my4moles

We at Goldfish Information Technologies (P) Ltd. respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private. As the owner and operator of www.4moles.com (the "Website") and our mobile application 4moles Golf Handicap & Booking (the "App"), hereafter referred to in this Privacy Policy as "4moles", "us", "our" or "we", we have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Website and mobile App (collectively referred to as “user” or “you”). For the purposes of this Agreement and our Terms of Service, any use of the terms "4moles", "us", "our" or "we" includes Goldfish Information Technologies (P) Ltd., without limitation. We will not use or share your personal information with anyone except as described in this Privacy Policy.

This Privacy Policy will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data. Furthermore, this Privacy Policy is intended to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and the laws implementing GDPR.

For the purpose of this Privacy Policy the Data Controller of personal data is 4moles and our contact details are set out in the Contact section at the end of this Privacy Policy. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For purposes of this Privacy Policy, "Your Information" or "Personal Data" means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information ("PII") and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include information, comments, content and other information that you voluntarily provide.

4moles collects information about you when you use our Website or App to access our services, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The term Services includes, collectively, various applications, websites, widgets, email notifications and other mediums, or portions of such mediums, through which you have accessed this Privacy Policy.

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site and in the App. Those changes will go into effect on the "Last updated" date shown at the end of this Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, "USE OF YOUR INFORMATION") AS DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS OF SERVICE FOR 4MOLES WHICH MAY BE ACCESSED HERE (TERMS OF SERVICE). IF YOU DO NOT AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE YOU MAY NOT ACCESS OR USE OUR SERVICES.

We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, order a membership to our Services, complete a form, survey, quiz or application, contact customer support, make a purchase, or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, phone number, photograph, credit card or other method of payment information, or any other personal information you choose to provide.

The following are situations in which you may provide Your Information to us:

• When you fill out forms or fields through our Services;
• When you register for an account with our Service;
• When you create a membership for our Services;
• When you upload a score into your profile;
• When you track golf course distances using the GPS;
• When you answer questions on a quiz/opinion poll;
• When you share news or post on myCircle;
• When you send a friend request to someone and give permission to access the contact list for invitation purposes.
• When you order bookings/services or products from, or through our Service;
• When you communicate with us or request information about us or our products or Services, whether via email or other means;

When you participate in any of our marketing initiatives, including, events, or promotions; and When you participate in forums, reviews or provide or post user generated content or other submissions.

We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies. We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.

We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your account with a social media service, e.g. LinkedIn, Facebook or Twitter, or a payment provider, e.g. Apple Pay or Google Wallet and third party payment, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.

We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and other users. This includes, without limitation, identity data, contact data, marketing and communications data, technical data and content data.

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.

When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

When you use the Services we may collect your precise location data. We may also derive your approximate location from your IP address.

We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, and information access authorization controls. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4moles uses third party payment processing gateways to collect, store and process payment information. Our current third party payment processors are CCAvenue & other 4moles does not store this information on our Website or servers.

The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:

• When signing up to use our Services, you have given us explicit consent allowing 4moles to provide you with our Services and generally to process your information in accordance with this Privacy Policy;
• It is necessary for entering into, or performing, the obligations of a contract between you and 4moles, including, without limitation, the Terms of Service agreement which may be accessed by you here (Terms of Service) and any membership/subscription for our Services that you order;
• It is necessary to register you as a user, manage your account and profile, and authenticate you when you log in.
• It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;
• To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.
• To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages.
• To send promotional communications that may be of specific interest to you.
• It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you;
• It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.

Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared.

We will use this information in order to:

• Provide users with our Services and customer support including, but not limited to, confirming emails related to our services, reminders, confirmations, requests for information and transactions.
• To process transactions and send users related information, including confirmations and invoices.
• Provide you with technical support, technical notices, updates, security alerts and administrative messages.
• Analyze, improve and manage our Services and operations.
• Resolve problems and disputes, and engage in other legal and security matters.
• Enforce our Terms of Service and any terms and conditions of any subscription for our Services.

Additionally, we may use the information we collect about you to:

• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of 4moles and other companies, where permissible and according to local applicable laws.
• Display advertising, including advertising that is targeted to you or other users based on your location, interests, as well as your activities on our Services.
• Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.

We will take appropriate measures to protect your personal information in accordance with this Privacy Policy.

We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

• With third party Service Providers to enable them to provide the Services you request;
• With the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public;
• With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate;
• With affiliated entities that provide payment processing services on our behalf;
• With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of 4moles or others;
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• If we otherwise notify you and you consent to the sharing; and
• In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.

We may disclose Your Information:

• To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
• To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security.

These companies are authorized to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;

• As required by law or ordered by a court, regulatory, or administrative agency;
• As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another's rights or property, including, without limitation, our rights or property;
• If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
• To enforce our Terms of Service, this Privacy Policy, and any other applicable agreements and policies;
• To enforce or protect our legal rights.

• Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other Apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
• Any information or content that you voluntarily disclose for posting publicly to our Service or the social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to our Service or the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using our Service or the social sharing service, have re-shared, copied or saved that User Content.

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use Cookies, software development kits (SDKs), and other technologies to identify your device when you visit our Site and use our Services, as well as when you visit other online sites and services.

• You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
• Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that 4moles does not share certain information as described in this Privacy Policy, you can direct 4moles not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
• Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
• Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
• Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
• Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
• Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.

Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 2 years and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for as long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).

If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at :

Goldfish Information Technologies (P) Ltd. B-11, Westend, New Delhi - 110021 • INDIA,

Email: [email protected].

We will address your concerns in accordance with applicable law.

Last Updated On 18-Apr-2024
Effective Date 18-Apr-2024