Effective Date: July 1, 2026 Last Updated: July 1, 2026 This Privacy Policy explains how The System Golf, Inc. (the “Company,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information in connection with The System platform (the “Application”) and any associated website, including but not limited to the website at the URL: https://thesystem.golf (the “Website”) This Privacy Policy is intended for users of the Application, including coaches, instructors, tutors, administrators, parents, guardians, and other authorized users. It also describes how the Application may process information about students. Because U.S. privacy law includes federal, state, and sector-specific requirements rather than one comprehensive national privacy law, additional notices or rights may apply depending on residence, age, role, or context. 1. Scope This Privacy Policy applies to personal information processed through the Application, the Website, support channels, communications, and services. This Privacy Policy does not apply to third-party websites, applications, or services that are not controlled by us. If the Application is used by or through a club, school, coaching organization, employer, or other organization, that organization may have its own privacy obligations and policies. 2. Personal Information We Collect We may collect the following categories of personal information. A. Account and Contact Information name; email address; phone number; organization name; account credentials; role or title; billing and subscription information. B. Student Profile Information student name; age, grade level, skill level, or similar profile details; parent or guardian contact information; coaching goals; lesson history; attendance or scheduling information; preferences, notes, and progress information. C. Lesson and Coaching Information lesson notes; drills; assignments; feedback; follow-up tasks; action items; next-lesson plans; review and send decisions; source or proof references. D. Media and Transcript Information voice recordings; video recordings; images; audio files; transcript text; media references; files uploaded by users. Voice, video, image, and transcript data may be sensitive depending on content, applicable law, and whether the data relates to a minor. Updated rules under the federal Children’s Online Privacy Protection Act (“COPPA”) treat certain biometric identifiers, including voiceprints and facial templates, as personal information for children under 13. E. Calendar and Scheduling Information lesson dates and times; availability; reminders; calendar context; event details; related metadata. F. AI Interaction Information prompts; instructions; generated summaries; draft follow-ups; recommended next actions; classifications; model outputs; user edits, approvals, rejections, and feedback. G. Device, Usage, and Technical Information IP address; browser type; device identifiers; operating system; log data; pages or features accessed; error reports; authentication events; security logs; approximate location derived from IP address. H. Communications support requests; emails; chat messages; feedback; survey responses; other communications with us. 3. Sources of Personal Information We may collect personal information from: users who enter or upload information; coaches, instructors, tutors, administrators, parents, guardians, or authorized representatives; connected calendars or integrations, if enabled; third-party service providers; Application logs and analytics; AI-assisted workflows within the Application. 4. How We Use Personal Information We may use personal information to: provide, operate, and maintain the Application; create and manage accounts; maintain student profiles and lesson records; store lesson notes, drills, media, transcripts, and follow-up states; generate lesson summaries, draft follow-ups, next-lesson plans, task classifications, and recommended actions; provide source-backed context and references; enable review and approval workflows; support gated external actions; provide customer support; communicate about the Application; improve Application functionality, reliability, and usability; monitor security and prevent fraud, misuse, or unauthorized access; debug, audit, and troubleshoot; comply with legal obligations; enforce terms and policies; protect rights, safety, and property. We do not intend for AI-assisted features to make final decisions about students without human review. 5. AI Processing The Application may process personal information using AI or automated systems to assist users with summaries, drafts, recommendations, classifications, and lesson preparation. The coach or authorized human user remains responsible for reviewing AI-assisted outputs before using, sending, or relying on them. Unless expressly stated in a separate agreement or consent notice, we will not use children’s personal information for AI model training in a manner that requires separate parental consent without obtaining required consent. FTC commentary on updated COPPA rules states that disclosures of children’s personal information for AI training are not integral to a website or online service and may require separate verifiable parental consent. 6. How We Disclose Personal Information We may disclose personal information to the following categories of recipients. A. Service Providers We may disclose information to vendors that help us provide the Application, such as: hosting providers; database providers; storage providers; transcription providers; AI service providers; analytics providers; email and notification providers; customer support tools; security and monitoring vendors; payment processors. The Application architecture may reference records backed by third-party infrastructure providers, so third-party infrastructure providers may process stored records, including student, lesson, transcript, media-reference, follow-up, and source-reference data. B. Authorized Users and Organizations Information may be visible to coaches, administrators, parents, guardians, or other authorized users depending on account settings and permissions. C. Integrations If users connect third-party calendars, messaging tools, learning tools, or other integrations, information may be exchanged with those services as directed by the user. D. Legal and Safety Disclosures We may disclose information when we believe disclosure is necessary to: comply with law; respond to lawful requests; protect rights, safety, or property; prevent fraud, security incidents, or misuse; enforce terms and policies. E. Business Transfers We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction. 7. Selling, Sharing, and Targeted Advertising We do not sell student personal information. We do not use student personal information for targeted advertising. We do not knowingly sell or share personal information of children under 16. If our practices change, we will update this Privacy Policy and provide required notices, opt-outs, and consents. State privacy laws often give residents rights to opt out of sale, targeted advertising, and certain profiling, though definitions and thresholds differ by state. 8. Children’s Privacy The Application may process information about students, including minors, when provided by coaches, parents, guardians, schools, or authorized organizations. If the Application is directed to children under 13, or if we knowingly collect personal information directly from children under 13, we will comply with COPPA, including required parental notices and verifiable parental consent. For children under 13, we will: provide required parental notice; obtain verifiable parental consent when required; allow parents to review personal information collected from the child; allow parents to request deletion of the child’s personal information; limit collection to what is reasonably necessary; retain children’s personal information only as long as reasonably necessary for the disclosed purpose; avoid indefinite retention of children’s personal information; obtain separate consent where required for disclosures to third parties, including certain advertising or AI-training-related disclosures. The FTC’s updated COPPA rule requires covered operators to obtain verifiable parental consent before collecting, using, or disclosing personal information from children under 13 and includes new requirements addressing third-party disclosures, retention limits, and biometric identifiers. 9. Student Privacy and School Use We do not anticipate that the Application will be used by a club, school, or educational institution, but will be used by individual users that are self-employed or are independent contractors. However, if the Application is used by a school or educational institution, the school may be responsible for determining whether laws such as FERPA, state student privacy laws, or school district rules apply. Where required by a separate written agreement, we will process student information as a service provider or school official and will use student information only for authorized educational or school purposes. Schools, parents, guardians, and authorized users should not upload student information unless they have the authority to do so. 10. Sensitive Personal Information The Application may process sensitive personal information if users upload or enter that information. Sensitive personal information may include: precise or approximate location information; student information; voice, video, images, or transcripts; health-related information if included in notes; biometric information if the media is processed to identify or authenticate a person; information about minors. Users should avoid uploading sensitive personal information unless necessary for the intended coaching purpose and authorized by law. We do not intend to use sensitive personal information to infer characteristics unrelated to the coaching workflow. 11. Data Retention We retain personal information for as long as reasonably necessary to provide the Application, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and maintain security. Retention periods may depend on: account status; organization settings; subscription terms; legal requirements; the type and sensitivity of data; user deletion requests; backup and disaster recovery schedules. For children’s personal information covered by COPPA, we will not retain the information indefinitely and will retain it only as long as reasonably necessary for the purpose for which it was collected, as required by the updated FTC rule. 12. Data Security We use reasonable administrative, technical, and physical safeguards designed to protect personal information. These safeguards may include: access controls; authentication; encryption in transit; vendor security review; logging and monitoring; role-based permissions; backup controls; incident response procedures. No security measure is perfect. Users should protect account credentials and limit access to authorized personnel. 13. Data Location Personal information may be processed and stored in the United States or other locations where we or our service providers operate. If information is transferred across borders, we will use safeguards required by applicable law. 14. Privacy Rights Depending on the user’s location and applicable law, the user may have rights to: know or confirm whether we process personal information; access personal information; correct inaccurate personal information; delete personal information; obtain a copy of personal information; opt out of sale, sharing, targeted advertising, or certain profiling; limit certain uses of sensitive personal information; withdraw consent where processing is based on consent; appeal a denied privacy request. State privacy laws vary in scope, thresholds, and rights, but many provide rights to access, delete, and opt out of certain data uses. To exercise privacy rights, contact us at privacy@thesystem.golf. We may need to verify identity before fulfilling a request. Authorized agents may submit requests where permitted by law. 15. California Privacy Notice If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us, California residents may have additional rights, including rights to know, delete, correct, opt out of sale or sharing, limit use of sensitive personal information, and not be discriminated against for exercising privacy rights. In the preceding 12 months, we may have collected the categories of personal information described in Section 2 above. We do not sell student personal information. We do not use student personal information for targeted advertising. If we engage in activities deemed “sharing” or “sale” under California law, we will provide required notices and opt-out mechanisms. California’s privacy law is broader than many other state laws and applies to for-profit businesses meeting specified thresholds, including revenue, processing-volume, or sale/share revenue thresholds. 16. Cookies and Similar Technologies We may use cookies, pixels, local storage, SDKs, and similar technologies to: keep users signed in; remember preferences; secure the Application; understand usage; improve performance; detect fraud or misuse. If required by law, we will provide cookie notices and choices. 17. Communications Preferences Users may receive administrative messages, service updates, security notices, and support communications. Users may opt out of marketing emails by using the unsubscribe link or contacting us. Transactional or service-related communications may still be sent. 18. Do Not Track and Global Privacy Controls Some browsers or devices offer “Do Not Track” or global privacy control signals. Where required by applicable law, we will honor legally recognized opt-out preference signals. Colorado and certain other state privacy laws include requirements related to universal opt-out mechanisms. 19. Changes to This Privacy Policy We may update this Privacy Policy from time to time. If changes are material, we will provide notice as required by law. The updated Privacy Policy will be effective when posted unless a later date is stated. 20. Contact Us Questions or requests about this Privacy Policy may be directed to: The System Golf, Inc. 67 Grove Hill Ave Newton, MA 02460 privacy@thesystem.golf (617) 433-8773
The System Golf, Inc. · Legal