Privacy & Data Policy
Effective Date: January 1, 2025
Last Updated: January 1, 2025
1. Purpose of This Policy
This Privacy & Data Policy explains how Skratchr Ltd ("Skratchr", "we", "our", "us") collects, uses, stores, and protects your personal data when you use our mobile app, website, and related services.
We comply with:
- UK GDPR (2021)
- EU GDPR (2018) (where applicable)
- UK Data Protection Act (2018)
- PECR / ePrivacy Regulations
2. Data We Collect
| Category | Examples | Purpose |
|---|---|---|
| Account Data | Name, email, username, profile photo, password | To create and manage your account |
| Golf Data | Scores, course names, badges, equipment, handicap | To track and display your performance |
| Partner Data | Verified handicap status via WHS/MyGolf integrations | To validate authenticity of records |
| Device & Usage Data | Device ID, IP address, app logs, crash reports | To maintain security and improve performance |
| Location Data (optional) | GPS location (when enabled) | To show nearby courses, events, and partners |
| Marketing & Communication Data | Preferences, in-app messages, emails | To send service updates and optional offers |
We do not collect special category data (e.g. health, ethnicity, religion).
3. How We Use Your Data
We process data to:
- Provide app functionality and personalise user experience;
- Enable golf round tracking, badges, and leaderboard features;
- Verify handicap data through authorised systems;
- Send service updates, community news, and feature information;
- Improve performance and detect misuse;
- Comply with legal obligations.
4. Legal Basis for Processing
Under UK GDPR, our lawful bases include:
- Consent – for optional features such as marketing or location tracking.
- Contract – to deliver the app's core functionality.
- Legitimate Interests – to improve and secure the platform.
- Legal Obligation – where required by regulators or law enforcement.
5. Data Sharing and Third Parties
We may share data with trusted partners only where necessary:
| Recipient | Purpose | Location |
|---|---|---|
| Cloud Hosting (AWS, Azure, etc.) | Secure storage and operation | UK/EU or approved SCC regions |
| Analytics Providers (e.g. Google Analytics, Mixpanel) | Usage analytics and performance | EU/US (with SCCs) |
| Golf Data Integrations (e.g. WHS, My England Golf) | Handicap verification | UK/EU |
| Marketing Platforms (e.g. Mailchimp, Meta Ads) | Communication and user engagement | UK/EU/US (SCCs applied) |
| Payment Processors (if applicable) | Paid services, events | UK/EU |
We do not sell, rent, or trade your data.
6. International Transfers
If data is transferred outside the UK/EEA, Skratchr ensures adequate protection using:
- UK/EU Adequacy Decisions, or
- Standard Contractual Clauses (SCCs) approved by the ICO and European Commission.
7. Data Retention
We keep data only as long as necessary for the purposes collected:
- Account data – retained while your account is active.
- Deleted accounts – permanently erased within 30 days.
- Backup data – securely deleted within 90 days.
- Legal or compliance records – retained for up to 6 years where required.
8. Your Rights
Under GDPR, you have the following rights:
- Access – request a copy of your data.
- Correction – amend inaccurate data.
- Deletion – request deletion ("right to be forgotten").
- Restriction – limit data processing.
- Portability – request data transfer in a readable format.
- Objection – object to processing or marketing.
- Withdraw Consent – at any time for optional features.
To exercise your rights, email: privacy@skratchr.com
9. Cookies and Tracking
Skratchr uses cookies or SDKs to:
- Remember login sessions;
- Measure app performance and engagement;
- Provide personalised experiences.
You can control or delete cookies through your device or browser settings.
10. Data Security
We use industry-standard security measures, including:
- Encrypted connections (HTTPS/TLS);
- Secure password hashing and token-based authentication;
- Access controls and audit logging;
- Regular security testing and monitoring.
Despite best efforts, no system is completely secure.
11. Children's Data
Skratchr is not intended for users under 16 years old.
If we learn we have collected data from a child under 16 without consent, we will delete it immediately.
12. Changes to This Policy
We may update this Policy from time to time.
Significant updates will be communicated through the app or by email.
13. Contact and Complaints
For questions or requests regarding your data:
?? connect@skratchr.com
If you are unsatisfied with our response, you can contact:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
?? 0303 123 1113
14. Version Control
Policy Version: 1.0
Effective From: January 1, 2025