Privacy Policy

This Privacy Policy for Unfurled Analytics LLC (doing business as ZenSwing) ("we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at http://www.zenswinggolf.com (the "Site")
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@zenswinggolf.com.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Email addresses
• Passwords

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is processed by our payment processors. We do not store full payment card numbers or security codes.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected from Google API Services

We may use Google API Services in connection with our Services. Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. Information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This may include your IP address, device information, browser type and settings, and information about your activity in the Services.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service, including analyzing your golf round narratives and generating performance insights.
• To respond to user inquiries and offer support.
• To send administrative information to you.
• To fulfill and manage your orders.
• To request feedback.
• To identify usage trends.
• To protect our Services.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK

The GDPR and UK GDPR require us to explain the valid legal bases we rely on. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your information to fulfill our contractual obligations to you.
• Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests.
• Legal Obligation. We may process your information where necessary for compliance with our legal obligations.
• Vital Interests. We may process your information to protect vital interests.

If you are located in Canada

We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section.

We may need to share your personal information in the following situations:

• Service Providers. We may share your information with third-party service providers who perform services for us, including:
  • Google Firebase (hosting, authentication, and database services)
  • Anthropic (AI-powered narrative analysis)
  • Google Analytics (website analytics)
  • Payment processors (for transaction processing)
• Legal Obligations. We may share your information where legally required to comply with applicable law.
• Vital Interests and Legal Rights. We may share your information where necessary to investigate, prevent, or take action regarding potential violations or suspected fraud.

We do not sell or share your personal information with third parties for their own marketing purposes.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Google Analytics. We use Google Analytics to help us understand how our users use the Site. You can opt out of Google Analytics here.

6. Do We Offer Artificial Intelligence-Based Services?

In Short: We offer AI-powered services that analyze golf performance narratives. You may opt out of AI-based processing.

As part of our Services, we offer AI-based features powered by Anthropic's language models. When you submit a post-round narrative, it may be processed by Anthropic's AI systems to generate insights and recommendations. We use AI to:

• Analyze post-round golf narratives you provide
• Identify mental game patterns, flow states, and performance blockers
• Generate personalized performance insights and recommendations

Opting Out of AI Processing

You have the right to opt out of having your personal information processed by our AI-based services. To opt out, contact us at hello@zenswinggolf.com. Please note that opting out may limit certain features, as AI-powered analysis is a core component of ZenSwing.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this policy, unless a longer retention period is required by law. No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the Internet can be guaranteed to be 100% secure.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data.

10. What Are Your Privacy Rights?

In Short: Depending on your location, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access, rectification, erasure, restrict processing, data portability, and object to processing of your personal information.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at hello@zenswinggolf.com.

Account Information

If you would like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

11. Controls for Do-Not-Track Features

Most web browsers include a Do-Not-Track ("DNT") feature. We do not currently respond to DNT browser signals, as no uniform technology standard has been finalized.

12. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of certain US states, you may have additional privacy rights under applicable state laws.

Categories of Personal Information We Collect

Category	Examples	Collected
Identifiers	Email address, IP address, account name	YES
Personal information (CA Customer Records)	Name, contact information, financial information	YES
Commercial information	Transaction information, purchase history	YES
Inferences	Preferences and characteristics	YES

Your Rights

You may have certain rights under applicable US state privacy laws, including the right to know what personal information we collect, request deletion, correct inaccuracies, and not be discriminated against for exercising your rights.

How to Exercise Your Rights

To exercise these rights, contact us at hello@zenswinggolf.com. We will consider and act upon any request in accordance with applicable data protection laws.

13. Do Other Regions Have Specific Privacy Rights?

European Economic Area (EEA), United Kingdom (UK), and Switzerland

If you are a resident of the EEA, UK, or Switzerland, you have the right to lodge a complaint with your national data protection supervisory authority if you believe we are unlawfully processing your personal information.

Canada

If you are a resident of Canada, you may have certain rights under Canadian privacy legislation, including the right to request access to and correction of your personal information.

14. Do We Make Updates to This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification.

15. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may email us at hello@zenswinggolf.com or contact us by post at:

Unfurled Analytics LLC
Durham, NC 27705
United States

16. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

To request to review, update, or delete your personal information, please contact us at hello@zenswinggolf.com.