ACUSHNET COMPANY PRIVACY POLICIES

Acushnet Company
P.O. Box 965
Fairhaven, MA 02719

ACUSHNET COMPANY WEBSITE PRIVACY POLICY

Acushnet Company wants you to know what information we collect from you when you visit this site, what we do with that information, and how you can change the information we have. Your use of this Internet site (this "Site") indicates your acceptance of this Privacy Policy, which may be revised at any time by Acushnet Company.

What Information Is Collected

When you visit this Site, we recognize only your domain name and not your e-mail address. We will see your e-mail address only if you fill out a form or send us an e-mail message. We may also collect information about you if you register on a page, fill out a survey, place an order, upload content, post blog entries or comments, participate in our contests or if you otherwise voluntarily tell us about yourself or your activities. We collect Internet-related Information from visitors to our Site, including the referring URL, your IP address, which browser you used to come to this Site, the country, state or province, the pages of our Site that you viewed during your visit and any search terms you entered on our Site, for the purposes of system administration, to gather broad demographic information, and to monitor the level of Site activity. We track customers' traffic patterns throughout their online sessions, including which pages or specific URLs a customer views while using the Site. We use your Internet-related Information to diagnose problems with our servers and software and to administer our Site.

How Information Is Used

When you provide information about yourself, we use it to improve our products and services and the content of this Site. We may also use it to complete purchase or other transactions or to send you information about our products and services. For details on how to opt out of receiving information, please see the Choice/Opt-out/Opt-in section of this Privacy Policy, below. When you use interactive features like our blogs (posting entries or submitting comments), or submit user content, please keep in mind that these features are inherently interactive. Information and materials you submit will be publicly available, thus if you include in your submission personally identifiable information (using your full name in the "name" field of a blog comment, for example), that information will become available to the general public on the Site. We may create aggregate information from records that contain personal information, and may include in those records information you have provided to us, or information we have obtained from third parties. We may use aggregate information for our legitimate business purposes.

Cookies

This Site uses cookies to track online activity of Web users. A cookie is a piece of data on the user's computer tied to information about the user. The cookie was placed by us, or by DoubleClick. In order provide personalization on our websites, the cookie may include your first name, email address and zip code. It does not contain your full name, address or telephone number.

For more detailed information about the Cookies used on the FootJoy websites please refer to our Cookies page .

For more information about DoubleClick, including information about how to opt out of these technologies, go to http://www.doubleclick.net/us/corporate/privacy .

Transparent GIFs

This Site uses pixels, or transparent GIF files, to help manage our online advertising and to help us manage our content by informing us what content is effective. Transparent GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. These GIF files are provided by our ad management partner, DoubleClick. These files enable DoubleClick to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our Site. Transparent GIFs are not tied to a user's personally identifiable information.

Sharing Information

We employ other companies to perform certain functions on our behalf, such as blog website hosting, fulfilling orders, delivering packages, and services related to the design, maintenance and improvement of this Site and our database and related systems. Regardless of whether you have provided us with consent, we will share your information with those companies that perform certain functions on our behalf under contract to us, as well as in the following other situations. We may also need to disclose personal information if required by law; when we have a good faith belief that such action is necessary to comply with a current judicial proceeding; to respond to a court order or legal process served on us; or when necessary to protect the rights, safety or property of users of this Site, the public or Acushnet Company. If we merge with or are acquired by another company, if we sell all or substantially all of our relevant assets or file for bankruptcy, we may disclose personal information to the acquirer. We may also disclose non-identifiable information about our users to third parties. We may also disclose personally identifiable information if you have given us consent to do so.

Choice/Opt-out/ Opt-in

Our users are given the opportunity to opt-out of having their email address used for commercial emails from Acushnet Company at the time they receive any marketing email messages from us (alternatively, we give our users the ability to opt-in before receiving such commercial marketing messages if we are required to give such an option under local law). In any case, users who no longer wish to receive our promotional communications may opt-out of receiving these communications by modifying their preferences in their Site user profile, or by contacting us via email at webmaster@acushnetgolf.com or at 1-800-225-8500.

Use of This Website by Children

This Site is not designed for, nor do we believe it is appealing to, children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. We encourage children to consult their parents before providing personal information. Parents, to learn more about how to protect your children online, visit http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm .

Links

This Site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every site that collects personally identifiable information. This privacy statement applies solely to information collected by this Site.

Security

We use reasonable efforts to protect our users' information. When users submit sensitive information via the Site, we use reasonable efforts to protect our users' information both online and off-line. When our order form asks users to enter credit card numbers, that information is encrypted and is protected with encryption software. While on a secure page, such as our checkout page, the lock icon on the bottom of most Web browsers becomes locked.

When we use software to protect your information online, we also use reasonable efforts to protect your information off-line. Access to our users' information is restricted to employees of our company and its affiliates and agencies who need the information to perform a specific job (such as billing or shipping).

Although we have taken steps to ensure that your personal information is not collected, used, or disclosed except as set forth by this Privacy Policy, technical mistakes are possible. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of electronically stored sensitive personal data via email or by conspicuous posting on the Website as soon as possible to the extent consistent with (a) the legitimate needs of law enforcement and (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Information Storage and Transfer

Your personal information will be kept in a database held on servers kept in a physically and technologically secure environment located in Fairhaven, Massachusetts, U.S.A. (or, in the case of certain blog sites, may be retained at the relevant service providers’ locations), accessed only by authorized personnel or contractors who are bound to keep your information confidential. We have in place procedures for training our employees about their obligations under this Privacy Policy, disciplining them for failure to follow this Policy. We also have in place internal procedures to confirm general company compliance with this Policy.

Your information will be transferred to Acushnet Company, Fairhaven, Massachusetts, United States of America, which location may be outside of your own country, and by providing us with your information, you are consenting to such transfer.

Correcting, Updating or Deleting Personal Information

If a user's personally identifiable information changes, or if a user no longer desires our service or in all other cases, we provide a way to access, correct, update or delete a user's personally identifiable information. This can be done by logging into your profile at this Site's registration on the home page or by our customer support at 1-800-225-8500. If you request that we delete your personally identifiable information or deactivate your account we may retain aggregate information developed from your personal information.

Notification of Changes

We reserve the right to change or update this policy at any time by posting a notice to that effect on this Site and other places where we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. However, if we are going to use users' personally identifiable information in a manner different from that stated at the time of collection, we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with the Site, or deleted their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Site notifying users of the change. In some cases, where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices. Your continued use of this Site constitutes your consent to these changes.

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact us by sending a question via our FAQ, or by calling 1-800-225-8500.

Please see Acushnet's Legal Notice or terms governing use of this Site.

ACUSHNET COMPANY EU AND SWITZERLAND PRIVACY POLICY

Acushnet Company complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Acushnet Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Acushnet Company’s certification, please visit http://www.export.gov/safeharbor/ .

DEFINITIONS

“agent" means any third party that uses personal information provided to Acushnet to perform tasks on request of the Company.

"personal information" means information relating to an identified or identifiable natural person.

"sensitive personal information" means personal information concerning race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, or a person’s health or sex life.

NOTICE

When Acushnet collects personal information from persons in the EU or Switzerland, it will inform them of the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Acushnet may disclose the information, the choices and means, if any, offered for limiting disclosure of personal information. Personal information will only be collected from individuals as permitted by the Program or as consented by the person. Notice will be provided when persons are asked for personal information, or as soon as practicable thereafter, and in any event before Acushnet uses the information for a purpose other than for which it was collected.

CHOICE

Acushnet offers the opportunity to choose (i.e., opt-out or opt-in when required by local law) whether their personal information is (1) disclosed to a non-agent third-party, or (2) used for a purpose other than that for which it was collected or subsequently authorized. For sensitive personal information, Acushnet gives persons the opportunity to affirmatively consent (i.e., opt-in) to the disclosure of the information to a non-agent third-party or use of the information for a purpose other than that for which it was collected or subsequently authorized by the individual.

SECURITY AND DATA INTEGRITY

Acushnet will use personal information only in ways compatible with the purposes for which it was collected or subsequently authorized and will take reasonable precautions to protect personal information in its possession from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Acushnet will take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.

ACCESS

Upon request and reasonable notice, Acushnet will grant persons reasonable access to personal information that it holds about them, and will take reasonable steps to permit correction, amendment, or deletion of information demonstrated to be inaccurate or incomplete.

TRANSFERS

Acushnet will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Acushnet learns that an agent is using or disclosing personal information in a manner contrary to this Policy, Acushnet will take steps to prevent or stop the use or disclosure.

ENFORCEMENT

Acushnet will conduct audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Acushnet determines has violated this Policy will be subject to disciplinary action up to and including termination.

DISPUTE RESOLUTION

Questions regarding use or disclosure of personal information should be directed to Acushnet’s Vice President and Assistant General Counsel at the address set forth below. Acushnet will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information according to this Policy. Acushnet has agreed to participate in the dispute resolution procedures of the panel established the European and Swiss data protection authorities to resolve disputes pursuant to the Safe Harbor Principles for complaints or disputes that cannot be resolved through this internal process.

CONTACT INFORMATION

Questions or comments regarding this policy should be submitted to:

Roland A. Giroux
VP and Assistant General Counsel
Acushnet Company
333 Bridge Street
Fairhaven, MA 02719
USA
Phone: 508-979-2000
Fax: 508-979-3092

AMENDMENTS

This Policy may be amended as appropriate, according to the requirements of the Program and Acushnet will provide appropriate notice of such amendments.

EU AND SWITZERLAND EMPLOYEE PRIVACY NOTICE

This notice is provided in connection with, and is based upon, the principles set forth in the Acushnet Company EU and Switzerland Privacy Policy listed above (the "EU and Switzerland Privacy Policy").

This notice describes the data privacy policy of Acushnet Company (“Acushnet") concerning transfer of personal information of Acushnet employees from the European Union (“EU”) and Switzerland to Acushnet corporate headquarters in the United States. For the purposes of this notice, personal information means information relating to a present or former employee of Acushnet or any of its subsidiaries that can be linked to that individual.

Acushnet collects and uses personal information about employees only for legitimate purposes reasonably related to an employee's employment, the employee's performance of the duties and responsibilities of his or her position, or Acushnet's ability to make services and benefits available to the employee.

NOTICE

Acushnet only transfers personal information to the US for payroll management, headcount, incentive and merit decisions, succession planning, organization promotion and advancement, participation in benefit programs and other traditional human resources and/or personnel functions. The information transferred includes contact information, including name, address, internal or external identification numbers, compensation information, performance ratings, proposed incentive and merit increases and benefit program eligibility and participation information. The information collected is used solely for human resource administration, and is not further disseminated or used for any other purpose (e.g., marketing).

No sensitive personal information, as defined in the EU and Switzerland Privacy Policy, is sent to the US.

Employees are permitted reasonable access, after notice, to the personal information transferred to the US and may correct, amend or delete information that is inaccurate as reasonably possible. For access to your personal information, please contact your local human resource representative.

Acushnet also transfers personal information to third-parties who use personal information provided for human resource administration tasks on behalf of Acushnet. Acushnet obtains assurances from these third parties that they will safeguard personal information consistent with the terms of the EU and Switzerland Privacy Policy. If Acushnet learns that a third party is using or disclosing personal information in a manner contrary to the terms of the EU and Switzerland Privacy Policy, Acushnet will take steps to prevent or stop the use or disclosure.