident’s Personal Information for a business purpose pursuant to a written
contract, provided that the contract prohibits the entity receiving the information from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the
services specified in the contract for the business, or as otherwise permitted by the CCPA, including retaining, using, or disclosing the Personal Information for a commercial purpose other than providing the
services specified in the contract with the business.

3. RESPONSIBILITIES

(a) Club Champion Marketing Team Responsibilities

1. The Club Champion Marketing Team is responsible for approving any data protection statements attached to documentation and communications provided to employees as well as documentation and communications sent to customers of Club Champion, such as emails and letters or information notices displayed on Club Champion’s websites.
2. The Club Champion Marketing Team is responsible for addressing any data protection queries from California Residents, journalists, or media outlets like newspapers.
3. The Club Champion Marketing Team will ensure that all Covered Persons are trained about their data protection responsibilities as part of the induction Process and at regular intervals thereafter.
   Covered Persons whose roles require regular access to Personal Information, or who are responsible for implementing this Policy or responding to Verifiable Personal Information Requests under this
   Policy, will receive additional training to help them understand their duties and how to comply with them.
4. Each business unit and their respective departments are responsible for working with the Club Champion Marketing Team, and Operations Department to implement appropriate compliance controls
   specific to their operations (including but not limited to business practices, other guidance, and training of Covered Persons), in particular the vetting of any potential or current Service Provider to which
   Personal Information may be transferred or disclosed, as part of their business relationship with Club Champion. Covered Persons are required to follow the applicable business practices and other
   guidance, and to take the training required by their business units and/or departments.

(b) Covered Person Responsibilities

Covered Persons may have access to the Personal Information of other Covered Persons and of our customers in the course of their employment, contract, volunteer period, internship or apprenticeship. Where
this is the case, Club Champion relies on Covered Persons to help meet its data protection obligations.

Covered Persons who have access to Personal Information are required:

1. to access only Personal Information that they have authority to access and only for authorized purposes;
2. not to disclose Personal Information except to Covered Persons (whether inside or outside Club Champion) who have appropriate authorization;
3. to keep Personal Information secure (for example, by complying with rules on access to premises, computer and mobile access, password protection, and secure file storage and destruction);
4. not to remove Personal Information, or devices that can be used to access Personal Information, from Club Champion’s premises without implementing appropriate security measures
   (such as encryption, password protection, and lockable cases) to secure the data and the device;
5. where documents are password protected, passwords must be transmitted separately and not via email;
6. to ensure any documents (including emails) which contain Personal Information are:
   (A) kept in an orderly fashion;
   (B) filed on registered electronic or paper files as soon as practicable if they are to be retained;
   (C) erased or securely destroyed (e.g., shredded) when they are no longer required (in accordance with Club Champion’s data retention policy);
7. not to keep random collections of odd papers or old emails. If they need to be retained, they should be properly filed, as mentioned above;
8. to observe Club Champion’s clear desk policy;
9. to ensure that if required, they could retrieve Personal Information for which they are responsible to answer an inquiry from an California Resident; and
10. notify the Club Champion Marketing Team immediately, in the event of a data breach.

Failing to observe these requirements may amount to a disciplinary offense, which will be dealt with under Club Champion’s disciplinary procedure. Significant or deliberate breaches of this Policy, such as accessing employee or customer data without authorization or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

(c) Operations Department Responsibilities

The Operations Department is responsible for:

1. ensuring all systems, services, and equipment used for storing Personal Information meet acceptable security standards and comply with Club Champion’s Information Security Policy;
2. performing regular checks and scans to ensure security hardware and software is functioning properly; and
3. evaluating any potential Service Provider Club Champion is considering using to store or Process data (for instance, cloud computing services).

4. NOTICE OF PRIVACY PRACTICES

All Personal Information should be Processed by lawful and fair means, in a transparent fashion. It is important to ensure that at or before Club Champion collects Personal Information, Club Champion provides California Residents with an appropriate notice (“Privacy Notice”) and information as to the categories, use and disclosure of the Personal Information Club Champion collects and Processes. Club Champion should only collect categories of Personal Information that have been appropriately disclosed to California Residents in a Privacy Notice. Covered Persons should limit Personal Information Processing to the minimum amount necessary to accomplish the purpose for which such Personal Information is collected, pursuant to Club Champion’s policies and procedures. Under no circumstances should Club Champion or Covered Persons sell Personal Information.

5. CALIFORNIA RESIDENT RIGHTS AND REQUESTS

(a) California Resident Rights. California Residents have a number of rights in relation to their Personal Information. California Residents can;

1. request that Club Champion disclose to the California Resident the categories and specific pieces of Personal Information Club Champion has collected about them (“Request to Know”);
2. request that Club Champion delete any Personal Information about the California Resident that Club Champion has collected about them (“Request to Delete”); and
3. request to receive a copy of their Personal Information in a readily usable format that allows the California Resident to transmit the Personal Information from one entity to another without hindrance.

(b) Verifiable Personal Information Requests. Verifiable Personal Information Requests may be made in writing or via phone. If you receive a Verifiable Personal Information Request, please notify the Club Champion Marketing Team immediately. It is Club Champion’s duty to confirm receipt of a request by a California Resident within 10 days and provide information about how Club Champion will Process the request.

The Club Champion Marketing Team will be responsible for sending the California Resident the appropriate Verifiable Personal Information Request form to verify the identity of the California Resident. (See Appendix B for sample email responses to common Verifiable Personal Information Requests and Appendix C for common Verifiable Personal Information Request forms.) Club Champion must receive the completed Consumer Right Request form prior to addressing the California Resident’s request.

Club Champion has a duty to respond to verified Requests to Know and Requests to Delete within 45 days from the date the request was received.

California Residents may exercise their rights by contacting the Club Champion Marketing Team at This email address is being protected from spambots. You need JavaScript enabled to view it., by calling (888) 340-7820 the “Contact Information”). The Contact Information will be included in all agreements between Club Champion and California Residents that address the collection of Personal Information.

6. REQUIREMENTS FOR SERVICE PROVIDER ENGAGEMENT

(a) Verifiable Personal Information Requests.

If a Service Provider Processes Personal Information on behalf of Club Champion, Club Champion must have in place a written contract:

1. prohibiting the Service Provider from (a) selling the Personal Information, (b) retaining, using or disclosing the Personal Information for any purpose other than to the extent required to perform the
   obligations subcontracted to it, and (c) retaining, using or disclosing the Personal Information outside of its relationship with Club Champion.
2. that includes a written certification from the Service Provider that it understands and will comply with the above restrictions.

(b) All business units and departments shall work with Operations Department and the Club Champion Marketing Team to:

1. require Service Providers to inform the California Resident to submit Verifiable Personal Information Requests regarding Personal Information that such Service Provider collects or maintains on
   Club Champion’s behalf directly to Club Champion and provide the California Resident with information about Club Champion’s submission methods;
2. require Service Providers to explain the basis for any denial of a Verifiable Personal Information Request by the Service Provider regarding a Request to Know or delete from a California Resident regarding Personal Information that the Service Provider collects or maintains on Club Champion’s behalf;
3. take reasonable steps to select and retain approved suppliers that can maintain appropriate security measures to protect Personal Information in a manner consistent with this Policy and any applicable laws;
4. require Service Providers by contract to implement and maintain appropriate technical and organizational security measures for Personal Information and to protect Personal Information from unauthorized access, destruction, use, modification, or disclosure;
5. require Service Providers to report information security incidents and breaches to Club Champion without delay following discovery of such breach (ideally between 24 / 48 hours) and provide
   evidence relating to such breach context and extent; and
6. monitor suppliers for compliance with their data protection obligations and, in case of any doubt, mandate an audit of such supplier data protection practices, in compliance with the agreement entered with Club Champion.

7. CHANGES TO THIS POLICY

Club Champion may amend this Policy consistent with the requirements of the CCPA, including notice about any amendment.

8. EFFECTIVE DATE

This Policy is effective as of January 1, 2020.

PRIVACY POLICY

Your privacy is important to Club Champion. So we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. Please take a moment to familiarize yourself with
our privacy practices and let us know if you have any questions.

COLLECTION AND USE OF PERSONAL INFORMATION

Club Champion and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your
experience with Club Champion more convenient and personal. If you want to disable cookies, go to your web browser preferences and then to the Security pane to disable cookies.

• As is true of most websites, we gather some information automatically and store it in log files. This information includes internet Protocol (IP) addresses, browser type and language, internet service
  provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data.
• We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, and to gather demographic information about our user base as a whole. Club
  Champion may use this information in our marketing and advertising services.
• In some of our email messages, we use a “click-through URL”. When customers click one of these URLs, we track this click-through data to help us determine interest in particular topics and measure
  the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
• Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to
  customers. Any of the information we collect from you may be in one of the following ways:
  • To personalize your experience (your information helps us to better respond to your individual needs).
  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you).
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).
  • To process transactions. Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other
    than for the express purpose of delivering the purchased products or service requested by the customer.
  • To send periodic emails. The email address you provide for order processing may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related products or service information, etc. Note: If at anytime you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

DO WE DISCLOSE ANY INFORMATION TO OUTSIDE PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operations of our website, conducting our
business, or servicing you, so long, as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our
site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, and other uses.

HOW DO I OPT-OUT OF ANY / ALL COMMUNICATIONS?

We fully support your ability to opt-out of all communications from Club Champion. You can do so by emailing us at info (at) clubchampiongolf (dot) com with the title “UNSUBSCRIBE” in the title or simply call at
(630) 908-7548 and explain your wishes.

THIRD PARTY LINKS

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility
or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

SERVICE PROVIDERS

Club Champion online services use Secure Sockets Layer (SSL) encryption on all web pages where personal information is collected. To make purchases from these services, you must use an SSL-enabled browser
such as Safari, Firefox, or internet Explorer. Doing so protects the confidentiality of your personal information while it’s transmitted over the internet. To make sure your personal information is secure, we
communicate our privacy and security guidelines to Club Champion employees and strictly enforce privacy safeguards within the company.

TERMS AND CONDITIONS

This is an agreement between you and clubchampiongolf.com. This Agreement governs your use of any website or web page operated by clubchampiongolf.com. You represent that you are at least 18 years of
age, that you have attained the age of majority in the province, state or country in which you reside, and that any information that you submit is correct. Clubchampiongolf.com offers the use of the website to you
conditioned on your acceptance without modification of this agreement. Your use of the websites constitutes your acceptance of this agreement. This agreement contains disclaimers of warranties and liability,
and a limitation on time to bring a claim (see “disclaimer of warranties,” “limitation of liability” and “you have a limited time to bring a claim,” below.) These provisions form an essential basis of our bargain.

USE OF THIS SITE

Clubchampiongolf.com may contain proprietary notices and copyright information, the terms of which must be observed and followed. Information on this site may contain technical inaccuracies or typographical
errors. Information, including product pricing and availability, may be changed or updated without notice. Clubchampiongolf.com and their subsidiaries reserve the right to refuse service, terminate accounts,
and/or cancel orders in its discretion, including, without limitation, if clubchampiongolf.com believes that customer conduct violates applicable law or is harmful to the interests of clubchampiongolf.com.

CONDITIONS OF USE

By using this site, you signify your agreement to the following conditions of use without limitation or qualification. Please read these conditions carefully before using this site. Clubchampiongolf.com may at any
time revise these terms and conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current terms and conditions to which you
are bound.

DISCLAIMER OF WARRANTIES

The materials on this website are provided “as is” and without warranties of any kind, either expressed or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular
purpose. Clubchampiongolf.com does not warrant that the functions contained in the materials will be uninterrupted or error-free, that defects will be corrected, or that this website or the server that makes it
available are free of viruses or other harmful components. Clubchampiongolf.com does not warrant or make any representations regarding the use or the results of the use of the materials on this website in terms
of their correctness, accuracy, reliability, or otherwise. You (and not clubchampiongolf.com) assume the entire cost of all necessary servicing, repair, or correction. Links to other sites may be available for access
through this home page. Such external internet addresses contain information created, published, maintained or otherwise posted by organizations independent of clubchampiongolf.com. Clubchampiongolf.com
does not endorse, approve or certify any information, product or service referenced or provided at such addresses.

LIMITATION OF LIABILITY

While clubchampiongolf.com uses reasonable efforts to include accurate and up-to-date information on this website, errors or omissions may occur. Clubchampiongolf.com makes no warranties or
representations as to the accuracy of this website. Under no circumstances including, but not limited to, negligence by act or omission, shall clubchampiongolf.com or any party involved in creating, producing, or
delivering this website be liable for any direct, incidental, consequential, indirect, or punitive damages that result from the use of, or the inability to use, the materials on this website, even if Clubchampiongolf.com
or a clubchampiongolf.com authorized representative has been advised of the possibility of such damages. Applicable law may not allow the limitation or exclusion of liability of incidental or consequential
damages, so the above limitation or exclusion may not apply to you. In no event shall clubchampiongolf.com’s total liability to you for all damages, losses, and causes of action exceed the amount paid by you for
accessing this website. clubchampiongolf.com assumes no responsibility and shall not be liable for any damages due to viruses that may infect your computer equipment or other property on account of your
access to, use of, or browsing in the website or your downloading of any materials, data, text, images, video, or audio from this website.

YOU HAVE LIMITED TIME TO BRING YOUR CLAIM

You and clubchampiongolf.com agree that any cause of action arising out of or related to the clubchampiongolf.com websites must commence within one (1) year after the cause of action accrues. Otherwise,
such cause of action is permanently barred.

TRADEMARKS/SERVICE MARKS AND COPYRIGHTS

Images displayed on this website are either the property of, or used with permission by, clubchampiongolf.com. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically
permitted herein. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

CHANGES TO OUR PRIVACY POLICY

Club Champion reserves the right to modify this policy at any time. If we decide to change our privacy policy, we will post this change on this page. This policy was last modified on 7/14/2022.

PRIVACY QUESTIONS

If you have any questions or concerns about Club Champion’s Privacy Policy or data processing, please contact us. Club Champion Golf, 825 75th St., Willowbrook, IL 60527 or call (630) 908-7548.

THE CLUB CHAMPION STORY

Established in 2010, Club Champion has grown from a regional three-studio fitting business to a trusted golf club fitting expert with locations in every major golf market nationwide. Our Tour-level fittings were designed by Master Fitter and Builder Nick Sherburne, the company’s founder.

Nick found his way into golf club fitting in 1998 by helping out with club repairs and custom fitting at EJL Golf. With the advent of launch monitors, new shaft technology, grip updates and clubhead advancements, Nick shifted his mindset about fitting. No longer just an art, the science and technique of a proper fitting became a founding principle for the future of Club Champion.

Former CEO Joe Lee and former chairman Keith Bank partnered with Nick in 2010 to launch the budding brand. They saw potential in the idea that professional-level services were just as valuable to amateur players in the golf world — if we play the same equipment and wear the same clothing as the pros, we should be able to customize our game the same way as well. The business acumen of Joe and Keith combined with Nick’s passion and experience helped catapult the brand to the forefront of the fitting industry.

“We went from a Chicagoland staple to a flourishing brand because we saw the huge difference fitted equipment can make in a golfer’s game and we’re making that improvement available to everyone through our expansion to markets across the U.S.," says Lee.

A decade later, Club Champion employs over 220 team members, including roughly 150 fitters nationwide. We’ve been featured in CNBC, Forbes, Sports Illustrated, Golf Digest, The Wall Street Journal, USA Today and more, and we are a perennial National Golf Foundation Top 100 company. We’re also a regular feature on Golf Digest’s semi-annual Top 100 fitter list, driven in part by the more than 100,000 fittings we complete per year.

Our story is still being written, as we have plans for further expansion both in the U.S. and internationally.

WE WENT FROM A CHICAGOLAND STAPLE TO A FLOURISHING BRAND BECAUSE WE SAW THE HUGE DIFFERENCE FITTED EQUIPMENT CAN MAKE IN A GOLFER’S GAME AND WE’RE MAKING THAT IMPROVEMENT AVAILABLE TO EVERYONE THROUGH OUR EXPANSION TO MARKETS ACROSS THE U.S. ”

Joe Lee

Joe Lee
Club Champion Founder
& Chairman

FEATURED ARTICLE

TRENDING

Club Champion has joined forces with TXG – Tour Experience Golf – Canada’s top custom fitter. Now your game will literally know no borders.