Privacy Policy

1. Introduction

This Privacy Policy explains how Swingalytica (a brand of RealGolf.Games UG (haftungsbeschränkt)) collects, processes, stores, and protects personal data of users in accordance with the General Data Protection Regulation (GDPR) and German data protection law.

2. Controller

The data controller is:

RealGolf.Games UG (haftungsbeschränkt)
Katrepeler Landstraße 59a
28357 Bremen, Germany
Email: info@swingalytica.com

3. Categories of Personal Data

We may collect the following data:

• Contact information (e.g., name, email address)
• Authentication data (hashed passwords)
• Usage data (e.g., app features used, error reports, session statistics)
• Payment information (processed via third-party providers like Paddle)

4. Legal Basis for Processing

Data is processed based on:

• Consent (Art. 6(1)(a) GDPR)
• Performance of a contract (Art. 6(1)(b) GDPR)
• Legal obligations (Art. 6(1)(c) GDPR)
• Legitimate interests (Art. 6(1)(f) GDPR) – e.g., security, fraud prevention, analytics

5. Use of Third-Party Services

Swingalytica uses third-party services including MongoDB Atlas, Render, Upstash, Supabase, Paddle, and Resend. These providers act as data processors under Art. 28 GDPR. Personal data shared with them is limited to what is necessary for the service and is protected according to our agreements.

6. Cookies and Tracking

We use essential cookies required for site operation. Any additional tracking or analytics requires explicit consent, which users can give or withdraw at any time.

7. Rights of Data Subjects

Users have the following rights:

• Right to access personal data (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restrict processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR), e.g., Datenschutzbehörde Bremen

Requests can be sent to info@swingalytica.com. We will respond within one month, as required by law.

8. Data Security

We implement technical and organizational measures to protect personal data against unauthorized access, alteration, loss, or disclosure.

9. Data Retention

We retain personal data only as long as necessary:

• Golf swing and session data, profile information: Deleted immediately upon account deletion request.
• Invoices and payment records: Retained by Paddle under their data processing agreement; no payment details are stored by Swingalytica.
• Transactional emails (metadata): Retained by Resend under their data processing agreement; no email content is stored by Swingalytica.
• Database backups: Retained for 7 days on a rolling basis. Deleted user data present in backups is removed when the backup expires, no later than 7 days after the live deletion.

10. Account Deletion

Users may request deletion of their account and all associated personal data at any time via the account settings or by contacting info@swingalytica.com.

Upon receiving a deletion request:

• All personal data (swing data, session data, profile) is permanently deleted immediately from our live systems. This includes all data that can be linked to the user account, ensuring that no identifiable information remains accessible.
• Residual copies in database backups are automatically removed within 7 days thereafter.
• Invoices and payment records are retained by Paddle under their data processing agreement; no payment details are stored by Swingalytica.
• Complete deletion occurs no later than 7 days after the initial request.

11. Changes to this Privacy Policy

We may update this Privacy Policy at any time. The current version is always available on our website. Users will be notified of material changes via the app or website.

12. Contact

For questions or complaints regarding data privacy, contact:
RealGolf.Games UG (haftungsbeschränkt)
Katrepeler Landstraße 59a
28357 Bremen, Germany
Email: info@swingalytica.com