Privacy Policy

Last updated: February 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 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

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))

• Collecting website analytics (via Google Analytics 4) to understand how visitors use our site and to improve our service
• 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
• Setting non-essential cookies (analytics) on our website

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 generate coaching recommendations and progressive drill sequences
• To track your swing improvement over time
• To deliver the service in your preferred language (we support 12 languages)
• 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.

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

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

How to manage cookies:

• You can 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 and coaching generation. Your videos are processed server-side through Google Cloud Functions and are not shared with any other party. Vertex AI Service Terms
• Google Analytics 4 — Website analytics (see Cookies section above). Google Privacy Policy

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: Retained while your account is active. Deleted within 30 days of an account deletion request
• Analysis data (scores, coaching, drill results): Retained while your account is active. Deleted within 30 days of an account deletion request
• 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

All data is stored on Google Cloud Platform infrastructure. 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.

To exercise any of these rights, 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