Privacy Policy

1. Introduction

PazGolf Ltd (“PazGolf,” “we,” “us,” or “our”) is a company registered in Northern Ireland (Company No. NI733614), with its registered office at 180a Belfast Road, Newtownards, Northern Ireland, BT23 4TA. We operate the PazGolf platform, which includes:

1. A golf competition management, handicapping, and scoring service.
2. PazGolf Snax, an on-course food and drink ordering platform that enables golfers to order from providers (caterers and club bar staff) at golf venues. Snax is governed by the separate PazGolf Snax Terms and Conditions.

Together, these are referred to as the “Service.”

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use our Service. It applies to all users of PazGolf, including individual subscribers, golf club administrators, club members whose data is managed through the platform, golfers placing orders through PazGolf Snax, and providers (caterers and club bar staff) fulfilling orders through PazGolf Snax.

We are committed to protecting your privacy and processing your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection legislation.

2. Data Controller and Data Processor

2.1. When PazGolf Is the Data Controller

PazGolf is the data controller for personal data we collect directly from you when you create an account, subscribe to the Service, or interact with us. This means we determine the purposes and means of processing your personal data.

2.2. When PazGolf Is the Data Processor

Where a golf club uses PazGolf to manage its members’ data (e.g., handicap records, competition scores, and membership details), the golf club is the data controller and PazGolf acts as the data processor. In these cases, we process member data only on the club’s instructions and in accordance with our agreement with the club.

If you are a club member and have questions about how your club uses your data, please contact your club directly in the first instance.

2.3. Providers as Independent Data Controllers SNAX

Where a provider (caterer or club bar staff) receives personal data about golfers through PazGolf Snax (such as names, order details, approximate location or hole position, and member card numbers), the provider acts as an independent data controller for the personal data they receive and process in the course of fulfilling orders. Each provider is independently responsible for complying with applicable data protection legislation in respect of the golfer data they receive.

PazGolf is not responsible for how providers use golfer data beyond what is necessary for order fulfilment. If you have concerns about how a provider has handled your data, please contact the provider directly in the first instance.

3. What Personal Data We Collect

3.1. Account Information

When you register for an account, we collect:

1. Full name
2. Email address
3. Password (stored in encrypted form)
4. Phone number (if provided)
5. Golf club affiliation (if applicable)

3.2. Golf and Playing Data

When you use the Service, we collect:

1. Competition and general play scores
2. Hole-by-hole scoring data
3. Handicap index and history
4. Score differentials and adjustments
5. Course and tee information
6. Playing dates, times, and markers
7. Competition entries and results
8. Society and trip participation records

3.3. Club Member Data

Where a golf club uses PazGolf to manage its members, we may process the following data on behalf of the club:

1. Member names and contact details
2. Membership type and status
3. Handicap and scoring records
4. Competition participation and results

3.4. Payment Information

When you make a payment, your payment details (e.g., card number, billing address) are collected and processed by our third-party payment provider. PazGolf does not store your full card details. We retain only a record of the transaction, including the amount, date, and a truncated reference for your payment method.

3.5. Technical and Usage Data

When you access the Service, we may automatically collect:

1. IP address
2. Browser type and version
3. Device type and operating system
4. Pages visited, features used, and time spent on the Service
5. Referring website or source
6. Crash reports and error logs

3.6. PazGolf Snax: Order Data SNAX

When you place or fulfil orders through PazGolf Snax, we collect:

1. Order details, including items ordered, quantities, and prices
2. Order status history (pending, accepted, ready, collected, rejected, not collected)
3. Order timing preferences (e.g., ASAP, at the turn, in 30 minutes)
4. Collection point selected
5. Order value (used for commission calculation)
6. Timestamps for each order status change

3.7. PazGolf Snax: Location Data SNAX

When you use PazGolf Snax, we may collect location data in two ways:

1. GPS location: If you grant permission via your browser, we collect your GPS coordinates when you place an order. While your order is active, your browser may send location updates approximately every two to three minutes to help the provider time preparation. GPS updates stop when your order is completed or cancelled. GPS location data is cached temporarily and is not stored permanently in our databases. It is treated as ephemeral data and is deleted once the associated order is completed or cancelled.
2. Scoring-derived location: If you are using PazGolf’s digital scoring feature during your round, the system may use your scoring progress (e.g., your last completed hole and average pace of play) to estimate your position on the course. This data is already collected as part of the scoring feature and involves no additional data collection beyond what is described in Section 3.2.

You may decline to share your GPS location when prompted by your browser. Declining GPS permission does not prevent you from placing orders, but your order may be flagged to the provider as location-unverified.

3.8. PazGolf Snax: Member Card Numbers SNAX

If you are a member of a golf club and order drinks or other items eligible for member pricing through Snax, you may choose to provide your member card number at the time of ordering. This number is shared with the relevant provider (e.g., club bar staff) so they can verify your membership and apply any applicable discount or charge your member account at the point of collection. PazGolf does not validate member card numbers against the club’s membership records.

3.9. PazGolf Snax: Provider Business Data SNAX

When a provider (caterer or club bar) registers for a PazGolf Snax account, we collect:

1. Business name
2. Contact name, email address, and phone number
3. Business address (used for invoicing)
4. Menu item details, descriptions, prices, images, and allergen information uploaded by the provider
5. Collection point details and photographs uploaded by the provider
6. Venue details, including name, address, and GPS coordinates of the coverage area

3.10. PazGolf Snax: Terminal Data SNAX

When providers use Snax Terminals to receive and manage orders, we collect:

1. Terminal login and session data
2. Records of which terminal processed which orders
3. Actions taken on the terminal (e.g., accepting, rejecting, or marking orders as ready)

4. How We Use Your Data

We use your personal data for the following purposes:

Purpose	Legal Basis (UK GDPR)
To create and manage your account	Performance of a contract (Article 6(1)(b))
To provide the Service, including handicap calculations, scoring, and competition management	Performance of a contract (Article 6(1)(b))
To process payments and manage subscriptions	Performance of a contract (Article 6(1)(b))
To facilitate on-course food and drink ordering through PazGolf Snax, including transmitting orders to providers SNAX	Performance of a contract (Article 6(1)(b))
To share golfer names, order details, and member card numbers with providers for the purpose of order fulfilment and payment SNAX	Performance of a contract (Article 6(1)(b))
To display golfer location or hole position to providers on Snax Terminals to assist with preparation timing SNAX	Legitimate interests (Article 6(1)(f))
To verify that golfers are within a venue’s coverage area when placing orders SNAX	Legitimate interests (Article 6(1)(f))
To calculate and invoice provider commission on Snax orders SNAX	Performance of a contract (Article 6(1)(b))
To monitor order patterns and “Not Collected” rates for fraud and abuse detection SNAX	Legitimate interests (Article 6(1)(f))
To send you important service communications (e.g., subscription renewals, security alerts, changes to our Terms)	Performance of a contract / Legitimate interests (Article 6(1)(b) / (f))
To send you marketing communications about PazGolf features, updates, or promotions	Consent (Article 6(1)(a))
To improve, develop, and optimise the Service	Legitimate interests (Article 6(1)(f))
To monitor usage patterns, diagnose technical issues, and maintain security	Legitimate interests (Article 6(1)(f))
To comply with legal obligations (e.g., tax, accounting, regulatory requirements)	Legal obligation (Article 6(1)(c))
To respond to your enquiries and provide customer support	Legitimate interests (Article 6(1)(f))

Where we rely on legitimate interests, we have carried out a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms.

5. Who We Share Your Data With

We do not sell your personal data to third parties. We may share your data with the following categories of recipients:

5.1. Service Providers

We use trusted third-party providers to help us operate the Service, including hosting providers, payment processors, email delivery services, and analytics tools. These providers process your data only on our instructions and are contractually required to protect it.

5.2. Golf Clubs

If you are a member of a golf club that uses PazGolf, your golf-related data (scores, handicap records, competition results) will be accessible to your club’s authorised administrators as necessary for the management of competitions and handicaps.

5.3. Other Users

Certain information is visible to other users of the Service as part of its core functionality, for example, your name, handicap, and scores may appear on leaderboards, competition results, or society records. You can manage your visibility preferences through your account settings where available.

5.4. PazGolf Snax: Providers SNAX

When you place an order through PazGolf Snax, the following data is shared with the provider(s) fulfilling your order:

1. Your name (so the provider can identify your order at the Collection Point).
2. Your order details (items, quantities, timing preference).
3. Your approximate location on the course or your current hole number and estimated arrival time (displayed on the provider’s Snax Terminal to help with preparation timing).
4. Your member card number, if you chose to provide one (shared only with the relevant club bar provider for the purpose of verifying membership pricing or charging your member account).

This data is shared to enable the provider to prepare and fulfil your order. Providers are independent data controllers for the golfer data they receive (see Section 2.3) and are responsible for handling it in accordance with applicable data protection law.

5.5. Legal and Regulatory Requirements

We may disclose your data if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5.6. Business Transfers

If PazGolf is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your data.

6. International Data Transfers

Your data is primarily stored and processed in the United Kingdom. If we need to transfer your data outside the UK, we will ensure that appropriate safeguards are in place in accordance with UK GDPR, such as Standard Contractual Clauses approved by the Information Commissioner’s Office (ICO), or transfers to countries with an adequacy decision.

7. How Long We Keep Your Data

7.1. Active Accounts

We retain your personal data for as long as your account is active and your subscription is in force.

7.2. After Cancellation or Deletion

If you cancel your subscription or request deletion of your account:

1. Your account data will be deleted or anonymised within 90 days of the request, unless we are required to retain it for legal or regulatory purposes.
2. Aggregated or anonymised data that can no longer identify you may be retained indefinitely for analytical and statistical purposes.
3. Records required for tax, accounting, or legal compliance will be retained for the period required by law (typically 6 years).

7.3. Club Member Data

Where PazGolf processes data on behalf of a golf club, retention is determined by the club. When a club terminates its subscription, we will delete or return all member data within 90 days unless otherwise instructed by the club or required by law.

7.4. PazGolf Snax: Data Retention SNAX

1. GPS location data: Cached temporarily during an active order. Deleted automatically when the order is completed, cancelled, or timed out. GPS data is not stored permanently in our databases.
2. Order history: Retained for the life of your account and subject to the same retention rules as other account data described in Section 7.2.
3. Provider invoicing and commission records: Retained for a minimum of 6 years after the invoice date, in accordance with UK tax and accounting obligations.
4. Snax Terminal access logs: Retained for 12 months from the date of the log entry.
5. Member card numbers: Stored with the associated order record for as long as the order history is retained. Not shared beyond the relevant provider at the time of the order.

8. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

Right	What This Means
Access	You can request a copy of the personal data we hold about you.
Rectification	You can ask us to correct any inaccurate or incomplete data.
Erasure	You can ask us to delete your data in certain circumstances (e.g., when it is no longer necessary for the purpose it was collected).
Restriction	You can ask us to restrict processing of your data in certain circumstances.
Data portability	You can request your data in a structured, commonly used, machine-readable format.
Objection	You can object to processing based on legitimate interests or for direct marketing purposes.
Withdraw consent	Where we process data based on your consent (e.g., marketing), you can withdraw that consent at any time.

To exercise any of these rights, please contact us using the details in Section 13. We will respond to your request within one month. In complex cases, we may extend this by a further two months, and we will inform you if this is necessary.

You will not be charged a fee for exercising your rights, except in cases where requests are manifestly unfounded or excessive.

9. Cookies and Similar Technologies

9.1. What Cookies We Use

We use cookies and similar technologies to operate the Service, remember your preferences, and understand how you use the platform. The types of cookies we use include:

1. Strictly necessary cookies: required for the Service to function (e.g., authentication, security, Snax Terminal session management). These cannot be disabled.
2. Functional cookies: remember your preferences and settings to improve your experience.
3. Analytics cookies: help us understand how users interact with the Service so we can improve it. These are only set with your consent.

9.2. Managing Cookies

Where non-essential cookies are in use (e.g., analytics), you will be presented with a cookie consent banner on your first visit so you can accept or reject them. You can also control cookies through your browser settings at any time, although disabling strictly necessary cookies will affect the functionality of the Service.

10. Marketing Communications

We will only send you marketing emails with your prior consent. Every marketing email includes an unsubscribe link, and you can opt out at any time. Opting out of marketing communications will not affect essential service communications (e.g., billing notifications, security alerts, or changes to our Terms).

11. Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, regular security assessments, access controls, and secure hosting infrastructure.

While we take every reasonable step to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining industry-standard protections.

12. Children’s Privacy

The core PazGolf Service (scoring, competitions, handicapping) is not directed at children under the age of 18. We do not knowingly collect personal data from children under 18 for these features. If you believe we have inadvertently collected data from a child, please contact us and we will take steps to delete it promptly.

PazGolf Snax allows users aged 16 and over to place food and drink orders. Alcoholic items may only be ordered by users aged 18 and over, and age verification is the responsibility of the provider at the point of collection. Where a user aged 16 or 17 uses Snax, we process their data in accordance with this Privacy Policy.

Where a golf club manages junior members through the Service, the club is responsible for ensuring that appropriate parental or guardian consent has been obtained and that such data is processed in accordance with applicable law.

13. Contact Us and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how we handle your data, please contact us:

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or legal requirements. If we make material changes, we will notify you by email or through the Service at least thirty (30) days before the changes take effect. We encourage you to review this page periodically.