1. Introduction

This Privacy Policy explains how Elevate Golf International Ltd (“ElevateGolf”, “we”, “us”, “our”) collects and processes personal data when you use the ElevateGolf mobile application, website and related services (the “Services”). We are the data controller for the processing described in this Policy unless stated otherwise. We are established in England and Wales.

By using the Services you acknowledge that you have read this Privacy Policy. This Policy works alongside, and is incorporated by reference into, our Terms and Conditions. If you do not agree, please do not use the Services.

1. Scope

This Policy applies to Players who purchase personalised tips and Coaches who provide them, as well as visitors to our website and support channels. It covers personal data processed via the App, our website, support email and our service providers. It does not apply to third‑party services we do not control (for example, PayPal®, app stores or external websites you may visit).

3. Data We Collect

3.1 Account and Profile Data

• Email address (used for one‑time passcode sign‑in) and basic profile information (display name, country, time zone, date of birth).
• Onboarding responses from Players and Coaches about goals, experience, preferences and credentials. We use these responses to operate our matching algorithm and to tailor the Platform experience.

3.2 Transactional and Payment Data

Payments are processed by PayPal®, which acts as an independent controller of your payment information. We do not receive or store full card or bank details. We receive limited transaction metadata (for example, a transaction ID, amount, time and status) necessary to reconcile orders, prevent fraud and provide support.

3.3 Content You Provide

• Player uploads: swing videos and written notes submitted with a tip request. These items become part of the Tip record and are retained while the account is active, as explained below.
• Coach uploads: Tip videos, written guidance and clarifications delivered to the Player. • Communications you send to support (for example, emails or forms).

3.4 Device and Usage Data

• Technical data such as device model, OS version, app version, language, IP address and identifiers generated by the app.
• Diagnostic logs, crash reports and performance analytics to maintain and improve the Services.
• Interaction data (for example, screens viewed, features used, timestamps) to understand usage and improve quality.
• Limited advertising and affiliate identifiers to measure in‑app adverts and referral links. We do not use cross‑app behavioural advertising for users under 18.

4. How We Use Personal Data

We use personal data to:

• create and manage accounts;
• enable Players to request Tips and Coaches to fulfil them;
• operate our matching algorithm that generates a match percentage;
• process payments and maintain order records;
• provide customer support, dispute resolution and safety enforcement (including acceptable‑use and non‑circumvention rules);
• send service messages (for example, receipts, delivery notifications, policy updates);
• send optional marketing emails and push notifications where permitted;
• run analytics, fix bugs and improve reliability and security; and
• comply with legal obligations (for example, tax, accounting and regulatory requests).

5. Legal Bases (UK/EU GDPR)

Depending on the context, we rely on:

• Performance of a contract – to provide the Services, deliver Tips and administer payments;
• Legitimate interests – to secure the Services, prevent misuse, improve features, and show limited in‑app adverts/affiliate links (balanced against your rights);
• Consent – for marketing emails and push notifications where required by law; and
• Legal obligations – for tax, accounting and responding to lawful requests. Where we rely on legitimate interests, you may object at any time (see Section 11), and we will respect your rights under applicable law.

6. Sharing and Disclosure

We share personal data only as necessary to operate the Services, including with:

• Payment processor – PayPal® acts as an independent controller for transactions;
• Hosting, analytics, crash reporting and customer‑support providers who act as our processors under contracts requiring confidentiality and data protection;
• Coaches (for Players’ Tip requests) and Players (for Coaches’ Tip deliveries) as needed to fulfil the request;
• App stores and push notification providers;
• Professional advisers and insurers; and
• Law enforcement, regulators or courts where required by law or to protect rights, users and the Platform.

We do not sell personal data. We may share de‑identified or aggregated information that does not identify you.

7. International Transfers

We primarily host user content in the EU (for example, AWS EU‑West). Some providers and support staff may be located outside the UK/EEA. Where personal data is transferred internationally, we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) and EU Standard Contractual Clauses (SCCs), together with supplementary measures as needed. You may contact us for more information about these safeguards.

8. Data Retention

We keep personal data only for as long as needed for the purposes described in this Policy. In particular:

• Tip records (including Player uploads that form part of a Tip and Coach Tip content) are retained while the Player account is active, so that Players can access their purchased Tips.
• Account, order and payment‑related data are typically retained for up to six years after account closure to meet tax, accounting and legal obligations.
• Diagnostic logs and analytics are kept for shorter periods necessary for security and improvement.
• Backups may persist for limited periods with restricted access.

Once data is no longer required, we delete or irreversibly de‑identify it. De‑identified data used for analytics or model improvement is not subject to deletion requests because it can no longer be linked to an individual.

9. Security

We use appropriate technical and organisational measures to protect personal data, including TLS in transit, encryption at rest, role‑based access controls, staff training and periodic security testing. No system can be 100% secure; you are responsible for keeping your account secure (for example, safeguarding access to your email used for one‑time passcodes).

10. Children and Teens

The Services are not available to children under 13. Users aged 13–17 may use the Services only with a parent or guardian’s consent and supervision, and payments must be made via the consenting adult’s PayPal® account. We do not knowingly collect personal data from children under 13. If you believe a child has provided us data, contact us and we will take appropriate steps to delete it. We do not use under‑18 data for cross‑app behavioural advertising.

11. Your Rights

Depending on your location, you have rights to request access to, correction or deletion of your personal data; to restrict or object to certain processing; and to request data portability. You may also withdraw consent for marketing at any time (for example, via in‑app settings or unsubscribe links), without affecting the lawfulness of processing before withdrawal. You can exercise your rights by emailing privacy@elevategolf.com. We may ask for information to verify your identity and will respond within the timeframe required by law (usually one month). Your rights may be limited in certain circumstances (for example, where we must retain data to comply with legal obligations).

12. Automated Decision‑Making and Profiling

We use a matching algorithm to generate a percentage match between Players and Coaches based on onboarding responses and platform signals. This feature helps Players discover relevant Coaches. It does not make binding decisions; Players remain free to choose any Coach using search and filters. If you have questions about this feature, contact privacy@elevategolf.com.

13. Cookies and Tracking Technologies

Our website and app use first‑party and service‑provider technologies for core functionality, analytics, crash reporting and limited advert/affiliate measurement. You can control app permissions in your device settings and manage cookies in your browser. For users under 18 we do not engage in cross‑app behavioural advertising.

14. Marketing Communications

We may send service emails that are necessary for your account or transactions. We will only send optional marketing emails or push notifications with your consent where required by law. You can opt out at any time via in‑app settings or the unsubscribe link. We do not sell personal data to third parties for marketing.

15. Third‑Party Links and PayPal®

The Services may contain links to third‑party websites, adverts or affiliate offers. Those services are governed by their own privacy policies. For payments, PayPal® acts as an independent controller of your payment data; please refer to PayPal’s privacy documentation for details of its processing.

16. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide at least 30 days’ notice via the App, Site or email before the changes take effect; non‑material updates take effect immediately when posted. Your continued use of the Services after the effective date means you accept the updated Policy.

17. Contact and Complaints

If you have questions or wish to exercise your rights, contact: privacy@elevategolf.com or by post: Elevate Golf International Ltd, 1 Warner House, Harrovian Business Village, Bessborough Road, Harrow, London, HA1 3EX, United Kingdom.

You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk or by calling +44 303 123 1113. We encourage you to contact us first so we can try to resolve your concern.