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Where we rely on consent (for example, for marketing, and for certain processing of a child's information), you can withdraw it at any time. Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights, and you can object (see Section 12).

Special category (health) information. Where we handle health or wellbeing information, we rely on an additional condition under UK law - usually your explicit consent, or the need to protect someone's vital interests where they are physically or legally incapable of giving consent (for example in a medical emergency during a session).

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5. Children's privacy (please read this if you are a parent or guardian)

Protecting children is central to what we do. Our programmes are aimed at young people aged 5-16, so most participants are children.

• Parental involvement. Where a service is provided directly to a child online (such as the App) and we rely on consent, UK law treats children under 13 as needing a parent or guardian to give or authorise that consent. For younger children generally, we expect a parent, guardian, school or coach to set up and manage the account and to make decisions on the child's behalf.

• Data protection by design for children. We design our Website and App with children in mind. In line with the ICO's Age Appropriate Design Code (the Children's Code) and the "children's higher protection matters" now set out in UK law, we consider how to protect and support children when they use our Services, we recognise that children may be less aware of the risks involved, and we recognise that children of different ages have different needs.

• What we collect from children. We keep the information we collect from children to what is needed to run the programme, keep them safe, and track their golfing progress. We do not use children's information to build marketing profiles or to serve them targeted advertising.

• Safeguarding. We follow recognised safeguarding practice for the sport (including the principles of SafeGolf). Where we have a genuine safeguarding concern, we may share information with parents, carers, or the appropriate authorities. More detail is in our SafeGolf information: [LINK].

• Parental rights. As a parent or guardian, you can ask to see, correct or delete your child's information, and you can withdraw consent, by contacting us using the details in Section 2.

 

6. Marketing communications

If you have given consent, or where the law otherwise allows, we may send you news, offers and updates about PathwayGolf by email.

You can opt out at any time by clicking "unsubscribe" in any marketing email, or by contacting us. We will not send marketing messages to a child without appropriate parental consent. Opting out of marketing will not stop essential service messages, such as messages about a booking, payment or your account.

 

7. Who we share your information with

We do not sell your personal information. We share it only where necessary, and with appropriate safeguards, including with:

• Coaches, PGA professionals, schools and academies involved in delivering a programme a child is enrolled in.

• Service providers who help us run our Services, such as our website and App hosting provider (our Website is built on Wix), email and communications tools, and analytics providers. These providers act on our instructions under contract.

• Payment providers who process payments securely on our behalf.

• Parents, carers and relevant authorities where necessary for safeguarding or to comply with the law.

• Professional advisers, insurers and regulators, and law enforcement, where we are legally required or permitted to share information.

• A buyer or successor if we reorganise, sell or transfer parts of our business.

 

8. Cookies and similar technologies

Our Website uses cookies and similar technologies to make the site work, to remember your preferences, and to understand how the site is used. Some cookies are essential; others (such as analytics) are only used where you have given consent through our cookie banner.

You can manage your preferences through the cookie banner and through your browser settings. For full details of the cookies we use and how to control them, please see our Cookie Policy: [LINK — you should have a separate cookie policy, or expand this section into one].

 

9. Transfers of information outside the UK

Some of our service providers (including our website platform) may store or process information in countries outside the UK. Where information is transferred outside the UK, we make sure it is protected by an appropriate safeguard recognised under UK law - such as a UK adequacy decision, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for more detail using the contact details in Section 2.

 

10. How long we keep your information

We keep your information only for as long as we need it for the purposes set out in this policy, and to meet our legal, accounting and safeguarding obligations. When we no longer need it, we securely delete or anonymise it.

As a general guide:

• Account and App data - for as long as the account is active, and then for 3 years afterwards.

• Enquiry and contact records - for 6 years.

• Financial records - for at least 6 years, to meet tax and accounting requirements.

• Safeguarding records - for the period required by safeguarding best practice and any applicable guidance.

 

11. How we keep your information secure

We use appropriate technical and organisational measures to protect your information against loss, misuse and unauthorised access - including access controls, secure hosting and staff awareness. No system can be guaranteed completely secure, but we take our responsibilities seriously and keep our measures under review. If a data breach is likely to put your rights at risk, we will notify the ICO and, where required, you.

 

12. Your rights

Under UK data protection law you have the right to:

• Be informed about how we use your information (this policy).

• Access the personal information we hold about you.

• Rectify information that is inaccurate or incomplete.

• Erase your information in certain circumstances ("right to be forgotten").

• Restrict how we use your information in certain circumstances.

• Object to us using your information where we rely on legitimate interests, and to object to direct marketing at any time.

• Data portability - to receive certain information in a reusable format.

• Withdraw consent at any time, where we rely on consent.

Where the information is a child's, a parent or guardian can usually exercise these rights on the child's behalf. To exercise any right, contact us using the details in Section 2. We will respond within the time limits set by law (generally within one month). Exercising these rights is normally free.

 

13. Complaints

If you are unhappy with how we have handled your information, please tell us first using the details in Section 2, so we can try to put things right. We operate an internal complaints process and will acknowledge your complaint and respond within the timeframes required by law.

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

Information Commissioner's Office (ICO) Website: www.ico.org.uk Helpline: 0303 123 1113

 

14. Automated decisions and profiling

The App uses your answers and progress to build and adjust a personal golf plan (for example, suggesting the next challenge or level). This helps us tailor coaching to each player. We do not make decisions that have legal or similarly significant effects on you based solely on automated processing without human involvement. If this ever changes, we will update this policy and tell you about your rights.

 

15. Other websites and social media

Our Website and communications may link to other websites and to our social media pages (such as Facebook and Instagram). We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies.

 

16. Changes to this policy

We may update this policy from time to time. When we make significant changes, we will update the "last updated" date above and, where appropriate, let you know by email or through the Website or App.

 

17. Related documents

This policy should be read together with our:

• Terms and Conditions

• Cookie Policy

• SafeGolf / safeguarding information

• Frequently Asked Questions

 

18. How to contact us

If you have any questions, requests or concerns about this policy or your information, please contact: info@pathwaygolf.co.uk

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