Privacy Policy
May 11, 2025
# Privacy Policy
**Effective Date: 11 May 2025**
##### Introduction
This Privacy Policy explains how True Golf Limited (“we”, “our”, or “us”) collects, uses, and protects your information when you use the True Golf App (“the App”). By creating an account and using the App, you agree to the collection and use of information in accordance with this policy.
##### Information We Collect
We collect the following types of information from users:
- **Personal Information**: First name, last name, player category (gender), email address, phone number, and local club
- **Device Data**: IP address, device ID, operating system
- **Usage Data**: App interactions, diagnostics, and performance data (collected via AWS)
- **Sensitive Data**: GPS data, but only when you manually submit a green location using the in-app selection feature. We do not track or collect continuous location data in the background.
##### Purpose of Data Collection
Your data is used for the following purposes:
- To provide and maintain App functionality
- To personalise your experience
- To process in-app purchases and authentication
- For analytics and performance tracking
- For customer support and communication
- For security and fraud prevention
##### Legal Basis for Processing
We process your personal data under the following lawful bases in accordance with the UK General Data Protection Regulation (UK GDPR):
- **Consent**: Where you have actively provided consent, such as when opting in to receive notifications or marketing communications
- **Contractual necessity**: To create and manage your user account, and provide core app features such as score tracking and course discovery
- **Legitimate interests**: To maintain and improve the App’s performance, enhance user experience, and communicate service updates, where such interests are not overridden by your rights
- **Legal obligations**: Where required to comply with applicable laws or regulatory requirements
You can withdraw your consent at any time by updating your preferences in the App or contacting us via the details provided below.
##### Third-Party Services
We use the following third-party services and APIs:
- **Firebase API**: For sending push notifications
- **Google Maps & Places API**: For location features
- **Adapty SDK**: For in-app purchases on Android and iOS
- **Twilio**: For sending one-time passwords (OTPs) to mobile numbers
- **Zoho**: For sending system emails
Each of these services has its own privacy policy, and your data may be processed in accordance with their terms.
##### International Data Transfers
Your data is primarily processed and stored within the United Kingdom and/or the European Economic Area (EEA) using secure Amazon Web Services (AWS) infrastructure.
In some cases, your personal data may be transferred to or accessed by service providers outside the UK or EEA. Where this occurs, we ensure appropriate safeguards are in place, such as:
- The use of Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO) or European Commission
- Transfers to countries with an adequacy decision by the UK government or European Commission
We take all necessary steps to ensure your data is protected in accordance with applicable data protection laws.
##### Data Retention
We retain your personal data only as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required or permitted by law.
##### Your Rights
As a resident of the United Kingdom or European Union, you have the following rights under UK GDPR and applicable data protection laws:
- **Right of access** – You can request a copy of the personal data we hold about you
- **Right to rectification** – You can request that inaccurate or incomplete data be corrected
- **Right to erasure (“right to be forgotten”)** – You can ask us to delete your personal data, subject to legal obligations
- **Right to restrict processing** – You can ask us to limit how we use your data in certain circumstances
- **Right to data portability** – You can request a copy of your data in a machine-readable format and transmit it to another controller
- **Right to object** – You can object to our processing of your data based on legitimate interests or direct marketing
- **Rights related to automated decision-making and profiling** – You have the right not to be subject to decisions based solely on automated processing, unless explicitly consented to or legally required
To exercise any of these rights, please contact us at the address provided in the "Contact & Data Protection Inquiries" section below.
##### Security Measures
Your data is securely stored using AWS infrastructure. We implement reasonable technical and organisational safeguards to protect your data from unauthorised access, disclosure, or misuse.
##### Children’s Privacy
The App is not intended for use by individuals under the age of 13. If we discover that we have collected personal information from a child under 13, we will take appropriate steps to delete such information.
##### Policy Updates
We may update this Privacy Policy from time to time. Any changes will be communicated within the App or via email. Your continued use of the App after changes take effect indicates your acceptance of the revised policy.
##### Contact & Data Protection Inquiries
If you have any questions about this Privacy Policy, your personal data, or wish to exercise your rights, please contact us.
This inbox is monitored for privacy and data protection-related inquiries. While we do not currently have a designated Data Protection Officer (DPO), your request will be reviewed by an appropriate member of our team.