Privacy Policy

1. Who we are

Proper Golfing Ltd is the data controller responsible for the personal information described in this Privacy Policy where we determine how and why that information is used.

Proper Golfing Ltd
Chandos Business Centre
87A Warwick Street
Leamington Spa
England
CV32 4RJ

Company number: 09655668
Website: propergolfing.com
Email: team@propergolfing.com

If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details above.

2. Personal information we collect

The personal information we collect depends upon how you interact with Proper Golfing.

Contact and identity information

This may include your name, email address, telephone number, postal address and other information you provide to us.

Booking, membership and account information

When you book coaching, simulator time, events or other services, or create an account or membership with us, we may collect information relating to your booking, membership, purchases and use of our services.

Payment and transaction information

When you purchase a product or service, payment information is processed through our payment providers. We may receive transaction information relating to the payment, although we do not necessarily receive or retain your complete card details.

Coaching information

When you receive coaching from Proper Golfing, we may collect information relating to your golf, including:

• your golfing goals
• playing experience
• handicap or ability level
• coaching history
• swing characteristics and shot patterns
• launch-monitor and simulator data
• equipment information
• coaching observations and lesson notes
• practice recommendations
• progress and outcomes
• other information you choose to provide during coaching

Coaching recordings and transcripts

Individual coaching sessions, online coaching sessions and member group coaching sessions may be recorded. Recordings may include audio and video and may be transcribed so that the content of coaching sessions can be reviewed, analysed and used for the purposes described in this Privacy Policy. Where a group coaching session is recorded, contributions made by participants may form part of the recording and transcript. We will take reasonable steps to make participants aware when a session is being recorded.

Communications

We may retain communications between you and Proper Golfing, including emails, messages, enquiries, feedback and customer-service communications.

Testimonials and feedback

If you provide feedback or a testimonial, we may retain it. Where we wish to use your name, photograph, video or other identifying information publicly for promotional purposes, we will consider the appropriate permission and lawful basis for that particular use.

Website and technical information

When you use our website, we may collect technical information such as your IP address, browser type, device information, operating system, pages visited, referring website, approximate location derived from technical information, date and time of visits and information about how you interact with our website. Some of this information may be collected through cookies and similar technologies.

3. Why we use your personal information

We may use personal information for purposes including:

• providing golf coaching and personalised feedback
• managing bookings and appointments
• providing simulator services
• operating memberships and group coaching
• supplying products and digital services
• processing and administering purchases
• communicating with customers and members
• maintaining coaching records and continuity between lessons
• understanding golfers’ progress and coaching outcomes
• training and quality assurance
• responding to enquiries and complaints
• operating, securing and improving our website and systems
• preventing fraud
• complying with legal, accounting and regulatory obligations
• marketing our products and services where permitted
• improving our coaching methods, products and services
• research and development of coaching systems and digital coaching services

4. Recording and transcription of coaching

Proper Golfing may record and transcribe individual coaching sessions, online coaching sessions and member group coaching sessions.

We may use recordings and transcripts for purposes including:

• delivering and reviewing coaching
• providing personalised feedback and follow-up
• maintaining continuity between coaching sessions
• training and quality assurance
• understanding coaching outcomes
• improving coaching methods
• identifying recurring golfing problems and coaching patterns
• research and analysis
• improving existing services
• developing new coaching systems and digital coaching services

Our recording of a coaching session does not mean that the recording will be published or made publicly available. Access to full coaching recordings and transcripts is restricted to people who require access for an authorised purpose. Where external service providers, contractors or development specialists require access to personal information on our behalf, we will consider and implement appropriate confidentiality, security and data-protection arrangements where required.

5. Using coaching knowledge to improve our services

One of Proper Golfing’s strengths is the practical coaching knowledge developed through working with golfers. We may analyse coaching sessions and coaching records to understand recurring patterns, problems, diagnoses, interventions and outcomes.

This may involve creating coaching summaries, classifications, anonymised case studies, statistical information, coaching patterns, diagnostic categories, coaching insights and other derived information. Where appropriate, we aim to remove or reduce information that directly identifies individual golfers before information is used for broader research, analysis, product development or the development of digital coaching systems.

Where information has been effectively anonymised so that an individual is no longer identifiable, it is no longer personal information for the purposes of UK data protection law. Removing a name alone does not necessarily make information anonymous. Information that can still be linked to an identifiable individual will continue to be treated as personal information.

6. Digital coaching and product development

Proper Golfing may use coaching knowledge and appropriately derived information to research, design, test, develop and improve digital coaching services and coaching technology.

Where another organisation, contractor or technology provider assists us with this work and personal information is involved, we will determine the appropriate data-protection relationship and put appropriate safeguards and contractual arrangements in place where required. We do not treat providing technical access to information as transferring ownership of Proper Golfing’s underlying coaching records.

Where practicable and appropriate for the relevant purpose, we seek to use anonymised, de-identified, minimised or summarised information rather than providing unnecessary access to complete identifiable coaching records.

7. Our lawful bases for using personal information

UK data protection law requires us to have a lawful basis for processing personal information. Depending upon the particular activity, we may rely upon:

• Contract, where processing is necessary to provide a product or service you have requested or to take steps at your request before entering into a contract
• Legitimate interests, where processing is necessary for our legitimate business interests or those of another party and those interests are not overridden by your rights and interests. These interests may include operating and improving Proper Golfing, maintaining appropriate coaching records, understanding the effectiveness of our services, securing our systems and developing our services
• Consent, where consent is appropriate or legally required. Where processing is based upon consent, you can withdraw that consent
• Legal obligation, where processing is necessary to comply with a legal or regulatory obligation

Different purposes may rely upon different lawful bases. We keep our processing activities and lawful bases under review.

8. Special category information

During a coaching conversation, you may occasionally choose to disclose information concerning your health or other information that receives additional protection under data protection law. We do not require you to provide unnecessary medical or other sensitive information.

Where we intentionally process special category personal information, we will ensure that an appropriate lawful basis and additional legal condition applies.

9. Children and young golfers

Proper Golfing may provide coaching to junior golfers. Where we process personal information relating to children or young people, we recognise that this information requires particular protection.

We will take appropriate steps regarding parental or guardian involvement, transparency and the use of recordings or other information depending upon the age of the golfer, the service being provided and applicable legal requirements.

10. Who we share information with

We do not sell your personal information.

We may share or provide access to personal information where necessary with trusted organisations that help us operate Proper Golfing. These may include providers of website and hosting services, booking systems, customer relationship management systems, email and communications services, payment processing, accounting, cloud storage, video hosting, transcription, analytics, IT and security, professional advice and technology or product-development services.

We may also disclose information where required by law, court order or regulatory requirement, or where reasonably necessary to establish, exercise or defend legal rights. Where another organisation processes personal information on our behalf, we will use appropriate contractual and organisational safeguards where required.

11. International transfers

Some of the technology and service providers we use may process or store personal information outside the United Kingdom.

Where personal information is transferred internationally, we will consider whether appropriate legal safeguards are required and use appropriate transfer mechanisms where applicable.

12. Cookies and analytics

Our website may use cookies and similar technologies. Some cookies are necessary for the website to function. Other technologies may be used for purposes such as analytics, remembering preferences, measuring website performance and marketing.

Where consent is legally required for cookies or similar technologies, we will seek that consent. Further information about the technologies currently used on our website and how you can manage your choices may be provided through our Cookie Policy and/or cookie-management tool.

13. Marketing

Where permitted, we may contact you with information about Proper Golfing products, coaching, memberships, events or services that we believe may be relevant to you. Where consent is required, we will obtain it.

You can unsubscribe from marketing communications at any time by using the unsubscribe option in an email or by contacting us. Service communications relating to an existing booking, membership, purchase or account are not necessarily marketing communications.

14. Data retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including satisfying legal, accounting, contractual and regulatory requirements. Different types of information may therefore be retained for different periods.

When determining an appropriate retention period, we consider the purpose for which information was collected, its nature and sensitivity, whether it forms part of an ongoing coaching relationship, legitimate coaching and business-record requirements, legal and accounting obligations, potential disputes or claims, security considerations and whether information can instead be anonymised.

We periodically review the information we hold and may securely delete or anonymise information that is no longer required.

15. Security

We take appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, destruction, alteration, unauthorised disclosure or access. Access to personal information is restricted according to business need and authorised purpose.

No internet, cloud or electronic storage system can be guaranteed to be completely secure, but we take reasonable measures appropriate to the nature of the information we process.

16. Your data protection rights

Depending upon the circumstances, UK data protection law may give you rights including the right to:

• ask for access to personal information we hold about you
• ask us to correct inaccurate or incomplete information
• ask us to delete personal information in certain circumstances
• ask us to restrict processing in certain circumstances
• object to certain processing
• receive certain personal information in a portable format
• withdraw consent where processing is based upon consent
• raise concerns about how your information is being used

These rights are not absolute and may depend upon the circumstances and the lawful basis upon which information is being processed.

To exercise your rights, please contact team@propergolfing.com. We may need to verify your identity before responding to a request.

17. Complaints

If you have concerns about how we use your personal information, please contact us first so that we can investigate and respond.

You also have the right to raise a concern with the Information Commissioner’s Office (ICO), the UK’s data protection regulator.

18. Third-party websites

Our website may contain links to websites or services operated by third parties.

We are not responsible for the privacy practices of independent third-party websites and recommend reviewing their privacy information before providing personal information to them.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices or legal requirements.

The latest version will be published on our website and the date at the top of the policy will show when it was most recently updated. Where a change materially affects how we use personal information, we will consider whether additional notice is appropriate.

20. Contact us

If you have questions about this Privacy Policy, wish to exercise a data-protection right or have concerns about how Proper Golfing uses your personal information, please contact:

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