Privacy Policy

Version 1.8 · Last updated: August 19, 2026

1. Introduction

This Privacy Policy ("Policy") explains how Round Update ("we," "us," or "our") collects, uses, discloses, and retains information when you use the Round Update application at app.roundupdate.com and related domains — including roundupdatecdn.com, which stores and delivers the photos, video, and voice notes uploaded to the Service (together, the "Service") — operated by Round Update LLC, a California limited liability company with a mailing address at 2108 N Street, Suite N, Sacramento, CA 95816. Round Update LLC is the controller (and, where applicable, the "business") responsible for the personal information described in this Policy.

This Policy is incorporated into and forms part of the Round Update Terms of Service. By using the Service you acknowledge this Policy. Where applicable law requires consent for a specific processing activity, we will obtain that consent separately and this Policy does not itself serve as that consent.

2. Summary

In plain terms: Round Update is built to work without an account. We collect the information needed to run live golf scoring and sharing — the names and scores you enter, and, if you choose, your email, phone number, photos, and comments. Anyone you give a round's link to can see that round's contents. We use a small number of service providers to run the app. We do not sell or share your personal information as those terms are defined under U.S. state privacy laws, we do not use third-party advertising or analytics trackers, we do not use your content to train artificial-intelligence models, and — as of the current version of the app — we do not collect your precise geolocation. We do ask for your date of birth, so that we can apply our minimum age requirement and, for account holders under 18, ask a parent or guardian to consent. The sections below give the detail.

This summary is provided for convenience only and does not modify the sections that follow.

3. Information You Provide

  • Player names. The names entered for players in a round. Because one person often sets up a round for a group, a name you did not enter yourself may be entered by someone else in your group. See Section 8 (Information About Other People).
  • Email address. If you choose to sign in, the email address you provide, used to send a one-time sign-in code and to associate saved rounds with your account.
  • Phone number. If you opt in to follow a round by text message, the mobile number you provide, used to send SMS notifications about that round.
  • Handicaps and scores. Self-reported handicap information and the golf scores entered during a round.
  • Hole updates, comments, and photos. Text updates and photos posted to a round, and comments posted to a round's discussion. Photos are re-encoded when uploaded, which removes embedded metadata such as EXIF data, including any GPS location.
  • Profile details. If you create an account, an optional display name and an optional avatar photo.
  • Round security details. A PIN you set to protect a round's editor link. PINs are stored in hashed (not plain-text) form.
  • Date of birth. The date of birth you provide when you create an account, or, on a device without an account, the first time you create a round or post content. Keeping score in a round someone else set up does not require it. We use it to apply the minimum age requirement in our Terms and to determine whether parental consent is required. See Section 17.
  • Parent or guardian contact and consent records. If you have an account and are under 18, the email address you give us for a parent or guardian, and a record of that person's response, including the date and time, the version of the legal terms accepted, and limited technical information.
  • Subscription and billing information. If you purchase Round Update Premium, our payment processor (Stripe) processes your payment and shares limited billing information with us — such as your subscription status, plan, current billing period, and a payment-processor customer identifier. We do not receive your full payment-card number.
  • Communications with us. If you email us or submit a request, the contents of that message and any information you include in it, retained so we can respond and keep a record of the request.

4. Information Collected Automatically

  • Device identifiers and local storage. To make the Service work without an account, we store small identifiers and settings in your browser's local storage — for example, a random per-device identifier, which player you have identified as in a round, and whether you have accepted our legal terms. These stay on your device until cleared.
  • IP address and technical data. When you use the Service, our hosting and security providers receive your IP address and standard request information (such as browser type, referring page, and general timestamps), used to operate the Service, prevent abuse, and enforce rate limits. For rate-limiting we store IP addresses only in a hashed form.
  • Bot-protection signals. On certain actions (signing in, creating a round, or signing up for notifications) we use a bot-protection challenge that processes your IP address and browser signals to distinguish people from automated scripts.
  • Age eligibility record. When you answer the date-of-birth question on a device without an account, we record only the result of that check — whether the device is eligible — along with the date and the device identifier described above. We do not store the date of birth you entered.
  • Diagnostic and error information. If the Service encounters an error, limited diagnostic information may be logged to help us diagnose and fix it.

5. Consent and Acceptance Records

When you accept our Terms and this Privacy Policy — for example, when starting a round, requesting a sign-in code, or joining a round — we keep a record of that acceptance for our legitimate interest in demonstrating agreement and for compliance with electronic-contracting requirements. This record includes the date and time, the version of the legal terms accepted, a device identifier and (if signed in) your account identifier, the email address used at sign-up (for the sign-up action only), your IP address, and your browser's user-agent string. These records are kept internally and are not shown to other users.

6. Information We Do Not Collect or Do

  • Precise geolocation. The current version of the Service does not collect, use, or share your device's precise geolocation. (Weather shown for a round is based on the golf course, not on your device.)
  • Age beyond what the age requirement needs. We ask for your date of birth to apply our minimum age requirement and to determine whether parental consent is required, and for no other purpose. We do not use age or date of birth for advertising, profiling, content ranking, or personalization of any kind, and we do not disclose it to third parties except as needed to operate the Service. Where you answer the question without an account, we keep only whether the device is eligible, not the date itself. See Section 17 (Children's and Teens' Privacy).
  • Sensitive personal information. We do not intentionally collect categories of information treated as "sensitive personal information" or "special category" data under applicable law — such as government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, health information, biometric data, union membership, sexual orientation, immigration status, or the contents of your private communications. We do not use or disclose sensitive personal information for any purpose that would require an opt-out right under U.S. state law. If you voluntarily include such information in free-text fields or photos, you do so at your own election and we ask that you not.
  • Metadata in uploaded media. Photos and videos can contain embedded metadata, such as the location where they were taken. We re-encode uploaded photos in a way that removes this metadata, and we make a best-effort attempt to remove location metadata from uploaded videos before they are stored. Because video file formats vary, we cannot guarantee that every trace of metadata is removed from every video. Please do not upload media whose embedded information you would not want visible to people you share the round with.
  • Third-party advertising and analytics trackers. We do not embed third-party advertising networks or third-party analytics/tracking scripts in the Service, and we do not engage in cross-context behavioral advertising or targeted advertising.
  • Payment information. We do not receive or store your full payment-card number. Round Update offers an optional paid subscription, and if you subscribe, your card details are provided directly to our payment processor, Stripe (listed in Section 10), not to us. The Service does not record or display wager amounts, and any wager among players is agreed and settled entirely outside of Round Update.
  • Automated decision-making and profiling. We do not use your personal information to make decisions that produce legal or similarly significant effects about you, and we do not engage in profiling in furtherance of such decisions.
  • AI model training. We do not use your User Content or personal information to train, fine-tune, or improve generative artificial-intelligence or machine-learning models, and we do not permit our service providers to do so with information they process on our behalf.

7. How We Use Information, and Our Legal Bases

We use the information described above to:

  • provide the Service — creating and displaying rounds, scores, leaderboards, updates, comments, and photos to the people a round is shared with;
  • authenticate sign-ins and associate saved rounds with your account;
  • send the notifications you opt into (for example, SMS updates about a round you follow);
  • send occasional product update and announcement emails about the Service, which you may opt out of at any time using the unsubscribe link in the email;
  • look up golf-course information and show weather for a course;
  • secure the Service, prevent abuse and fraud, debug errors, and enforce rate limits;
  • maintain records of acceptance of our legal terms;
  • respond to your questions, requests, and privacy-rights requests; and
  • comply with legal obligations, establish or defend legal claims, and enforce our Terms.

We do not use personal information for materially different, unrelated, or incompatible purposes without first providing notice and, where required, obtaining your consent.

Legal bases (for users in the EEA, UK, and Switzerland)

Where the EU/UK GDPR or comparable law applies, we rely on the following legal bases:

PurposeLegal basis
Creating, displaying, and sharing rounds; account sign-inPerformance of a contract (Art. 6(1)(b))
SMS notifications; optional profile detailsConsent (Art. 6(1)(a)), withdrawable at any time
Product update and announcement emailsLegitimate interests (Art. 6(1)(f)) in informing existing users about the Service, with an opt-out available in every email
Security, abuse prevention, rate limiting, bot protection, debuggingLegitimate interests (Art. 6(1)(f)) in operating a secure service
Consent and acceptance recordsLegitimate interests (Art. 6(1)(f)) and legal obligation (Art. 6(1)(c))
Responding to legal process; retention for legal claimsLegal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f))
Automated screening of uploaded images for known child sexual abuse materialLegal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) in keeping the Service safe

Automated content safety. Images uploaded to the Service are automatically compared against industry-standard lists of known child sexual abuse material by our storage and content-delivery provider. This is an automated hash-matching comparison; it is not used to profile you, to rank or personalize content, or for advertising, and no human reviews your images as part of it. A match may result in the content being blocked, your access being suspended, and a report to the National Center for Missing & Exploited Children as required by United States law (18 U.S.C. § 2258A). Where we are required to make such a report, we also preserve the associated content and account records for the period required by law, even if you have deleted them — see Section 13.

8. Information About Other People

The Service is designed so that one person can set up a round on behalf of a group. That means information about you — such as your name, score, or a photo you appear in — may be entered by another user rather than by you.

  • If you enter information about others: you are responsible for having a lawful basis and, where required, their permission, and for honoring any request from them to remove it. See the Terms of Service, Section 6.
  • If your information appears in a round you do not control: you may contact the person who created that round, or contact us at info@roundupdate.com and we will make reasonable efforts to assist, including by removing the information where we are able to do so.

9. How Information Is Shared and Made Public

  • With people you share a round with. Anyone who has a round's share link can view that round's scores, updates, comments, and photos. Share links are unlisted but are not secret: anyone who obtains a link — including by it being forwarded — can view the round. Do not post anything you would not want everyone with the link to see.
  • Among participants. Players and followers of a round can see the names, scores, and posts associated with that round.
  • Service providers. We disclose information to the providers listed in Section 10, who process it on our behalf under written agreements that limit them to processing for our specified purposes and prohibit selling or retaining it for their own purposes.
  • Sponsor content. The Service may display sponsor or promotional content. This content is served by us and does not involve third-party ad-tracking of you. We do not disclose your personal information to sponsors.
  • Legal and safety. We may disclose information if required by law or valid legal process, or where we believe in good faith that disclosure is necessary to protect the rights, safety, or property of Round Update, our users, or the public. Where permitted by law, we will make reasonable efforts to notify you of a legal demand for your information before disclosing it.
  • Business transfers. If Round Update is involved in a merger, acquisition, financing, reorganization, or sale of assets (including in bankruptcy), information may be transferred as part of that transaction. We will require the recipient to honor this Policy or provide notice and, where required, a choice before your information becomes subject to a materially different policy.

We do not sell your personal information, we do not share it for cross-context behavioral advertising or targeted advertising, and we have not done so in the preceding 12 months. We do not knowingly sell or share the personal information of consumers under 16 years of age.

10. Service Providers and Subprocessors

We rely on the following providers to operate the Service. Each processes only the information needed for its function and is bound by a written agreement restricting its use of that information:

ProviderPurpose in Round UpdateData it may process
SupabaseDatabase and authentication that runs the appNames, email addresses, scores, handicaps, hole updates, comments, PINs (hashed), consent records
VercelApplication hosting and deliveryIP address and standard server/request logs
Cloudflare (Turnstile, R2 storage, and content delivery)Bot and abuse protection on sign-in, round creation, and notification sign-up; storage and delivery of uploaded media from roundupdatecdn.com; automated screening of uploaded images against known child-sexual-abuse-material hash listsIP address and browser/challenge signals; photos, video, voice notes, and avatars
ResendSending transactional email (sign-in codes) and occasional product update and announcement emailsEmail address; parent or guardian email address for consent requests
StripeProcessing payments for paid subscriptionsName, email address, payment-card details (provided directly to Stripe), and billing information
TwilioSending optional SMS score-update notificationsPhone number
OpenGolfAPILooking up golf course and hole informationCourse search terms (no personal identifiers)
National Weather Service (weather.gov)Showing weather for a round's courseApproximate course location (not your device location)

11. Categories of Personal Information (U.S. State Law Disclosure)

The following table describes, for the preceding 12 months, the categories of personal information we collect using the category labels found in the California Consumer Privacy Act, as amended ("CCPA/CPRA"), and comparable state laws.

Statutory categoryExamples we collectSourcePurposeDisclosed to
IdentifiersName, email address, phone number, date of birth, parent or guardian email address, IP address, device identifier, account identifierYou; other users in your round; automaticallyProvide the Service; authenticate; notify; apply age requirements; securityService providers (Section 10)
Customer records (Cal. Civ. Code § 1798.80)Name, email address, phone numberYouProvide the Service; notifyService providers
Commercial informationSubscription plan and purchase/transaction recordsYou; StripeProvide and manage paid subscriptionsPayment processor (Stripe)
Internet or network activityRequest logs, browser type, bot-challenge signals, local-storage settingsAutomaticallyOperate and secure the ServiceHosting and security providers
Geolocation dataNone (course location only, not device location)
Audio, visual, or similar informationPhotos, video, voice notes, and avatars you uploadYouDisplay within a round; automated screening for known child sexual abuse materialStorage and content-delivery provider
Professional or employment informationNone collected
Education informationNone collected
Sensitive personal informationNone intentionally collected (see Section 6)
InferencesNone drawn

12. Cookies and Similar Technologies

Round Update relies primarily on browser local storage (described in Section 4) rather than advertising cookies. Some providers — for example, our bot-protection provider — may set their own cookies or similar technologies strictly necessary to deliver their service. We do not use cookies for third-party advertising, retargeting, or cross-site tracking.

Global Privacy Control and Do Not Track

Because we do not sell or share personal information or engage in targeted advertising, there is no opt-out for us to apply. We nonetheless recognize opt-out preference signals such as Global Privacy Control (GPC). We do not respond to Do Not Track browser signals, as no common standard for them has been adopted.

13. Data Retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, or for a longer period where required by law or to establish, exercise, or defend legal claims. Our current retention practices are:

InformationRetention period
Round data (scores, updates, comments, photos)Until deleted. A round can be deleted by the account that owns it, by the device that created it, and by anyone who has been given the round's PIN — the PIN grants full editing access, including deleting the round and everything in it. Rounds belonging to accounts inactive for 36 months may be deleted after advance notice to the account holder.
Your contributions to a round someone else createdDeleting your account unlinks it from those rounds and removes your profile — your display name and photo. The name entered for you on the scorecard, along with your scores, updates, comments and photos, stays in the round, so the round remains intact for the owner and the other players. If you want those removed as well, contact us at info@roundupdate.com.
Rounds you createdIf you were the only person in a round, deleting your account deletes that round and everything in it. If other people took part, the round is kept and simply has no owner, so their scores, updates, comments and photos are not destroyed along with your account — and yours stay in it too, as described above.
Account information (email, display name, avatar)For the life of the account, then deleted within 30 days of a deletion request.
Subscription and billing recordsFor the life of the subscription and afterward as needed for tax, accounting, and legal compliance (generally up to seven years).
Spectator and viewer dataWe do not create accounts for or retain personal information about people who only view a shared round. Aggregated, non-identifying view counts may be retained indefinitely.
Consent and acceptance records4 years from the date of acceptance, or 4 years after the account is closed, whichever is later.
Date of birth (account holders)For the life of the account, then deleted within 30 days of a deletion request.
Device age eligibility recordsThe result of the check and the device identifier only, retained while the device remains in use and for up to 12 months after. No date of birth is retained.
Parental consent records4 years from the date of consent, or 4 years after the account is closed, whichever is later.
Records of blocked under-13 registrationsA one-way hash of the email address and the date only, retained indefinitely so that we can enforce the block. We do not retain the date of birth or any other information from a blocked registration.
Security and rate-limiting logs (hashed IPs)90 days
Phone numbers for SMS notificationsUntil you opt out. After opt-out we delete the number and retain only a one-way hash on our suppression list, indefinitely, so we can continue honoring your opt-out.
Support correspondence24 months after the matter is resolved
Content subject to a legal preservation obligationWhere we are required to report content to the National Center for Missing & Exploited Children, we preserve the reported content and the associated account and device records for at least one year, as required by 18 U.S.C. § 2258A, and for longer if legal process requires it. This applies notwithstanding any deletion by you or any other retention period in this table.
Uploaded media after a round is deletedPhotos, video, and voice notes are removed from storage when the round they belong to is deleted, by an automated cleanup that runs daily; they may therefore remain in storage for a short period after deletion.
BackupsDeleted data persists in encrypted backups for up to 30 days before being overwritten.

14. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include row-level access controls that restrict database reads and writes, encryption in transit (TLS) and at rest, hashed storage of round PINs, hashing of IP addresses used for rate-limiting, bot-protection on sensitive actions, and access to production systems limited to personnel who need it.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping access to your email account secure and for deciding with whom you share round links and PINs.

Breach notification

If we become aware of a security incident affecting your personal information, we will notify you and applicable regulators as required by law and without undue delay.

15. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights regarding your personal information:

  • Know and access. Request confirmation of whether we process your personal information and a copy of it, including the categories collected, sources, purposes, and recipients.
  • Correct. Request correction of inaccurate personal information.
  • Delete. Request deletion of your personal information, subject to legal exceptions.
  • Portability. Request a copy of personal information you provided to us in a portable, machine-readable format, and where technically feasible, transmission to another controller.
  • Opt out. Opt out of any sale, sharing, or targeted advertising. As noted above, we do not engage in these activities.
  • Limit use of sensitive personal information. We do not collect sensitive personal information for purposes requiring this right.
  • Withdraw consent. Where processing is based on consent, withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal.
  • Object and restrict. Where the GDPR applies, object to processing based on legitimate interests and request restriction of processing in certain circumstances.
  • Non-discrimination. We will not deny you service, charge different prices, or provide a different level of quality because you exercised these rights.

How to submit a request

Submit requests to info@roundupdate.com. We will acknowledge receipt within 10 business days and respond within 45 days, with one extension of an additional 45 days where reasonably necessary, and we will inform you of any extension. Where the GDPR applies, we will respond within one month, extendable by two further months for complex requests.

Verification

To protect your information, we will take reasonable steps to verify your identity before acting on a request. For account holders, this generally means confirming control of the email address associated with the account. For requests concerning data collected without an account, we may ask for the round link, device identifier, or other information sufficient to match the request to the data. If we cannot verify a request, we will notify you and explain why.

Authorized agents

You may use an authorized agent to submit a request on your behalf. We may require written proof of the agent's authority, verification of your own identity, and direct confirmation from you that you granted the authority.

Appeals

If we decline a request in whole or in part, you may appeal by replying to our decision or writing to info@roundupdate.com with the subject line "Privacy Appeal." We will respond to an appeal within 45 days (or the period required by your state's law) with a written explanation of our decision. If your appeal is denied, you may contact your state attorney general or, in the EEA/UK, lodge a complaint with your local supervisory authority.

Self-service options

  • Account deletion. If you have an account, you can delete it from your account settings. A round you created and played alone is deleted with it. A round other people also took part in is kept, so that their scores, updates, comments and photos are not destroyed along with your account; it simply has no owner afterwards. Rounds you only joined as a player are also kept. In every round that is kept, the name entered for you on the scorecard and anything you posted remain — see the retention table in Section 13, and contact us at info@roundupdate.com if you want them removed as well.
  • Removing content. You can delete a round you control. If your information appears in a round controlled by someone else, see Section 8.
  • SMS opt-out. Reply STOP to any notification text to stop receiving messages.
  • Local storage. You can clear the identifiers Round Update stores by clearing your browser's site data for the Service.

16. Additional U.S. State Disclosures

California

California residents have the rights described in Section 15 under the CCPA/CPRA, and may also request, once per year and free of charge, information about disclosures of personal information to third parties for their direct marketing purposes under California's "Shine the Light" law (Cal. Civ. Code § 1798.83). We do not make such disclosures. California residents under 18 who are registered users may request removal of content they posted, as described in Section 15 and Cal. Bus. & Prof. Code § 22581.

Other states

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have comparable rights to access, correct, delete, and obtain a portable copy of their personal information, and to opt out of sale, targeted advertising, and certain profiling. Requests may be submitted as described in Section 15.

Nevada

Nevada residents may submit a verified request directing us not to sell certain covered information. We do not sell covered information as defined by Nevada law.

Washington and Nevada health data

We do not collect "consumer health data" as defined by the Washington My Health My Data Act or Nevada SB 370. Golf scores and self-reported handicaps are not health data.

17. Children's and Teens' Privacy

Children under 13. The Service is not directed to children under 13, and we do not knowingly collect personal information from them. We ask for date of birth when an account is created, and, on a device without an account, before a round can be created or content posted. We do not allow any of these where the answer indicates the person is under 13. If we learn that an account belongs to a child under 13, we will close it and delete the associated personal information. If you are a parent or guardian and believe your child under 13 has provided us personal information, contact us at info@roundupdate.com and we will delete it promptly.

Users aged 13 to 17. Creating a round without an account requires you to be 18 or older. A person aged 13 to 17 can take part in a round someone else created, and can create rounds of their own by creating an account. Where an account holder is under 18, we ask for a parent or guardian's email address and contact that person to review this Policy and our Terms and confirm their consent. Until we receive that confirmation, the account is limited: the user can sign in, take part in a round someone else created, and keep score in it, but cannot create rounds of their own or post content, comments, or photos.

How we treat accounts held by minors. For accounts we know belong to a user under 18:

  • We do not use their personal information for targeted advertising, cross-context behavioral advertising, or profiling.
  • We do not sell or share their personal information.
  • We do not use their age or date of birth to rank, recommend, or personalize what they see.
  • On rounds a minor creates, we turn off public commenting and do not show prompts encouraging the round to be shared more widely, and we never switch a minor's round to a less-private state by default. A round is shared only when the user chooses to send its link, and only people who have that link can view it.
  • We collect only the personal information needed to provide the Service, and we ask for no optional profile information beyond what an adult account requires.

Rights of parents and guardians. A parent or guardian of an account holder under 18 may contact us at info@roundupdate.com to review the personal information associated with their child's account, request that we correct or delete it, request that we stop collecting it going forward, or withdraw consent — which will close the account. We may ask for information sufficient to identify the account and to verify your relationship to the user before acting on the request. We will respond within the timeframes described in Section 15.

Removal of content posted by a minor. A registered user under 18 who is a California resident may request removal of content they posted, as described in Section 15 and Cal. Bus. & Prof. Code § 22581. We extend the same removal right to users under 18 in every state.

When a user turns 18. When an account holder reaches 18, the parental consent requirement no longer applies and the protections above that are specific to minors cease, other than any that continue to apply by law. Retention of the parental consent record is described in Section 13.

18. International Users and Data Transfers

Round Update is operated from California, United States, and our providers may process and store information in the United States and other countries. If you use the Service from outside the United States, you understand your information may be transferred to and processed in countries whose data-protection laws may differ from those of your own country.

Round Update LLC has not self-certified under the EU-U.S. Data Privacy Framework and does not rely on it. Where personal information originating in the EEA, UK, or Switzerland is transferred to or accessed from the United States by us or by the service providers listed in Section 10, we rely on the European Commission's Standard Contractual Clauses (Decision 2021/914), the UK Information Commissioner's International Data Transfer Addendum for UK transfers, and the Swiss Federal Data Protection and Information Commissioner's recognized adaptations for Swiss transfers, together with supplementary technical and organizational measures where appropriate — including encryption in transit and at rest, access controls, and data minimization. Where you provide information to us directly from the EEA, UK, or Switzerland, that submission is not itself a restricted transfer, but any onward disclosure to our providers is covered by the safeguards described above. You may request a copy of the relevant safeguards by writing to info@roundupdate.com.

EU/UK representative

Round Update is operated from the United States and is directed to users in the United States. We do not market the Service in the European Economic Area or the United Kingdom, and any processing of EEA or UK personal information is occasional, does not involve large-scale processing of special categories of data or of data relating to criminal convictions, and is unlikely to result in a risk to the rights and freedoms of individuals. On that basis we rely on the exemption in Article 27(2)(a) of the EU and UK GDPR and have not appointed a representative in the EU or the UK. If our processing changes such that the exemption no longer applies, we will appoint a representative and update this Policy with their name and contact details.

Data Protection Officer

We have not appointed a Data Protection Officer. Our processing does not meet the thresholds in Article 37(1) of the EU or UK GDPR: we are not a public authority, our core activities do not consist of regular and systematic monitoring of individuals on a large scale, and they do not consist of large-scale processing of special categories of data. Privacy questions should be directed to info@roundupdate.com.

Right to complain

If you are in the EEA, UK, or Switzerland, you have the right to lodge a complaint with your local data-protection supervisory authority. We would appreciate the chance to address your concerns first at info@roundupdate.com.

19. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the version number and "last updated" date at the top of this Policy. If the changes are material — for example, a new category of information collected, a new purpose of use, or a new disclosure recipient — we will provide advance notice through the Service, by email where we have your address, or by presenting the updated Policy for acceptance, and where required by law we will obtain your consent before applying the change to previously collected information. Prior versions are available on request at info@roundupdate.com.

20. Contact

Questions, requests, or complaints regarding this Privacy Policy can be sent to:

Round Update LLC · info@roundupdate.com · 2108 N Street, Suite N, Sacramento, CA 95816

For privacy-rights requests, please use the subject line "Privacy Request" so we can route and log it promptly.