Privacy Policy

Last updated: September 17, 2026

This privacy policy explains how SwingMatch.AI ("we", "our", or "us") collects, uses, stores, and protects your personal data when you use our mobile application, website, and related services. We are committed to being transparent about what we do with your data and to protecting your privacy in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Please read this policy carefully. By using our services, you acknowledge that you have read and understood how we handle your personal data as described below.

1. Who We Are (Data Controller)

SwingMatch AI Ltd is the data controller responsible for your personal data. This means we decide how and why your personal data is processed.

We have not appointed a separate Data Protection Officer as we are a small organisation. For any data protection queries, please contact us at privacy@swingmatch.ai and we will respond within 30 days.

2. What Personal Data We Collect

We collect different types of personal data depending on how you interact with us:

Website Waitlist Data

• First name, last name, and email address — collected when you sign up to our waitlist
• This data is stored in Google Cloud Firestore and used solely to notify you when SwingMatch.AI launches

Account Data (Mobile App)

• Email address and password — collected when you create an account (password is stored securely via Firebase Authentication and is never visible to us in plain text)

Physical Profile Data

• Height, arm length, flexibility assessment, and swing handedness — provided voluntarily by you to improve tour player matching accuracy

Swing Videos

• Golf swing videos you record and upload — stored in Google Cloud Storage and used exclusively for AI-powered swing analysis

Written Player Discovery

• Questions and swing preferences you type, recent conversation context, and the player suggestions and goals generated during the conversation — used to suggest relevant players from our catalogue, explain suggestions, and clarify your preferences
• Physical limitations or other personal information you choose to describe — providing these details is optional
• Goals you explicitly confirm and save in your physical profile — used in subsequent swing analysis and coaching

Shot Notes and Conversational Coaching

• Optional shot notes, including reported feel, contact, club, intended target, starting direction, curve and practice setting, are stored with the shot. We distinguish these reports from video observations and model estimates.
• Relevant shot notes, analysis, selected reference or drill, recent questions and replies, and reviewed coaching passages are sent to Google Vertex AI to provide follow-up coaching under your AI-analysis permission. Notes may inform the initial analysis when submitted with the footage.
• Editing notes changes the context used by future coach replies. The original analysis retains the report snapshot used when it was generated.
• Coach check-in and expansion preferences are stored on your device separately for each signed-in account. Disabling check-ins hides proactive prompts; manual notes and coaching remain available.

Analysis Data

• Biomechanical measurements, swing scores, coaching recommendations, drill sequences, and tour player match results — generated automatically by our AI from your uploaded videos

Device and Technical Data

• Device type, operating system version, and app version — collected automatically by the app platform
• IP address, browser type, pages visited, and referring URLs — collected via Google Analytics 4 on our website

3. Lawful Basis for Processing

Under UK GDPR Article 6, we must have a lawful basis for processing your personal data. We rely on the following bases:

Contract Performance (Article 6(1)(b))

• Processing your account data, physical profile, swing videos, and analysis data to provide the SwingMatch.AI service — this processing is necessary to deliver the service you have signed up for

Legitimate Interest (Article 6(1)(f))

• Improving our AI models and analysis accuracy using anonymised and aggregated data
• Ensuring the security and proper functioning of our services

We have carried out a balancing test for each legitimate interest to ensure our interests do not override your rights. You can request details of these assessments by contacting us.

Consent (Article 6(1)(a))

• Collecting your name and email for our waitlist — you provide this voluntarily and can withdraw at any time
• Sending you marketing communications about SwingMatch.AI — only with your explicit opt-in consent
• Written AI discovery and swing-video AI analysis, each requested separately in the app
• Setting non-essential cookies (analytics) on our website — see Section 6 for how the cookie banner works

Where we rely on consent, you have the right to withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

4. How We Use Your Data

• To provide AI-powered swing analysis and personalised coaching
• To match you with biomechanically similar tour players based on your physical profile
• To suggest tour players based on the written swing preferences you choose to share and to carry your confirmed goals into analysis and coaching
• To generate coaching recommendations and progressive drill sequences
• To track your swing improvement over time
• To display the app interface in your preferred language (we support 12 interface languages; written player-discovery replies and catalogue descriptions are currently in English)
• To notify waitlist subscribers when SwingMatch.AI launches
• To understand website usage through analytics
• To respond to your support queries

5. Automated Decision-Making and Profiling

SwingMatch.AI uses automated processing (including profiling) as a core part of the service, in line with UK GDPR Article 22. Here is what this means for you:

What automated decisions do we make?

• Tour Player Matching: Our AI analyses your physical profile data (height, arm length, flexibility, handedness) and swing biomechanics to automatically match you with the most achievable tour player swing model. This is an automated decision based on your data.
• Swing Analysis: Our AI analyses your swing videos to extract biomechanical measurements, identify swing faults, generate scores, and produce coaching recommendations. No human reviews your video before results are generated.
• Drill Recommendations: Based on the identified faults and your matched tour player, our AI automatically selects and sequences practice drills tailored to you.

How does it work?

Your swing videos are processed by Google's Gemini AI models via Vertex AI. The AI extracts biomechanical data points (such as joint angles, body positions, and movement sequences) at key moments in your swing. These are compared against a database of tour player biomechanics to find your closest match and identify areas for improvement.

Written player discovery and your choices:

With your separate permission for written AI discovery, we send your written request and relevant recent conversation context to Google Vertex AI to generate player suggestions. Relevant player catalogue information is also included. Written-discovery consent does not authorise video analysis; video analysis asks for its own permission. You can browse player tiles and search player names without consenting to written AI discovery. Submitted name searches are processed by our service and may be retained in the private discovery session, but are not sent for AI inference when handled as a name lookup.

You choose whether to select a suggested player. Before suggested goals are added to your physical profile for subsequent analysis and coaching, you can edit them and confirm what to save. These recommendations are golf-coaching suggestions, not medical assessments or guarantees of safety or performance.

What are the consequences?

The automated decisions affect the coaching content, drills, and tour player comparisons you see within the app. They do not have legal or similarly significant effects on you — they are used solely to personalise your golf coaching experience.

Your rights regarding automated decisions:

• You can request human review of any automated decision by contacting us at privacy@swingmatch.ai
• You can express your point of view and contest any automated decision
• In "Rebuild" mode, you can override the AI match by choosing your own tour player

AI transparency (EU AI Act):

Swing analysis, AI player suggestions, and generated coaching content in SwingMatch.AI use artificial intelligence and are identified as such in the app. Player-name lookup and browsing player tiles do not require AI inference. SwingMatch.AI does not use emotion recognition or biometric categorisation, and does not use your video or body-position data to identify you. Body-position points are used solely to analyse your golf swing.

6. Cookies and Tracking

Our website uses cookies and similar tracking technologies. Here is what we use and why:

Essential Cookies

• Session management and security — these are strictly necessary for the website to function and do not require consent

Analytics Cookies (Google Analytics 4)

• Purpose: To understand how visitors use our website, which pages are most popular, and how people find us
• Provider: Google LLC
• Cookies set: _ga, _ga_* (used to distinguish users and sessions)
• Duration: Up to 2 years
• Data collected: Pages visited, time on site, referring URL, approximate location (country/city level), device and browser type
• IP anonymisation: GA4 does not store full IP addresses
• Consent basis: Analytics cookies do not fire until you actively accept them in the cookie banner shown on your first visit. If you reject or dismiss the banner without accepting, analytics stays off. Your choice is remembered on this device and applies across all our pages.

How to manage cookies:

• Change your choice at any time using the "Cookie Preferences" link in the footer (or at the bottom of this page)
• You can also disable analytics cookies by adjusting your browser settings
• You can install the Google Analytics Opt-Out Browser Add-on
• Most browsers allow you to block or delete cookies via their settings — see your browser's help documentation for instructions

Disabling analytics cookies will not affect your ability to use our website.

7. Third-Party Services (Data Processors)

We use the following third-party services to operate SwingMatch.AI. Each acts as a data processor on our behalf:

• Google Cloud Platform (Firebase Authentication, Cloud Firestore, Cloud Storage, Cloud Functions) — Account management, data storage, video storage, and backend processing. Google Cloud Data Processing Terms
• Google Vertex AI (Gemini AI models) — AI-powered video analysis, coaching generation, and written player discovery. Video analysis and written discovery request separate permission. For written discovery, your requests and relevant recent conversation context are processed server-side through Google Cloud Functions and Vertex AI. Vertex AI Service Terms
• Google Analytics 4 — Website analytics (see Cookies section above). Google Privacy Policy
• RevenueCat — Purchase verification and subscription/entitlement management for the App Store. RevenueCat receives your device's purchase receipt and an account identifier to confirm active membership or pilot access; it does not receive swing videos, analysis data, or discovery/coaching conversations. RevenueCat Privacy Policy

Founding pilot entitlement: if you are selected for the 100-person founding pilot, we record a pseudonymous entitlement grant (an account identifier and grant date) to enforce the one-year free period and prevent duplicate grants. This ledger does not include your name or email beyond what's already in your account, and is retained for as long as needed to administer the pilot and for a reasonable period afterward for audit purposes. It is included in your data export and removed on account deletion, consistent with Section 9 below.

We do not sell your personal data. We do not share your data with third parties for their own marketing purposes. We only share data with the processors listed above, or when required by law or legal process, or to protect the rights and safety of our users.

8. International Data Transfers

Our third-party processors (Google Cloud Platform, Google Analytics) may process your data outside the United Kingdom, including in the United States.

Where your data is transferred outside the UK, we ensure it is protected by appropriate safeguards as required by UK GDPR Article 46:

• Google Cloud / Vertex AI / Firebase: Google's Data Processing Terms include Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO), along with supplementary measures. Google also complies with the UK Extension to the EU-US Data Privacy Framework. See Google Cloud Data Processing Terms.
• Google Analytics 4: Covered by Google's data processing terms which include UK-approved SCCs. GA4 does not store full IP addresses, reducing the personal data transferred.

You can request a copy of the relevant transfer safeguards by contacting us at privacy@swingmatch.ai.

9. Data Retention

We keep your personal data only for as long as we need it. Here are our specific retention periods:

• Waitlist data (name and email): Retained until the app launches, plus 6 months — then deleted unless you create an account or give us consent to keep it
• Account data (email, profile, physical measurements): Retained while your account is active. Deleted within 30 days of an account deletion request
• Swing videos: The raw video you upload is deleted automatically once analysis completes, and in all cases within 48 hours. The trimmed clip of your swing stays in your account while it is active, so you can review your progress over time. Clips are deleted automatically if your account is inactive for 36 months, and within 30 days of an account deletion request
• Body-position (pose) data: Points extracted from your video to analyse your swing are never used to identify you. They are retained while your account is active to power progress comparisons, and are permanently deleted after 36 months of account inactivity, or within 30 days of an account deletion request, whichever comes first
• Analysis data (scores, coaching, drill results): Retained while your account is active. Deleted within 30 days of an account deletion request
• Coaching conversations and saved practice focus: Scheduled for deletion after 30 days without activity. Expired conversation history is excluded from new coaching replies while awaiting scheduled deletion. Shot notes follow their associated video record; report snapshots follow analysis-data retention. Account export includes saved notes, analysis snapshots and coaching conversations; account deletion removes them.
• Discovery sessions: Written requests, recent conversation context, and generated suggestions are stored privately in your account and scheduled for deletion after 30 days without activity. Deletion is performed by scheduled retention processing rather than at an exact-to-the-minute deadline. Starting a new conversation clears the current conversation in the app; it does not immediately delete the preceding stored session
• Confirmed discovery goals: Goals you explicitly confirm and save in your physical profile are retained with that profile until changed or deleted. They do not expire with the discovery conversation
• Website analytics data (Google Analytics): Retained for 14 months by Google, then automatically deleted
• Support correspondence: Retained for 2 years after the last communication, then deleted

When data is deleted, it is permanently removed from our systems and those of our processors. Some data may persist in encrypted backups for a short period before automatic deletion.

10. Data Storage and Security

Our service stores account data on Google Cloud Platform infrastructure. The app also uses local device storage, including a temporary file when you export your data. Copies you choose to save or share remain in your chosen destination. We take data security seriously and use the following measures:

• All data is encrypted in transit using TLS (Transport Layer Security)
• All data is encrypted at rest using Google Cloud's default encryption
• Passwords are hashed and salted via Firebase Authentication — we never see or store your password in plain text
• Access to production systems is restricted and logged
• We follow Google Cloud's security best practices
• We do not store payment card information

While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. If you become aware of any security issue, please contact us immediately at privacy@swingmatch.ai.

11. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights. These apply to all personal data we hold about you:

• Right of access (Article 15): You can request a copy of all personal data we hold about you. We will respond within one month.
• Right to rectification (Article 16): You can ask us to correct any inaccurate or incomplete personal data.
• Right to erasure (Article 17): You can request that we delete your account and all associated data. You can do this directly in the app via the account deletion feature, or by emailing us. We will complete the deletion within 30 days.
• Right to restrict processing (Article 18): You can ask us to temporarily stop processing your data in certain circumstances (for example, if you contest the accuracy of the data).
• Right to data portability (Article 20): You can request your personal data in a structured, commonly used, machine-readable format.
• Right to object (Article 21): You can object to processing based on legitimate interest. We will stop unless we can demonstrate compelling grounds that override your interests.
• Rights related to automated decision-making (Article 22): You can request human review of automated decisions (see Section 5 above).
• Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time by contacting us or using the unsubscribe link in any marketing email.

You can request a JSON copy of your account data using Profile → Export My Data and choose where to save it using your device's save/share sheet. The export includes discovery sessions still retained in your account and your saved profile goals. Export files may contain personal information, so choose their destination carefully. The app downloads the export through authenticated access and cleans up its temporary local file after the save/share sheet closes. Account deletion is available from Profile → Delete Account and includes discovery sessions and saved goals.

To exercise any of these rights, including withdrawing consent, you can also contact us at privacy@swingmatch.ai. We will respond within one month. If your request is particularly complex, we may extend this by a further two months, but we will let you know within the first month.

We will not charge a fee for handling your request unless it is manifestly unfounded or excessive.

12. Right to Complain to the ICO

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:

We would appreciate the opportunity to address your concern before you contact the ICO. Please reach out to us first at privacy@swingmatch.ai.

13. Marketing Communications

We will only send you marketing emails (such as product updates, feature announcements, or promotional offers) if you have given us your explicit consent to do so.

• You can opt in to marketing emails when signing up for the waitlist or creating an account
• Every marketing email contains an unsubscribe link — you can opt out at any time with one click
• You can also opt out by emailing privacy@swingmatch.ai
• Opting out of marketing will not affect service-related emails (such as account confirmations or security alerts)

14. Children's Privacy

SwingMatch.AI is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@swingmatch.ai and we will delete it promptly.

Users aged 13 to 17 should have the consent of a parent or guardian before using SwingMatch.AI.

15. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes:

• We will update the "Last updated" date at the top of this page
• For significant changes, we will notify you by email (if we have your email address) or through a prominent notice on our website or in the app
• We encourage you to review this policy periodically

16. Contact Us

Cookie Preferences