It is important to us that you have confidence in our processing of personal data that can be associated with you. Therefor we want you to be aware of how we process data, that we comply with applicable laws and regulations and that our processing has been adapted to comply with the requirements of the data protection legislation, including the General Data Protection Regulation ("GDPR"). This privacy policy is applicable when you create or have created a user account where you may book golf tee times, pay membership fees, rent or buy equipment etc at golf clubs, facilities and other golf related partners to Sweetspot, through our mobile application Sweetspot (the "Application").

1. General

Data refers to all personal data and other information that we collect and store regarding your use of our services, in order to provide our service and improve it, as well as to provide you with tailor made offers and information.

2. What kind of Personal data do we collect?

2.1 Data – in this instance personal data – consists of all information which directly or indirectly relates to a natural person. This includes e.g. name, address, golf federation or club membership information and/or identification and location information.

2.2 When you use our services, the following personal data might be processed:

(i) Identification information: name, date of birth and gender

(ii) Contact information: email address and phone number

(iii) Login information: password

(iv) Golf related information: golf federation and/or club membership information and/or identification, golf handicap

(v) Device information: IP-address and location information (e.g. GPS)

(vi) User information: search history in the Application and booking history in the Application

3. How do we collect Personal data?

3.1 We access your personal data through various methods, primarily by information you yourself provide in the Application.

3.2 Information on memberships at golf clubs and golf handicap may be obtained from golf federations.

3.3 We also collect information through cookies, pixels, and local disk storage on your device.

3.4 We may also collect information from our collaborative partners with which we have entered into agreements in order to provide the services to you.

4. Why do we process your personal data and on what basis?

Sweetspot uses your personal data for various purposes:

4.1 Obligations towards users

We process your personal data to fulfil our obligations towards you as a user. For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. Processing is necessary for the performance of a contract to which you are party. We store your personal data for this purpose as long as the contract applies between you and Sweetspot.  

4.2 Administration of user accounts

We process your personal data to administer your user account in the Application, and provide the services in accordance with our terms and conditions (https://sweetspot.io/terms). For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. Processing is necessary for the performance of a contract to which you are party. We store your personal data for this purpose as long as the contract applies between you and Sweetspot. 

4.3 To locate golf courses and/or facilities

We process your personal data to locate nearby golf courses and/or facilities. For this purpose we process your device- (including location information) and user information. Processing is necessary for the performance of a contract to which you are party. We store your personal data for this purpose as long as the contract applies between you and Sweetspot. 

4.4 Golf course check-in

We process your personal data in order to detect your arrival at a golf course where you have booked a game, so that you can be automatically checked in with the course at arrival. For this purpose we process your identification- and device information (including location information). Processing is necessary for the performance of a contract to which you are party. We store your personal data for this purpose until you are checked-in.

4.5 Information and marketing purpose

We process your personal data to inform you about new updates to the services or the terms and conditions and to send you notifications and messages by text, email or in the Application (including marketing and information from us and the golf facilitates). For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to inform you about, inter alia, new updates and to send out notifications and messages including marketing. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose. We store your personal data for this purpose as long as you have an account at Sweetspot.

4.6 Improvement and development of services

We process your personal data to improve and develop the services or new services of products in the Application, and to analyse how you use the services. For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information.  The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to improve and develop the services or new services of products in the Application and to analyse how you use the services. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose. We store your personal data for this purpose as long as you have an account at Sweetspot.

4.7 Assurance of properly functioning and non-violation of the terms and conditions

We process your personal data to make sure that technical functions within the services are properly functioning and to prevent use in violation with the terms and conditions. For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to ensure properly functioning and to prevent use in violation with the terms and conditions. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose. We store your personal data for this purpose as long as you have an account at Sweetspot.

4.8 To fulfill contractual obligations towards a third party

We process your personal data to fulfil our contractual obligations towards third parties. For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. If we process your personal data to fulfil our contractual obligations towards a third party the processing is based on a balance of interests. It is a legitimate interest of ours to be able to fulfil such obligations. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose. We store your personal data for this purpose as long as we have an obligation towards a third party, provided that you have an account at Sweetspot.

4.9 To exercise and defend our rights

We process your personal data to establish, exercise or defend our rights. For this purpose we process your identification-, contact-, login-, golf related-, device- (including location information) and user information. It is a legitimate interest of ours to be able to exercise or defend our rights. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose. We store your personal data for this purpose as long as you have an account at Sweetspot and after that if necessary for this purpose.

4.10 Responsibilities under applicable law

We process your personal data to fulfil our responsibilities under applicable law. For this purpose we process your identification-, contact-, login-, golf related-, device- (not including location information) and user information. Processing is necessary for compliance with a legal obligation to which Sweetspot is subject. We store your personal data for this purpose as long as we have responsibilities under applicable law and/or as long as it is required by law.

5. How do we process your personal data?

5.1 Sweetspot processes your personal data when you book a tee time in the Application. When booking, information about your golf federation membership identification is sent to golf federations in order for your golf handicap and membership to be continually updated in the Application.

5.2 If you as a user of the Application invite other players to a booked tee time the personal data of the invited players will be transferred according to the following:

(i) if the invited player is also a user of the Application, information about golf federation membership identification will be transferred, and the invited player will receive information about the tee time through the Application;

(ii) if the invited player is not a user of the Application, information regarding phone number will be transferred, and the invited player will receive information about the tee time to its mobile device; and

(iii) information on how many players and who those players are will be sent to the golf facilitates for each specific tee time.

5.3 Sweetspot share your personal data with the following recipient categories:

5.3.1 Golf federations

We share your personal data with golf federations, as stated in clause 5.1, in order for your golf handicap and membership to be continually updated in the Application. Processing is necessary for the performance of a contract to which you are party.

5.3.2 Golf facilities

We share your personal data with Golf facilities for each specific tee time to inform the facilities on the number of players and who those players are, as stated in clause 5.2(iii). Processing is necessary for the performance of a contract to which you are party.

5.3.3 Suppliers of IT-systems

We share your personal data with Suppliers of IT-systems in order for us to provide services and improve the user experience of those services. The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to provide services and improve the user experience of those services. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose.

5.3.4 Cloud Service Providers

We share your personal data with Cloud Service Providers in order for us to provide services. The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to provide services. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose.  

5.3.5 Buyers and Investors

We share your personal data with buyers and investors in case of a reorganisation of the business operations as well as transfer, merger or acquisition. The processing of your personal data is based on a balance of interests. It is a legitimate interest of ours to be able to share your personal data in case of a reorganisation of the business operations as well as transfer, merger or acquisition. It is not overridden by the interests or fundamental rights and freedoms of yours. Also, the processing is necessary for this purpose.

5.3.6 Authorities

We share your personal data with authorities in accordance with mandatory applicable law. Such processing is necessary for compliance with a legal obligation to which Sweetspot is subject.

5.4 We transfer personal data outside the EU/ESS, to the USA. In the event your personal data is transferred to the USA, such transfer will be in accordance with applicable data protection legislation as we use appropriate safeguards in the form of standard data protection clauses and as we have adopted supplementary measures.

6. For how long do we store your personal data?

6.1 Sweetspot will store your personal data as long as the data is necessary for the purpose for which the data was collected, or if necessary for another purpose which is not in conflict with the original purpose for collection. Sweetspot will erase the personal data that is no longer needed, but may retain certain personal data to fulfil its responsibilities under law and maintain the current relationship with the holder of the user account.

6.2 Location data is erased every time you shut down the Application.

6.3 Personal data that must be saved for a certain amount of time according to law will be saved even after you terminate your user account.

6.4 If you unsubscribe from direct marketing or other information, the personal data collected for this purpose will be erased.

7. Your rights

7.1 The right to request access and correction

You have the right to, without any cost, request a record of Sweetspot's processing of personal data in respect of you. If you consider that certain personal data stored by Sweetspot is incorrect, you may request that the personal data is corrected.

7.2 The right to deletion

Your personal data will not be stored for a longer period than stated in clause 4 and 6 and Sweetspot will delete personal data in accordance with applicable law. However, you have the right to demand the deletion of incorrect data and personal data when the processing is no longer necessary. A request of deletion may also be made in respect of personal data which is being processed due to a legitimate interest.

7.3 The right to object

You have the right to object against processing based on a legitimate interest. The processing of personal data conducted by Sweetspot based on a legitimate interest is stated above in clause 4. The right to object means that you may declare that the processing by Sweetspot based on a legitimate interest should not occur.

7.4 The right to limit processing of personal data

You have the right to request a limitation of the processing of personal data in the following cases:

(i) if you question the correctness of any personal data;

(ii) if the processing of personal data is prohibited and you chose a limitation of the personal data instead of deletion;

(iii) if the personal data is no longer needed the purposes for which it was collected and processed, but you need the personal data to establish, practice or defend against legal claims; or

(iv) if you have objected to the processing that is based on a legitimate interest.

A limitation of the processing of personal data means that the personal data will continue to be stored, but Sweetspot will not process any personal data without your consent.

7.5 The right to data portability

You have the right to request access to personal data in a structured, generally used and machine-readable format regarding such data that you have provided to Sweetspot, if the data is processed with your consent or on the basis of an agreement.

7.6 The right to withdraw consent

If you have provided Sweetspot consent, you may withdraw it. When you withdraw your consent the processing that the consent referred to will cease to occur and the personal data collected on the basis of your consent will be deleted, if the personal data is not needed for another purpose for which Sweetspot has the right to process your personal data.

7.7 Exercising your rights

If you want to exercise your rights as stated above you are welcome to contact us, see clause 9 below. A request will be handled swiftly, and you will be informed of the reasons for our decision, if your request is not granted in full.

8. Competent authorities

If you are displeased with Sweetspot's processing of personal data or a decision regarding a request in accordance with clause 7.7 you always have the right to contact the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) to file a complaint.

9. Contact information

9.1 You are welcome to contact us by email at hello@sweetspot.io or the address below concerning any questions about our processing of personal data.

9.2 The controller is Sweetspot AB, organisation number 559095-3583, c/o PE Accounting, Box 90255, 120 24 Stockholm, https://sweetspot.io/