Privacy Policy

Last Updated: July 3, 2025*

Welcome to the Surfline\Wavetrak group privacy policy.

Surfline\Wavetrak, Inc. is a corporation registered in Delaware, United States of America. The group of companies operating under the “Surfline” brand (and to whom this policy applies) is made up of different legal entities including, Surfline\Wavetrak, Inc., Wavetrak Limited, Wavetrak Oceania Pty Ltd, and Surfline NZ Limited (collectively, “Surfline”). This Privacy Policy is issued on behalf of the Surfline group of companies so when we mention "Surfline", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Surfline group of companies responsible for processing your data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data in connection with your access to or use of our websites, apps, products and services (including without limitation Surfline’s domains and subdomains, cameras, forecasts, Cam Rewind, Surfline Sessions, and Perks) (collectively, the “Services”). It also tells you about your privacy rights and how the law protects you.

Please also read our Terms of Use for more information on the terms governing the Services.

If you are a resident of the United States of America, United Kingdom or European Economic Area, please refer to the separate annexes which provide further details relevant to those jurisdictions and outline any further rights you may have under this policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. THIRD PARTY AD SERVERS

10. COOKIE POLICY

11. YOUR LEGAL RIGHTS

ANNEX A: PRIVACY INFORMATION FOR U.S. RESIDENTS

ANNEX B: PRIVACY INFORMATION FOR UK AND EEA RESIDENTS

ANNEX C: PRIVACY INFORMATION FOR SURFLINE SESSIONS USERS

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data under applicable privacy and data security laws through your use of our Services.

Our Services are not intended for use by children, meaning individuals under the age of 16, and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, or would like to contact our Data Protection Officer, you can do so by email at [email protected] or by mail using the contact information below.

Surfline

2261 Market Street STE 10852, San Francisco, CA 94114, Attn: Legal

Changes to the Privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review and make changes from time to time and will take appropriate measures to inform you as required by applicable data protection laws. To see when this Privacy Policy was last updated, please see the "Last Updated" date above. Please come back from time to time for the latest information on our privacy practices.

Your continued use of the Services after any updates to this Privacy Policy take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not want to acknowledge or accept any updates to this Privacy Policy, you may cancel your account and stop using the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party promotions and services and links

From time-to-time we partner with third parties to provide you with products, promotions, giveaways, sweepstakes or other experiences. We will take measures to notify you and may show you the privacy policies belonging to those third parties, when third parties will receive information in connection therewith. Their privacy policy will govern the collection of your personal data, in addition to this Privacy Policy.

Our websites and apps may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and any information collected by them is subject to that third party’s own privacy policies. We do not control these third-party websites and services and are not responsible for their privacy policies. When you leave our websites and apps, we encourage you to read the privacy policy of every website or service you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Standard Identity Data includes name, alias, address (including zip code), email, phone number, marital status, date of birth, and gender.

• Profile Data includes username, password, account type (i.e., whether you are a free user have a paid membership), and any additional information you choose to enable your use of the Services such as general location, profile photo, marketing and communications preferences, interests, preferences, surf experience, lifestyle information, support communications, feedback, reviews and survey responses.

• Transaction Data includes details of products and services you have purchased from us. To order products or services, you may need to provide certain identity data (like name and address) and financial information (like your bank account or credit card information) in order to facilitate the processing of payments. We will collect the data we need in order to process that purchase (for example, payment details). However, your financial information is collected and stored by our third-party payment processing company and use and storage of that data is governed by the third-party payment processor’s applicable privacy policy. Currently, we use Stripe, Inc. as our Payment Processor. You can access Stripe’s Consumer Terms of Service at https://stripe.com/legal/consumer and their Privacy Policy at https://stripe.com/privacy. We are not responsible for any error by, or other acts or omissions of, the Payment Processor.

• Technical Data includes internet protocol (IP) address, device ID, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, browsing patterns, history, referral source, search terms leading you to our Services, operating system and platform, and other technology on the devices you use to access our Services.

• Usage Data includes information about how you use our Services and information that you provide including the length of time spent using any of our services, the frequency of your use of the Services or any portion thereof, photographs, videos, comments, or other data you may upload, and any meta data contained therein.

• Promotions, Sweepstakes, and Contest Data includes any information you provide to us in connection with any promotions, sweepstakes and/or contests that we run, including for example name, email, mailing address, social media usernames and responses to contest questions.

• Sensitive Personal Data includes (i) precise geolocation, physical movements, and health data (e.g., workout, health rate and energy data) in connection with use of Surfline Sessions and (ii) identification documentation (e.g., driver’s license, passport, or other government-issued identification card) for identity verification as described below. This data will only be collected and processed where it is necessary and where you have provided consent.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

Surfline Sessions™ Data

For users of Surfline Sessions, please refer to the separate annex which provides further details relevant to how your data is processed in connection with your use of that feature.

Identify Verification Data

We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses that you provide as well as information about the devices that connect to its services. Stripe shares this information with us and uses this information to operate and improve the services it provides, including for fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. We initiate the deletion of verification data once we have verified a user’s age, and that the user is who they claim to be. If you would like to request deletion of your data, we suggest reaching out to Stripe at [email protected]. You can learn more at https://stripe.com/legal/privacy-center#stripe-identity and read Stripe’s privacy policy at https://stripe.com/privacy. If you object to the use of Stripe for biometric verification, you may contact us to discuss alternative means to verify your identity.

Connected Devices/Accounts Data

We enable you to connect your Surfline account with third parties (i.e., devices, apps or accounts that integrate with the Services). We may, with your consent if you enable the connection, collect information from the third-party devices and accounts to facilitate interaction with our Services. For example, you may connect your Apple Watch or Rip Curl Search GPS Watch to enable Sessions features and information from such devices and accounts will be passed along to us. Information collected by these third parties is subject to their terms and policies and may not provide you with the same privacy controls that are available on Surfline.

Surf Park Image Data

Surfline may partner with surf park operators (a “Park Partner”) to provide video capture and related services at the Park Partner’s property. Your surf sessions may be captured on Surfline cameras installed at such properties and shared on our Services. Still or video images captured by cameras installed at Park Partner properties may constitute Standard Identity Data to the extent visitors are recognizable and will be used in accordance with this Privacy Policy, the Terms of Use and any additional waiver or releases granted to Park Partners.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Except as set forth above with respect to Identity Verification Data and Surfline Sessions Data, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions:

You may give us your Identity Data, Profile Data, Transaction Data, Promotions Data by filling in forms or by corresponding with us through the Services, by post, phone, email or otherwise. This includes personal data you provide when you:

• use our Services;

• create an account or profile to use our Services;

• subscribe to a Service, email updates or publications;

• request marketing to be sent to you;

• enter a competition, sweepstakes, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions:

As you interact with our Services, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data through your devices, cookies, web beacons, tracking technologies, and other similar technologies, whether implemented by us or a third party. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our “Cookie Policy” below for further details.

Third parties or publicly available sources:

We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from parties such as:

  • analytics providers such as Google;

  • advertising networks; and

  • search information providers or internet search providers.

• Identity and Transaction Data from providers of technical, payment and delivery services.

• Identity and Profile Data from data brokers, social media networks, online stores and marketplaces or aggregators.

• Identity and Profile Data where you access our Services using your Facebook or Google credentials. We will automatically collect certain information, such as your Facebook or Google user ID. We will use any information collected from Facebook or Google, including the user ID Facebook or Google attribute to you, only in accordance with Facebook’s or Google’s policies and your preferences selected through Facebook or Google.

• Sensitive Personal Data from third party devices and accounts that you enable to connect to your Surfline account for purposes of identity verification and use of Sessions as noted in the paragraph above related to Identity Verification Data and Annex C for Surfline Sessions Data.

4. HOW WE USE YOUR PERSONAL DATA

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. The table in Section 2 above described the ways we plan to use your personal data, and the legal bases we rely on to do so. Most commonly, we will use your personal data in the following circumstances:

• Performance of a Contract. Where we need to perform the contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interest. Where it is necessary for our legitimate interests (or those of a third party) in conducting and managing our business and your interests and fundamental rights do not override those interests (unless we have your consent or are otherwise required or permitted to by law).

• Compliance with a Legal Obligation. Where we need to comply with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

We may use your Identity, Transaction, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Depending on your location and applicable law, you will receive marketing communications from us if you have provided your express opt in consent, if you requested information from us or if you created an account or purchased goods or services from us and you have not opted out of receiving that marketing.

Depending on your location and applicable law, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at [email protected].

Where you opt out of receiving these marketing messages, this will not apply to messaging we send you or personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

In general, your personal data will remain with us, but we may share your personal data with the parties described below.

• Internal Third Parties: other companies in the Surfline group of companies acting as controllers or processors and who are based in the United States of America, the United Kingdom, Australia and New Zealand and provide IT and system administration services and undertake leadership reporting. We may also share your data with any employee, contractor or agent of these companies in order to operate, optimize, improve, and/or further develop our services.

• External Third Parties. Defined as service providers (acting as processors) based in United States of America, and other countries, who provide services to us.

  • Vendors, consultants, and other service providers who process your data on our behalf when they provide services to us, for example data analytics, ad networks, research, marketing, fraud prevention, and financial services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Regulators, law enforcement, tax and customs authorities, governmental authorities and other authorized persons required by law or deemed by us to be necessary, appropriate, or in the best interests of Surfline who require reporting of processing activities in certain circumstances.

  • Advertising partners to customize your experience and better tailor the services, products, marketing and advertising on our Services and on their third-party sites. Our advertising partners are companies that provide services that help us provide advertising to you. These companies may use their own tracking technologies to collect or request information about you. For more information on how our sites may use third-party ad servers and your ability to opt-out of targeted advertising from such third-party ad servers, please see the section below on “Third Party Ad Servers.”

  • Third parties that partner with us to sponsor, promote or brand content or programs (e.g., competitions, sweepstakes, giveaways, or promotions).

  • To the extent you authorize to do so, affiliated or unaffiliated third parties for marketing purposes.

  • Payment processors as necessary to submit and process payments, collect any amounts owed, or otherwise address any payment obligations or issues.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. To the extent possible, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Surfline operates from various countries around the world, as do our service providers and other third parties to whom we may need to disclose your personal information, as described above. This means that when you use or interact with Surfline, your personal information may be transferred to other countries that have different data protection laws than those where you reside.

However, whenever we transfer personal information to other countries, we ensure that the personal information is transferred in accordance with applicable data protection laws and this Privacy Policy.

Specifically, when we transfer personal data outside the UK or EEA, we will attempt to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK government (as applicable).

• Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK government (as applicable) which give personal data the same protection it has in Europe.

• We will put in place specific organization and technical safeguards to further limit the personal data transferred and to protect your personal data.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Specifically, we will retain your Identity Data as long as any account with us remains in force. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. THIRD PARTY AD SERVERS

Our advertising service vendors and other third parties will at times use tracking technologies to serve you advertisements tailored to interests you have shown by using our Services and other sites, applications, destinations, and services you have visited, and for other lawful business purposes. In doing so, these third parties will collect non-personally identifiable data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of tracking technologies by third parties is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith. If you do not want the services that tracking technologies provide, you may be able to opt-out of certain tracking technologies or limit use by visiting http://optout.networkadvertising.org, using script-blockers, and modifying the tracking options in your web browser, phone, computer, or other device or software. We do not guarantee that any such actions will prevent or limit the tracking technologies or that any opt-out decision will be honored by any third party.

Surfline has partnered with She Media Ad Services, among others, to manage certain programmatic advertising. She Media implements tracking technologies on Surfline’s properties, and She Media’s privacy policy is located here.

10. COOKIE POLICY

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our websites and cannot be switched off in our systems. They include, for example, cookies that enable you to log into secure areas of our websites.

• Analytical or performance cookies. These cookies enable the website to provide enhanced functionality and personalization, such as allowing us to recognize and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These cookies allow the website to provide enhanced functionality and personalization and are used to recognize you when you return to our websites. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites, and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them at our Cookie List.

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies. Some of the providers we use for the cookies employed on our site provide individual opt-out mechanisms, such as Google Analytics (here) and Comscore (here).

Except for strictly necessary cookies, which are essential for the Services to function, you can choose which cookies we can set by using our consent management platform we employ to record your preferences about third party cookies. You may also be able to update your browser settings to manage your preferences about third party cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites.

Cookie-based opt-outs must be performed on each device and browser that you wish to opt-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device.

If you opt-out of cookies identified above, you may still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

11. YOUR LEGAL RIGHTS

If you are a resident of the United States, please refer to ANNEX A: PRIVACY INFORMATION FOR U.S. RESIDENTS. If you are a resident of either the UK or EEA, please refer to ANNEX B: PRIVACY INFORMATION FOR RESIDENTS UK AND EEA RESIDENTS.

ANNEX A

PRIVACY INFORMATION FOR U.S. RESIDENTS

This Annex A is adopted to comply with U.S. comprehensive privacy laws, such as the California Consumer Privacy Act (CCPA) and any terms defined in the applicable privacy laws have the same meaning when used in this Annex A. If you reside in another state with similar rights, we will comply with those rights accordingly and as described in this Annex A.

1. Sales or Sharing of Personal Information for Cross Context Behavioral or Targeted Advertising

We may sell or share your digital activity information with third parties in order to receive information about the performance of our marketing campaigns and usage statistics related to our sites or applications. This activity may constitute a “sale” or “share” under applicable comprehensive privacy laws. If you are a resident of certain states, including California, you may have the right to opt-out from the “sale” or “share” of personal information for targeted or cross context behavioral advertising. To our knowledge, our personal information sales and sharing do not include information about individuals we know are under age 16. We have sold or shared personal information to advertising service providers such as Facebook and Google in the last twelve (12) months.

You may opt-out of the sale or sharing of your information by utilizing one of the options in the Exercising Rights section below or enabling the Global Privacy Control (GPC) on your browsers.

If you are age 16 or older, you have the right to direct us to not sell or share your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at [email protected] or indicating your preferences via the “Do Not Sell My Personal Information Link” at the bottom of surfline.com or in the Account settings on mobile.

2. Sensitive Personal Information

We do not use or disclose sensitive personal information outside of the permissible uses permitted under the CCPA.

3. Your Rights and Choices:

You may have rights regarding your personal information. This section describes your rights and explains how to exercise those rights. You do not need to create an account with us to exercise your rights.

Access to Specific Information and Data Portability Rights

You may have the right to request that Surfline disclose certain information to you about our collection and use of your personal information.

Deletion Request Rights

You may have the right to request that Surfline delete your personal information that we collected from you and retained, subject to certain exceptions.

Correction Request Rights

You may have the right to request we correct any inaccurate personal information we may hold about you. We will use commercially reasonable efforts to correct inaccurate personal information, taking into account the nature of the personal information and the purpose for our processing.

Appeal Rights

You may have the right to appeal a refusal to take action on a request by contacting us at [email protected].

Exercising Rights

To exercise the rights described above, please submit a verifiable consumer request to us by any of the following:

• Visiting Surfline Support Center and submitting the request online.

• Emailing us at [email protected].

• Writing us at Surfline, CCPA Request, 2261 Market Street STE 10852, San Francisco, CA 94114

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact Surfline Support provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made from your membership email sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4. Non-Discrimination:

We will not discriminate against you for exercising any of your rights.

5. California’s “Shine the Light” Law:

In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please send an email to [email protected].

6. Contact Information:

If you have any questions or comments about this notice, the ways in which Surfline collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://support.surfline.com/hc/en-us/requests/new

Email: [email protected]

Postal Address: Surfline, 2261 Market Street STE 10852, San Francisco, CA 94114, Attn: CCPA Request

ANNEX B

PRIVACY INFORMATION FOR UK AND EEA RESIDENTS

This Annex B is adopted to comply with the General Data Protection Regulation (GDPR) and any terms defined in the GDPR have the same meaning when used in this Annex B.

1. Legal Rights of UK and EEA Residents

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.

  • Where our use of the data is unlawful, but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you. We will provide to you your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by any of the following:

• Visiting Surfline Support Center and submitting the request online.

• Emailing us at [email protected].

• Writing us at Surfline, GDPR Request, 2261 Market Street STE 10852, San Francisco, CA 94114

2. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

3. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

4. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

ANNEX C

PRIVACY INFORMATION FOR SURFLINE SESSIONS USERS

This Annex C describes how Surfline processes your information when using Surfline Sessions.

Surfline Sessions is a feature within the Services that allows users to utilize data-tracking features, including GPS location data, to record surf sessions, including waves ridden, top speed attained, and the length of your longest ride. If you have a Premium (or Premium+) membership, additional information as described below may also be available through Surfline cameras. The personal data we collect through Surfline Sessions™ may include:

• Standard Identity Data and Profile Data. Personally identifiable information you provide through our Services, including your name, user ID, email address, zip code, username, and password;

• Usage Data. This includes:

  • Sensory and motion data from your mobile device, including information from the location and motion sensing hardware within your device, in order to calculate and detect information about your ride, including the approximate length of rides, estimated maximum speed, and attempted waves;

  • Information about your ride history, including number of waves over time, number of ride sessions over time, number of ride sessions in specific surf locations, the longest (time and distance) waves, and the maximum speed on waves;

  • If you have a Premium (or Premium+) membership and a Surfline Session is in front of a Surfline camera, your ride information may be paired with the ride video clip from the camera.

• Technical Data. Device information, including the operating system and device unique identifier (such as IP address or device ID).

• Sensitive Personal Data. This includes:

  • Precise location information through the GPS tracker in your mobile device, when you enable location tracking services, interacting with our App during the time your Surfline Session™ is active.

  • Health information, including heart rate and energy data, collected by third party devices and accounts that you consent to sharing with Surfline by enabling connections between Surfline and such third-party devices and accounts. Certain health information may be inferred from sources such as heart rate or other measurements, including calories burned during a surf session.

Surfline Sessions: How are my Sessions displayed and shared?

Each tracked Surfline Sessions will appear in your Surfline account and will be displayed with relevant usage data such as ride time, ride length, and estimated maximum speed, along with date, time and location of ride. In addition, if you tracked a ride in front of a Surfline camera and have a membership plan with access to Cam Rewinds, a video clip of your ride will be paired with the Surfline Session. When a Surfline Session is recorded, it will automatically create a unique URL for each Surfline Session that will be traceable to a specific user. These links are publicly available by default so that you can share these links and allow others to view your Surfline Session. Please note, your Surfline Sessions data, including name, location and all other relevant ride information will be accessible through the publicly available link.

* Non-material change made on July 3, 2025 to Annex A and Annex B, clarifying options for submitting data requests to Surfline.