Privacy Policy | GolfCard

Effective Date: October 21, 2025

This Privacy Policy is effective immediately for all users.
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This Privacy Policy describes the ways GolfCard Financial Services, Inc. and its affiliates (“GolfCard,” “we,” “our” or “us”) may collect, use, and disclose your personal information in connection with products and services (the “GolfCard Services”) offered through GolfCard, including the GolfCard website or the GolfCard mobile application (collectively, the “App”. You accept this policy by using GolfCard Services on our App or by any other means.

If you have any financial product or service with us, including a GolfCard Card (defined below), we will use and share any Non-Public Information (“NPI”) as defined by the Gramm-Leach-Bliley Act (“GLBA”) that we collect from or about you related to your use of that product or service in accordance with our GLBA Privacy Notice.

Furthermore, you acknowledge that the use of any credit card offered by Celtic Bank, through GolfCard (a “GolfCard Card”) is governed by the Cardholder Agreement that is provided to you as well as Celtic Bank’s privacy policy.
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If you have any questions about our Privacy Policy or how it applies to specific data, please contact us at support@thegolfcard.com. We will make every effort to resolve your concerns.
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Any terms not defined in this Privacy Policy have the meanings given to them in our Terms.

1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to your Personal Information that you provide to us, that we collect through our App, and that we otherwise collect when you use or access the GolfCard Services. By accessing or using GolfCard Services, you agree to the collection, use, disclosure, and processing of your Personal Information as we describe in this Privacy Policy.

In this Privacy Policy, “Personal Information” means information that can be associated with a specific person and can be used to identify that person. Personal Information does not include information that has been aggregated and/or anonymized so that it does not identify a specific person.

When GolfCard shares your Personal Information with vendors and other third party service providers (“Third Party Service Providers”) who perform functions on our behalf, we require the security and confidentiality of your information, as well as limiting their use of the information to what is reasonable and necessary to carry out their work with us and comply with applicable laws and regulations.

This Privacy Policy does not apply to Third Party Service Providers that you elect to access through the GolfCard Services or that you share information with directly. While we attempt to facilitate access only to those Third Party Service Providers that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Service Providers. We encourage you to carefully review the privacy policies of any Third Party Service Providers you access.

The Third Party Service Providers that we work with include, but are not limited to, Plaid Inc. (“Plaid”) and Highnote Platform, Inc. (“Highnote”). By using our Services, you grant us, Celtic Bank, Highnote, and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal/) and Highnote in accordance with the Highnote Privacy Policy (https://highnote.com/agreements/privacy).

2. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT

We may collect Personal Information from you directly, from third parties, or automatically when you use our Services. We describe each source below.

Information We Collect Directly From You:

If you create a GolfCard Account, apply for a GolfCard Card or otherwise provide your contact information to us, you will provide us with Personal Information that may include:

Identifiers, such as your name, username, password, one-time passwords or other multi-factor authentication elements, email address, home address, date of birth, phone number, social security number, date of birth, and employment, address and income history.
Government-issued photo ID, such as a driver’s license or passport, photograph, proof of address documentation and proof of identity documentation.
Physical characteristics, demographic information, and related details (such as sex, race, gender, color, marital status, and citizenship status) present in the documents you provide us.

Information We Collect from your Authorized Bank Account:

As part of our GolfCard Services, you may provide a Third-Party Service Provider with access credentials (for example, username and password) that allow us to gain online access to one or more accounts that you maintain with a third-party financial institution and that you choose to designate for use in connection with GolfCard Services (each, an “Authorized Bank Account”).

We may receive different types of information from your Authorized Bank Accounts, including:

Account information, including your financial institution name, account name, and account type.
Account balance information, including current and available Authorized Bank Account balances.

If you choose to link your Authorized Bank Account, you authorize the use of this information to provide you with GolfCard Services. This authorization will remain in effect until you notify us that you wish to revoke this authorization, which may affect your ability to receive the GolfCard Services.

Information We Collect from your Use of the Services

We may collect the following Personal Information when you use the Services:

Payment Information: When you make payments through the Services, we or our third party payment processor, may collect information related to your payments, such as your payment method, account number, type, or expiration date.
Transaction Data: We currently monitor card transactions for your participation in the GolfCard Services including the Pure Golf Rewards Program. The data collected from you includes your registered card identifier, merchant, transaction date/time and amount.
Communications Information: We may collect information regarding communications with us, including through SMS, emails, communications with member services, voice recordings, chatbots, surveys, social media pages, and any other information or medium you choose to provide to us.
Inferences: We may make inferences from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. For example, we may infer your general geographic location (such as city, state, and country) based on your IP address.
Third Parties: We may collect information about you from third parties that perform services and analytics for us. Such companies may include credit bureaus, data providers, fraud detection services and data analytics providers, as well as certain of our Third Party Service Providers and their partners.

Information We Collect by Automated Means

We may use automated means to collect Personal Information when you use the GolfCard Services. Personal Information we collect by automated means may include:

When You Visit Our Website: When you visit our website, we may collect certain information automatically through various technologies, including cookies, pixels, and similar tracking technologies. This automatically collected information may include:
Device information (IP address, device type, operating system, browser type)
Usage information (pages visited, dates visited, time spent, clickstream data, referral URLs)
General location information (based on IP address)

When You Use Our Mobile App: When you use our mobile app, we may collect certain information automatically through various technologies and features built into our app and your device. This automatically collected information may include:
Device information (device type, operating system version, unique device identifiers, device settings, usage statistics)
App usage information (features used, in-app actions, session duration, app performance data)
Mobile ad identifiers (such as Apple's IDFA or Google's Advertising ID)
Location information, including precise geolocation data (if location permissions are granted)

For more details about the specific technologies we use to collect this information, including how to restrict or disable them, please see the "Technologies We Use" section below.

Aggregate and De-identified Information: We collect statistical information about both unregistered and registered users that is not Personal Information and cannot be tied back to you, your GolfCard Account or your web browser or mobile application (“Aggregate and De-identified Information”). Some of this information is derived from Personal Information. We may use Aggregate and De-identified Information for various business purposes where permissible under applicable laws and regulations, including for analytics or to develop or improve our services and marketing. We may share this Aggregate and De-identified Information with Third Party Service Providers for their business purposes. Third Party Service Providers may also share with us non-private, aggregated or otherwise non-Personal Information that they have independently developed or acquired.

We may also use and share Aggregate and De-identified Information for research, including research conducted by government entities, non-profit entities, and academic institutions. This may involve publishing findings or combining Aggregate and De-identified Information with other data sets, but such information will not be shared in a way that allows you or any other person to be personally identified.

3. How We Use Your Personal Information

We may use your Personal Information as described below:

Provide and improve the GolfCard Services: To provide our Services, including determining your eligibility, establishing GolfCard Accounts, fulfilling and processing transactions; creating records of transaction data; using transaction data such as transaction amount, transaction time and merchant location to confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for rewards; for internal purposes such as auditing the GolfCard Services, or for data analysis. We also use your Personal Information to improve, modify, or develop the GolfCard Services.
Fraud prevention, security, and privacy protection: To verify your identity; fight fraud (including spam or malware), security concerns, and other privacy-related concerns; and to analyze your interaction with the GolfCard Services (e.g., what links you click on).
Investigate misconduct: To investigate and address any potential misconduct or misuse of the GolfCard Services. This includes preventing or stopping, or attempting to prevent or stop, illegal activities, protecting the safety and legal rights of ourselves or others, and enforcing our Terms and other agreements.
Communicate with you and respond to requests: To communicate with you to respond to your inquiries, comments, or requests related to the GolfCard Services or to help you troubleshoot any issues you may be experiencing. We may also use your Personal Information to send you important notices. Because some of these communications are necessary, such as notices of changes to our terms or policies, you cannot opt out of receiving them.
Information we collect by automated means: We use information we collect by automated means to remember your preferences and settings, keep you logged in, improve App stability and performance, tailor the GolfCard Services, provide personalized content, understand how you use our Apps, and other similar uses.
Direct marketing, targeted advertising, and GolfCard Service updates: For direct marketing purposes, including sending you information we think may interest you. These advertisements may be both for our own products and services and for third-party products and services. For information about how advertising technologies we use work and how you can opt out, please see the "Technologies We Use" section below.
Analytics and performance monitoring: We use analytics services and other technologies to understand how the GolfCard Services are used and to improve performance. These services collect information about how you interact with the GolfCard Services. For details about these analytics technologies, please see the "Technologies We Use" section below.
Legal purposes and compliance with the law: To respond to actual or potential legal claims against GolfCard, Celtic, or any Third Party Service Provider and to comply with contractual and legal obligations under applicable law and for other legal purposes such as to enforce our Terms.
Consented purposes: For other purposes with your consent.

4. HOW, AND WITH WHOM, IS MY INFORMATION SHARED?

Information Disclosed for Our Everyday Business Purposes: We share information about you for our everyday business purposes, such as to process your application, assist in underwriting, process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.
Information Disclosed for GolfCard Services: We may provide transaction data and other information to Celtic, Highnote, and other Third Party Service Providers, the payment card networks, merchants, and other partners for use in connection with the program. This information may be Personal Information and NPI, such as your primary account number.
Information Disclosed for Marketing Purposes: We share information about you for our marketing purposes to offer products and services to you. See our Privacy Notice below for more information on our practices for sharing with non-affiliates for marketing purposes.
Information Disclosed Pursuant to Business Transfers: If we decide to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we (or substantially all of our assets) were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that may be transferred or acquired by a third party. Any acquirer of us or our assets may continue to use your Personal Information as set forth in and in accordance with this policy.
Information Disclosed for Our Protection and the Protection of Others: We reserve the right to access, read, preserve and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof, (iii) detect, prevent or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
Information We Share With Your Consent: In addition to the disclosures described in this General Privacy Policy, we may also share your information, which may include your Personal Information, in additional ways, if you consent.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. Technologies We Use

We and our Third Party Service Providers use technologies to provide content, advertising, and other functionality for our GolfCard Services. We typically use these technologies:

Cookies: Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. Cookies allow us to make it easier to use our sites. Unless you adjust your browser setting to refuse cookies, our system will issue cookies when you visit our site. We use two types of cookies: (1) session cookies, which remain in your browser while it is open, and (2) persistent cookies, which remain in your browser for the period specified by the cookie unless you delete it. Cookies may be provided by a first party, meaning us, or a third party, such as other companies.
Clear GIFs, pixel tags, and other Technologies: Clear GIFs are tiny graphics with a unique identifier, similar to cookies. Clear GIFs, however, are embedded invisibly on web pages. We may use clear GIFs (also called web beacons, web bugs, or pixel tags) with our services to track user activities, help us manage content, and compile statistics about the usage of our services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.
Third-party analytics: We use automated devices and applications, such as Google Analytics (more info here) to evaluate how our Services are used. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services and combine the information they collect about you from us with other information they have collected, which may include tracking activity across time and unaffiliated properties, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. Our Privacy Policy does not cover how these third parties use your data. Google will store the information that Google Analytics generates, which will be subject to Google’s privacy policies.

6. What Choices Do I Have Regarding My Information?

We offer you certain choices regarding your Personal Information.

You can always choose not to disclose certain information to us, but please note that certain information is required for use of GolfCard Services.
You may request that we remove your bank and financial information, although this may negatively impact your ability to use GolfCard Services.
You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and we will continue to store and use information we collected in connection with your past Account activity.
You can choose to not receive certain communications from us by clicking the “unsubscribe” link at the bottom of promotional emails or replying “STOP” to SMS messages. These choices do not apply to certain informational communications, such as surveys and mandatory communications. If you do not want to receive push notifications from us, you can use the settings on your mobile device to turn them off. We also offer push notifications on certain web browsers, which can also be turned off on your browser’s settings.

You may be able to restrict whether the technologies used can collect your Personal Information or track you, as discussed below.

Cookies and Personalized Advertising: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. But if you adjust your preferences, the Services may not work correctly. Please note that cookie-based opt-outs are not effective on mobile applications. That said, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, Google, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data and other advertising partners participating in self-regulatory programs. You can access these and learn more about targeted advertising, consumer choice, and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

Do-not-track signals: We do not respond to do-not-track signals. You may disable certain tracking as discussed above, such as by disabling cookies.

7. IS INFORMATION ABOUT ME SECURE?

We protect your Personal Information from unauthorized access and use by maintaining physical, electronic and procedural safeguards in compliance with applicable law. These measures include computer safeguards and secured files and buildings. We authorize our contractors and employees to access your information only when they need it to do their work, and we require companies that work for us to protect your information. However, we cannot guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

8. Additional Privacy Disclosures

What Information of Mine Can I Access? If you are a registered user, you can view information associated with your Account by logging into your Account or by contacting us at support@thegolfcard.com. In addition, you can access and delete cookies through your web browser settings, as detailed above.
How Can I Delete My Account? If you decide to delete your Account, you can do so by emailing support@thegolfcard.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. We will continue to store, access, and use information about you and your Account in compliance with this Privacy Policy and as required by any applicable legal or regulatory obligations.

Children’s Privacy: GolfCard’s products are not directed to minors under the age of 18. If GolfCard obtains actual knowledge that the company has collected personal information from a minor under the age of 18, GolfCard will promptly delete it, unless legally obligated to retain such data.

9. WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. If we make changes in the way we collect or use information, we will attempt to notify you by posting an announcement on the GolfCard Services or sending you an email; however, any changes to the Privacy Policy are effective as soon as we post them here.

For more information regarding this Privacy Policy, or if you have any questions or concerns, please contact us at support@thegolfcard.com.