Privacy Policy

Effective Date: 1 January 2026
Last Updated: 22 February 2026

1. Introduction and Data Controller

We at FairwayHub OÜ value your privacy and are committed to protecting your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR).

This Privacy Policy explains how we collect, use, and share information about you when you visit our website (fairwayhub.club) or use our Social Network platform (the "Service").

Who is responsible for your data?

The Data Controller responsible for your personal data is:

  • Legal Name: FairwayHub OÜ
  • Registry Code: 17414823
  • Address: Kalaranna 25-29, Tallinn, Estonia, 10415
  • Email: hello@fairwayhub.club

2. Collection and Use of Your Information

When you use or access the Services, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

  • Contact Information: Basic contact details, such as name, address, phone number, and email. We use this information where necessary to perform our contract with you to provide the Services, and to communicate with you (including, with your consent where required, to tell you about certain promotions or products or services that may be of interest to you). If you invite others to use our Services, we will collect their email address from you to send the invitation. We use this information solely to facilitate the invitation and do not use it for other marketing purposes unless the recipient becomes a user.
  • Account Information: Such as name, username, email and password. We use this information where necessary to perform our contract with you to provide the Services and to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately at hello@fairwayhub.club.
  • Profile Information.
  • Payment Information: Such as credit or debit card information and billing address, which we collect using a third-party payment processor. We use this information where necessary to perform our contract with you to process your payment and provide the Services.
  • Created Information: Content that you create, such as posts, likes and comments. Including hashtags that you use, metadata about the content that you create, such as the location where a photo was taken or the date that a file was created. Also, the time and frequency of your activities when using our Services.
  • Camera Information: Content that you provide through our camera feature or your camera roll settings. We use information from the camera for storing your pictures on the social network, on your profile image and as part of Journal entries. All the Camera Information is only what you have consented to and submitted to us.
  • Messages: Messages that you send and receive, including their content, for the purpose of providing you with a communication option within the platform with other members.

Information Collected Automatically

We and certain third parties also automatically collect certain information about your interaction with the Services ("Usage Information") through the use of cookies and other tracking technologies ("Tracking Technologies"). Usage Data includes:

  • Device information: Such as device type, time zone setting, operating system, unique device identifier, and internet protocol (IP) address.
  • Location information: Such as the approximate location.
  • Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, and interactions with marketing emails.
  • Views of and interactions with a Fairway and its content, to gather aggregated information about how people use Fairway and its content.

We use Usage Data in our legitimate interests to tailor features and content to you, run analytics and measure and better understand user interaction with the Services, and we may permit third parties to use Usage Data for such purposes.

Information We Collect About Your Followers and Other Connections

To improve your experience on our platform, we try to suggest meaningful connections and activities. For this, we may collect and use the information about followers, groups, accounts, Golf Club pages and other users and communities you're connected to and interact with ("Other Information"). This includes how you interact with them across our Service and which ones you interact with the most.

Based on the information above, we may suggest a person to follow for you through "People to Follow". We take into account whether your followers or people you follow belong to a group when we suggest you join it.

3. How We Use Your Data & Legal Basis

Under GDPR, we must have a "legal basis" for every way we use your data.

PurposeType of DataLegal Basis (GDPR Art. 6)
To provide the Service (Account management, platform access, authentication)Contact & Account InformationContractual Necessity: We need this to fulfil our Terms of Service with you.
To communicate with you (Responding to support tickets)Contact InformationLegitimate Interest: To respond to your inquiries for support.
Marketing (Sending newsletters or product updates)Contact InformationConsent: If you opted in via a form. OR Legitimate Interest: If you are an existing customer (soft opt-in), subject to your right to opt-out.
Security & Fraud PreventionTechnical InformationLegitimate Interest: To ensure the security of our IT services and network. Legitimate Interest: To prevent harmful behaviour and keep people safe on our Products.
Legal Compliance (Tax, accounting, legal disputes)Payment InformationLegal Obligation: To comply with Estonian tax laws and EU regulations.
Analytics (Improving our application)Usage & Technical InformationConsent: Obtained via our Cookie Banner.
PersonalisationUsage, Created & Other InformationConsent: We personalise your experience, like by suggesting people to follow, groups to join.

4. Automated Processing and AI-Driven Personalisation

To provide you with tailored fitness recommendations, our App utilizes automated processing and Artificial Intelligence (AI) technologies.

  • How We Use AI: Our system analyses the personal data you provide, frequency of games, and scores of games to generate a Personalised Summary and Coaching Plan. This process is automated to ensure your training schedule adapts in real-time to your progress.
  • The Logic Involved: Our algorithms utilise LLM technology to correlate your historical performance with sports science principles. This results in automated adjustments to training plan content, for example, focus areas.
  • Human Intervention: While our AI is designed for accuracy, it does not replace professional medical or training advice. You have the right to express your point of view regarding your generated plan by contacting us at hello@fairwayhub.club.
  • Data Training: We do not sell your data to third parties for the purpose of training external AI systems.
  • User Controls: You can opt out of AI-driven personalisation at any time in the App Settings by unsubscribing.

5. Data Sharing and Recipients

We do not sell your personal data. However, we may share data with specific third parties essential to our operations ("Data Processors"). These parties process data only on our instructions and are bound by confidentiality agreements.

Categories of Recipients include:

  • Cloud Hosting Providers: to host our infrastructure.
  • Analytics Providers: to understand website traffic.
  • CRM & Marketing Tools: to manage customer relationships.
  • Payment Processors: to handle billing (if applicable).
  • LLM Providers: to provide personalised training plans and performance improvements.

We may also disclose your data if required by law, such as to respond to a subpoena or request from the Estonian Data Protection Inspectorate.

6. International Data Transfers

FairwayHub OÜ is based in Estonia (European Union). However, some of our service providers may be located outside the European Economic Area (EEA), specifically in the United States.

When we transfer data to the US or other non-EEA countries, we ensure it is protected by:

  • Adequacy Decisions: Transferring to countries deemed "adequate" by the EU Commission; OR
  • EU-US Data Privacy Framework: Ensuring US vendors are certified under this framework; OR
  • Standard Contractual Clauses (SCCs): Using EU-approved contracts that guarantee the safety of your data.

7. Data Retention & Account Deletion

We retain your personal data only as long as necessary to fulfil the purposes for which it was collected.

Marketing Data

Retained until you unsubscribe (opt-out), or for 24 months after your last interaction.

Account Data

Retained for the duration of your contract plus a grace period of 6 months to allow for reactivation, unless you request deletion earlier.

Legal/Financial Data

Retained for 7 years as required by the Estonian Accounting Act and tax laws.

Account Deletion

You may delete your account at any time directly through the [Settings > Account > Delete Account] menu within the App. In accordance with Apple App Store Review Guidelines and Google Play Data Safety requirements:

  • Scope of Deletion: Upon account deletion, we will purge all personal data associated with your profile, including your AI-generated training history and camera-stored images, from our active servers.
  • Retention Period: Data is typically deleted within 30 days of your request. Some data may be retained longer if required for legal, tax, or fraud prevention purposes, or as part of encrypted backups, which are overwritten over time.
  • Subscriptions:Deleting your account does not automatically cancel active subscriptions billed through the Apple App Store or Google Play. You must manage your subscriptions directly through the respective platform's settings.

8. Your Rights (GDPR)

You can exercise the following rights by sending a specific request to the Data Controller at the following email address: hello@fairwayhub.club

RightDescription
Access
(Article 15 GDPR)
The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him are being processed, and, where that is the case, access to the personal data and to the following information: purpose of management, categories of processed data, recipients (if any), transfer and adequate guarantees (if any), period for which personal data will be stored, rights of data subjects, existence of an automated decision-making process (if any). The Data Controller provides a copy of personal data. If the request is made by electronic means, information is supplied in a commonly used electronic format, unless otherwise indicated.
Rectification
(Article 16 GDPR)
The data subject has the right to obtain the rectification of wrong personal data and the integration of incomplete personal data.
Erasure
(Article 17 GDPR)
The data subject shall have the right to obtain from the Data Controller the erasure of his personal data in the following cases: the personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed, withdrawal of consent (and there is no other legal bases for the processing), he opposes the processing for the reasons related to his particular situation (and there are no overriding legitimate grounds for the processing), he opposes the processing for direct marketing purposes, the personal data have been unlawfully processed, the personal data have to be erased for compliance with legal obligation, the data have been collected in relation to the offer of information society services. The right shall not apply if the processing is necessary for exercising the right of freedom of expression and information, for compliance with legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority, for reasons of public interest in the area of public health, for archiving purpose in the public interest, scientific and historical research purpose or statistical purpose, for the establishment, exercise or defence of legal claim.
Restriction of Processing
(Article 18 GDPR)
The data subject shall have the right to obtain from the Data Controller the restriction of processing if: the accuracy of the personal data is contested by the data subject (for a period enabling the Controller to verify the accuracy), the processing is unlawful (but the data subject opposes the erasure of the personal data and requests the restriction of their use rather than erasure), the personal data are required by the data subject for the establishment, exercise or defence of legal claim, although the Data Controller no longer needs it, he exercised the right to object (while the Data Controller verifies the existence of legitimate and prevailing reasons).
Objection
(Article 21 GDPR)
The data subject shall have the right to object to the processing of personal data if (i) it is based on public interest or legitimate interest and (ii) if personal data are processed for direct marketing purposes, including profiling.
Data Portability
(Article 20 GDPR)
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a data Controller, in a structured, commonly used and machine-readable format (applicable to automated decision-making processes).
Withdrawal
(Article 13 GDPR)
The data subject has the right to withdraw the consent at any time without affecting the lawfulness of processing based on the consent before withdrawal.
Complaint
(Article 13 GDPR)
The data subject has the right to lodge a complaint with a supervisory authority.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorised disclosure. This includes encryption (TLS/SSL), access controls, and regular security assessments.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any third-party sites you visit.

11. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority.

Since our headquarters are in Estonia, our lead supervisory authority is:

  • Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
  • Website: www.aki.ee
  • Email: info@aki.ee
  • Address: Tatari 39, 10134 Tallinn, Estonia

If you have any questions about this Privacy Policy, please contact us at:

hello@fairwayhub.club