Acushnet Thailand Privacy Notice

Effective Date: February 18, 2025

Last Updated: February 18, 2025

Previous Update: October, 2020

1. Introduction and Scope

Acushnet Golf (Thailand) Ltd. and its affiliates (collectively, "Acushnet"), respects your concerns about privacy. Unless otherwise indicated, all Acushnet brands, including but not limited to Titleist, FootJoy, Vokey, Scotty Cameron, Links & Kings, Pinnacle, etc., follow this Privacy Notice where published.

This Privacy Notice describes the types of personal information we obtain about you, how we use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard personal information and how you can contact us about our privacy practices.

Our practices comply with Personal Data Protection Act B.E. 2562 (2019).

2. Data Protection Officer (DPO)

We have appointed a Data Protection Officer to oversee our data protection program:

Contact Details:
Data Protection Officer,
Acushnet Golf (Thailand) Ltd.
1858/3-4 Interlink Tower Bangna 4th Floor,
Debaratna Road KM.4.5, South Bangna
Bangna, Bangkok, Thailand 10260
Email: Dpo_SEA@acushnetgolf.com

We aim to respond to all data-related queries within 5 business days and fulfill access requests within 30 days.

3. Information We Obtain

We may obtain certain personal information that you choose to submit to us through our Online Services, including:

  • contact information, such as name, email and postal addresses, and phone number;
  • login credentials when you create an account through our Online Services;
  • payment card details, which are collected by our third-party payment processor on our behalf;
  • gender and age or date of birth;
  • government identification;
  • information about products and services purchased, product sizes, measurements and customizations, interests and preferences, and experience with our products and services;
  • professional information, such as your occupation and job title;
  • information we obtain from third-party social media services if you choose to link to, create, or log into your account with us through these services; and
  • other information you choose to provide, such as through communications with us.

Information We Obtain By Automated Means

When you visit our Online Services, we may obtain certain information by automated means, such as cookies, web beacons, web server logs, and other technologies. The information we collect in this manner may include:

  • your IP address, unique device identifier, web browser characteristics, device characteristics;
  • operating system, WiFi network identifiers and signals, language preferences;
  • details about your interactions with our Online Services (pages visited, clickstream data);
  • dates and times of your visits.

For additional information, please see our cookie policy.

4. How We Use The Information We Obtain

We collect, use, and disclose your personal data for the following purposes :

Core Business Purposes

  • Providing our products and services
  • Processing and fulfilling your orders
  • Managing your account and verifying your identity
  • Processing payments and maintaining transaction records
  • Delivering products and tracking shipments
  • Providing customer support and responding to inquiries

Additional Uses

  • Personalizing your shopping experience
  • Analyzing and improving our services
  • Conducting market research
  • Detecting and preventing fraud
  • Ensuring security of our platforms
  • Complying with legal obligations

Marketing Communications

With your consent, we may use your personal data to:

  • Send promotional materials;
  • Provide updates about new products;
  • Inform you about special events and offers;

You may withdraw your consent for marketing communications at any time by contacting our DPO or using the unsubscribe options provided.

Note: Withdrawing consent for core business purposes may affect our ability to provide services to you.

5. Legal Basis for Processing

Under the Personal Data Protection Act B.E. 2562 (2019), we process your personal data based on the following legal bases:

  • Contract Performance: We process your personal data where necessary to perform our contract with you or to take steps at your request before entering into a contract.
  • Legal Obligations: We process your personal data where necessary to comply with our legal obligations.
  • Legitimate Interests: We process your personal data based on our legitimate interests, provided these interests don't override your fundamental rights, such as preventing fraud or improving our services.
  • Consent: We process your personal data based on your consent for marketing communications, and use of analytical cookies.

6. How Long We Store Information

We will retain your personal information for the period reasonably necessary to achieve the purposes described in our Privacy Notice, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

7. Third Party Analytics

We use third-party web analytics services, such as Google Analytics, to understand how visitors use and improve our Online Services. These service providers collect the following information through cookies, web beacons, and similar technologies:

  • Pages visited and navigation patterns;
  • Time spent on each page;
  • Device information (browser type, operating system);
  • General location data (city/country level); and
  • IP address (in anonymized form)

This information helps us:

  • Analyze website traffic and user behavior;
  • Improve our Online Services;
  • Enhance user experience; and
  • Measure the effectiveness of our features.

You can opt out of Google Analytics by:

Analytics data may be processed in servers located outside Malaysia, including in the United States. We ensure appropriate safeguards are in place through contractual agreements with our analytics providers.

8. Interest Based Advertising

Through our Online Services, we may collect information about your online activities to provide you with advertising tailored to your interests. You may see our ads on other websites because we participate in advertising networks. These networks track your online activities over time by collecting information through automated means, including through cookies, web server logs, and web beacons.

To opt out of interest based advertising you can:

  • Device Settings: Use your device or browser settings to limit tracking or reset the advertising identifier
  • Cookie Controls: Adjust your cookie settings through our Cookie Preferences tool.
  • Contact our DPO at Dpo_SEA@acushnetgolf.com

Note: Even if you opt out of interest-based advertising, you will still see ads, but they won't be tailored to your interests.

9. How We Share The Information We Obtain

We may disclose your personal data to the following categories of recipients:

  • Our employees who require access to perform their duties
  • Service providers who process personal data on our behalf, including:
  • Payment processors
  • Delivery partners
  • IT service providers

As required by the Personal Data Protection Act B.E. 2562 (2019), we ensure that these recipients maintain appropriate security measures to prevent unauthorized or unlawful processing, and against accidental loss or destruction of personal data. We have written agreements in place that require them to process personal data only on our instructions and in accordance with applicable data protection laws.

10. How We Protect Personal Information

We implement appropriate measures to maintain security and prevent unauthorized, accidental, or unlawful loss, access, use, alteration, disclosure, or destruction of your personal data. In the event of a personal data breach that poses a risk to the rights and freedoms of individuals, we will notify the Personal Data Protection Committee within 72 hours of becoming aware of the breach. Where a breach is likely to result in a high risk to your rights and freedoms, we will notify you and the affected individuals without undue delay.

11. Children's Privacy

Our Online Services are intended for a general audience and are not directed to children under the age of 18. We do not knowingly collect personal information online from children under the age of 18. If you believe we have inadvertently collected such data, please contact our DPO at the earliest.

12. Your Rights Under the PDPA

Under the Personal Data Protection Act B.E. 2562 (2019), you have the following rights:

Right to Access and Obtain Copy:

  • Right to access and obtain a copy of your personal data;
  • Right to request disclosure of how your personal data was obtained without your consent

Right to Data Portability:

  • Right to receive your personal data in a commonly used and machine-readable format;
  • Right to request we send your personal data directly to another data controller

Right to Object:

  • Right to object to the collection, use, or disclosure of your personal data;
  • Right to object to processing for direct marketing purposes at any time

Right to Erasure:

  • Right to request erasure or destruction of your personal data;
  • Right to request we anonymize your personal data.

Right to Restrict:

  • Right to request restriction of use of your personal data

Right to Rectification:

  • Right to request correction of your personal data to ensure accuracy

Right to Withdraw Consent:

  • Right to withdraw your consent at any time
  • Withdrawal will not affect the lawfulness of processing based on consent before withdrawal

To exercise these rights or if you have questions about your personal data, please contact our Data Protection Officer at Dpo_SEA@acushnetgolf.com

13. Updates to This Policy

This Privacy Notice may be updated periodically to reflect changes in our personal information practices. We will post a notice on our Online Services to notify you of significant changes to our Privacy Notice and indicate at the top of the Notice when it was most recently updated.

14. How To Contact Us

If you have any questions about this Privacy Notice, please contact us at Dpo_SEA@acushnetgolf.com. We aim to respond promptly to your privacy questions or concerns.