Privacy Policy

Notice at Collection

The following table summarizes, for each category of personal information we collect, the purposes for collection, whether the category is sold or shared, and the categories of third parties or service providers that receive it. For more detail on each item, please refer to the corresponding sections of this Privacy Policy.

1. Information We Collect

We collect the following categories of personal information in connection with our Services:

2. How Your Information Is Collected

We collect your personal information from the following sources:

• Directly from you — when you create an account through our mobile application, contact us, or otherwise provide information to us
• From the ACE robot — which automatically captures Player Tracking Data, Live Play Data, and Video and Photo Content during your round
• From your use of our Services — including your interactions with our mobile application and website, collected through automated means such as cookies and analytics tools

3. Why We Collect and Use Your Information

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

• Providing, operating, and maintaining the Services, including delivering Live Play Data and Video and Photo Content to you through the mobile application
• Enabling you to view, manage, and share your golf round content and performance data
• Creating and managing your Valeron account
• Training, improving, and enhancing our systems, algorithms, robot performance, and the Services, including the accuracy of player tracking, content capture, and data analysis
• Debugging and identifying and repairing errors that impair the functionality of the Services
• Ensuring the security and integrity of our systems and preventing fraud
• Communicating with you about your account, the Services, updates, and responding to your inquiries
• Analyzing usage trends and improving the user experience on our website and mobile application
• Complying with our legal and regulatory obligations

4. Categories of Information Sold to or Shared with Third Parties

Valeron does not sell your personal information. We do not share your personal information with third parties for cross-contextual behavioral advertising or targeted advertising purposes.

5. Categories of Information Disclosed for a Business Purpose

We may disclose the following categories of personal information to the following categories of service providers strictly for business purposes necessary to operate the Services:

All service providers are contractually obligated to use your personal information only as necessary to provide their services to Valeron and are prohibited from using it for their own purposes. These disclosures are made solely for business purposes necessary to operate and deliver the Services to you. Our service provider contracts also include the right for Valeron to take reasonable and appropriate steps to help ensure that each service provider uses personal information in a manner consistent with this Privacy Policy and to stop and remediate any unauthorized use.

6. Use or Disclosure of Sensitive Personal Information

Under the CCPA/CPRA, certain categories of personal information are considered “sensitive personal information.” Valeron's collection of data may include information that could be characterized as sensitive, such as precise geolocation (player location on the course) and biometric-adjacent data (likeness, gait, body dimensions) captured by the ACE robot.

Player Tracking Data—which includes likeness, gait, and body dimension information—is de-identified and stored only in the ACE robot's onboard memory during your round. It is never associated with your account and is automatically deleted at the conclusion of your round.

To the extent we collect or process any sensitive personal information, we use it only for the following purposes:

• To perform the Services reasonably expected by Players
• To ensure the security and integrity of the Services
• To verify or maintain the quality or safety of the ACE robot and related Services, and to improve, upgrade, or enhance the Services

You have the right to limit the use and disclosure of your sensitive personal information. If you exercise this right, we will limit our use and disclosure to the purposes listed above. To exercise this right, you may submit a request by emailing privacy@valeron.ai or writing to us at the address provided in Section 16, or through any “Limit the Use of My Sensitive Personal Information” link we make available in the mobile application or on our website.

7. Data Security and Storage

We take the security of your data seriously. We use encryption for data in transit and at rest where technically appropriate and feasible, using industry-standard encryption protocols. This applies to data stored on the ACE robot, data transmitted between the robot and our cloud services, and data held in our cloud infrastructure.

• On-Robot Storage: Player Tracking Data is encrypted on the ACE robot's onboard memory and is automatically deleted at the conclusion of your round.
• Data in Transit: Live Play Data and Video and Photo Content are transmitted from the ACE robot to the Valeron Data Service via encrypted cellular and WiFi connections.
• Cloud Storage: Your account information, Live Play Data, and Video and Photo Content are stored on encrypted public cloud infrastructure.

8. Cookies and Similar Technologies

Our website at valeron.ai uses cookies and similar technologies. We use:

• Essential Cookies: Necessary for the website to function properly.
• Analytics Cookies: Help us understand how visitors interact with our website so we can improve the user experience. These cookies collect information such as pages visited, time spent on pages, and referring URLs.

We do not use advertising or retargeting cookies. Our mobile application does not use cookies but may collect usage analytics as described in Section 1.5.

9. Data Retention

We retain your personal information in accordance with the following practices:

• Player Tracking Data: Automatically deleted from the ACE robot's onboard memory immediately at the conclusion of your round.
• Account Information, Live Play Data, and Video and Photo Content: Retained for as long as your account is active. This data is subject to earlier deletion upon a verified deletion request submitted under Section 11, except where retention is required by law or falls within a permitted exception described in that section.
• Inactive Accounts: If your account is inactive for 12 consecutive months, we will provide you with notice before deactivating and deleting your account and associated data.
• Deletion Requests: Upon a verified deletion request, we will delete your personal information in accordance with Section 11.

We may retain certain information as required by law or for legitimate business purposes, such as resolving disputes or enforcing our agreements.

10. Use of Data to Train and Improve Our Systems

Valeron uses Player Tracking Data, Live Play Data, and Video and Photo Content to train and improve our systems, algorithms, and Services. This includes improving the ACE robot's ability to track players, capture content, analyze golf performance, and deliver a better overall experience.

When data is used for training and improvement purposes, we take steps to de-identify it where feasible. Aggregated or de-identified data that can no longer reasonably identify you may be used without restriction.

11. Your Rights Under California Law

As a California consumer, you have the following rights under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA):

• Right to Know – You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business purpose for collecting the information, and the categories of third parties to whom we have disclosed the information.
• Right to Delete – You have the right to request that we delete your personal information, subject to certain exceptions. Upon receipt of a verified request, we will delete your personal information from our records and direct our service providers to do the same. We may not delete your personal information if it is reasonably necessary to:
  • Complete a transaction or provide a service you requested, or otherwise perform a contract between you and us
  • Help ensure security and integrity to the extent reasonably necessary and proportionate
  • Debug to identify and repair errors that impair existing intended functionality
  • Exercise a right provided for by law
  • Comply with the California Electronic Communications Privacy Act
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
  • Comply with an existing legal obligation
• Right to Correct – You have the right to request that we correct inaccurate personal information that we maintain about you. Upon receipt of a verified request, we will use commercially reasonable efforts to correct the inaccurate information.
• Right to Opt-Out of Sale or Sharing – While Valeron does not sell or share personal information for cross-contextual behavioral advertising, you retain the right to opt-out of any future sale or sharing.
• Right to Limit Use of Sensitive Personal Information – You have the right to limit our use and disclosure of your sensitive personal information to the purposes described in Section 6.
• Right to Non-Discrimination – We will not discriminate against you for exercising any of your rights. This means we will not deny you services, charge you different prices, provide a different level or quality of service, or suggest that you will receive a different price or level of service.

12. How to Exercise Your Rights

You can submit a request to exercise your rights to access, correct, or delete your personal information by contacting us at:

Please note that you may only make a data access or portability request twice within a 12-month period.

13. Children's Privacy

The Services are intended for individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe that a person under 18 has provided personal information to us, please contact us at privacy@valeron.ai.

14. Sharing Content with Others

Our mobile application allows you to share your Live Play Data and Video and Photo Content with others (for example, by sending videos, photos, or performance data to friends or posting on social media). When you choose to share content, that content may be viewed, copied, or further shared by the recipients. Valeron is not responsible for how others use content that you have chosen to share.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this Privacy Policy and, for material changes that affect the categories of personal information collected, the purposes for which it is used, or its sold or shared status, we will provide direct notice to you via in-app notification or email before the changes take effect. We encourage you to review this Privacy Policy periodically.

16. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: