Privacy policy

AI GOLF COACH PTY LTD (ACN 698 412 467, ABN 57 698 412 467) is an Australian proprietary company registered in New South Wales. It is building AI Golf Coach, an application that analyses a golf swing from video recorded on an ordinary phone. In this policy "we", "us" and "our" mean that company.

What this policy covers

• This website at aigolfcoach.im.
• The AI Golf Coach application, on every platform it is published to.
• Email sent to our published address.

What it does not cover

• Apple and Google, who run the stores, handle payment and collect their own information under their own policies.
• Your device manufacturer and your mobile carrier.
• Any website reached by following a link from ours.

Controller, not processor

Australian privacy law does not use the controller and processor split that European law does, but the distinction is still useful for saying who decides what. For everything described here we are the entity that decides why and how personal information is handled. We do not process personal information on behalf of another organisation, we have no business customers, and nobody else instructs us on what to do with a recording.

Most privacy policies for a phone application are long because of advertising. This one is long because of video.

A swing recording is a moving image of a named person's body, filmed in a place they go regularly, usually by somebody who knows them. It can show a face, a house, a car, a club logo on a shirt, other people walking past, and the inside of a garage. Nothing else this company could plausibly hold comes close to it, which is why the handling of it gets six sections rather than a sentence.

The rules the rest of this policy implements

1. Analysis happens on your device unless you decide otherwise for a specific recording.
2. What we would rather hold is the derived numbers, not the pixels.
3. Uploading is never automatic, never a background process, and never the price of using the application.
4. Faces are blurred on the device before an upload is offered.
5. Training a model on your recording requires a separate, specific and revocable consent.
6. No biometric identification and no health inference is performed at any point.

Is a swing video sensitive information under the Act

Section 6 of the Privacy Act defines sensitive information to include health information and biometric information used for automated biometric verification or identification, and biometric templates. Our position, stated so you can disagree with it, is that an ordinary swing recording analysed for joint angles is not sensitive information within that definition, because we build no biometric template, run no identification, and draw no health conclusion.

We also think that answer is too convenient to rely on. A recording of your body is treated throughout this policy as though the higher standard applied to it: consent based, minimised, short retention, and never used for a new purpose without asking. If the Commissioner or a court ever took the wider view, our practice would not have to change.

What is actually inside a recording

The point of that table is the last two rows. A pose sequence is a few kilobytes of numbers that answers every question the application asks, and it cannot be turned back into a picture of you. Wherever the design allows it, the numbers are what survives and the video is what goes.

"On device" is a phrase that has been stretched until it means very little, so here is exactly what it will mean here.

What runs locally

• Decoding the video into frames.
• The pose model that places landmarks on each frame.
• The depth lift that turns those landmarks into estimated joint angles.
• Face detection and the blur applied on top of it.
• Every comparison between one of your recordings and another of your recordings.
• The rendering of the overlay you see on the screen.

In that mode no frame of your video is transmitted anywhere, and the application works with the device offline. That is the intended default and the mode the product is designed around.

Where the honesty is required

1. An older or lower powered device. A model small enough to run everywhere is worse than one that is not. Where a device cannot run the full model, the application will say so and offer the choice between a reduced local analysis and an upload. It will not silently upload because the local path was slow.
2. A feature that genuinely needs a server. Sharing a recording with a coach, or asking a person to look at it, cannot happen on your phone alone. Those features are opt in per recording and are described below.
3. Crash diagnostics. A crash report is generated by the operating system, not by us. It contains memory state, and in principle a fragment of a decoded frame can sit in memory at the moment of a crash. Crash reporting is therefore optional and off until you switch it on, and we ask for it only when you are reporting a fault.

What is stored on your phone

None of that is personal information in our hands, because none of it reaches us. It is listed anyway, because "we do not collect it" is a weaker statement when nobody has told you what exists.

Some things cannot be done on a phone. When one of them is what you have asked for, a recording has to leave the device. This section is the complete account of when that happens.

The four occasions, and no others

What never happens

• No background upload, no overnight sync, no "cloud backup" of your recordings switched on by default. There is no such feature.
• No upload triggered by a network becoming available, by charging, or by anything other than you pressing a control that says what it does.
• No upload of a recording you have not looked at.
• No retention of an uploaded recording beyond the period shown on the screen where you agreed to send it.

The upload screen

Where consent is asked for it is asked for properly. The screen names what will be sent, where it will be processed, how long it will be kept, and what happens if you say no, before the button is reachable. Declining costs you that one feature for that one recording and nothing else. There is no dark pattern where the decline control is grey text and the accept control is a large green button, and if you ever see one, that is a defect worth reporting.

In transit and at rest

Uploads travel over TLS. A stored recording is encrypted at rest by the underlying platform and is addressed by a random identifier rather than by anything about you. Access to the storage is limited to the small number of people who can reach production systems at all, is logged, and is used for answering your request rather than for looking at recordings.

Withdrawing consent

Consent given for one recording can be withdrawn for that recording at any time, in the application or by email, and withdrawal removes the uploaded copy within seven days. Withdrawal does not undo an analysis already returned to you, because that result is on your phone and is yours.

This is the section most likely to be quietly reversed by a company under pressure, so it is written in the strongest terms available to us.

What a training consent would look like

• A separate control in settings, off by default, that is not touched by accepting the terms, creating an account, or agreeing to an upload.
• Plain wording stating what would be retained, for how long, and what it would be used for.
• Reversible at any time from the same screen, with the effect described in the next paragraph.
• No feature, no discount and no unlock made conditional on switching it on. If contributing were ever rewarded, the reward would be described here first, and a payment for data is a purchase rather than a consent.

What withdrawal does, honestly

Withdrawing training consent stops any further use of your material immediately, and your recordings and pose sequences are removed from every training set within 30 days. What it cannot do is reach into a model that has already been trained and extract your contribution. Machine learning does not work that way, and any company telling you it can un-train a shipped model is describing something it is not doing.

That limitation is the reason the consent is separate and off by default. A decision that cannot be fully undone should not be one you made by tapping past a wall of text.

What we do use to improve the product

• Recordings we make ourselves, of people who have agreed in writing to exactly that use.
• Publicly licensed pose and motion datasets, used under their own terms.
• Aggregate statistics that describe the population and not a person, for example the distribution of frame rates people record at, or how often the camera is far enough off line to make an estimate unreliable. Those figures carry no identifier and cannot be traced back.
• Your written bug reports, which are words rather than video, and which we treat as feedback about the software.

No third party model providers

Your recordings are not sent to an external machine learning provider for analysis, and no third party is given access to them for its own model development. If that ever changed it would be a material change to this policy, notified under the changes section before it took effect, and it would be opt in.

An application that watches a body is close to two things it must not do quietly. Both are ruled out.

No biometric identification or verification

The application does not recognise faces, does not create or store a face template, a gait template or any other biometric template, and does not attempt to work out whether two recordings show the same person. Face detection exists in the product for exactly one reason, which is to find a face in order to blur it, and the detection result is discarded once the blur is applied.

This matters legally as well as ethically. Biometric templates and biometric information used for automated identification are sensitive information under section 6 of the Privacy Act, which brings a consent requirement under APP 3.3 and tighter handling throughout. We stay out of that category by design rather than by argument.

No health or medical inference

The application does not infer, record or display any conclusion about your health, and specifically does not attempt to detect injury, pain, impairment, disability, range of motion loss, fatigue, age, sex, body composition or fitness.

Health information is also sensitive information under the Act, and an inference about a person's health is health information even when the person never told you anything. A sentence such as "this movement pattern is associated with lower back injury" would be a clinical claim generated by software that has never examined you, and it will not appear.

If you mention pain

Nothing in the application asks about symptoms and there is no field to record them. If you mention pain or injury in an email to us, the reply will say that we are not qualified to advise on it and will suggest a qualified health practitioner. That correspondence is health information, it is handled under the same access, correction and deletion rights as everything else, and it is deleted on request without argument.

No emotion, attention or behavioural inference

The application does not analyse facial expression, does not estimate mood or frustration, does not measure how long you looked at the screen, and does not score your engagement. There is no idle timer, no session length target and no retention mechanic built on any of it.

A practice range is a public place. Somebody filming their own swing will regularly capture a stranger in the background, a playing partner on the next mat, or a child on the putting green. Those people never agreed to anything.

What the application does about it

• Faces detected in a frame are blurred on the device before any upload is offered, including faces that are not yours. The blur is applied to the copy that leaves the phone, so it cannot be undone by us.
• The analysis tracks one subject. Other people in the frame are not analysed, not measured and not given a pose sequence of their own.
• No attempt is made to count, identify, re identify or link the people in the background of a recording.

What we ask of you

Blurring a face is a mitigation, not permission. Before you upload a recording with somebody else in it, the terms of use ask you to have their agreement, and to have a parent's agreement where they are a child. Where the recording is of somebody else's swing rather than your own, that person needs to have agreed to the recording being made and uploaded. We cannot verify any of this, which is precisely why it is stated as your obligation rather than assumed away.

Information about somebody else that reaches us anyway

This is unsolicited personal information under Australian Privacy Principle 4, dealt with in its own section below. In practice a recording containing a third party who should not be in it is deleted rather than analysed, and the deletion is confirmed to whoever raised it.

If you appear in a recording somebody else uploaded

You do not need to be a user of this application to make a request about it. Write to [email protected] with "Someone filmed me" in the subject line. Give us enough to identify the recording and nothing more than that. We will deal with the request on its merits within seven days, and we will not require you to prove a relationship with whoever uploaded it beyond being satisfied the request is genuine. Where we can delete, we delete first and discuss afterwards.

The law that governs this policy is the Privacy Act 1988 (Cth) and, in particular, the thirteen Australian Privacy Principles set out in Schedule 1 to that Act. Throughout this document a reference to "APP 6" or similar means the corresponding Australian Privacy Principle.

Australian Privacy Principle 1, which is why this page exists

APP 1 requires an organisation to manage personal information in an open and transparent way, to take reasonable steps to implement practices and systems that ensure compliance, and to maintain a clearly expressed and up to date privacy policy that is available free of charge and in an appropriate form.

APP 1.4 sets out what that policy has to contain: the kinds of personal information collected and held, how it is collected and held, the purposes of collection, use and disclosure, how an individual may access and correct it, how to complain and how a complaint will be handled, whether information is likely to be disclosed to overseas recipients and to which countries. Each of those is a numbered section of this document rather than a sentence buried in a paragraph, because a policy that technically contains the information but hides it is not "clearly expressed".

Australian Privacy Principle 1, and why this document exists

APP 1 is the reason there is a privacy policy here at all. It requires an entity to manage personal information in an open and transparent way, to take reasonable steps to implement practices, procedures and systems that ensure compliance with the other principles and that allow it to deal with enquiries and complaints, and to keep a clearly expressed and up to date privacy policy. APP 1.4 then sets out what that policy has to cover: the kinds of personal information collected and held, how it is collected and held, the purposes of collection, use and disclosure, how an individual can seek access and correction, how an individual can complain and how the complaint will be handled, and whether the information is likely to be disclosed to overseas recipients and in which countries. Every one of those is answered in a numbered section below rather than left to inference.

The small business threshold, and why it does not get us out of this

Section 6D of the Privacy Act exempts most businesses with an annual turnover of $3 million or less from the Australian Privacy Principles. AI GOLF COACH PTY LTD was registered in 2026 and its turnover is presently below that threshold, so on a narrow reading the Act may not yet bind it.

We are not relying on that. Several of the exceptions in section 6D would in any event pull a business like ours back inside the Act as it grows, including a business that discloses personal information about another individual to anyone else for a benefit, service or advantage. More to the point, the exemption is an accident of turnover, not a statement that the information stops mattering. This policy is written as though the Australian Privacy Principles apply in full, and we will handle requests and complaints on that basis.

Other Australian law that applies

• Spam Act 2003 (Cth), which governs commercial electronic messages, requires consent, sender identification and a working unsubscribe facility.
• Do Not Call Register Act 2006 (Cth), which governs unsolicited telemarketing. We do not telemarket.
• Australian Consumer Law, Schedule 2 to the Competition and Consumer Act 2010 (Cth), which gives you consumer guarantees that cannot be excluded by anything we write.
• Part IIIC of the Privacy Act, the Notifiable Data Breaches scheme, dealt with at its own section below.
• Privacy and Other Legislation Amendment Act 2024 (Cth), which introduced a statutory tort for serious invasions of privacy, provided for a Children's Online Privacy Code, and added transparency obligations for certain automated decisions. Those last two are dealt with in their own sections.

Why this policy does not set out a lawful basis for each purpose

If you have read a European or United Kingdom privacy policy you will be expecting a table of lawful bases, with consent, contract and legitimate interests set against each purpose. Australian law does not work that way, and inventing that table here would be dressing one regime in another's clothes.

The Privacy Act asks a different set of questions, and this policy answers them category by category instead: whether a collection was reasonably necessary for one of our functions or activities under APP 3, whether it was by lawful and fair means, whether a use falls within the primary purpose or a related secondary purpose you would reasonably expect under APP 6, and whether anything that counts as sensitive information was collected with your consent under APP 3.3.

Where the General Data Protection Regulation or the UK GDPR does apply to processing of yours, the lawful bases we would rely on are performance of a contract for the analysis you asked for, consent for everything optional including uploads and model training, and legitimate interests for security, abuse prevention and fault diagnosis. You can object to the last of those and we will stop unless we can show compelling grounds that override your interests.

These tables are the whole list. A category that does not appear here is not collected.

What the application will collect

What this website collects

No analytics, no advertising, no pixel and no session recording runs on this website, which is why there is no consent banner on it.

From correspondence

Your email address, whatever you put in the message, any attachment, and the metadata your mail provider added. Support threads are kept 24 months and complaint threads 7 years.

Australian Privacy Principle 5 requires that we tell you certain things at or before the time we collect personal information about you, or as soon as practicable afterwards.

We meet that obligation in three places, and deliberately not only here:

• In the store listing. Apple's privacy nutrition labels and Google Play's Data Safety section state what an application collects before you install it. Those declarations are kept consistent with this policy, and if they ever diverge, treat the divergence as a bug and tell us.
• At the point of collection in the app. A permission prompt explains what the permission is for before the operating system dialog appears, not after.
• Here. This document is linked from every screen of the website and from the settings screen of the application.

APP 5 also requires us to tell you the consequences of not providing information. Those consequences are set out against each item in the collection tables, and for the app permissions in the permissions table.

Australian Privacy Principle 2 gives you the option of dealing with us anonymously or under a pseudonym, unless that is impracticable or we are required by law to deal with an identified individual.

The application does not need to know who you are

Analysing a swing on your own device requires no account, no email address, no name and no sign in. That is the default path through the product and it will stay the default. Where the application needs to refer to a record in a support conversation it uses a random support identifier generated on the device, which you can reset whenever you like.

An account exists only to carry purchases and shared recordings between devices. Choosing not to have one costs you those two things and nothing else, and there is no reduced or nagging version of the product for people who decline.

Writing to us

You may write from a pseudonymous email address and we will answer. We do not require a real name in correspondence and we do not ask what yours is.

Where the option genuinely narrows

A request to access or correct personal information is the one place anonymity fails, because we have to be satisfied you are the person the information relates to before handing anything over. That is dealt with under access and correction below, and the verification we do is the least we can manage rather than the most we could ask for.

Australian Privacy Principle 4 deals with personal information we receive without having asked for it.

This happens most often when somebody sends us a bug report and includes a full screen recording, a diagnostic export, or a message thread containing other people's details. When we receive personal information we did not solicit, we decide within a reasonable period whether we could have collected it under APP 3. If we could not, and the information is not contained in a Commonwealth record, we destroy it or de-identify it as soon as practicable, provided it is lawful and reasonable to do so.

Practically: unsolicited attachments containing third party personal information are deleted from the inbox and from any backup rotation on its ordinary cycle, and the substance of the bug is recorded without them.

Australian Privacy Principle 6 governs what we may do with personal information once we hold it. The rule is that information collected for one purpose may be used for that purpose, and for a secondary purpose only where you would reasonably expect it and the secondary purpose is related to the first, or where you have consented, or where a specific exception in the Act applies.

What we use it for

• Producing the analysis you asked for, and showing it to you.
• Comparing your own recordings with each other, on your device.
• Diagnosing crashes and defects, and checking that a fix worked.
• Delivering a recording to a coach you nominated.
• Answering your correspondence.
• Taking payment through a store, and meeting our tax and accounting obligations.
• Complying with a legal obligation.

What we do not do with it

• We do not sell personal information. Not to a data broker, not to an equipment manufacturer, not to an insurer, and not as part of an audience product.
• We do not license, publish or share a corpus of swing recordings, and we are not building one as a second business.
• We do not train models on your material without the separate consent described above.
• We do not use your recordings or your correspondence to target anything at you, because nothing is targeted at you.
• We do not profile you across other companies' products, and there is no identity graph anywhere in this system.
• We do not use a recording to work out where you live, which club you belong to, or who you play with.

Disclosure to law enforcement and to courts

We may disclose personal information where the Act permits it: where required or authorised by or under an Australian law or an order of a court or tribunal, where a permitted general situation under section 16A applies, including a serious threat to life, health or safety, or to an enforcement body where reasonably necessary for an enforcement related activity.

Where we make such a disclosure to an enforcement body we make a written note of it, as APP 6.5 requires. Where the law allows us to tell you a request was made, we will. A request for a person's swing recordings would be an unusual thing for an enforcement body to want, and it would be scrutinised rather than waved through.

This is the complete list of who receives personal information from us.

Not on this list, and not coming

No data broker. No advertising network. No analytics vendor. No customer data platform, enrichment service or identity graph. No machine learning provider processing your recordings on its own account. No insurer, no equipment manufacturer and no golf club. Adding any recipient means changing this table first and announcing it under the changes section.

A coach is a person, not a processor

Where you share a recording with a coach you have nominated, that person receives it because you told us to send it. What they then do with it is between you and them, and we cannot control it. Revoking the share stops their access through our system within seven days, but it cannot recover a copy they made outside it. Share accordingly.

Business transfer

On a sale of the company or the product, personal information may transfer to the buyer. Where we are lawfully able we will give notice on this website before the transfer completes. The buyer is bound by this policy until it publishes its own, and it cannot reduce your rights for information collected earlier without your consent. A buyer that wanted the recordings in order to train models would need the same separate consent from you that we would need, and we will not treat a change of ownership as a way around that.

Australian Privacy Principle 7 restricts the use of personal information for direct marketing. The Spam Act 2003 (Cth) sits on top of it for anything sent by email, SMS or instant message, and it is a strict regime: consent, accurate sender identification, and a functional unsubscribe facility that stays live for at least 30 days and is actioned within 5 working days.

Our position

We do not run a marketing list. We have never sent a marketing email under this company name. If that changes, it will be opt in, the consent will be recorded with a timestamp and the wording you agreed to, and the first message will say where the address came from.

Writing to our support address does not subscribe you to anything. That is the most common way small companies quietly build a list, and we do not do it.

There is no advertising to complicate this

The application carries no advertising, no sponsored content and no affiliate links, so there is no advertising network to disclose and no advertising identifier to control. If that ever changes it will be described here before a single request is made, and personalised advertising would be off unless you switched it on.

Coaching content is not marketing either

A drill or an explanation shown inside the application because of what your swing did is part of the product you asked for, not a commercial electronic message. We will not use that surface to sell you a lesson, a club, a subscription upgrade or anyone else's product.

Australian Privacy Principle 8 governs disclosure of personal information to a recipient outside Australia. Section 16C of the Act makes us accountable for an overseas recipient's act or practice: if an overseas recipient we disclosed information to does something that would have breached the Australian Privacy Principles, that act is taken to have been done by us, and we are liable for it.

We treat that as the operative rule rather than the exceptions, which is why the list of overseas recipients is short and named rather than described as "our trusted partners".

How we meet APP 8

Before disclosing personal information overseas we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles, principally by contract. The relevant contractual terms are the data processing terms published by each provider, which bind them to process the data only on our instructions, to keep it secure, to assist with individual rights requests, and to notify us of a breach.

We do not rely on the APP 8.2(a) exception for recipients in countries with substantially similar laws, because assessing that for each jurisdiction is a judgement we are not qualified to make and getting it wrong shifts the risk onto you.

Where the data actually goes

The countries in which personal information may be held or accessed are named in the recipients table in this policy. That table is the authoritative list. If a provider changes region we update the table.

How this compares with an international transfer regime you may know

Australia has no adequacy list, no standard contractual clauses, and no equivalent of the United Kingdom's International Data Transfer Agreement. Section 16C does the work those instruments do elsewhere, by making us answerable for what an overseas recipient does rather than by approving the destination in advance. Where an international transfer of your personal information is also governed by European or United Kingdom law, we will meet that law's own transfer requirements in addition to APP 8.

The practical position for the most sensitive category is short. Server side analysis of an uploaded recording is configured to run in an Australian region, so an uploaded recording is not the subject of an international transfer at all. What does cross a border is purchase and crash data held by the stores, and correspondence held by our email provider.

Australian Privacy Principle 9 restricts an organisation from adopting, using or disclosing a government related identifier, which includes a tax file number, Medicare number, driver licence number or passport number.

We do not collect any government related identifier. We have no reason to, our products have no age verification or identity verification step that would need one, and no field in any system we operate is intended to hold one.

If you send us one anyway, for instance by attaching a photograph of a licence to an email, it is treated as unsolicited personal information under the section above and destroyed.

Australian Privacy Principle 10 requires that personal information we collect is accurate, up to date and complete, and that information we use or disclose is also relevant.

Most of what we hold is machine generated and therefore accurate in the narrow sense that it faithfully records what a device reported. The category most likely to go stale is anything you told us yourself, such as an email address in a support thread. We do not periodically re-verify those, because doing so would mean contacting people who have finished dealing with us.

The practical remedy is the correction right under APP 13, described below, which you can use at any time and free of charge.

Australian Privacy Principle 11 requires us to take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, and to destroy or de-identify it when it is no longer needed for any purpose for which it may be used or disclosed.

What "reasonable steps" means for a company this size

• Transport encryption on every connection. The website and every app endpoint are served over HTTPS only.
• Encryption at rest for stored data, provided by the underlying platform.
• Multi-factor authentication on every administrative account that can reach production data or a store console.
• Access on a need to know basis. The number of people who can reach production data is small and is reviewed when anyone joins or leaves.
• Separate credentials for development and production, so a compromised development credential does not reach live data.
• Collecting less. The most reliable security control available to a company this size is not holding the data, which is why the collection tables are short.

What we do not have, stated plainly

We say this because the alternative is a paragraph of confident language that means nothing. No system is perfectly secure, and a company that tells you otherwise is either mistaken or selling something.

Australian Privacy Principle 11.2 requires destruction or de identification once information is no longer needed for any purpose for which it may be used or disclosed, unless a law requires us to keep it.

Destruction means removal from live systems, and expiry from backups on their ordinary rotation, which completes within 35 days. We do not restore a deleted recording from a backup. De identification means removing every identifier and any field from which one could be reconstructed, and for video there is no such thing as de identification, which is why video is deleted rather than de identified.

Never requested, at all

Location of any precision, including coarse location and background location. Contacts. Calendar. SMS and call logs. Phone state. Body sensors, health data and any connection to Apple Health or Google Fit. Bluetooth and nearby devices. Accessibility services. Background activity of any kind.

A build asking for one of these is either a mistake or is not ours, and we would like to hear about it at [email protected].

App Tracking Transparency

On iOS, Apple's tracking prompt exists so an application can ask for the advertising identifier and link your activity across other companies' products. We do not do that, so the prompt is never shown. There is nothing to allow and nothing to deny. The App Store privacy label for this application declares no tracking, and the Google Play Data Safety declaration is kept consistent with this policy. A divergence between a store declaration and this page is a defect, and reporting one is welcome.

Deleting one recording

In the application, open the recording and choose Delete. It is removed from the device immediately. Where a copy is on a server because you uploaded it, that copy is queued for deletion in the same action and is gone within seven days.

Deleting your account, and deleting your data

1. In the application: Settings, then Delete everything. One confirmation. This clears every recording, every pose sequence, every preference and the account if you have one.
2. By email: write to [email protected] with "Delete my data" in the subject line, from the address on the account, or quoting the support identifier if you never made an account.

Both stores require an in application account deletion path and an out of band one. Both exist here, and neither is buried, and neither charges you anything.

If you never made an account

Uninstalling removes everything held on the device, because that is where it all was. If you had uploaded anything, send us the support identifier and we will delete what is keyed to it. If you have lost the identifier, tell us and we will do what we can, though we will say honestly when a record cannot be connected to you rather than deleting somebody else's data on a guess.

What deletion does, row by row

We confirm in writing when a deletion is complete. We do not flag a record as deleted and keep the file, and we do not "delete" a recording by removing its index entry while the object stays in storage.

Australian Privacy Principle 12 gives you the right to ask for access to the personal information we hold about you. Australian Privacy Principle 13 gives you the right to ask us to correct it.

How to ask

Email [email protected] with "Privacy request" in the subject line. Tell us what you want and give us enough to find it. For information tied to a device rather than an account, that means the support identifier shown on the application's settings screen, because without it we cannot connect a record to you.

Verifying who you are

We have to be satisfied you are the person the information is about, or an authorised representative. Where a request relates to an account, we verify through the email address on the account. Where it relates only to a support identifier, possession of that identifier is what we can verify, and we will say so rather than pretend to a higher level of confidence. We will not ask you to send identity documents.

Timing and cost

We respond within 30 days. Access is free. We do not charge for making a request, and we do not charge for correction. If giving access in a particular form imposes a genuine cost, for example producing a bulk export in an unusual format, we will tell you the charge before doing the work and it will not be excessive.

When we can refuse

The Act lists the grounds, and they are narrower than people expect. They include where giving access would have an unreasonable impact on the privacy of others, where the request is frivolous or vexatious, where the information relates to existing or anticipated legal proceedings and would not be discoverable, and where giving access would be unlawful.

If we refuse, in whole or in part, we will give you written reasons, tell you which ground we rely on, and tell you how to complain. Where we can give you part of the information, or give it in another way that meets your need, we will offer that instead of a flat refusal.

Correction

If information is inaccurate, out of date, incomplete, irrelevant or misleading, we will correct it. If we have disclosed the information to someone else and you ask us to notify them of the correction, we will take reasonable steps to do so unless it is impracticable or unlawful.

If we refuse to correct, you may ask us to attach a statement to the record saying that you consider it inaccurate, and we will take reasonable steps to make that statement apparent to anyone who later looks at the record. That right is often overlooked and it is worth knowing about.

Golf is played by children, and a parent filming a child's swing is an obvious use of an application like this one. That makes children a real question here rather than a formality.

Who the product is for

AI Golf Coach is directed at adult club golfers. It is not designed to appeal primarily to children, it contains no child oriented content, and where a store asks for a target audience declaration we declare a general adult audience.

The Australian position on age

The Privacy Act fixes no age at which a person can consent for themselves. The OAIC's guidance is that capacity should be assessed individually where practicable, and that as a general rule a person aged 15 or over is presumed to have capacity unless something suggests otherwise. We apply that presumption.

The Privacy and Other Legislation Amendment Act 2024 provides for a Children's Online Privacy Code to be developed by the Information Commissioner, applying to services likely to be accessed by children. We will comply with that Code as it applies to us once it is registered and in force, and we will update this policy then rather than guess at its terms now.

A child in a recording

• Where an adult records a child's swing, the recording is personal information about the child. It stays on the device under the same defaults as any other recording, and uploading it is the same deliberate per recording decision.
• The terms of use require the agreement of a parent or guardian before a recording of a child is uploaded, and where the child is old enough to understand, the child's agreement too.
• Faces are blurred before upload, which matters most for the child on the putting green who has nothing to do with any of this.
• A recording of a child is never used for model training, regardless of what consent anybody has given, because a parent cannot meaningfully consent on a child's behalf to a use that cannot be undone.

Accounts

We do not knowingly create an account for a person under 15 without the consent of a parent or guardian. There is no social feature, no chat, no public profile, no leaderboard and no way for one user to contact another, so there is no route by which a child could be approached through this product.

If a child's information has reached us

Write to [email protected]. We will delete it without requiring you to prove a legal relationship beyond what is needed to be satisfied the request is genuine, and we will confirm when it is done.

The Privacy and Other Legislation Amendment Act 2024 inserts a requirement that a privacy policy disclose the kinds of personal information used in substantially automated decisions that significantly affect an individual's rights or interests, together with the kinds of such decisions made. That requirement commences on 10 December 2026. Our position is disclosed here in advance of it.

Nothing here meets that threshold

We make no automated decision that significantly affects your rights or interests. Nothing in this product decides whether you get credit, a job, insurance, a service, a benefit or a legal entitlement, and nothing reports on you to anybody who does.

The automated processing that does happen

• Pose estimation and the figures derived from it. This is automated, and it is the product. It produces a description of a movement for you to look at. It makes no decision about you and is not disclosed to anyone else unless you send it.
• The confidence rating attached to each figure. Also automated. Its only effect is to decide whether a number is shown, shown with a warning, or withheld. Withholding a number is a decision about our own output rather than about you.
• Abuse controls on uploads. Rate limits and file checks can refuse an upload. If one wrongly blocks you, write to us and a person will look at it.

A person is always available

Where any automated behaviour of this product affects you and you disagree with it, ask and a person will review it. That commitment does not depend on the 2026 provisions applying to us, and it does not depend on you framing the request in legal language.

Part IIIC of the Privacy Act establishes the Notifiable Data Breaches scheme. It applies to an eligible data breach, meaning unauthorised access to, unauthorised disclosure of, or loss of personal information where a reasonable person would conclude the access or disclosure would be likely to result in serious harm to any of the individuals to whom the information relates, and the risk has not been prevented by remedial action.

The process we follow

1. Contain. Stop the access, revoke the credential, take the affected component offline if that is what it takes.
2. Assess. Where we suspect an eligible data breach may have occurred, we carry out a reasonable and expeditious assessment and complete it within 30 days of becoming aware of the grounds for suspicion, which is the period section 26WH allows.
3. Remediate. If remedial action means serious harm is no longer likely, the breach is not notifiable and we record why.
4. Notify. If it is an eligible data breach, we prepare a statement for the Commissioner and notify the Office of the Australian Information Commissioner (OAIC), GPO Box 5218, Sydney NSW 2001, telephone 1300 363 992, oaic.gov.au as soon as practicable. We then notify affected individuals, or if that is not practicable, publish the statement on this website and take reasonable steps to publicise it.

What a notification will contain

Our identity and contact details, a description of the breach, the kinds of information concerned, and the steps we recommend you take. We will not pad it with reassurance that has not been earned, and we will say what we do not yet know.

If you think a breach has happened

Write to [email protected] with "Security" in the subject line. We would rather chase a false alarm than miss a real one, and we will not treat a good faith report as hostile.

A statutory tort of serious invasion of privacy commenced on 10 June 2025 under Schedule 2 to the Privacy and Other Legislation Amendment Act 2024. It allows an individual to sue for intrusion upon seclusion or misuse of information, where the invasion was intentional or reckless, where a person in the plaintiff's position would have had a reasonable expectation of privacy, and where the invasion is serious.

This is a right you have against anyone, including us, and it exists independently of the complaints process described below. We mention it because most privacy policies do not, and a right you do not know about is not much of a right.

This website sets no cookies of its own, runs no analytics and carries no advertising. A strictly necessary security cookie may be set by our hosting provider to tell automated traffic from human traffic.

There is no consent banner because nothing here needs consent. The reasoning, and the complete list of what may be stored, is in the cookie notice.

Cookies are a website mechanism and the application does not use them. What the application keeps on your device is listed in the on device section above, and none of it reaches us.

Step one: tell us

Email [email protected] with "Privacy complaint" in the subject line. Set out what happened and what you want done. We acknowledge within 5 business days and respond substantively within 30 days. If it will take longer, we will tell you why and give you a date.

Step two: the Commissioner

If you are not satisfied with our response, or we do not respond within 30 days, you can complain to the Office of the Australian Information Commissioner (OAIC), GPO Box 5218, Sydney NSW 2001, telephone 1300 363 992, oaic.gov.au.

The OAIC will normally expect you to have complained to us first and given us 30 days, but it can accept a complaint without that in appropriate cases. There is no fee. You do not need a lawyer and you do not need our agreement.

What we will not do

We will not require you to sign a non-disclosure agreement as a condition of us dealing with a privacy complaint, and we will not treat making a complaint as a breach of our terms of use.

This policy is written to Australian law because that is the law that binds us. If you are outside Australia, some additional rights may apply to you, and we do not want the absence of a mention to be read as a refusal.

European Economic Area and United Kingdom

Where the General Data Protection Regulation or the UK GDPR applies to our processing, you have rights of access, rectification, erasure, restriction, portability and objection, and a right to complain to your national supervisory authority. In the United Kingdom that authority is the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113. In the European Economic Area it is the authority for the country you live in. Where we rely on legitimate interests, you may object and we will stop unless we can demonstrate compelling legitimate grounds that override your interests. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

Send any such request to [email protected] and say which law you are relying on, so we apply the right timetable. We answer GDPR requests within one month.

California

Under the California Consumer Privacy Act as amended, you have rights to know, delete, correct and opt out of the sale or sharing of personal information. We do not sell personal information and we do not share it for cross context behavioural advertising as those terms are defined in that Act. There is no advertising anywhere in the application or on this website, so there is nothing here to opt out of. Global Privacy Control signals sent by your browser to this website are honoured.

Everywhere else

If a right exists where you live and you tell us about it, we will deal with the request on its merits rather than on whether we are technically obliged to.

We may change this policy. When we do, we update the effective date and the version number in the header of this page.

Where a change materially reduces your rights or materially expands what we collect, we will give notice before it takes effect: a notice in the app on next launch, and a note at the top of this page for at least 30 days. We will not make a material change effective retrospectively.

Previous versions are not published as separate pages, but we keep them. If you want to know what this document said on a particular date, ask and we will send you that version.

All privacy matters reach one address.

Email: [email protected]

Entity: AI GOLF COACH PTY LTD, ACN 698 412 467, ABN 57 698 412 467, registered in Australia, New South Wales.

We do not publish a postal address on this website. If you need to serve a document, the company's registered office is recorded against ACN 698 412 467 on the register maintained by the Australian Securities and Investments Commission, which is the address that has legal effect for service.

If you would rather not deal with us at all, you can go straight to the Office of the Australian Information Commissioner (OAIC), GPO Box 5218, Sydney NSW 2001, telephone 1300 363 992, oaic.gov.au.