Privacy Policy

08/16/2024

Information about us and our Privacy Policy

BBP Investment Holdings, LLC and Brunswick Bowling Products, LLC ("we", “us”, or "Brunswick") have established this Privacy Policy (this “Policy”) to explain how we treat information we collect from you through Sync Scoring, Sync Management, www.BrunswickCloud.com, www.SyncPassport.com, www.playpinpix.com, www.brunswickbowling.com, www.brunswickbowlinginternational.com, www.columbia300.com, www.dv8bowling.com, www.ebonite.com, www.hammerbowling.com, www.powerhousebowling.com, www.radicalbowling.com, www.robbys.com, www.trackbowling.com, www.ultimatebowling.com, www.easy-strike.com (“Websites”) and the related websites, mobile applications, networks, widgets, software, tools, mobile, scoring, management, business transactions and other similar services provided by us (collectively, together the “Services”) and through participating bowling centers/family entertainment centers/leisure centers/restaurants/etc. (“Center” or “Centers”).

This Policy does not apply to personal information collected from you in other ways, including through third parties, or through websites that we do not own or control. We reserve the right to change this Privacy Policy at any time, so please review it frequently. If we change this Policy, we will post a revised Policy on our Sites. If you continue to use the Services thereafter, you hereby provide your consent to the revised Policy. By using the Services, you consent to the collection, use, and disclosure of Personal Information in accordance with this Policy.

Personal Information

“Personal Information,” as used in this Policy, is information that specifically identifies an individual, such as an individual's name, address, telephone number, e-mail address, or similar personal data. Personal Information also includes information about an individual’s activities, such as (but not limited to) information about his or her activity on our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked to Personal Information that identifies that individual.

Personal Information does not include “aggregate” or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

Information We Collect

Collection of Voluntarily Provided Information

We collect Personal Information that our users provide to us in a variety of ways on our Services. These include the following:

User Accounts and Profiles:

We give you the ability to register for a personal account and to create and update a user profile on the Services. When you register an account on the Services, we require that you provide your email address, and at your option, user name, password, user profile, date of birth, and additional biographical information. You are also given the opportunity to associate your account with a bowling center or centers. We may indicate that some information is required for you to register for the account or to create the profile, while other information is optional.

Integrated Services:

You may access or register for the Services through the use of your user name and passwords for certain services provided by third parties (each an “Integrated Service”), such as through the use of your Facebook credentials through Facebook Connect. By doing this, you authorize us to access and store the credentials you provide, your name, email address(es), date of birth, gender, current city, profile picture URL, and other similar information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your Facebook or other Integrated Service privacy settings to understand and change the information sent to us through Facebook Connect or other Integrated Services. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Services.

Entertainment Features:

As part of the experience in the Center, you have the ability to provide information as part of the session/attraction/game/etc. This could include, but not limited to, names, pictures, user selections, scores, and scoring statistics. This information is only available for the specific session and is used for individual customer service.

Interactive Features:

The Services may contain interactive functionality that allows you to engage with other users on the Services. If you use any interactive functionality on our Services that request or permit you to provide us with Personal Information (including, for example, any services that allow you to post user materials on any of our Services), we collect the Personal Information that you provide to us in the course of using these interactive features.

Correspondence:

If you contact us by e-mail, using a contact form on the Services, or by mail, fax, or other means, we collect the Personal Information contained within, and associated with, your correspondence. We may also collect information from or about you through your contact with our customer support teams, sales teams, or other employees of our organization. The use of this information is limited to the purpose for which you contacted us.

We limit the use of SMS (text messages) to conversational purposes only.  If you initiate a conversation with one of our employees via SMS, then consent is implied.  If you no longer wish to receive messages from that employee, simply reply “Stop” to any message.  SMS consent and phone numbers will never be shared with third parties or affiliates under any circumstances. SMS consent is not shared with any third parties or affiliates for marketing purposes.

Appointment information:

Centers may collect your information at the Center as it pertains to an appointment. This appointment may be made via online reservation, phone reservation, waitlist reservation, or other. When making an appointment, the center may collect your name, phone number, email address, shoe size, address, and additional personal details as it relates to the appointment. This data is stored at the center and may be recalled for future correspondence or reporting.

E-mail Newsletters:

We or a Center may offer e-mail newsletters from time to time on our Services. If you sign up to receive a newsletter from us or the Center, we collect your e-mail address.

Passive Information Collection

When you visit the Website, we automatically collect information such as (but not limited to) your IP address, cookie information, browser type, system type, the content and pages that you access on the Site, the dates and times you access the Website, and the “referring URL” (i.e., the page from which you navigated to the Website). Similarly, when you use the Services from a mobile device, we automatically collect a variety of information about your mobile device and your use of the Services, such as your IP address, Device ID (as defined below), device type and operating system, browser type, as well as the dates and times you access or use the Services, and actions you engage in using the Services. This information is gathered for all users.

When you sign in at a participating Center, we automatically collect information such as game information, activity, scores, and purchase history. This information is gathered for all users and the data collected is only available to Brunswick, the involved Center, and you.

We may collect this information passively using technologies such as (but not limited to) standard server logs, cookies, and clear GIFs (also known as “web beacons”). If we link or associate any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this policy. Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form.

Information from Other Sources

We may receive information about you, including Personal Information, from third parties (such as affiliated bowling centers) and may combine this information with other Personal Information we maintain about you. If we do so, this Policy governs any combined information that we maintain in personally identifiable format.

Use of Information

In general, we will only use the information you provide to us, including Personal Information, for the purpose for which such information was provided. For example, we use the information you provide us when registering for an account on the Services to create your user account and enable your interaction with other users of the Services. We may also use this information to deliver to you information about Brunswick or to conduct trend analysis, pattern detection, and Website administration. Users may opt-out of receiving future mailings from Brunswick and other entities by following the instructions set forth in the opt-out section of the mailings.

Non-personal demographic and profile data is used to tailor your experience of the Services, showing you content we think you might be interested in. This information may also be shared with advertisers on an aggregate non-personal basis.

We use your IP Address to help diagnose problems with our server, and to administer our Website.

When you view our Website, we may store some information on your computer. This information will be in the form of a “cookie” or similar file. We use cookies to deliver content specific to your interests and to prevent you from reentering all your registration data at each connection.

Your data is available to the following parties:

• Authorized Center staff at centers you associate with
• Brunswick Data Controller and Compliance Teams
• Brunswick Engineering to maintain, support, and improve the services
• Brunswick employees engaged in providing requested services to you

Disclosure of Personal and Other Information

We may provide certain automatically-collected, aggregated, or other data, including Personal Information, to our subsidiaries, affiliated companies and other trusted businesses or persons for various purposes, including providing and improving the Services (e.g., payment processing and transmission of communications); compliance with reporting obligations; for business or marketing purposes; to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services; and for our other purposes described in this Policy. For example, if you would like to redeem awards at a participating bowling center, we will disclose certain Personal Information to the bowling center in order to authenticate the transaction. We will share Personal Information with our Partners once you have opted in to associate your account with their bowling center. We limit the Personal Information shared with these third parties to that which is necessary to carry out those functions and require that our partners respect and comply with applicable law as a condition of doing business with them. We may share Personal Information and other information with third parties (including regulatory or law enforcement authorities) in order to carry out a user's request or if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

Some features of the Services may allow you to upload, post, or otherwise transmit user material (“User Materials”) to public areas of the Services, such as content that you post in a public profile on the Services. We may make these User Materials available for display upon Brunswick properties that are not governed by this Policy, as well as to services operated by third parties (such as affiliated bowling centers) that display content from the Website (collectively, “Syndicated Services”). Please be aware that any Personal Information that you include within any User Materials will be made available to other users of the Services who view it. You include Personal Information in User Materials at your sole risk. We may allow you to select privacy options that limit access to some types of Personal Information in User Materials, but no security measures are impenetrable or perfect. Additionally, even after information posted on the Services is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Services. We cannot warrant or guarantee that any Personal Information that you provide on and in connection with the Services will not be accessed, viewed, or used by unauthorized persons.

If you post any information to a public area of the Services, including your Personal Information, please be aware that it is no longer "Personal Information" for the purposes of this Policy, and we or anyone else may use such information without restriction. If you provide access to Personal Information or other information to a limited set of other users through any of our privacy controls or other settings, please understand that Brunswick has no control over how others may collect, use or disclose such information.

Note that when you sign into your Services user account, bowl and record games at participating bowling centers, information about your games will be broadcast, real-time, on the System. By using the Service, you expressly agree that information about your bowling games may be broadcast real-time to other users and visitors to the Website.

Other Websites; Links

The Services may contain links to other websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this Policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. We are not responsible for the privacy practices of these third-party websites and services. We encourage you to carefully review the privacy policies applicable to any such website or service you visit before providing any personal information on them.

Data Retention and Deletion

User data entered for Services under User Account & Profiles, Integrated Services, and Email Newsletters (under the Collection of Voluntarily-Provided Information section) is stored and retained until a user deletes their account. No data is removed unless at the request of the user.

User data for Appointment information (under the Collection of Voluntarily-Provided Information section) hosted at the Center is defaulted at 400 days from the origination of the appointment, but the retention length can be changed at the discretion of the Center. Active transactions are deleted after 30 days along with any email address included in the transaction.

Names, scores, and statistics for Entertainment Features (under the Collection of Voluntarily-Provided Information section) hosted at the Center is defaulted at 120 days from the origination of the session, but the retention length can be changed at the discretion of the Center. All other information from the session (ex. Pictures) are immediately deleted.

Users can export customer data, via the functionality of the Sync Passport Service, at any time during the term of the agreement or by contacting privacy@brunswickbowling.com. Users can also delete customer data, via the functionality of the Sync Passport Service or by emailing your request to privacy@brunswickbowling.com., at any time. When Brunswick receives a complete deletion instruction from you, Brunswick and any applicable Center will delete the relevant customer data from applicable systems within a maximum period of 180 days unless retention obligations apply.

User data collected for Correspondence (under the Collection of Voluntarily-Provided Information section) may be accessed, corrected, or deleted upon request by contacting privacy@brunswickbowling.com.

Children’s Privacy

The Services are intended for general audiences and is not directed to children under 16. We do not knowingly collect or maintain Personal Information from persons under 16 years of age on the Services, and no part of the Services is directed to persons under 16. If we learn that Personal Information of children under the age of 16 has been collected on the Services without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 16 has obtained an account for any of the Services or otherwise provided Personal Information to us, then you may alert us at support@brunswickbowling.com and request that we delete that child’s Personal Information from our systems.

Cookie Policy

A cookie is a small file placed onto your device that enables website features and functionality. Brunswick uses cookies to recognize you when you visit SyncPassport or related sites and applications, remember your preferences, and give you a personalized experience that’s in line with your settings. Additionally, cookies allow us to bring customized features to you through SyncPassport plugins such as our “Share” button. Brunswick does not use cookies for any advertising purposes.

Categories of Use and Description

Authentication: If you’re signed in to SyncPassport or other Brunswick Websites, cookies help us show you the right information and personalize your experience.

Security: We use cookies to enable and support our security features, and to help us detect malicious activity and violations of our Service Terms.

Preferences, features and services: Cookies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on SyncPassport and other Brunswick Websites more easily.

Performance, Analytics and Research: Cookies help us learn how well our site and plugins perform in different locations. We also use cookies to understand, improve, and research features and services, including when you access Brunswick Websites from other websites, applications, or devices such as your work computer or your mobile device.

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

Security

Our Website has industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. Brunswick operates global infrastructure designed to provide state-of-the-art security through the entire information processing lifecycle. This infrastructure is built to provide secure deployment of services, secure storage of data with end-user privacy safeguards, secure communications between services, secure and private communication with customers over the Internet, and safe operation by administrators. Brunswick Services run on this infrastructure.

Business Transfers

Information about our users, including Personal Information, may be disclosed as part of any merger, acquisition, or sale of company assets, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which Personal Information would be transferred as one of our business assets.

International Users; Cross-Border Transfers; Compliance

Brunswick is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the EU-US and Swiss-US Privacy Shield Frameworks, to the Frameworks’ applicable Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about these Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website.

Primarily, the Services are hosted in the United States, however data can reside in any of our geographically diverse data centers throughout the world. If you use our Services from the other regions with laws governing data collection and use that may differ from United States law, please note that you are transferring your personal data to the United States. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing your Personal Information, you consent to the transfer of your Personal Information to the United States and to other world regions and the use of your Personal Information in accordance with this Policy.

Brunswick is responsible for the processing of personal data it receives, and under Privacy Shield we may subsequently transfer that data to a third party acting as an agent on our behalf. Brunswick complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Brunswick is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Brunswick may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Brunswick Bowling Products, LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brunswick Bowling Products, LLC via email at privacy@brunswickbowling.com.

Brunswick Bowling Products, LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland and human resources data transferred explicitly from the EU in the context of the employment relationship.

Under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your Additional Privacy Rights as a Resident of Certain U.S. states

The rights described in this section apply only if you are a resident of a state within the United States that has an applicable and effective privacy law providing for the below rights. 

• Data portability: You can ask for a downloadable copy of your personal information in a machine-readable format. You can also request that we transmit the data to someone else where it’s technically possible.
• Knowledge and access: You may have the right to know more about personal information that we have collected and disclosed in the preceding 12 months. You may be able to access, receive details on collection, the purpose of processing, and any sharing that may have occurred.
• Deletion: You have the right to request Brunswick to delete the personal information we have collected about you under certain circumstances.
• Non-discrimination for the exercise of your privacy rights: You have the right to not receive discriminatory treatment by Brunswick for the exercise of your privacy rights.  
• Rectification: If you believe that any personal information we are holding about you is incorrect or incomplete, you can request that we change, correct, or supplement the data.
• Opt-out of selling or sharing your personal information: Brunswick does not sell or share your personal information.  You have the right to request Brunswick to not share your personal information for the purposes of cross-context behavioral advertising or targeted advertising. 
• No Automated Decision Making: We do not undertake any decision making about you based solely on automated processing, including profiling. 

We will not share your personal information with third parties for the third parties’ direct marketing purposes unless you have agreed to such a disclosure.

We will verify your request using your name and email. Depending on the nature of your request, we may need additional information to verify your identity. You may authorize an agent to make a request on your behalf to exercise your privacy rights under applicable privacy laws.

 Certain U.S. states provide the right to appeal Brunswick’s denial of an individual rights request.

To exercise your rights or to allow your authorized agent to exercise your rights, please call 1-800-937-2695 menu option 3,1,1,2 or contact our Privacy Team at privacy@brunswickbowling.com.

 

GDPR

Brunswick fully complies with the EU General Data Protection Regulation (GDPR), replacing the 1995 EU Data Protection Directive. The GDPR strengthens the rights that individuals have regarding personal data relating to them and seeks to unify data protection laws across Europe, regardless of where that data is processed.

As a user of the Services, you have the full right to:

• Opt-out of data collection
• Delete your data/account
• Transfer your data/account
• Request the Controller to assist in any of the above
• File a grievance with the Controller

Brunswick may be either a Processor or Controller depending on the services you use. If you are using Services under the control of a Center, then the Center is the Controller. Please direct your privacy inquiries and requests for access, correction or deletion of personal information to the Center. If you are using Services under the control of Brunswick, such as Correspondence (under the Collection of Voluntarily-Provided Information section) , then Brunswick is the Controller. In this case please direct your privacy inquiries and requests for access, correction or deletion of personal information to privacy@brunswickbowling.com.

The Data controller and Data Protection Officer for data processing is Brunswick with registered offices in Muskegon, Michigan, USA, e-mail address privacy@brunswickbowling.com. By writing to the same email address, you may request further details and explanations regarding Data processing.

Data Protection Requirements

Processing According to Instructions

Any data that a customer and its users input to our systems will only be processed in accordance with the customer’s instructions, as described in our Personal Information section outlined in this document.

Assistance to the Controller

Data Subject's Rights

Data controllers can use the various Services, administrative consoles and services functionality to help access, rectify, restrict the processing of, or delete any data that they and their users put into our systems. This functionality will help them fulfill their obligations to respond to requests from data subjects to exercise their rights under the GDPR.

Data Protection Team

Users have access to a dedicated team where data protection related enquiries can be directed by sending the request to privacy@brunswickbowling.com.

Incident Notifications

Brunswick will promptly inform you of incidents involving your customer data in line with the data incident terms in our current agreements and the updated terms that will apply starting on 25 May 2018, when the GDPR comes into force.

Security

According to the GDPR, the controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. This is outlined in our Security section of this document.

Data Retention and Deletion

Please see the Data Retention/Deletion section of this document.

Modifications to this Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you and will be located here. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Service prior to the effective date of the changes. By continuing to access or use the Service after those changes become effective, you agree to the revised Privacy Policy.