Privacy Policy
- Last Updated:
- October 12, 2026
- Data Controller:
- Alessandro Frappa (individual), Italian tax code FRPLSN03H09L483Q (the "Controller").
- Based in:
- Codroipo (UD), Italy.
- Privacy Contact:
- info@golfstatsapp.com
1. Introduction and Legal Basis for Processing
This Policy describes how the Controller collects, uses, and protects your personal data, in compliance with the General Data Protection Regulation (GDPR - Regulation EU 2016/679).
1.1 Legal Basis (Why We Process Data)
The processing of your data is based on the following conditions (Art. 6 GDPR):
- Contract Performance: Processing is necessary to provide you with the App Services (registration, calculation of statistics and Strokes Gained, access to Pro features).
- Consent: For sending marketing communications, for push notifications on iPhone, for using your device location when you look for golf courses near you and, explicitly, for the wellness check-in in the calendar, because it involves health data.
- Legitimate Interest: For statistical analysis, system security, and improving the App. On the same basis we email you summaries and tips about your game, which you can opt out of at any time.
2. Data Categories Collected
We collect the following types of data based on your use of the App. Providing identification data is necessary to create an account; the other data is optional, but without it some features are not available.
| Data Category | Specific Data Collected | Processing Purpose | Legal Basis |
|---|---|---|---|
| Identification Data (PII) | Name, Surname, Email Address. | Account management, login, service communications, billing (for Pro). If you don't use the app notifications, we also email you short summaries and tips about your game (for example your month in numbers): you can opt out at any time by replying STOP to one of these emails. | Contract Performance. |
| Game and Profile Data | Prevalent Playing Country, Country of Origin, Handicap; if you choose to give them, your home club, your year of birth, your playing goal, the area where you think you lose strokes, whether you have a coach, how many rounds you play a month or, for coaches, how many students you coach and a phone number, visible to other users as a contact; for athletes, a phone number, visible only to their own coaches so they can message you on WhatsApp. | Profiling for personalized statistical analysis. | Contract Performance. |
| Performance Data (Input) | Detailed data on recorded shots (distance, surface, lie, shot outcome). | Calculating your statistics and Strokes Gained, and showing them to you and to the coaches and friends you choose to connect with. | Contract Performance. |
| Coach-Student Data | Lessons between coach and student (day, time, place, type, status of the proposal, any counter-proposals and reasons for declining, the note the coach writes for the student), the notes the coach writes on the student's rounds, including on a single hole, and the messages the coach sends to their students. For the coach only: the price, payment and package of the lesson, a private note on the lesson and private notes on the student. | Letting the coach follow the student and organise lessons: the student sees their lessons, the note written for them and the notes on their own rounds; prices, payments and private notes are seen only by the coach. Deleted when either of them deletes their account. | Contract Performance. |
| Training Calendar | The sessions, tournaments and commitments that you or your coaches add, with how they went (effort from 1 to 10, minutes, comments, exercise loads), routines, and the limitations to respect set by you or your coaches. | Planning and recording training together with the coaches you are connected with, who can see it and propose changes. Deleted when you delete your account. If you turn on the calendar link (iCal), anyone with the link sees confirmed entries and accepted lessons, without notes, prices or days off for injury or illness; you can turn it off at any time and the link stops working. | Contract Performance. |
| Wellness Check-in (health data) | Only if you turn on the check-in in the calendar: your daily answers on sleep, pain (and where in the body), stress and energy. These are data concerning health. | Showing you and your coaches how you are doing, and alerting your coaches when an answer points to a problem. You can turn the check-in off at any time in the calendar settings: the answers already given are deleted. | Explicit consent (Art. 9(2)(a) GDPR). |
| Location Data | Your device's location, only if you allow it and only while you look for golf courses near you. It is used at that moment and not stored. | Finding golf courses near you when you start a round. | Consent. |
| Push Notifications (iOS app) | A device identifier for notifications (token), your language and time zone, only if you turn on notifications in the app. It is deleted when you sign out or delete your account, or when the token stops working (for example if you uninstall the app). | Sending you the notifications you chose (round analysis, calendar, requests, subscription), at the right local time: at night only those that come from a person (lessons, requests, replies, messages from your coach). How often reminders arrive adapts to how often you play or practise. Tips and news only if you turn them on separately. You can turn them off at any time in the app or iPhone settings. The same messages stay in the app's notification centre for 30 days, even if push notifications are off. | Consent. |
| Technical Usage Data | IP address, device type, OS, crash reports, access times, usage events and session recordings used to improve the app (everything you type is masked), the text of reports (bugs or suggestions) you choose to send us; when you sign up, where you came from (referring site, landing page, campaign parameters) and the browser you used (user agent). | System security, diagnostics, technical support, improving user experience, understanding which channels new users come from. | Legitimate Interest. |
| Payment Data (Pro Users) | Subscription history, plan type. (Note: credit card details are not processed by us. On the website, payment is handled by Stripe; on the iOS app, in-app purchases are handled by Apple and synced via RevenueCat, which receives an anonymous user identifier and subscription status). | Pro contract management and billing, on both purchase channels. | Contract Performance. |
3. Purposes of Processing (How We Use Data)
Your personal data is processed for the following purposes:
- Service Provision: Allowing you to register, access, and use the App's statistical features (including Pro features).
- Statistical Analysis: Your shot data is processed by our statistics engine to calculate Strokes Gained and the other statistics shown in the app. This processing has no legal or similarly significant effects on you.
- Security and Fraud Prevention: Monitoring usage to prevent violations of T&Cs.
- Marketing (With Consent Only): Sending promotional communications or newsletters, only if you have provided explicit and separate consent.
- No Sale of Data: We do not sell your personal data and do not use it for targeted advertising. Game data may be processed in anonymous, aggregated form solely to improve the Service.
4. Processing Methods and Retention
4.1 Anonymization: Data may be anonymised or pseudonymised for statistical analysis and to improve the Service.
4.2 Security: Your data is stored on secure servers with adequate technical and organizational measures (encryption, firewalls, access controls).
4.3 Retention Period: Your data is kept for as long as your account exists. When you delete your account, it is deactivated immediately, and your profile, rounds, statistics and files are permanently deleted after 4 days. We keep only what the law requires, such as payment and invoicing records, for the period the law requires. Technical logs and usage analytics are kept for a limited period and then deleted automatically. Anonymous, aggregated statistics may be retained indefinitely.
4.4 Website Forms: People without an account can leave us their details through three website forms: the waiting list (email, and optionally name and phone), the "Work with us" application and the presentation request for a club (club, name, role, email, and optionally phone and interest). We use them only to reply to that request, based on your consent, and we record the text and date of the consent given. Club requests are deleted automatically after 12 months; waiting-list sign-ups and applications are kept until you ask us to delete them. You can ask at any time to see or delete this data by writing to info@golfstatsapp.com.
5. Data Sharing (Recipients)
Your data is shared only with the providers we need to run the service, or with authorities when required by law. The main ones are: Google (Firebase and Google Cloud: hosting, database, sign-in, push notifications, crash reports, and reCAPTCHA for security; on the website also Google Analytics), Apple (Sign in with Apple and in-app purchases on iPhone), RevenueCat (managing in-app purchases), Stripe (payments on the website), PostHog (usage analytics, servers in the EU), Brevo (service emails and tips) and Upstash (protection against abuse, which briefly processes IP addresses). Each of them acts on our behalf under a data processing agreement and provides the same or equal protection of your data as described in this Policy.
6. International Data Transfer (Global Market)
Data may be transferred to servers or providers located outside the European Union. In such cases, the Controller ensures that the transfer occurs only in the presence of adequate safeguards (e.g., Standard Contractual Clauses - SCC).
7. Your Rights (Under GDPR)
You have the right to Access, Rectification, Erasure ("Right to be Forgotten"), Restriction, Portability, Objection, and Withdrawal of Consent. You can delete your account and its data at any time from Settings → Delete Account, in the app or on the website, and turn off location access in your device settings. For any other request, write to the dedicated Privacy email address: info@golfstatsapp.com. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. We do not take decisions based solely on automated processing that produce legal or similarly significant effects concerning you (Art. 22 GDPR).
8. Right to Complain
If you believe the processing violates the GDPR, you have the right to lodge a complaint with the Data Protection Authority (Piazza Venezia, 11 - 00187 Rome, Italy).