Privacy Statement

This Privacy Statement explains how KaddieIQ Limited handles personal information when you visit the KaddieIQ website, including kaddieiq.com, contact us through the Website or choose to receive communications from us.

Product-specific applications and services may have separate privacy notices describing additional processing.

1. WHO WE ARE#

The data controller is:

KaddieIQ Limited
Company number: 17096125
Registered in England and Wales
Registered office:

167–169 Great Portland Street
5th Floor
London
W1W 5PF
United Kingdom

Privacy enquiries:

privacy@kaddieiq.com

2. THE INFORMATION WE MAY PROCESS#

The information we process depends upon how you interact with the Website.

We may process the following categories of information where applicable.

Information you give us#

This may include information that you choose to provide when:

• contacting us;
• submitting a Website form;
• requesting information;
• registering an interest in a product or service;
• joining a mailing list;
• participating in a promotion or Beta programme; or
• otherwise communicating with KaddieIQ.

This may include:

• your name;
• email address;
• telephone number, if you provide it;
• organisation or golf-club details, if relevant;
• the content of your enquiry; and
• other information you choose to provide.

We ask you not to provide unnecessary sensitive personal information through general Website forms.

3. TECHNICAL INFORMATION#

When you access the Website, technical systems involved in delivering and securing the Website may process information such as:

• IP address;
• browser type;
• device type;
• operating system;
• date and time of requests;
• requested webpages;
• referral information; and
• security or diagnostic information.

Some of this information may be processed automatically by hosting, network or security providers as part of providing the Website.

We do not treat technical information as anonymous merely because it does not contain your name.

4. COOKIES AND SIMILAR TECHNOLOGIES#

The Website may use cookies, local storage or other storage and access technologies where required for Website operation.

Where a technology is strictly necessary to provide a service requested by you or otherwise falls within an applicable legal exception, it may be used without consent where the law permits.

Where consent is required for a non-essential cookie or similar technology, we will seek that consent before using it.

Where applicable, Website controls will allow you to make choices about non-essential technologies.

The specific technologies actually used by the Website, their purposes, third-party involvement and relevant duration should be described through the Website's cookie or privacy controls.

We will not rely merely on continued browsing as consent where valid consent is legally required.

5. CONTACTING KADDIEIQ#

If you contact us, we use the information you provide to:

• read and respond to your enquiry;
• provide requested information;
• provide customer or product support;
• maintain appropriate correspondence records; and
• protect or exercise our legal rights where necessary.

Depending on the circumstances, our lawful basis may be:

• taking steps at your request before entering a contract;
• performance of a contract;
• our legitimate interests in communicating with customers, prospective customers and Website users; or
• compliance with a legal obligation.

6. MARKETING COMMUNICATIONS#

Where KaddieIQ offers an email newsletter, tips, news or other electronic marketing, we will obtain any permission required by UK law.

Where we rely on consent:

• the choice will be voluntary;
• marketing will not be enabled merely because you visit the Website;
• you can withdraw consent at any time; and
• marketing emails will include an appropriate unsubscribe mechanism.

We may use Brevo to send email communications where applicable.

Withdrawing marketing consent does not affect the lawfulness of processing that occurred before withdrawal.

We may retain minimal suppression information after an unsubscribe request so that we can continue to respect that request.

7. HOW WE USE PERSONAL INFORMATION#

Depending upon your interaction with the Website, we may use information to:

• operate and secure the Website;
• respond to enquiries;
• provide information requested by you;
• administer our relationship with users, customers or business contacts;
• manage legitimate product or service enquiries;
• send marketing where permitted;
• prevent fraud, misuse and security incidents;
• troubleshoot technical problems;
• maintain necessary business records;
• comply with legal obligations; and
• establish, exercise or defend legal claims.

We will not use personal information for a materially incompatible purpose without an appropriate lawful basis and, where required, further notice.

8. OUR LAWFUL BASES#

Depending upon the processing activity, KaddieIQ may rely upon:

Contract#

Where processing is necessary to provide something you have requested or to perform a contract with you.

Steps before a contract#

Where you ask us to take steps before entering into a contract.

Legitimate interests#

Where processing is necessary for a legitimate business purpose and your rights and interests do not override that purpose.

Examples may include:

• responding to ordinary business enquiries;
• operating and securing the Website;
• preventing misuse;
• maintaining business records; and
• protecting legal rights.

Consent#

Where you have freely chosen to give consent, including where consent is required for particular electronic marketing or non-essential storage/access technologies.

You may withdraw consent at any time.

Legal obligation#

Where we must process information to comply with law.

9. WHO WE SHARE INFORMATION WITH#

We do not sell personal information.

We may disclose information to service providers where reasonably necessary to operate KaddieIQ's business or Website.

These may include providers of:

• Website hosting;
• infrastructure;
• email services;
• security;
• IT support;
• communications;
• professional services; and
• other services necessary to operate the Website.

Our Website infrastructure includes Netlify for web hosting.

Where applicable, Brevo may process information for email delivery.

Product-specific services may use additional providers identified in the privacy notice for the relevant product.

We may also disclose information where:

• required by law;
• required by a court or competent authority;
• reasonably necessary to investigate fraud or unlawful activity;
• reasonably necessary to protect KaddieIQ's legal rights; or
• connected with a genuine corporate restructuring, financing, merger, acquisition or sale, subject to applicable data-protection law.

10. THIRD-PARTY WEBSITES AND SERVICES#

The Website may link to:

• Apple;
• Google;
• Stripe;
• social-media platforms;
• golf organisations;
• golf courses;
• suppliers; or
• other external services.

Those organisations control their own websites and may process personal information under their own privacy notices.

A link from KaddieIQ does not mean that KaddieIQ controls the third party's privacy practices.

11. INTERNATIONAL TRANSFERS#

Some technology or service providers may process information outside the United Kingdom.

Where KaddieIQ is responsible for making an international transfer that requires safeguards under UK data-protection law, we will use an appropriate lawful transfer mechanism.

Depending upon the destination and circumstances, this may include:

• UK adequacy regulations;
• approved contractual safeguards; or
• another transfer mechanism permitted by UK data-protection law.

We do not state that all Website-related information is stored exclusively in the United Kingdom.

12. HOW LONG WE KEEP INFORMATION#

We keep personal information only for as long as reasonably necessary for the purpose for which it is held.

Retention may depend on:

• the nature of the information;
• the reason it was collected;
• whether you remain in contact with us;
• legal and accounting requirements;
• limitation periods;
• security requirements; and
• whether information may be required to establish, exercise or defend legal claims.

Enquiries#

Ordinary correspondence is retained only for as long as reasonably necessary to deal with the enquiry and maintain appropriate business records.

Marketing#

Marketing information is retained while you remain appropriately subscribed.

If you unsubscribe, we may retain the minimum information necessary on a suppression record to ensure that your preference continues to be respected.

Technical and security records#

Technical information is retained for periods appropriate to security, troubleshooting and operational purposes.

13. CHILDREN#

The general KaddieIQ Website is not designed to collect personal information unnecessarily from children.

KaddieIQ applications or services that permit users aged under 18 will have their own product-specific privacy information where appropriate.

If we become aware that personal information has been collected in circumstances where it should not have been collected, we will take appropriate action.

14. SECURITY#

We use reasonable technical and organisational measures intended to protect personal information against:

• unauthorised access;
• accidental loss;
• inappropriate disclosure;
• alteration; and
• misuse.

No Website, network or internet transmission can be guaranteed to be completely secure.

15. YOUR UK DATA-PROTECTION RIGHTS#

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

• the right to be informed about how your information is used;
• the right to access personal information held about you;
• the right to correct inaccurate information;
• the right to request erasure;
• the right to restrict certain processing;
• the right to object to certain processing;
• the right to data portability in applicable circumstances; and
• the right to withdraw consent where processing is based on consent.

Some rights are subject to legal conditions and exemptions.

Direct marketing#

You have the right to object to the use of your personal information for direct marketing.

Exercising your rights#

Contact:

privacy@kaddieiq.com

We may need to take reasonable steps to verify your identity before responding to a request.

16. COMPLAINTS#

If you have concerns about how KaddieIQ handles your information, please contact us first at:

privacy@kaddieiq.com

You also have the right to complain to the UK's data-protection regulator, the:

Information Commissioner's Office (ICO)

Nothing in this Privacy Statement limits that right.

17. CHANGES TO THIS PRIVACY STATEMENT#

We may update this Privacy Statement to reflect:

• changes to the Website;
• changes to our services;
• changes to suppliers;
• changes in our handling of information; or
• changes in law or regulatory guidance.

Where appropriate, we will provide notice of material changes.

The current version will show its most recent update date.

18. CONTACT#

Privacy enquiries and data-protection requests should be sent to:

KaddieIQ Limited
Company number: 17096125
167–169 Great Portland Street
5th Floor
London
W1W 5PF
United Kingdom

Email: privacy@kaddieiq.com

© KaddieIQ Limited. All rights reserved.