GolfAI

Draft — pending legal review. This document has not yet been reviewed by a lawyer and is not final. 草稿，待律师审阅。

GolfAI / Legal

Privacy Policy

Version 2026-10-01 — draft  ·  Effective date: {{Effective date}}

This policy explains what GolfAI collects when you use the GolfAI practice app and this website, where that information is stored, who else processes it and in which countries, and the choices you have. It is written against the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).

The short version: your account and saved practice are stored in Sydney, Australia. The optional AI features send your recordings, camera frames, voice and body keypoints to computers in Australia and mainland China, and to OpenAI and Google in the United States. Those features only run if you separately agree to that, and you can use the app to store, view, compare and label practice without them.

1. Who we are

GolfAI is operated by {{Company legal name}} (ABN {{ABN}}), {{Registered address}}. In this policy “GolfAI”, “we”, “us” and “our” mean that company.

GolfAI is a practice app for indoor golf. It also has an on-course mode, for keeping a scorecard and measuring shot distances. {{Lawyer to review: added for release 2.1}} Golfers record photos and short videos of their practice; the app stores them, can add AI-assisted posture observations and coaching feedback, and lets coaches and venue staff with access review and label a student’s practice.

Our privacy contact is {{Privacy contact name}}, {{Privacy contact email}}. {{Lawyer to confirm whether the Privacy Act applies to the company or whether it should opt in}}

2. Where GolfAI is offered

The owner has not yet decided the market scope. Keep one of the two options below and delete the other.

Option A — Australia only (delete if not chosen)

GolfAI is offered to golfers, coaches and indoor venues in Australia. It is not offered to people located in mainland China or elsewhere. This policy is written for Australian privacy law. Some of our computing is located outside Australia; section 7 explains this.

Option B — Australia and mainland China (delete if not chosen)

GolfAI is offered to golfers, coaches and indoor venues in Australia and in mainland China. Sections 1 to 17 apply to everyone. The following additional terms apply if you are located in mainland China. They are a draft for the reviewing lawyer.

Personal information handler

For users in mainland China, the personal information handler under the Personal Information Protection Law of the People’s Republic of China (PIPL) is {{China personal information handler entity}}. {{Lawyer to confirm whether a representative or dedicated entity in mainland China must be appointed and reported under PIPL Article 53}}

Legal basis

We handle your personal information on the basis of your consent, and where it is necessary to provide the service you asked for. You can withdraw consent at any time (section 8). Withdrawing does not affect handling that took place before you withdrew.

Sensitive personal information

Recordings of your body and voice, body keypoints and posture measurements, and the personal information of anyone under 14 may be sensitive personal information under PIPL. We ask for your separate consent before handling it, and explain why it is needed (to store and review your practice and, if you choose, to run the AI features) and the effect on you. {{Lawyer to confirm which data categories are sensitive personal information and the wording of the separate consent}}

Transfers out of mainland China

Your account and saved practice are stored in Sydney, Australia, and the AI coach uses OpenAI and Google in the United States, so your information leaves mainland China. We ask for your separate consent to that transfer and tell you the recipient’s name and contact details, the purpose and method of handling, the types of information and how to exercise your rights against the recipient (see the table in section 6). {{Lawyer to confirm the cross-border transfer mechanism: standard contract filing, security assessment or certification}}

Minors under 14

If you are under 14, your parent or guardian must consent before you use GolfAI, and we apply the rules in section 12 to your information. {{Lawyer to confirm dedicated handling rules for under-14s}}

Your rights and contact in mainland China

You may ask to access, copy, correct, delete or transfer your personal information, restrict or refuse its handling, withdraw consent, and ask us to explain these rules. Contact {{China contact name}} at {{China contact email}}. You may also complain to the relevant authority in mainland China.

3. What we collect

Account details

Practice media

Your profile

Ask GolfAI Coach and practice plans

Rounds, scores and shot distances

What the analysis produces

What coaches and you add

Consent records

Technical records

On your device

Enquiries

Recordings show your body and movement, and anything else in frame. We do not ask you for health information, and you should not include it in coach conversations. If your recordings capture other people, you are responsible for having their agreement (see the Terms of Use).

4. How we collect it

You can decline to give us information. The current app asks for a username, a password, your age and agreement to the Terms of Use and this policy when you register. An account created before these questions were added, or with an older version of the app, is asked for them the next time the app is opened; until it answers, it can store and view practice but the AI features stay off. The AI features do not run without the AI processing agreement.

5. Why we use it

We do not use your practice data for model improvement unless you opt in.

6. Who processes your information, and where

The first two rows apply to everyone with an account. The AI rows apply only when you use an AI feature, which requires the separate AI processing agreement. The last rows apply only to the enquiry form.

WhoCountryWhat it receivesWhen
Amazon Web Services (our main server, the “gateway”)Sydney, AustraliaStores accounts, practice media (photos, GIFs, videos including their audio), analyses, coach labels, highlights, AI feedback, consent records and the audit log.Always, for every account.
{{Deployment partner legal name}} (deployment partner){{Deployment partner country}}Operates the AWS account for us and has administrator access to it, so it is technically able to access everything stored on the Sydney server.Ongoing, as part of running the service.
GolfAI primary computing nodeMelbourne, Australia (a computer we operate)The recording, camera frames, voice or body keypoints the AI feature needs. For a coach review of a video, the whole video file.When you use an AI feature. This is the first choice for AI work.
Alibaba Cloud (backup computing node)Mainland China, {{Alibaba Cloud region}}The same material as the primary node, when it handles the request. Those requests reach it through Alibaba Cloud’s ESA edge network, which decrypts and re-encrypts the connection and so can see the content of the request in transit. It also stores a copy of the record of every AI coach request (the frames, voice and text sent, and the reply), whichever node handled it.When an AI request is handled by the backup node instead of the primary node; and, for the stored record, each time you use the AI coach.
AutoDL (rented GPU server)Mainland ChinaRecordings or camera frames sent for pose inference.When pose analysis is run on this server.
OpenAI ({{OpenAI contracting entity}})United StatesFor the AI coach: images or frames, voice and text. For a coach review of a video, our computing node sends at most 4 frames from it, not the whole file.When you use the AI coach (review, chat, quick tips, voice teaching, live voice coach) and the request is handled by OpenAI.
Google, Gemini ({{Google contracting entity}})United StatesThe same kinds of material as OpenAI: images or frames (at most 4 from a video), voice and text.When you use the AI coach and the request is handled by Google.
Alibaba Cloud (enquiry storage)Mainland China, {{Alibaba Cloud region}}Partnership enquiries: name, email, organisation, interest and message, and a keyed hash of the sender’s IP address.Only when someone submits the enquiry form on this website.
Lark mail{{Lark mail data region}}The contents of a partnership enquiry, as an email to the GolfAI team.Only when someone submits the enquiry form.

The Sydney server also stores your profile, your “Ask GolfAI Coach” conversations and practice plans, your rounds and scores, your shot distances and the numbers entered from a simulator. {{Lawyer to review: added for release 2.1}}

When you use “Ask GolfAI Coach”, your question goes to the same AI recipients as the other AI coach features, together with what it needs from your account to answer: your profile and your practice history. {{Lawyer to review: added for release 2.1}} It runs only if you have given the AI processing agreement. {{Lawyer to review: added for release 2.1}}

If you switch on voice commands, your browser’s or phone’s speech recognition may send your voice to the browser or phone maker (for example Google or Apple), which handles it under its own terms. {{Lawyer to review: added for release 2.1}} We do not choose that provider and do not receive the audio. {{Lawyer to review: added for release 2.1}}

Every administrator account on the service can see, label and delete any student’s practice, including recordings, analyses, feedback, labels and highlights. Coach accounts have the same access to every student’s practice, unless the service is set to limit each coach to the students an administrator has assigned to them; a coach then sees, labels and deletes only the practice of those students. {{Owner to confirm the coach access setting: every student, or only the students assigned to each coach}} Administrators can also create, disable and reset accounts.

We may also disclose information where the law requires or authorises it.

7. Sending information outside Australia

Storing, viewing, comparing and labelling your practice, and saving highlights, happens on the Sydney server. Using those features does not send your practice to the AI recipients listed above.

The AI features are different. When you use one, the material it needs leaves the Sydney server. It goes first to our computing node in Melbourne where that node is available, and otherwise to the backup node in mainland China; pose inference can run on a rented GPU server in mainland China; and the AI coach sends images or frames, voice and text to OpenAI or Google in the United States. A record of each AI coach request is also copied to, and stored on, our server in mainland China, whichever node handled it. The table in section 6 lists each recipient.

You should know the following before you agree:

For these reasons the AI features are optional and only run if you have given the separate AI processing agreement. If you do not agree, or you withdraw, the app refuses AI requests for your account and for your recordings, and everything else keeps working.

{{Lawyer to confirm the APP 8 position: reliance on informed consent under APP 8.2(b) or accountability under APP 8.1 with contractual protections}}

8. Your three privacy choices

We ask for three separate agreements and record each one with the policy version, the time and a keyed hash of your IP address.

1. Service (required)
You agree to the Terms of Use and this Privacy Policy. The current app does not create an account without it; an account created earlier is asked for it the next time the app is opened.
2. AI processing (required only for AI features)
You agree that the AI features may send your recordings, camera frames, voice and body keypoints to the recipients in section 6, including those in mainland China and the United States. Without it you can still store, view, compare and label practice and use highlights.
3. Model improvement (optional, off by default)
You agree that we may use your practice data to improve and train our models (section 13).

Changing or withdrawing a choice. In the app, open Your account, then Privacy, then Privacy choices. You can switch AI processing or model improvement off or on at any time. A change applies from then on; it does not undo processing that has already happened. To withdraw the service agreement, ask us to close your account (section 11).

When someone else, such as a coach, asks for AI analysis of one of your recordings, the app checks your AI processing choice, not theirs.

9. How long we keep it

10. How we protect it

No system is completely secure. Section 6 sets out who else can technically access your information, including our deployment partner and, for AI requests to the backup node, Alibaba Cloud’s edge network. If a data breach is likely to cause serious harm, we will tell you and the Office of the Australian Information Commissioner as the law requires.

11. Your rights

Access
You can see your practice, analyses, feedback and privacy choices in the app. You can ask us for a copy of the personal information we hold about you.
Correction
You can ask us to correct information that is inaccurate, out of date or incomplete.
Deletion
You can delete individual recordings in the app. You can ask for the archived content of your AI coach conversations to be erased in Your account, then Privacy (section 9 explains what that covers). Deleting a whole account and exporting your data are being added to the app: {{Confirm in-app path for account deletion and data export}}. Until then, ask our privacy contact. Deleted content can remain in backups for up to about 14 days (section 9). In the current version of the app, a student can delete their own account in Your account, then Privacy, then Delete my account: the app asks for your password and for you to type DELETE, tells you what will be deleted and what stays, signs you out, and cannot be undone. {{Lawyer to review: added for release 2.1}} Coach and administrator accounts are removed by an administrator. {{Lawyer to review: added for release 2.1}}
Export
You can ask for an export of your practice data. {{Confirm in-app path for account deletion and data export}} In the current version of the app, a student can download a copy in Your account, then Privacy, then Download my data. {{Lawyer to review: added for release 2.1}} The file holds your account details and privacy choices, your profile, the list of your recordings, their stored analyses, the swing reviews your coaches sent you, your AI coach conversations, highlights, “Ask GolfAI Coach” conversations and plans, rounds and shot distances, and the simulator numbers entered for your swings. {{Lawyer to review: added for release 2.1}} It does not hold the recordings themselves, which you can open in the app; you can download it a few times a day. {{Lawyer to review: added for release 2.1}}
Withdrawing consent
You can withdraw the AI processing or model improvement agreement at any time in Your account, then Privacy, then Privacy choices (section 8).
Complaints
Please contact us first (section 17) so we can try to resolve it. We will acknowledge your complaint and respond within a reasonable time, normally 30 days. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au.

We may need to confirm your identity before acting on a request. We do not charge for making a request.

12. Children and young people

GolfAI accounts are for people aged {{Minimum age}} and over.

When a student registers they state their age. If they are under 18, the registration form requires a parent or guardian to agree, and we store the guardian’s name and contact (an email address or phone number) with the record of that agreement. An account created before this rule, or with an older version of the app, is asked for the age and the guardian’s agreement the next time the app is opened, and the AI features stay off until then. The AI features run for a student under 18 only where both the AI processing agreement and the guardian’s agreement are in place.

A parent or guardian can ask us for access to, or deletion of, their child’s information, and can change the privacy choices with the child in the app. We may need to confirm the guardian’s identity and relationship first. {{Lawyer to confirm how guardian consent is verified}}

13. Improving our models

We will use practice data to improve and train models only for students who have switched on the optional model improvement choice. It is off by default, and declining it does not limit any feature. {{Owner to confirm whether any student practice data is used for model improvement today, and the mechanism that limits it to students who opted in}}

If you switch it on, we may use your practice media, keypoints, analyses, coach labels and AI feedback to evaluate, improve and train the models GolfAI uses. {{Where model improvement work is carried out and who can access the data}}

You can switch it off at any time in Your account, then Privacy, then Privacy choices. From then on, your practice data must not be selected for model improvement. Switching off does not remove what a model has already learned from data used while the choice was on. {{Confirm whether copies already taken for model improvement are deleted on withdrawal}}

14. This website

This website (paigolf.com, outside the app) uses no cookies, trackers, analytics or external fonts. Its fonts, images and film are served from our own server. Like any web server, ours receives your IP address and browser details when you load a page. The only personal information the website asks for is in the enquiry form.

15. The partnership enquiry form

When you submit the enquiry form on the homepage, your name, email address, organisation, interest and message pass through our server in Sydney and are stored on our server at Alibaba Cloud in mainland China. They are then emailed to the GolfAI team through Lark mail ({{Lark mail data region}}) so we can respond.

We do not store your raw IP address with the enquiry; we store a keyed hash of it to limit abuse of the form. Sending an enquiry does not subscribe you to marketing emails.

We keep enquiries for {{Retention period for enquiries}}. No retention limit is applied yet. You can ask us to delete your enquiry at any time.

16. Changes to this policy

Each version of this policy has a version number; this is version 2026-10-01. When we publish a new version, signed-in students are asked to review it the next time they open the app. If we materially change how AI processing works, such as adding a recipient or a country, the AI features stop for your account until you agree again. Your consent records keep the version you agreed to.

17. Contact us

{{Company legal name}}
{{Registered address}}
Privacy contact: {{Privacy contact name}}, {{Privacy contact email}}

See also the Terms of Use, or return to the GolfAI homepage.