PRIVACY POLICY
Last updated September 18, 2025
This Privacy Notice for
Perflection.AI, Inc.
) your personal information when you use our services (
- Visit our website
at https://perflection.ai or any website of ours that links to this Privacy Notice
- Use
SwingLens .A Coach-Led AI training platform that empowers coaches and recreational golfers to teach and train anytime, anywhere.
- Engage with us in other related ways, including any sales, marketing, or
events
Questions or concerns? Reading this Privacy Notice will help
you understand your privacy rights and choices. We are responsible for making decisions about how your
personal information is processed. If you do not agree with our policies and practices, please do not use
our Services.contact@perflection.ai .
SUMMARY OF KEY POINTS
This
summary provides key points from our Privacy Notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of contents below to find the section you are
looking for.
What
personal information do we process? When you visit, use, or navigate our Services, we may process
personal information depending on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about personal information you disclose to us.
Do we
process any sensitive personal information? Some of the information may be considered
Do we
collect any information from third parties?
How do we
process your information? 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 may also process
your information for other purposes with your consent. We process your information only when we have a valid
legal reason to do so. Learn more about how we process your
information.
In what
situations and with which
How do we
keep your information safe? We have adequate
What are
your rights? Depending on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you
exercise your rights? The easiest way to exercise your rights is by
visiting
contact@perflection.ai
Want to learn more
about what we do with any information we collect? Review the Privacy Notice
in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.We collect personal
information that you voluntarily provide to us when you
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:
-
names
-
email addresses
-
phone numbers
-
mailing addresses
-
usernames
-
passwords
-
contact preferences
-
contact or authentication data
-
billing addresses
-
debit/credit card numbers
Sensitive Information.
-
health data
-
student data
-
video of users' physical movement including their faces
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 handled and stored byStripe
https://stripe.com/zh-us/privacy
Social Media
Login Data. We may provide you with the option to register with us using your existing social
media account details, like your Facebook, X, or other social media account. If you choose to register in
this way, we will collect certain profile information about you from the social media provider, as described
in the section called
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 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.
The 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. Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and settings and information about your
activity in the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches, and other actions you take such as which features you
use), device event information (such as system activity, error reports (sometimes called
"crash dumps" ), and hardware settings).
- Device Data. We collect device data such as information about your
computer, phone, tablet, or other device you use to access the Services. Depending on the device used,
this device data may include information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service provider and/or mobile
carrier, operating system, and system configuration information.
Google API
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.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 facilitate
account creation and authentication and otherwise manage user accounts. We may process your
information so you can create and log in to your account, as well as keep your account in working
order.
- To deliver
and facilitate delivery of services to the user. We may process your information to provide
you with the requested service.
- To respond
to user inquiries/offer support to users. We may process your information to respond to
your inquiries and solve any potential issues you might have with the requested service.
- To send
administrative information to you. We may process your information to send you details
about our products and services, changes to our terms and policies, and other similar
information.
- To
fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. We may
process your information if you choose to use any of our offerings that allow for
communication with another user.
- To request feedback. We may process your
information when necessary to request feedback and to contact you about your use of our
Services.
- To send you marketing and promotional communications.
We may process the personal information you send to us for our marketing purposes, if
this is in accordance with your marketing preferences. You can opt out of our marketing emails at
any time. For more information, see
" WHAT ARE YOUR PRIVACY RIGHTS? " below.
- To post testimonials. We post testimonials on
our Services that may contain personal information.
- To protect our
Services. We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and prevention.
- To evaluate and
improve our Services, products, marketing, and your experience. We may
process your information when we believe it is necessary to identify usage trends,
determine the effectiveness of our promotional campaigns, and to evaluate and improve
our Services, products, marketing, and your experience.
- To identify usage
trends. We may process information about how you use our Services to better
understand how they are being used so we can improve them.
- To comply with
our legal obligations. We may process your information to comply with
our legal obligations, respond to legal requests, and exercise, establish, or
defend our legal rights.
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 (i.e.If you are located in Canada, this section
applies to you.
We may process your information if you have given us
specific permission (i.e.
In some exceptional cases, we may be legally permitted
under applicable law to process your information without your consent, including,
for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations
and fraud detection and prevention
- For business
transactions provided certain conditions are met
- If it is contained in
a witness statement and the collection is necessary to assess, process, or
settle an insurance claim
- For identifying
injured, ill, or deceased persons and communicating with next of
kin
- If we have reasonable
grounds to believe an individual has been, is, or may be victim of financial
abuse
- If it is reasonable
to expect collection and use with consent would compromise the availability or
the accuracy of the information and the collection is reasonable for purposes
related to investigating a breach of an agreement or a contravention of the laws
of Canada or a province
- If disclosure is
required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
- If it was produced by
an individual in the course of their employment, business, or profession and the
collection is consistent with the purposes for which the information was
produced
- If the collection is
solely for journalistic, artistic, or literary purposes
- If the information is
publicly available and is specified by the regulations
- We may disclose de-identified information for approved
research or statistics projects, subject to ethics oversight and confidentiality
commitments
We
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates.
We may share your information with our affiliates, in which case we
will require those affiliates to
honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business
Partners. We may share your information with our business partners
to offer you certain products, services, or promotions.
- Other
Users. When you share personal information
(for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.The Services
We may use cookies and similar tracking
technologies (like web beacons and pixels) to gather information when you
interact with our Services. Some online tracking technologies help us
maintain the security of our Services
We also permit third parties and service
providers to use online tracking technologies on our Services for analytics
and advertising, including to help manage and display advertisements, to
tailor advertisements to your interests, or to send abandoned shopping cart
reminders (depending on your communication preferences). The third parties
and service providers use their technology to provide advertising about
products and services tailored to your interests which may appear either on
our Services or on other websites.
To the extent these online tracking technologies
are deemed to be a
Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie
Notice
analyzeRemarketing with Google Analytics
Google Display
Network Impressions Reporting
Google Analytics
Demographics and Interests Reporting
To opt out of being tracked by Google Analytics across the Services,
visit https://tools.google.com/dlpage/gaoptout.
Google Analytics
We may share your information with Google Analytics to track and7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.As part of our Services, we offer products,
features, or tools powered by artificial intelligence, machine learning, or
similar technologies (collectively,
). These tools are designed to enhance your experience and provide you
with innovative solutions. The terms in this Privacy Notice govern your use of
the AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party
service providers (
), including Google Cloud AI
You must not use the AI Products in any way that violates the terms or
policies of any AI Service Provider.
Our AI Products
Our AI Products are designed for the following
functions:
-
Video analysis
-
AI bots
-
AI insights
-
AI predictive analytics
-
AI translation
-
Image analysis
-
Machine learning models
-
AI applications
-
Natural language processing
-
Text analysis
How We Process Your Data Using
AI
All personal information processed using our AI
Products is handled in line with our Privacy Notice and our agreement with
third parties. This ensures high security and safeguards your personal
information throughout the process, giving you peace of mind about your data's
safety.
Our Services offer you the ability to register
and log in using your third-party social media account details (like your
Facebook or X logins). Where you choose to do this, we will receive certain
profile information about you from your social media provider. The profile
information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends list,
and profile picture, as well as other information you choose to make public
on such a social media platform.
We will use the information we receive only
for the purposes that are described in this Privacy Notice or that are
otherwise made clear to you on the relevant Services. Please note that we do
not control, and are not responsible for, other uses of your personal
information by your third-party social media provider. We recommend that you
review their privacy notice to understand how they collect, use, and share
your personal information, and how you can set your privacy preferences on
their sites and apps.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary toWe will only keep your personal information
for as long as it is necessary for the purposes set out in this Privacy
Notice, unless a longer retention period is required or permitted by law
(such as tax, accounting, or other legal requirements).
As a general rule, our retention period for all categories of personal information is tied to your account status. We
will permanently destroy your personal information upon the earliest of the following events:
- The initial purpose for collecting the information has been satisfied;
- You submit a verifiable request for us to delete your information (as described in the "Your Privacy Rights" section), subject to any legal or contractual exceptions; or
- A maximum of three (3) years has passed since the termination or deletion of your user account.
When we have no ongoing legitimate business
need to process your personal information, we will either delete or
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system ofWe have implemented appropriate and reasonable
technical and
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:In some regions (like
below.
We will consider and act upon any request in
accordance with applicable data protection laws.
Withdrawing your
consent: If we are relying on your consent to process your
personal information,
HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
below
However, please note that this will not affect
the lawfulness of the processing before its withdrawal nor,
Opting out of marketing and
promotional communications: You can
unsubscribe from our marketing and promotional communications at any time by
"STOP" or "UNSUBSCRIBE"
below. You will then be removed from the marketing lists. However, we
may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.
No mobile information will be shared with third
parties or affiliates for marketing or promotional purposes. Information
sharing to subcontractors in support services, such as customer service, is
permitted. All other use case categories exclude text messaging originator
opt-in data and consent; this information will not be shared with third
parties.
Account Information
If you would at any time 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.
-
Contact us using the contact information provided.
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 in our files to prevent
fraud, troubleshoot problems, assist with any investigations, enforce our
legal terms and/or comply with applicable legal requirements.
Cookies and similar
technologies: Most Web browsers are set to accept cookies
by default. If you prefer, you can usually choose to set your browser to
remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our
Services.
If you have questions or comments about your privacy
rights, you may email us at contact@perflection.ai
.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (California law requires us to let you know how
we respond to web browser DNT signals. Because there currently is not an
industry or legal standard for
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident ofCategories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section| Category | Examples | Collected |
|---|---|---|
|
A. Identifiers
|
Contact details, such as real name,
alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address,
email address, and account name
|
|
|
B. Personal information as defined in
the California Customer Records statute
|
Name, contact information, education,
employment, employment history, and financial
information
|
|
|
|
Gender, age, date of birth, race and
ethnicity, national origin, marital status, and other demographic
data
|
|
|
|
Transaction information, purchase
history, financial details, and payment
information
|
|
|
|
Fingerprints and
voiceprints
|
|
|
|
Browsing history, search history,
online
|
|
|
|
Device location
|
|
|
|
Images and audio, video or call
recordings created in connection with our business
activities
|
|
|
|
Business contact details in order to
provide you our Services at a business level or job title, work
history, and professional qualifications if you apply for a job with
us
|
|
|
|
Student records and directory
information
|
|
|
|
Inferences drawn from any of the
collected personal information listed above to create a profile or
summary about, for example, an individual’s preferences and
characteristics
|
|
|
|
|
|
We only collect sensitive personal information,
as defined by applicable privacy laws or the purposes allowed by law or with
your consent. Sensitive personal information may be used, or disclosed to a
service provider or contractor, for additional, specified purposes. You may
have the right to limit the use or disclosure of your sensitive personal
information.
We may also collect other personal information
outside of these categories through instances where you interact with us in
person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in
customer surveys or contests; and
- Facilitation in
the delivery of our Services and to respond to your inquiries.
- Category A -
As long as the user has an account with us
- Category B -
As long as the user has an account with us
- Category
- As long as the user has an account with us
- Category
K - As long as the user has an account with us
- Category
L - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect inHow We Use and Share Personal Information
Will your information be
shared with anyone else?
We may disclose your personal
information with our service providers pursuant to a written
contract between us and each service provider. Learn more
about how we disclose personal information to in the section,
We may use your personal
information for our own business purposes, such as for
undertaking internal research for technological development
and demonstration. This is not considered to be
We have not disclosed, sold, or
shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12)
months. We will
not sell or share personal information in the future belonging
to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:- Right to know whether
or not we are processing your personal data
- Right to access your
personal data
- Right to correct
inaccuracies in your personal data
- Right to request the
deletion of your personal data
- Right to obtain a copy
of the personal data you previously shared with us
- Right to
non-discrimination for exercising your rights
- Right to opt out of
the processing of your personal data if it is used for targeted
advertising
(or sharing as defined under California’s privacy law) , the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ( "profiling" )
Depending upon the state where you
live, you may also have the following rights:
- Right to access the categories of
personal data being processed (as permitted by applicable law,
including the privacy law in Minnesota)
- Right to obtain a list of the
categories of third parties to which we have disclosed personal
data (as permitted by applicable law, including the privacy law
in
California, Delaware, and Maryland )
- Right to obtain a list of specific
third parties to which we have disclosed personal data (as
permitted by applicable law, including the privacy law in
Minnesota and Oregon )
- Right to review, understand, question,
and correct how personal data has been profiled (as permitted by
applicable law, including the privacy law in Minnesota)
- Right to limit use and disclosure of
sensitive personal data (as permitted by applicable law,
including the privacy law in California)
- Right to opt out of the collection of
sensitive data and personal data collected through the operation
of a voice or facial recognition feature (as permitted by
applicable law, including the privacy law in Florida)
How to Exercise Your Rights
To exercise these rights, you can contact usWe will
Under certain US state data
protection laws, you can designate an
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.If you submit the request through
an
contact@perflection.ai
California
California
Civil Code Section 1798.83, also known as the
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us atCalifornia
California
Civil Code Section 1798.83, also known as the 14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.Australia
We collect and process your
personal information under the obligations and conditions set by
This Privacy Notice satisfies the
notice requirements defined in
both Privacy Acts
If you do not wish to provide the
personal information necessary to
fulfill
- offer you the products or
services that you want
- respond to or help with your
requests
- manage your account with
us
- confirm your identity and
protect your account
At any time, you have the right to
request access to or correction of your personal information.
You can make such a request by contacting us by using the
contact details provided in the section
If you believe we are unlawfully
processing your personal information, you have the right to
submit a complaint about
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.We may update this Privacy
Notice from time to time. The updated version will be
indicated by an updated
8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.