Privacy Statement

This Privacy Statement explains how KaddieIQ Limited collects, uses and protects personal information when you use the KaddieIQ Flight Plan application (“the App”).

It applies to the UK version of the App.

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. OUR APPROACH TO PRIVACY#

KaddieIQ Flight Plan has been designed to minimise the personal information sent to KaddieIQ.

In particular:

• normal GPS positioning used to calculate golf distances is processed on your device;
• normal compass and directional calculations are processed on your device;
• we do not currently use advertising networks in the App;
• we do not currently use analytics tools in the App;
• we do not sell your personal information;
• marketing is optional and off by default; and
• account deletion can be initiated from within the App.

3. INFORMATION WE PROCESS#

The information we process depends on how you use the App.

3.1 Account identifier#

An account identifier is created for the App.

During testing or where anonymous functionality is available, this may initially be an anonymous identifier.

3.2 Email address#

If you create or convert to a signed-in account, we process the email address used for the account.

The email address is used to identify and authenticate your account and to send sign-in or confirmation codes.

If you use Sign in with Apple and choose Apple's Hide My Email option, we may receive the private relay email address supplied by Apple rather than your personal email address.

3.3 Sign-in information#

Where email sign-in is used, a six-digit sign-in or verification code may be sent to you.

The code is currently valid for approximately 10 minutes.

We do not require you to create a conventional KaddieIQ password for this sign-in method.

3.4 Your plan and subscription status#

We may keep information recording whether your account is:

• free;
• promotional;
• trial; or
• paid,

together with relevant entitlement or subscription dates.

Where you purchase a subscription through the Apple App Store, Apple processes the payment.

KaddieIQ does not receive your complete payment-card information from Apple.

We may receive or process information necessary to determine whether your account is entitled to paid App functionality.

3.5 Records of acceptance#

We keep a record of your acceptance of relevant versions of:

• the Terms & Conditions;
• the Privacy Statement; and
• any App disclaimer presented to you.

That record may include:

• the version accepted;
• date and time;
• App version; and
• confirmation of the age declaration presented to you.

We use this information to administer the service and to keep an appropriate record of the terms under which the App was used.

3.6 Marketing preferences#

You may be offered the option to receive KaddieIQ tips and news by email.

Marketing is optional and off by default.

If you opt in, we record your choice and the date on which it was made.

If you later change your preference, we record the updated choice.

You can withdraw your marketing consent at any time:

• through the applicable setting in the App; or
• by using the unsubscribe facility in a marketing email.

Withdrawing marketing consent does not affect your ability to use the App.

4. LOCATION INFORMATION#

Location is important to the core golf functionality, but different location uses are handled differently.

4.1 Golf distances and directional arrows#

Your phone's position is used on the device to calculate or display:

• distance information;
• green direction; and
• other location-dependent golf information.

For these normal distance and directional calculations, your phone's GPS position is not sent to KaddieIQ's servers.

Your device controls whether the App is allowed access to location information.

If you deny or disable location permission, location-dependent features may not work.

4.2 “Courses near me”#

If you actively ask the App to find golf courses near you, your current device position is sent to KaddieIQ's backend service for the purpose of identifying courses within approximately 25 kilometres.

The App does not deliberately add that location to your player profile or save it as part of your course history.

The location is used to respond to the nearby-course request.

4.3 Weather#

Weather is requested using the location of the selected golf course, not your live personal GPS position.

The selected course location is rounded to approximately one kilometre before being used for the weather request.

KaddieIQ's server requests weather information from MET Norway.

We do not intentionally send your email address, account identifier or live personal GPS position to MET Norway for that weather request.

5. INFORMATION STORED ON YOUR DEVICE#

The App may store information locally on your device including:

• unit preferences;
• theme or display preferences;
• screen/rest-time preferences;
• selected courses;
• recently used courses;
• course and hole information;
• your current hole;
• tournament-round start information;
• cached or saved weather information; and
• relevant local acceptance information.

This local information is used to operate the App.

It is not treated as server-held KaddieIQ account data merely because it is stored on your device.

6. SECURITY INFORMATION#

KaddieIQ uses security measures intended to protect account creation and the service from automated abuse.

A Cloudflare security check may be used during account creation.

As part of providing that security service, Cloudflare may process technical information such as an IP address and device or browser information required to distinguish legitimate users from automated activity.

We use Apple App Attest as a security and fraud-prevention measure to help confirm that requests to KaddieIQ's systems originate from a genuine instance of the KaddieIQ application running on a genuine Apple device and have not been improperly modified or tampered with. In providing this protection, Apple and KaddieIQ may process technical security information associated with the App Attest process, including cryptographic attestation or assertion data, key identifiers and information relating to the integrity and identity of the application instance. App Attest does not itself establish or verify your legal identity. We use this information only for purposes including protecting accounts and services, preventing fraud, misuse and unauthorised access, and maintaining the security and integrity of the App. Our lawful basis for this processing is our legitimate interest in securing KaddieIQ's systems, users and services. We do not use App Attest information for advertising or marketing profiling.

7. WHY WE USE YOUR INFORMATION#

We use personal information for the following purposes.

Providing the App and your account#

This includes:

• creating and maintaining an account;
• authenticating you;
• providing golf functionality;
• maintaining your plan or entitlement;
• delivering requested nearby-course functionality; and
• operating App features.

Our principal lawful basis is performance of our contract with you, or taking steps at your request connected with that contract.

App security and preventing abuse#

We process appropriate technical information to protect the App, accounts, infrastructure and users.

Our lawful basis is our legitimate interest in maintaining a secure and reliable service and preventing misuse.

Keeping records of Terms and privacy choices#

We maintain records of relevant acceptance and choices so that we can administer the service and establish what terms and preferences applied at a particular time.

Our lawful basis is our legitimate interest in maintaining appropriate business and legal records and, where necessary, establishing, exercising or defending legal claims.

Marketing#

We send KaddieIQ marketing email only where we have the required permission.

Where we ask you to opt in, our lawful basis is consent.

You can withdraw that consent at any time.

8. WHO WE USE TO OPERATE THE APP#

KaddieIQ uses third-party service providers to operate parts of the App.

These currently include:

Supabase#

Used for:

• application database services;
• account authentication;
• server functions; and
• related backend services.

KaddieIQ's main Supabase application database is configured in the eu-west-1 Ireland region.

Brevo#

Used to send transactional email such as sign-in and confirmation codes.

Where you have separately opted in to marketing, Brevo may also be used to send KaddieIQ marketing emails.

Cloudflare#

Used for account-creation security and protection against automated abuse.

Netlify#

Used in connection with KaddieIQ's web-hosted services and associated application infrastructure where applicable.

MET Norway#

Used to obtain weather information.

MET Norway receives the rounded location of the selected golf course for the weather request. We do not intentionally send your account or email information to MET Norway as part of that request.

Apple#

Apple may process information where you:

• download the App from the App Store;
• use Sign in with Apple;
• make an Apple In-App Purchase;
• maintain or cancel an App Store subscription; or
• request an App Store refund.

Apple and KaddieIQ may also process technical security information through Apple App Attest, as described in section 6 above.

Apple's processing is also governed by Apple's own privacy information and service terms.

9. COURSE INFORMATION#

Golf-course data may include information from OpenStreetMap contributors, available under the Open Database Licence.

Course data itself is not used by KaddieIQ to create advertising profiles about you.

10. NO ADVERTISING, ANALYTICS OR SALE OF DATA#

The current KaddieIQ Flight Plan build does not:

• contain third-party advertising;
• use advertising networks;
• use behavioural advertising;
• use analytics tools to profile App usage; or
• sell personal information.

If this changes materially in the future, this Privacy Statement and the applicable App Store privacy information must be updated before the new processing is introduced where required.

11. MARKETING EMAIL#

KaddieIQ does not treat creation of an account as consent to marketing.

The marketing option is separate and optional.

If you consent, marketing may include KaddieIQ tips, news and information about KaddieIQ services.

Every marketing email will provide a means of unsubscribing.

If you unsubscribe or otherwise object to email marketing, we will stop using your information for that marketing.

We may retain the minimum information reasonably necessary on a suppression or “do not contact” record so that we can respect your request and avoid adding you back to marketing communications inadvertently.

12. CHILDREN AND USERS AGED 16 OR 17#

KaddieIQ Flight Plan is not intended for children under 16.

Users aged 16 or 17 may use the App with the permission of a parent or legal guardian.

A paid subscription must be purchased by someone aged 18 or over.

Because users aged 16 and 17 may access the App, KaddieIQ aims to apply appropriate privacy protections to younger users.

The current App is designed so that:

• marketing is off by default;
• there are no third-party advertisements;
• there are no advertising profiles;
• there are no analytics tools in the current build; and
• the GPS information used for ordinary golf-distance calculations remains on the device.

13. WHERE INFORMATION IS HELD#

KaddieIQ's core application database is hosted using Supabase in Ireland within the European Union.

Not every organisation involved in delivering the App necessarily processes all information solely in Ireland.

Apple, Cloudflare, Netlify, Brevo and other infrastructure providers may process certain information in other countries as part of their services.

Where KaddieIQ makes an international transfer of personal information that requires protection under UK data-protection law, we will use an applicable adequacy regulation or other appropriate legal safeguard as required.

14. HOW LONG WE KEEP INFORMATION#

We do not keep personal information for longer than reasonably necessary for the purpose for which it is held.

Our retention approach is based on the following criteria:

Account data#

Your KaddieIQ account information is normally retained while the account remains active.

When you use the account-deletion function, the current deletion process is designed to remove your KaddieIQ account and associated active account information.

Subscription and plan information#

Subscription or entitlement information is retained for as long as necessary to administer your account and paid or promotional access and for any period for which retention is reasonably necessary to resolve a transaction or legal issue.

Records of acceptance#

Records showing what Terms, Privacy Statement or disclaimer you accepted may be retained where reasonably necessary to establish the terms under which the service was provided or to establish, exercise or defend legal claims.

Marketing choices#

Marketing preferences are retained while relevant to your account and marketing choices.

Where you opt out, we may retain the minimum suppression information required to make sure that your opt-out continues to be respected.

Security information#

Technical security information is retained only for as long as reasonably necessary for security, abuse prevention and related legal purposes, subject to the retention arrangements of the relevant infrastructure provider.

15. ACCOUNT DELETION#

If you have a KaddieIQ account, you can initiate account deletion from within the App using the applicable account settings.

The current deletion process is designed to remove the KaddieIQ account and associated active account information, including applicable:

• account information;
• email information held for the account;
• plan information;
• preference records; and
• App account data.

The App also clears applicable locally stored App information as part of the deletion process where supported.

Limited information may be retained where KaddieIQ has a lawful reason or legal obligation to retain it, including information strictly necessary to respect a marketing opt-out or establish, exercise or defend legal claims.

Important: Apple subscriptions#

Deleting your KaddieIQ account does not automatically cancel an Apple subscription.

If you have an active Apple auto-renewable subscription, Apple may continue billing until that subscription is cancelled through your Apple Account.

You should cancel the Apple subscription before deleting your KaddieIQ account if you do not want it to renew.

16. YOUR DATA-PROTECTION RIGHTS#

Under UK data-protection law, depending on the circumstances, you may have rights including:

• the right to be informed about how we use your information;
• the right to access personal information we hold about you;
• the right to correct inaccurate information;
• the right to request deletion of information;
• 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.

Withdrawing consent does not affect the lawfulness of processing that took place before the withdrawal.

Direct marketing#

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

If you object or unsubscribe, we will stop using your information for that marketing.

To exercise a privacy right, contact:

privacy@kaddieiq.com

We may need to take reasonable steps to verify that a request relates to you before acting on it.

17. ANONYMOUS OR TEST ACCOUNTS#

Where the App permits an anonymous account, we may not hold an email address or name that allows us readily to identify the person using that account.

If you make a data-protection request in relation to an anonymous account, we may therefore need information that reasonably demonstrates which anonymous account is yours.

We will not require more information than is reasonably necessary to identify the relevant account and deal with the request.

18. SIGN IN WITH APPLE#

If you use Sign in with Apple, Apple authenticates your Apple Account and provides KaddieIQ with the information necessary to create or identify your KaddieIQ account.

If you choose Hide My Email, Apple supplies a private relay email address.

KaddieIQ will use that relay address in the same way as an ordinary account email address for relevant account communications.

Apple's processing of information through Sign in with Apple is governed by Apple's own terms and privacy arrangements.

19. APPLE APP STORE PURCHASES#

Purchases made through the Apple App Store are processed by Apple.

Apple is responsible for handling the customer's App Store payment method and related billing process.

KaddieIQ may process subscription or entitlement information necessary to determine whether paid functionality should be available to your account.

For App Store refunds, billing history and subscription-management information, Apple also processes information under its own terms and privacy policy.

20. COOKIES AND LOCAL STORAGE#

The current App does not use cookies for advertising or analytics.

The App stores certain information locally on your device because that information is necessary or useful for App functionality.

This may include settings, cached course information and other locally maintained App state described above.

21. AUTOMATED DECISION-MAKING#

KaddieIQ Flight Plan does not currently use your personal information to make solely automated decisions that produce legal or similarly significant effects on you.

22. SECURITY#

We take reasonable technical and organisational measures designed to protect the information for which KaddieIQ is responsible against:

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

No internet-connected system can be guaranteed to be completely secure.

You should also take reasonable steps to protect access to your device, Apple Account and email account.

23. CHANGES TO THIS PRIVACY STATEMENT#

We may update this Privacy Statement where necessary because of:

• changes to the App;
• new features;
• changes to service providers;
• legal or regulatory changes; or
• changes to our processing of personal information.

Where a change is material, we will provide appropriate notice where required.

The latest version will identify its last-updated date.

24. COMPLAINTS#

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

privacy@kaddieiq.com

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

Information Commissioner's Office (ICO)

Nothing in this Privacy Statement limits that right.

25. CONTACT#

Privacy questions and rights 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.