Last updated – 26th September 2025
1. Introduction
This Privacy Policy explains how Elevate Golf
International Limited (“Elevate Golf”, “we”, “us”, “our”) collects and
processes personal data when Players and Coaches use the Elevate Golf mobile
application, website, and related services (together, the “Services”). Elevate
Golf is the data controller for the processing described in this Policy,
unless stated otherwise.
We are established in England and Wales. Our Services are
global, but our operations comply with the UK General Data Protection
Regulation (UK GDPR), the Data Protection Act 2018, the EU GDPR (where
applicable), and relevant international privacy laws such as the California
Consumer Privacy Act (CCPA/CPRA).
By using the Services, Users acknowledge that they have read
this Privacy Policy. This Policy forms part of, and should be read alongside,
our Terms & Conditions. If you do not agree, please do not use the
Services.
2. Scope of this Policy
2.1 Who this Policy applies to.
This Privacy Policy applies to all individuals whose personal data is processed
by Elevate Golf. This includes, without limitation:
· Players, who register to request and
receive Tips;
· Coaches, who register to provide Tips;
· Individuals who contact us, including by
email, support channels, or in-app chat;
· Business contacts, such as media
representatives, sports personalities, influencers, suppliers, vendors,
partners, and investors; and
· Social media users, where Elevate Golf
processes personal data directly (for example, when responding to messages or
comments).
2.2 Services covered.
This Policy applies to the Elevate Golf mobile application, the public-facing
website, and official Elevate Golf communications channels. It also covers data
processed for account creation, content submission, verification, customer
support, and business development.
2.3 Services not covered.
This Policy does not apply to:
· Payments processed by PayPal. All
financial transactions are handled directly by PayPal under its own terms and
privacy policy. Elevate Golf does not collect or store card details.
· Social media platforms. Where Users
engage with Elevate Golf through third-party platforms (such as Facebook,
Instagram, TikTok, X, LinkedIn, or YouTube), the processing of personal data is
also subject to those platforms’ own privacy policies.
· Third-party devices or networks. Any use
of the Services on devices, networks, or app stores is also subject to the
policies of those providers.
3. Data We Collect
3.1 Account Information.
For Players, we collect personal details such as name, email address,
confirmation of age (18+), profile information, and learning preferences, as
well as any information voluntarily added to a Player profile. For Coaches, we
collect personal details such as name, email address, professional
qualifications, verification materials, and profile content (including
biography, photo, video, and sample Tip). Coaches are required to connect a
PayPal Business Account to receive payments. This connection is managed
directly by PayPal. Elevate Golf does not collect or store PayPal login
credentials, but may receive confirmation and limited metadata (such as account
ID or email) from PayPal in order to enable payouts and resolve disputes.
3.2 Content Submissions.
Players provide videos, images, text, and other content when requesting a Tip.
Coaches create and upload video, image, text, or audio content when providing a
Tip.
3.3 Payment Information.
Elevate Golf does not collect or store payment card details. All financial
transactions are processed directly by PayPal under its own terms and privacy
policy. Elevate Golf may receive limited payment metadata from PayPal,
including confirmation of payment status, payer name or email address, and
transaction ID, for the purposes of confirming transactions and resolving
disputes.
3.4 Device and Technical Data.
When Users access the Platform, we may collect device identifiers (such as
device ID), IP address, operating system details, log data relating to access
and actions within the app, and error reporting information. This data is used
to secure, maintain, and improve the Services.
3.5 Website Interactions.
When individuals interact with the Elevate Golf website, we may collect
personal data including an email address provided to sign up for launch
notifications, or a name and email address provided through the website chatbot
when raising a support ticket. The website also uses essential and analytics
cookies, as explained further in our Cookie Policy.
3.6 Communications.
We retain records of communications with Elevate Golf, including by email,
through support channels, and via social media messages, where personal data is
provided.
3.7 Business and Partnership
Data.
We collect the contact details of media representatives, sports personalities,
influencers, suppliers, vendors, partners, and investors who engage with
Elevate Golf in a business capacity.
4. How We Use Personal Data
4.1 To provide the Services.
We process personal data to create and manage Player and Coach accounts, to
facilitate Tip requests and responses, and to deliver Player submissions to
Coaches and Coach Tips to Players. The lawful basis for this processing is the
performance of our contract with the User.
4.2 To process payments.
Personal data is processed to facilitate payments through PayPal and to enable
payouts to Coaches. Elevate Golf receives confirmation and limited metadata
from PayPal, such as payment status, payer details, and transaction
identifiers, which are used to verify payments and resolve disputes. The lawful
basis is the performance of a contract and our legitimate interest in
preventing fraud and ensuring accurate settlement of transactions.
4.3 To verify Coaches.
We process personal data, including professional qualifications and
verification materials, to confirm the identity and eligibility of Coaches. The
lawful basis is our legitimate interest in safeguarding Players and maintaining
quality standards, and, where applicable, compliance with legal obligations.
4.4 To communicate with Users.
We use personal data to send account confirmations, service notifications,
security alerts, and other operational messages. We also use it to respond to
enquiries and provide customer support. The lawful basis is the performance of
a contract.
4.5 To send marketing communications.
Where Users have opted in, we process personal data to send news, promotions,
and updates about Elevate Golf. Users may withdraw consent at any time, and
they may opt out of marketing communications without affecting their ability to
use the Services. The lawful basis is consent under GDPR, with equivalent
opt-out rights provided under CCPA/CPRA.
4.6 To ensure safety, compliance, and enforcement.
We process personal data to monitor compliance with our Terms & Conditions
and Acceptable Use Policy, to investigate fraud, abuse, harassment, or misuse
of the Platform, and to take action where necessary, including suspending or
disabling accounts. The lawful basis is our legitimate interest in maintaining
a safe and trusted platform, and compliance with legal obligations where
applicable.
4.7 To improve and develop the Services.
We analyse technical and usage data to understand how Players and Coaches use
the Platform, to test new features, and to enhance overall performance. We may
also process anonymised Player submissions and Tips to train and improve our
technology, including artificial intelligence and machine learning systems.
Personal data used for these purposes is anonymised so that individuals cannot
reasonably be identified. The lawful basis is our legitimate interest in
improving our services and technology, and, where required by law, consent.
4.8 To comply with legal obligations.
We may process and retain personal data where necessary to comply with
applicable legal obligations, including maintaining transaction and account
records for audit and regulatory purposes, and responding to lawful requests
from courts, regulators, or law enforcement authorities.
5. Children’s Data
5.1 Current availability.
At present, the Services are available only to individuals aged 18 or over.
Junior accounts are not yet available in this release.
5.2 Blocked registration.
If an individual under 18 attempts to register, the process will be blocked and
no account will be created. Elevate Golf does not retain personal data,
including email addresses or device identifiers, from such attempts.
5.3 Future junior accounts.
Elevate Golf is developing specific account types for junior users. These
accounts will be introduced in a later release of the Platform and will be
subject to appropriate safeguards, including parental consent where required by
law.
5.4 Parental consent.
Where processing of children’s data is permitted by law, it will only take
place with verified parental or guardian consent and in line with applicable
age requirements.
6. Sharing of Data
6.1 Between Players and Coaches.
When a Player requests a Tip, the content of that request, including any video,
image, or text submission, is shared with the selected Coach. When a Coach
provides a Tip, that content is shared with the Player who made the request.
This sharing is necessary for the performance of the contract between Elevate
Golf and the User.
6.2 With service providers.
We share personal data with trusted third-party service providers who support
the operation of the Services. These include:
PayPal,
which processes all payments and provides Elevate Golf with limited
transaction metadata;
Amazon
Web Services (AWS), which hosts the Platform and stores personal data
in secure facilities located in the United Kingdom (EU-West region);
Zoho
and other support platforms, which may be used to manage customer
support tickets and communications; and
Analytics
and security providers, which help us understand usage, improve the
Platform, and protect against fraud or abuse.
These providers are bound by contractual obligations to
process personal data only on our instructions and in compliance with
applicable law.
6.3 With business partners.
Where necessary, we may share limited personal data with business partners such
as media representatives, influencers, suppliers, vendors, or investors for
business development, partnership management, or contractual purposes.
6.4 With regulators and legal authorities.
We may disclose personal data if required to do so by law, regulation, legal
process, or governmental request. We may also disclose information where
necessary to enforce our Terms & Conditions, protect our rights, or ensure
the safety of Players, Coaches, or the public.
6.5 No sale of data.
Elevate Golf does not sell personal data to third parties. Personal data is
shared only as described in this Policy.
6.6 Access by employees and contractors.
Personal data may be accessed by Elevate Golf employees or authorised
contractors where this is necessary to operate, maintain, or support the
Services. Access is strictly limited to those who need it for their role. All
such individuals are bound by confidentiality obligations and required to
process personal data in compliance with this Policy and applicable law.
7. International Transfers
7.1 Primary storage location.
Personal data processed by Elevate Golf is primarily stored on Amazon Web
Services (AWS) servers located in London, United Kingdom (region eu-west-2).
7.2 Transfers outside the UK and EEA.
Some of our service providers or authorised contractors may process personal
data outside the United Kingdom and the European Economic Area (EEA). Where
such transfers occur, Elevate Golf ensures that appropriate safeguards are in
place to protect personal data. These safeguards may include:
the
use of the UK’s International Data Transfer Agreement (IDTA) or the
European Commission’s Standard Contractual Clauses (SCCs);
reliance
on adequacy regulations or adequacy decisions, where the destination
country has been formally recognised as providing adequate protection; or
other
lawful transfer mechanisms permitted under applicable data protection
laws.
7.3 Further information.
Users may request more information about the safeguards applied to
international transfers by contacting Elevate Golf using the details set out in
Section 12 of this Policy.
8. Retention of Data
8.1 General principle.
We retain personal data only for as long as is necessary to fulfil the purposes
for which it was collected, or as required by law. Where data is no longer
required, it will be securely deleted, anonymised, or otherwise rendered
unusable.
8.2 Account data.
Personal data associated with a Player or Coach account is retained for as long
as the account remains active. If an account is disabled or closed, account
information may be retained for a limited period in accordance with our Privacy
Policy and data retention rules, including for fraud prevention, audit, or
legal compliance.
8.3 Tips and submissions.
Player submissions and Coach Tips are retained in the Platform to enable Users
to access them. If a Player deletes a submission or Tip, the content will be
anonymised so that it can no longer be linked to an identifiable individual,
but may still be used in anonymised form for service improvement and analysis.
8.4 Payment records.
Transaction records and related personal data received from PayPal are retained
as required by applicable tax and accounting laws.
8.5 Support communications.
Records of communications with customer support are retained for as long as
necessary to resolve the enquiry and for a reasonable period thereafter for
audit and training purposes.
8.6 Business and partnership data.
Contact details of media representatives, influencers, suppliers, vendors,
partners, and investors are retained for as long as necessary to manage the
business relationship and for a reasonable period thereafter.
8.7 Legal and regulatory retention.
Where the law requires us to retain data for a specific period, or where data
is relevant to a dispute, investigation, or enforcement action, we will retain
it for the duration required.
9. User Rights
9.1 Rights under UK and EU data protection law.
If you are located in the United Kingdom or European Economic Area, you have
the following rights in relation to your personal data: the right of access,
rectification, erasure, restriction, portability, and objection, as described
in applicable law.
9.2 Rights under California law.
If you are a California resident, you have additional rights under the
California Consumer Privacy Act (as amended by the CPRA), including the right
to know what personal information we collect and disclose, the right to delete
or correct personal information, the right to opt out of the sale or sharing of
personal information (Elevate Golf does not sell or share personal information
for such purposes), and the right not to be discriminated against for
exercising your rights.
9.3 How to exercise your rights.
You may exercise your rights by contacting us at
privacy@elevategolf.com. We may need
to verify your identity before fulfilling your request. At present, the
fulfilment of these rights may be handled by manual processes. This means, for
example, that access requests may be provided by way of manual data export, and
deletion requests may result in account disablement and anonymisation of
associated content. We are continuing to develop tools to improve automated
access, portability, and deletion, and will update this Policy when those tools
are available.
9.4 Complaints.
If you are located in the UK or EU and are not satisfied with how we handle
your request, you have the right to lodge a complaint with the Information
Commissioner’s Office (ICO) in the United Kingdom, or with your local data
protection authority.
10. Cookies and Tracking
10.1 Cookies on the website.
Our website (
www.elevategolf.com)
uses cookies and similar technologies to operate effectively, to analyse usage,
and to improve performance. Cookies are small text files stored on your device
when you access our website.
10.2 No cookies in the app.
The Elevate Golf mobile application does not use cookies. Data collected within
the app is limited to account, content, and technical information as described
in this Policy.
10.3 Types of cookies used.
The categories of cookies used on our website include essential cookies
(necessary for the site to function), and analytics cookies (which help us
understand how visitors use the site). Full details of the cookies we use,
their purpose, and duration are set out in our separate
Cookie Policy,
which forms part of this Privacy Policy.
10.4 Managing cookies.
Website visitors can control or delete cookies through their browser settings,
and may also adjust cookie preferences through the cookie banner displayed when
visiting our site. Please note that disabling essential cookies may affect the
proper functioning of the website.
11. Data Security
11.1 Our commitment.
Elevate Golf takes the security of personal data seriously. We apply technical
and organisational measures designed to protect personal data against
accidental or unlawful destruction, loss, alteration, unauthorised disclosure,
or access.
11.2 Measures in place.
Our measures include the use of secure hosting on Amazon Web Services (AWS) in
London (eu-west-2), encryption of data in transit and at rest where
appropriate, access controls to restrict personal data to authorised staff and
contractors only, and regular monitoring of systems for vulnerabilities.
11.3 User responsibility.
Users are responsible for keeping their account credentials confidential.
Elevate Golf is not responsible for unauthorised access resulting from a User’s
failure to protect their credentials.
11.4 Limitations.
While we apply appropriate safeguards, no method of transmission over the
internet or method of electronic storage is completely secure. For this reason,
we cannot guarantee the absolute security of personal data.
12. Changes to this Policy
12.1 Right to update.
Elevate Golf may update this Privacy Policy from time to time to reflect
changes in our Services, legal requirements, or business practices.
12.2 Notification of changes.
Where changes are material, we will provide reasonable notice to Users, for
example by posting an update within the Platform or on our website, or by
sending an email notification. The date of the most recent version will always
be shown at the top of this Policy.
12.3 Continued use.
Continued use of the Services after an updated Privacy Policy takes effect
constitutes acceptance of the updated terms.
13. Contact Us
13.1 Data controller.
The data controller responsible for personal data under this Privacy Policy is:
Elevate Golf International Limited
1 Warner House
Harrovian Business Village
Bessborough Road
Harrow, London
Middlesex HA1 3EX
United Kingdom
13.2 Contact details.
For any questions about this Policy, or to exercise your data rights, please
contact us at:
13.3 Supervisory authority.
If you are located in the United Kingdom, you have the right to raise concerns
with the
Information Commissioner’s Office (ICO) at
www.ico.org.uk. If you are
located elsewhere in the European Economic Area, you may contact your local
data protection authority.