Privacy Policy
FairwaySplitter. Last updated: 25 July 2026.
This Privacy Policy explains how FairwaySplitter ("we", "us", "our") collects, uses, shares and protects your personal data when you use the FairwaySplitter mobile application (the "App"), and sets out your rights and how to exercise them.
1. Who we are and the law we follow
FairwaySplitter is the data controller for the personal data described in this policy. We are based in the United Kingdom. You can contact us about privacy at privacy@fairwaysplitter.app.
We process personal data in accordance with UK data protection law, namely the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025, together with the Privacy and Electronic Communications Regulations 2003 (PECR). Where this policy refers to specific Articles, these are Articles of the UK GDPR.
2. The personal data we collect
Data you provide
- Account data: your email address and a password. Passwords are stored only as a salted, irreversible hash - we never have access to your plain-text password.
- Golf profile: optional information you choose to enter, such as your name, handedness, handicap, self-assessed skill level, and the areas of your game you are working on.
- Content you create: rounds, scores, recorded shots, swing videos, saved courses, coaching notes, and any social posts, captions, comments, likes or friend connections you make in the App.
Data collected through your use of features
- Precise location (GPS): when you use the on-course features, we process your device's precise location to calculate distances to the green and other points. The locations of shots you choose to record are stored as part of your round history.
- Camera, microphone and photo library: accessed when you record or select a swing video. Videos you capture are uploaded to our storage so they can be processed and played back.
- Diagnostic and technical data: when the App crashes or errors, our crash-reporting provider collects technical information such as device model, operating system version, app version, and error/stack-trace details, together with a limited trail of in-app events leading up to the error.
We do not knowingly collect special category data (Article 9). Please do not submit health, biometric or other special category information through free-text fields or content.
3. Purposes and lawful bases (Article 6)
We only process your personal data where we have a lawful basis to do so. The table below sets out what we do and the basis we rely on.
| Purpose | Lawful basis (Article 6(1)) |
|---|---|
| Creating and securing your account; authenticating you | (b) Performance of a contract |
| Providing core features: GPS distances, scoring, shot and swing tracking, course data | (b) Performance of a contract |
| Accessing location, camera, microphone and photos on your device | (a) Consent, given through your device permissions and withdrawable at any time; and (b) performance of a contract for the feature you requested |
| Generating AI swing feedback (see section 4) | (b) Performance of a contract |
| Operating optional social features you choose to use | (b) Performance of a contract; (a) consent for content you choose to publish |
| Sending account and service emails (e.g. email confirmation, password-reset codes) | (b) Performance of a contract |
| Diagnosing problems, fixing bugs, keeping the App secure | (f) Legitimate interests - to provide a secure, reliable service. We have balanced these interests against your rights. |
Where we rely on consent, you may withdraw it at any time (Article 7(3)) without affecting the lawfulness of processing carried out before withdrawal - for example by turning off a permission in your device settings. Where we rely on legitimate interests (Article 6(1)(f)), you have the right to object (Article 21).
4. AI swing analysis and automated processing
When you use the swing-analysis feature, still frames extracted from your swing video, together with the golf context you have provided (such as club used and your chosen focus areas), are transmitted through our secure server to a third-party artificial-intelligence provider, which generates written coaching feedback that is returned to you.
This feedback is informational golf coaching only. It does not produce any decision that has legal effects concerning you or similarly significantly affects you, and so it is not "solely automated decision-making" within the meaning of Article 22. We do not use your videos or frames to build advertising profiles, and we do not sell them.
5. Who we share your data with
We do not sell your personal data. We share it only with the processors and service providers that operate the App on our behalf, under contracts that require them to protect it and to process it only on our instructions (Article 28):
| Category of recipient | Purpose |
|---|---|
| Cloud hosting, database and file-storage providers | Storing your account, content, videos and images, and authenticating you |
| An artificial-intelligence provider | Generating your swing feedback (see section 4) |
| Mapping and location-services providers | Map imagery for the GPS features |
| Weather and elevation-data providers | Wind and elevation data (receive location coordinates, not your identity) |
| Video-processing providers | Turning swing videos into shot-tracer videos |
| Email delivery and routing providers | Sending and routing account and contact emails |
| Crash- and error-reporting providers | Diagnosing and fixing technical problems |
| App distribution, beta-testing and update platforms | Distributing the App, running the beta programme, and delivering updates |
Content you post to social features is shared with other users according to the visibility you choose. We may also disclose personal data where required to comply with a legal obligation, to establish, exercise or defend legal claims, or to protect the rights, safety or property of our users or others.
6. International data transfers
Some of our providers are located outside the United Kingdom, including in the United States. Where we transfer personal data internationally, we do so only where a lawful transfer mechanism is in place - either a UK "adequacy" determination, or appropriate safeguards under Article 46 (such as the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses together with the UK Addendum), assessed against the data protection test introduced by the Data (Use and Access) Act 2025. You may request further information about the safeguards we rely on using the contact details in section 12.
7. How long we keep your data
- Account and profile data is retained for as long as your account remains active.
- Raw swing videos are deleted automatically once the relevant round is finished. The processed shot-tracer video is retained until you delete it (subject to a per-user limit on saved tracers).
- You can delete rounds, tracers and other content within the App at any time.
- Diagnostic and crash data is retained only for as long as needed to investigate and fix issues.
- When you close your account, we delete or irreversibly anonymise your personal data, except where we are required to retain some of it to comply with a legal obligation.
8. Your rights
Under the UK GDPR you have the following rights, which you can exercise free of charge:
- Access (Article 15) - to obtain a copy of the personal data we hold about you.
- Rectification (Article 16) - to have inaccurate data corrected.
- Erasure (Article 17) - to have your data deleted in certain circumstances.
- Restriction (Article 18) - to limit how we process your data in certain circumstances.
- Data portability (Article 20) - to receive data you provided in a structured, commonly used, machine-readable format.
- Objection (Article 21) - to object to processing based on our legitimate interests.
- Withdraw consent (Article 7(3)) - at any time, where we rely on your consent.
- Rights relating to automated decision-making (Article 22) - although, as explained in section 4, we do not carry out decision-making of that kind.
9. How to complain
If you are unhappy with how we have handled your personal data, you can complain directly to us at privacy@fairwaysplitter.app. Under the Data (Use and Access) Act 2025 you have a right to raise a complaint with us as the controller, and we will acknowledge and respond to it.
You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner's Office (ICO), at ico.org.uk, although we would appreciate the chance to address your concerns first.
10. Device permissions
The App requests permission to use your location, camera, microphone and photo library. You can grant or revoke each of these at any time in your device settings. Some features will not function without the relevant permission.
11. Children
The App is not directed to children under 13, and we do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, please contact us and we will delete it.
12. Security
We implement appropriate technical and organisational measures to protect your personal data (Article 32), including encryption of data in transit, salted password hashing, and access controls that restrict each user's data to their own account. No method of transmission or storage is completely secure, but we take reasonable steps to protect your information and to detect and address issues.
13. Cookies and similar technologies
The App is a mobile application and does not use advertising cookies. We use only the local storage and device identifiers necessary to keep you signed in, remember your preferences, and operate the crash reporting described above. These are strictly necessary or low-risk technical functions under PECR as amended by the Data (Use and Access) Act 2025.
14. Changes to this policy
We may update this policy from time to time. We will post the updated version at this URL and update the "Last updated" date above. Where changes are significant, we will take reasonable steps to bring them to your attention.
15. Contact us
For any privacy question or to exercise any of your rights, contact us at privacy@fairwaysplitter.app. We aim to respond to rights requests within one month, as required by Article 12(3).