Standing Privacy Policy

Plain-English Summary

Who we are. Standing is a Canadian golf league and tournament app run by 17101112 Canada Inc. (d/b/a “Standing”), based in Toronto, Ontario.

What we collect. Your name and mobile number (required to sign in); optional email, handicap, and league details; scores and attendance; payment ledger entries; and basic device and security logs.

Why we collect it. To run your leagues and tournaments, send you messages you’ve agreed to receive, process payments, keep the app secure, and improve the service.

Who sees it. Other league members see names, scores, and standings — never your phone number or email. Organizers see their own league’s data. We do not sell your data or use it for advertising.

Your rights. You can access, export, correct, or delete your data at any time — mostly through the app itself. We respond to requests within 30 days.

Questions? Contact our Privacy Officer: Daniel Yang — hello@standingleague.com.

1. Who We Are

Legal name: 17101112 Canada Inc., doing business as “Standing”

Federal Corporation No.: 1710111-2

Standing is accountable for the personal information it controls, as required by the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), Schedule 1, Principle 1, and An Act respecting the protection of personal information in the private sector, CQLR c P-39.1, as amended by Law 25 (“Law 25”), s. 3.1.

2. Scope and Applicability

This policy applies to all personal information Standing collects, uses, or discloses in connection with the Standing app and website from users across all of Canada and the United States. We comply with applicable federal, state, and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, comprehensive state privacy laws in the United States, and Quebec's Act respecting the protection of personal information in the private sector (Law 25).

This policy covers information about:

Dual-role notice. Standing acts as a controller for personal information it collects for its own operational purposes (account management, security, service improvement). Standing acts as a processor for personal information that golf courses and their organizers collect about their golfers. Section 10 explains this distinction and its consequences for golfers.

3. Information We Collect

3.1 Everyone — Shared Account Identity

The following applies to all account holders:

3.2 Golfers (League Members)

In addition to the shared identity above:

3.3 Tournament Entrants

Tournament entrants sign in by mobile number. We collect:

Tournament entrant data is visible only to the organizer of that tournament.

3.4 Organizers and Course Staff

In addition to the shared identity above:

3.5 Location Information

3.6 Automatically Collected Information

3.7 What We Never Collect

4. Purposes of Collection and Use

We collect and use personal information only for the following purposes:

a. League and event operations. Creating and managing leagues, tournaments, pairings, scorecards, standings, handicaps, awards, and the substitute pool.

b. Communications. Sending texts, push notifications, and emails that you have consented to receive, including sign-in codes, league reminders, organizer “Send a Notice” messages, entry confirmations, and receipts.

c. Payment processing. Recording dues, fees, buy-ins, winnings, and payouts in the ledger; facilitating payments through Stripe where enabled.

d. Security. Authenticating sign-ins, detecting and preventing fraud and abuse, rate-limiting, bot protection, and enabling “sign out on every device.”

e. Service improvement. Diagnosing errors, monitoring performance, and understanding aggregate usage patterns to improve the app.

f. Legal compliance. Meeting obligations under applicable Canadian law, including tax record-keeping and breach notification.

We do not sell personal information. We do not use personal information for third-party advertising.

We do not sell or share your SMS opt-in data or personal information with third parties for marketing purposes.

(PIPEDA, Sch. 1, Principles 3 & 4; Law 25, ss. 12–14; CASL, S.C. 2010, c. 23, s. 10)

Express consent is obtained at sign-up for all data collection described in this policy. Consent checkboxes are separate and unbundled — you are not required to consent to optional communications (texts, push, email) as a condition of using the core service.

Implied consent applies to existing users who have had an active business relationship with Standing within the past two years, for commercial electronic messages consistent with that relationship, as permitted by CASL.

Withdrawal. You may withdraw consent at any time by:

Withdrawal may limit features that depend on the withdrawn consent. It does not affect the lawfulness of processing before withdrawal, and it does not override legal retention obligations.

5A. Sensitive Personal Information

Standing does not typically collect or process sensitive personal information as defined by applicable privacy laws. However, if we do collect sensitive data (such as precise geolocation, health data, or other categories defined as sensitive under your jurisdiction's law), we apply heightened protections and obtain appropriate consent.

Jurisdiction-Specific Sensitive Data Requirements:

• California: California law provides a "limit use and disclosure" right rather than requiring opt-in consent. California residents may limit our use of sensitive personal information to purposes necessary to perform services reasonably expected by the consumer.

• All Other U.S. States with Comprehensive Privacy Laws: These states require opt-in consent or separate consent before processing sensitive personal information. We obtain such consent before processing sensitive data of residents of these states.

• Maryland, Oregon, and Minnesota: These states impose additional restrictions on the processing of sensitive personal data beyond standard consent requirements.

• Quebec: Heightened consent requirements apply for sensitive information under Law 25.

• British Columbia and Alberta: PIPA requires heightened consent and safeguards for sensitive information.

• Other Canadian Jurisdictions: PIPEDA requires meaningful consent, with heightened requirements for sensitive personal information.

We do not sell or share sensitive personal information for cross-context behavioral advertising or targeted advertising.

6. How Information Is Shared

We share personal information only with the service providers listed below, and only to the extent necessary for the stated purpose. We do not sell personal information or share it for third-party advertising.

Supabase — Database, authentication, file storage, and background jobs. Hosts essentially all account and gameplay data (names, phone numbers, emails, handicap indexes, scores, payment ledger). Data is stored in the Canadian region (ca-central-1); Supabase is a US company. Bound by the Supabase Data Processing Agreement.

Vercel — Application hosting and content delivery. Receives all web requests in transit and operational logs (personal identifiers redacted). United States. Bound by the Vercel Data Processing Agreement.

Twilio — Text messaging. Receives mobile phone numbers and the content of league texts and one-time sign-in codes. United States. Bound by the Twilio Data Processing Agreement.

Resend — Transactional email. Receives email addresses and the content of account emails (entry confirmations, receipts, reminders). United States. Bound by the Resend Data Processing Agreement.

Expo — Mobile push notifications. Receives device push tokens and notification content. United States. Bound by Expo/EAS terms.

Stripe — Payment processing and payouts. Receives payment and cardholder data directly from the user; for courses collecting dues, their banking and identity details go directly to Stripe. Standing stores only Stripe account identifiers, payout-readiness status, and transaction ledger entries. United States and Canada. Bound by the Stripe Data Processing Agreement.

Anthropic — AI assistance for league setup and scorecard reading. Receives only the text or scorecard image submitted for processing (which may contain names and scores); photos are not stored by Standing after processing. United States. Bound by Anthropic’s commercial terms with zero-retention API handling.

Google — Optional sign-in. Receives a sign-in request and returns the user’s Google name and email. United States. Bound by Google’s Data Processing Terms.

OpenStreetMap Nominatim — Geocoding. Receives a course street address to return map coordinates. European Union. Subject to OpenStreetMap’s terms of service.

Sentry — Error monitoring, if enabled. Receives error reports with personal identifiers scrubbed before transmission. United States. Bound by the Sentry Data Processing Agreement.

PostHog — Usage analytics, if enabled. Receives server-side aggregate usage counts keyed to a league, not to an individual; no personal profiles; no cookies. United States. Bound by the PostHog Data Processing Agreement.

Cloudflare Turnstile — Bot protection, if enabled. Receives IP address and challenge data. United States and global. Bound by Cloudflare’s Data Processing Addendum.

Visibility within the app:

7. Cross-Border Transfers

(Law 25, s. 17; PIPEDA, Sch. 1, Principle 7)

The primary database is stored in Canada (Supabase, ca-central-1 region). The following service providers process data outside Canada:

Data transferred outside Canada may be subject to the laws of the receiving country, including lawful access by foreign governments. We have entered into data processing agreements with each provider that include contractual safeguards equivalent to standard contractual clauses. As required by Law 25, we have conducted a Privacy Impact Assessment for cross-border transfers of personal information of Quebec residents.

Jurisdiction-Specific Cross-Border Requirements:

• United States: No U.S. state law in the comprehensive privacy statutes imposes a general cross-border transfer prohibition or adequacy requirement. However, ordinary controller/processor contracts, security measures, notice requirements, and assessment duties apply.

• Quebec: Privacy impact assessments are required for transfers of personal information outside Quebec where there is a risk of serious injury (Law 25, s. 17).

• British Columbia: PIPA requires accountability, consent or purpose alignment, and appropriate safeguards for cross-border transfers.

• Alberta: PIPA requires accountability, consent or purpose alignment, and contractual safeguards for cross-border transfers.

• Nova Scotia: The Personal Information International Disclosure Protection Act, S.N.S. 2006, c. 3 imposes additional requirements for cross-border transfers of personal information.

• All Jurisdictions: We maintain appropriate contractual safeguards with all service providers, implement security measures, provide notice of cross-border transfers, and conduct assessments as required by applicable law.

8. Controller–Processor Relationship

(PIPEDA, Sch. 1, Principle 1; Law 25, s. 3)

Golf courses and their organizers are the accountable controllers for the personal information of their golfers. Standing processes that information as a service provider under a Data Processing Addendum entered into with each course.

If you have questions about how your course collects or uses your personal information, please contact your league organizer or course directly. Standing will refer course-specific data inquiries to the relevant organizer where appropriate.

9. Automated Decision-Making

(Law 25, s. 12.1)

Handicap calculations, pairing assignments, and substitute-pool offers are determined by fixed, rule-based algorithms. They do not involve AI profiling, machine learning, or decisions based on personal characteristics beyond the golf data you provide. Organizers retain full control and may review and correct any output at any time.

Jurisdiction-Specific Rights:

• Quebec residents have the right to request that a human review any automated decision that significantly affects them, and to receive an explanation of the factors and parameters that led to the decision (Law 25, s. 12.1).

• Minnesota residents have rights to profiling explanations, review, and re-evaluation under Minn. Stat. §§ 325M.10–.24.

• Connecticut residents have rights regarding solely automated significant decisions under Conn. Gen. Stat. §§ 42-515 to -526.

• Colorado residents have opt-out rights and protections for profiling under Colo. Rev. Stat. §§ 6-1-1301 to -1314.

• California residents have automated-decision notice and opt-out provisions under CCPA/CPRA, Cal. Civ. Code §§ 1798.100–1798.199.100.

• Most other comprehensive state privacy laws provide opt-out rights only for profiling producing legal or similarly significant effects.

• British Columbia and Alberta residents have access and correction rights, but no specific automated-decision explanation requirement has been confirmed under their respective PIPA statutes.

See Section 14A for complete details on your jurisdiction-specific rights.

10. Cookies and Tracking Technologies

(Law 25, s. 8; CASL, s. 8)

Essential cookies (always active — no consent required):

Optional technologies (active only after you opt in via the cookie banner):

No optional cookie or pixel is placed on your device until you accept. Optional boxes are never pre-ticked. You may change or withdraw your cookie choice at any time via the cookie-settings link in the app footer; declining does not affect your use of Standing. Some analytics also run server-side without placing cookies on your device.

11. Commercial Electronic Messages and CASL

(CASL, ss. 6(2)(a), 6(2)(c), 10, 13)

Consent basis:

Every commercial electronic message we send includes:

Unsubscribe: Unsubscribe requests are honoured within 10 business days. Replying STOP to any text removes you from all Standing text messages immediately. STOP status is retained indefinitely so we never text you again.

Organizer “Send a Notice” messages sent through Standing are commercial electronic messages subject to CASL. Organizers are responsible for ensuring they have the required consent from recipients before using this feature.

Consent records — including consent type, date, and source — are retained for at least three years after the last message or after consent is withdrawn.

12. Data Retention

(PIPEDA, Sch. 1, Principle 5; Law 25, s. 23; Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), s. 230; Breach of Security Safeguards Regulations, SOR/2018-64, s. 9)

Account identity (name, mobile number, email, handicap index): retained while your account is active. Anonymized within 30 days of account deletion or after 24 consecutive months of inactivity.

League and play history (scores, attendance, standings, substitute history): retained for the life of the league to preserve accurate historical results. On account deletion, personal identifiers are removed and remaining results are anonymized.

CASL consent records (opt-in type, date, source): retained for at least three years after the last message or after consent is withdrawn.

STOP/opt-out records: retained indefinitely.

Financial and payment records (dues, ledger entries, Stripe transaction identifiers): retained for seven years, as required by the Income Tax Act.

Security and support logs (with personal identifiers redacted): retained for 90 days.

Breach register: retained for at least 24 months, as required by SOR/2018-64, s. 9.

Error and usage data (Sentry, PostHog): retained for 90 days.

Rolling database backups: overwritten on an approximately 30-day cycle; deleted data ages out of backups within that window.

Prospect and business-contact data: retained for up to 24 months of no engagement, then deleted.

Anonymization vs. deletion. Where deletion would destroy accurate historical records (e.g., past scores, financial summaries), we anonymize the data so it can no longer identify you, rather than erasing the record entirely. Anonymized data is no longer personal information.

13. Security Safeguards

(PIPEDA, Sch. 1, Principle 7; Law 25, s. 20; SOR/2018-64)

Technical safeguards:

Organizational safeguards:

No security system is perfect. We work continuously to improve these measures.

14. Your Privacy Rights

(PIPEDA, Sch. 1, Principles 6 & 9; Law 25, ss. 27–28)

Access. You may request a copy of the personal information we hold about you. Most of your information is visible when you sign in.

Export (portability). Use Export my data on your Account page to download your personal information in a portable, machine-readable format. This right is available to all users and satisfies the portability right under Law 25, s. 27, for Quebec residents.

Correction. Edit your name, mobile number, and other profile details on your Account page. Score or standing corrections are made by your league organizer.

Deletion. Use Delete my account on your Account page. We remove your personal identifiers and anonymize any historical records that must be retained for accuracy or legal compliance. Records subject to mandatory retention (e.g., financial records for seven years) are retained only for the required period and then deleted. Your STOP status is retained indefinitely.

Withdrawal of consent. Reply STOP to any text, turn off notifications on your Account page, or delete your account. See Section 5.

Human review of automated decisions (Quebec residents). See Section 9.

How to submit a request. Use the self-serve tools in the app, or email hello@standingleague.com. Because sign-in is tied to your mobile number, we verify your identity through the number on file before acting on a written request.

Response time. We respond within 30 days. If a request is complex and requires more time, we will notify you of the reason and provide a revised date. Reasonable requests are free of charge.

Refusals. If we cannot fulfill a request (for example, because a record has been anonymized or is subject to a legal retention obligation), we will explain the reason in writing.

14A. Your Rights by Jurisdiction

This section provides specific information about privacy rights available to residents of different U.S. states and Canadian provinces and territories. These rights are in addition to the general rights described in Section 14 above.

14A.1 United States State-Specific Rights

The following states have enacted comprehensive consumer privacy laws. If you are a resident of one of these states, you have the rights described below in addition to the general rights in Section 14.

(a) California

Applicable Law: California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), Cal. Civ. Code §§ 1798.100–1798.199.100

Your Rights:

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you.

• Right to Delete: Request deletion of your personal information, subject to certain exceptions.

• Right to Correct: Request correction of inaccurate personal information.

• Right to Portability: Request a copy of your personal information in a portable, machine-readable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Sharing for Cross-Context Behavioral Advertising: We do not share personal information for cross-context behavioral advertising.

• Right to Limit Use and Disclosure of Sensitive Personal Information: You may limit our use of sensitive personal information to purposes necessary to perform services reasonably expected.

• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights.

• Automated Decision-Making: You have the right to notice and opt-out of automated decision-making in certain contexts.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: California Privacy Protection Agency and California Attorney General.

Private Right of Action: Limited to data security breaches only (Cal. Civ. Code § 1798.150).

(b) Colorado

Applicable Law: Colorado Privacy Act (CPA), Colo. Rev. Stat. §§ 6-1-1301 to -1314

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Colorado Attorney General.

Private Right of Action: None.

(c) Connecticut

Applicable Law: Connecticut Data Privacy Act (CTDPA), Conn. Gen. Stat. §§ 42-515 to -526

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of solely automated decisions that produce legal or similarly significant effects.

• Right Regarding Automated Decisions: You have rights regarding solely automated significant decisions.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Connecticut Attorney General.

Private Right of Action: None.

(d) Delaware

Applicable Law: Delaware Personal Data Privacy Act (DPDPA), Del. Code tit. 6, §§ 12D-101 to -111

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Delaware Attorney General.

(e) Florida

Applicable Law: Florida Digital Bill of Rights, Fla. Stat. §§ 501.701–.722

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Florida Attorney General.

Private Right of Action: None.

(f) Indiana

Applicable Law: Indiana Consumer Data Protection Act (ICDPA), Ind. Code §§ 24-15-1-1 to -12-1

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Indiana Attorney General.

Private Right of Action: None.

(g) Iowa

Applicable Law: Iowa Consumer Data Protection Act (ICDPA), Iowa Code §§ 715D.1–.9

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Iowa Attorney General.

Private Right of Action: None.

(h) Kentucky

Applicable Law: Kentucky Consumer Data Protection Act (KCDPA), Ky. Rev. Stat. §§ 367.3611–.3626

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Kentucky Attorney General.

Private Right of Action: None.

(i) Maryland

Applicable Law: Maryland Online Data Privacy Act (MODPA), Md. Code Ann., Com. Law §§ 14-4601 to -4614

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data. Maryland imposes additional restrictions on the processing of sensitive data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Maryland Attorney General.

Private Right of Action: None.

(j) Minnesota

Applicable Law: Minnesota Consumer Data Privacy Act (MCDPA), Minn. Stat. §§ 325M.10–.24

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, with rights to explanations, review, and re-evaluation.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data. Minnesota imposes additional restrictions on the processing of sensitive data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Minnesota Attorney General.

(k) Montana

Applicable Law: Montana Consumer Data Privacy Act (MCDPA), Mont. Code Ann. §§ 30-14-2801 to -2813

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Montana Attorney General.

Private Right of Action: None.

(l) Nebraska

Applicable Law: Nebraska Data Privacy Act (NDPA), Neb. Rev. Stat. §§ 87-1101 to -1110

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Nebraska Attorney General.

Private Right of Action: None.

(m) New Hampshire

Applicable Law: New Hampshire Privacy Act (NHPA), N.H. Rev. Stat. Ann. §§ 507-H:1 to :11

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: New Hampshire Attorney General.

Private Right of Action: None.

(n) New Jersey

Applicable Law: New Jersey Data Privacy Act (NJDPA), N.J. Stat. Ann. §§ 56:8-166.4 to -166.6

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: New Jersey Attorney General.

Private Right of Action: None.

(o) Oregon

Applicable Law: Oregon Consumer Privacy Act (OCPA), Or. Rev. Stat. §§ 646A.570–.589

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data. Oregon imposes additional restrictions on the processing of sensitive data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Oregon Attorney General.

Private Right of Action: None.

(p) Rhode Island

Applicable Law: Rhode Island Data Transparency and Privacy Act (RDTPPA), R.I. Gen. Laws §§ 6-48.1-1 to -10

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Rhode Island Attorney General.

(q) Tennessee

Applicable Law: Tennessee Information Protection Act (TIPA), Tenn. Code Ann. §§ 47-18-3301 to -3313

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Tennessee Attorney General.

Private Right of Action: None.

(r) Texas

Applicable Law: Texas Data Privacy and Security Act (TDPSA), Tex. Bus. & Com. Code §§ 541.001–.006

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Texas Attorney General.

Private Right of Action: None.

(s) Utah

Applicable Law: Utah Consumer Privacy Act (UCPA), Utah Code Ann. §§ 13-61-101 et seq.

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Utah Attorney General.

Private Right of Action: None.

(t) Virginia

Applicable Law: Virginia Consumer Data Protection Act (VCDPA), Va. Code Ann. §§ 59.1-575 to -585

Your Rights:

• Right to Access: Confirm whether we are processing your personal data and access such personal data.

• Right to Deletion: Delete personal data you have provided.

• Right to Correction: Correct inaccuracies in your personal data.

• Right to Portability: Obtain a copy of your personal data in a portable and readily usable format.

• Right to Opt-Out of Sale: We do not sell personal information.

• Right to Opt-Out of Targeted Advertising: We do not engage in targeted advertising.

• Right to Opt-Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

• Consent for Sensitive Data: We obtain consent before processing sensitive personal data.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Enforcement: Virginia Attorney General.

14A.2 Canadian Provincial and Territorial Rights

In addition to the rights provided under federal PIPEDA legislation (described in Section 14), residents of Canadian provinces and territories have the following additional rights based on their jurisdiction:

(a) Quebec

Applicable Law: Act respecting the protection of personal information in the private sector (Law 25), CQLR c. P-39.1

Your Rights:

• Right of Access: Request access to your personal information in our possession.

• Right to Rectification: Request correction of inaccurate, incomplete, or equivocal personal information.

• Right to De-indexing: Request that your personal information be de-indexed from search engines in certain circumstances.

• Right to Portability: Request that your personal information be communicated to you in a structured, commonly used technological format.

• Right to Withdraw Consent: Withdraw consent at any time, subject to legal or contractual restrictions.

• Right to Object to Automated Decision-Making: Request human intervention for any automated decision that significantly affects you (see Section 9).

• Privacy Impact Assessments: We conduct privacy impact assessments for high-risk processing, including transfers outside Quebec.

• Breach Notification: We will notify you promptly if a breach creates a risk of serious injury (Law 25, ss. 3.5-3.8).

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Complaints: Commission d'accès à l'information du Québec (cai.gouv.qc.ca).

(b) British Columbia

Applicable Law: Personal Information Protection Act (PIPA), S.B.C. 2003, c. 63

Your Rights:

• Right to Notice: Receive clear notice about the purposes for which your personal information is collected.

• Right to Consent: Provide meaningful consent before your personal information is collected, used, or disclosed.

• Right of Access: Request access to your personal information in our possession.

• Right to Correction: Request correction of inaccurate or incomplete personal information.

• Cross-Border Transfer Safeguards: We implement accountability measures, obtain appropriate consent, and maintain contractual safeguards when transferring your personal information outside British Columbia.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Complaints: Information and Privacy Commissioner for British Columbia (oipc.bc.ca).

(c) Alberta

Applicable Law: Personal Information Protection Act, S.A. 2003, c. P-6.5

Your Rights:

• Right of Access: Request access to your personal information in our possession.

• Right to Correction: Request correction of inaccurate or incomplete personal information.

• Right to Meaningful Consent: Provide informed and voluntary consent before your personal information is collected, used, or disclosed.

• Safeguards: We maintain appropriate safeguards to protect your personal information.

• Cross-Border Accountability: We implement accountability measures and contractual safeguards when transferring your personal information outside Alberta.

How to Exercise Your Rights: Contact us at hello@standingleague.com or use the self-serve tools in your Account page.

Complaints: Information and Privacy Commissioner of Alberta (oipc.ab.ca).

(d) Saskatchewan

Applicable Law: PIPEDA (federal) applies to commercial activities in Saskatchewan.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Information and Privacy Commissioner of Saskatchewan (oipc.sk.ca).

(e) Manitoba

Applicable Law: PIPEDA (federal) applies to commercial activities in Manitoba.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Manitoba Ombudsman (ombudsman.mb.ca).

(f) Ontario

Applicable Law: PIPEDA (federal) applies to commercial activities in Ontario. For health information, the Personal Health Information Protection Act (PHIPA), 2004, S.O. 2004, c. 3, Sch. A may apply.

Your Rights: See Section 14 for your rights under PIPEDA. If PHIPA applies to health information we process, you have additional rights under that Act.

Complaints: Information and Privacy Commissioner of Ontario (ipc.on.ca).

(g) New Brunswick

Applicable Law: PIPEDA (federal) applies to commercial activities in New Brunswick.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Office of the Ombud for New Brunswick (ombudnb.ca).

(h) Nova Scotia

Applicable Law: PIPEDA (federal) applies to commercial activities in Nova Scotia. The Personal Information International Disclosure Protection Act, S.N.S. 2006, c. 3 addresses cross-border transfers.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Information and Privacy Commissioner of Nova Scotia (novascotia.ca/oipc).

(i) Prince Edward Island

Applicable Law: PIPEDA (federal) applies to commercial activities in Prince Edward Island.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Information and Privacy Commissioner of Prince Edward Island (assembly.pe.ca/ipc).

(j) Newfoundland and Labrador

Applicable Law: PIPEDA (federal) applies to commercial activities in Newfoundland and Labrador.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Office of the Information and Privacy Commissioner for Newfoundland and Labrador (oipc.nl.ca).

(k) Yukon

Applicable Law: PIPEDA (federal) applies to commercial activities in Yukon.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Yukon Information and Privacy Commissioner (ombudsman.yk.ca).

(l) Northwest Territories

Applicable Law: PIPEDA (federal) applies to commercial activities in the Northwest Territories.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Information and Privacy Commissioner of the Northwest Territories (nwtlegislature.ca).

(m) Nunavut

Applicable Law: PIPEDA (federal) applies to commercial activities in Nunavut.

Your Rights: See Section 14 for your rights under PIPEDA.

Complaints: Information and Privacy Commissioner of Nunavut (accessandprivacy.nu.ca).

Private Right of Action: None.

Private Right of Action: None.

Private Right of Action: None.

Private Right of Action: None.

15. Children and Minors

The Standing app is not intended for persons under 13 years of age. Accounts found to belong to users under 13 will be deleted.

Age gate. At sign-up, users must self-declare that they are 13 or older.

Users under 18. A user who indicates they are under 18 must have a parent or guardian provide express consent via a separate email confirmation before the account is activated. The parent or guardian holds the account on the minor’s behalf and agrees to this policy for them.

Junior golfers. A junior golfer does not hold an independent account. A parent or guardian holds the account and is responsible for all data associated with it.

16. Data Breach Notification

(SOR/2018-64, ss. 3–6, 9; Law 25)

If Standing experiences a breach of security safeguards involving personal information that poses a real risk of significant harm to affected individuals, we will:

17. Complaints and Escalation

If you have a concern about how Standing handles your personal information:

Step 1 — Privacy Officer. Contact Daniel Yang at hello@standingleague.com. We will acknowledge your complaint promptly and respond within 30 days.

Step 2 — Regulatory Authorities. If you are not satisfied with our response, you may file a complaint with the appropriate regulatory authority based on your jurisdiction:

United States State Enforcement Authorities:

• California: California Privacy Protection Agency (cppa.ca.gov) and California Attorney General

• Colorado: Colorado Attorney General

• Connecticut: Connecticut Attorney General

• Delaware: Delaware Attorney General

• Florida: Florida Attorney General

• Indiana: Indiana Attorney General

• Iowa: Iowa Attorney General

• Kentucky: Kentucky Attorney General

• Maryland: Maryland Attorney General

• Minnesota: Minnesota Attorney General

• Montana: Montana Attorney General

• Nebraska: Nebraska Attorney General

• New Hampshire: New Hampshire Attorney General

• New Jersey: New Jersey Attorney General

• Oregon: Oregon Attorney General

• Rhode Island: Rhode Island Attorney General

• Tennessee: Tennessee Attorney General

• Texas: Texas Attorney General

• Utah: Utah Attorney General

• Virginia: Virginia Attorney General

Note: Most U.S. comprehensive privacy laws provide for Attorney General enforcement only, with no private right of action (except California's limited security breach action under Cal. Civ. Code § 1798.150).

Canadian Privacy Commissioners:

• Federal: Office of the Privacy Commissioner of Canada (canada.ca/en/privacy-commissioner)

• Quebec: Commission d'accès à l'information du Québec (cai.gouv.qc.ca)

• British Columbia: Information and Privacy Commissioner for British Columbia (oipc.bc.ca)

• Alberta: Information and Privacy Commissioner of Alberta (oipc.ab.ca)

• Saskatchewan: Information and Privacy Commissioner of Saskatchewan (oipc.sk.ca)

• Manitoba: Manitoba Ombudsman (ombudsman.mb.ca)

• Ontario: Information and Privacy Commissioner of Ontario (ipc.on.ca)

• New Brunswick: Office of the Ombud for New Brunswick (ombudnb.ca)

• Nova Scotia: Information and Privacy Commissioner of Nova Scotia (novascotia.ca/oipc)

• Prince Edward Island: Information and Privacy Commissioner of Prince Edward Island (assembly.pe.ca/ipc)

• Newfoundland and Labrador: Office of the Information and Privacy Commissioner for Newfoundland and Labrador (oipc.nl.ca)

• Yukon: Yukon Information and Privacy Commissioner (ombudsman.yk.ca)

• Northwest Territories: Information and Privacy Commissioner of the Northwest Territories (nwtlegislature.ca)

• Nunavut: Information and Privacy Commissioner of Nunavut (accessandprivacy.nu.ca)

Step 3 — Commission d’accès à l’information du Québec. If you are a Quebec resident, you may also file a complaint with the CAI at cai.gouv.qc.ca.

18. Payment Processing

(PIPEDA, Sch. 1, Principle 4; Income Tax Act, s. 230)

Card payments are processed by Stripe. Payment card and bank account details are entered directly into Stripe’s interface and never pass through or are stored on Standing’s servers.

Standing stores only:

Card payments are available where enabled. Stripe is currently operating in test mode; live payments will be enabled on a per-course basis as Standing expands.

19. Policy Updates

(Law 25; Electronic Commerce Act, 2000, S.O. 2000, c. 17)

We may update this policy from time to time. When we do:

The current version and its effective date are always displayed at the top of this page.

20. Language and Governing Law

(Electronic Commerce Act, 2000, S.O. 2000, c. 17; Consumer Protection Act, 2002, S.O. 2002, c. 30, Sched. A)

This policy is offered in English, Canadian French, and Simplified Chinese. The English version governs in the event of any conflict between versions.

This policy and all privacy matters relating to Standing are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.

While this policy is governed by Ontario and Canadian federal law, residents of other jurisdictions retain all rights under their applicable state or provincial privacy laws. In the event of any conflict between the governing law of this policy and the mandatory privacy rights available under your home jurisdiction's law, your privacy rights under your home jurisdiction's law prevail to the extent required by that law.

21. Contact — Privacy Officer

(Law 25, s. 3.1; PIPEDA, Sch. 1, Principle 1)

Privacy Officer: Daniel Yang

Email: hello@standingleague.com

For all privacy questions, access requests, corrections, deletions, or complaints, contact the Privacy Officer using the information above.

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