Privacy Policy

SwingLens.golf Last updated: 8 March 2026

1. Who We Are

SwingLens.golf (“we”, “us”, “our”) is operated by Dead Level Ltd. This policy explains how we collect, use, and protect your personal data when you use the SwingLens.golf application and website.

Contact: [email protected]

2. What Data We Collect

Account Information

• Name, email address, and password when you create an account
• Billing information (processed securely by our payment provider, Polar — we do not store your card details)

Swing Data

• Video recordings you upload for analysis
• AI-generated swing analysis data, ratings, and coaching feedback
• Progress tracking data and session history

Usage Data

• Device type, operating system, and browser information
• App usage patterns and feature interactions
• Crash reports and performance data

Cookies and Tracking

We use cookies and similar technologies on our website. You can manage your preferences at any time using the cookie preferences button on our site.

• Necessary cookies — Essential for the website to function (e.g., storing your cookie consent preferences). These cannot be disabled.
• Analytics cookies — Help us understand how visitors use our site so we can improve it. We use Umami Analytics (self-hosted, privacy-focused) for basic site analytics. When you consent to analytics cookies, Google Analytics may also be used via Google Tag Manager.
• Marketing cookies — Used by our advertising partners (Google Ads, TikTok) to build a profile of your interests and show you relevant adverts on other sites. These are only set when you consent to targeting and advertising cookies.

Cookie Table

3. How We Use Your Data

We use your data to:

• Provide swing analysis and personalised coaching feedback
• Track your progress over time and adapt drills to your development
• Process payments and manage your subscription
• Send important service communications (e.g. account changes, billing)
• Improve our AI analysis and overall service quality
• Respond to your support requests
• Measure advertising effectiveness and optimise our marketing campaigns (when you consent to marketing cookies)

We will never sell your personal data to third parties.

4. AI Processing

Your swing videos are processed using AI to generate coaching feedback. This processing is essential to the service we provide. Video frames and extracted data are sent to our AI providers for analysis. We do not use your personal swing data to train AI models without your explicit consent.

5. Legal Basis for Processing (UK/EU)

We process your data under the following legal bases:

• Contract: To provide the service you have subscribed to
• Legitimate interest: To improve our service and prevent fraud
• Consent: For optional marketing communications, analytics cookies, and advertising cookies

6. Data Sharing

We share data only with:

• Polar (payment processing — as Merchant of Record, Polar is the seller and processes transactions under their own privacy policy)
• Cloud hosting providers for secure data storage
• AI service providers for swing analysis processing
• Umami Analytics (self-hosted) for privacy-focused, anonymised website analytics
• Google (via Google Tag Manager) — When you consent to analytics and/or marketing cookies, data may be shared with Google for analytics, advertising conversion tracking, and enhanced conversions. Enhanced conversions may involve sending hashed contact information (such as email address) to Google for more accurate conversion attribution.
• TikTok (via Google Tag Manager) — When you consent to marketing cookies, data may be shared with TikTok for conversion tracking and audience building.

We do not share your swing videos or personal coaching data with other users unless you explicitly choose to share them.

Google Tag Manager

We use Google Tag Manager (GTM) as a tag management system to deploy and manage tracking scripts on our website. GTM itself does not collect personal data, but it enables other tags (such as Google Ads and TikTok) to function according to your consent preferences.

Enhanced Conversions

When you consent to marketing cookies, we may use Google Ads enhanced conversions. This means hashed (anonymised) contact data you provide (such as your email address when signing up) may be sent to Google to improve the accuracy of conversion measurement. This data is hashed before transmission and cannot be used to personally identify you.

7. Data Retention

• Account data: Retained while your account is active, deleted within 90 days of account closure
• Swing videos: Retained while your account is active; you can delete individual videos at any time
• Analysis data: Retained while your account is active for progress tracking
• Billing records: Retained for 7 years as required by law
• Cookie consent preferences: Retained for 1 year, then you will be asked to confirm your preferences again

8. Your Rights

Under UK GDPR and EU GDPR, you have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data (“right to be forgotten”)
• Export your data in a portable format
• Restrict or object to certain processing
• Withdraw consent at any time (including cookie consent via the cookie preferences button on our website)

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

9. Data Security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit and at rest, access controls, and regular security reviews.

10. International Transfers

Your data may be processed outside the UK/EEA by our service providers (including Google and TikTok, when you consent to the relevant cookies). Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses.

11. Children

SwingLens.golf is not directed at children under 16. We do not knowingly collect data from children under 16. If you believe we have collected such data, please contact us immediately.

12. Changes to This Policy

We may update this policy from time to time. We will notify you of significant changes via email or in-app notification. Continued use of the service after changes constitutes acceptance.

13. Contact and Complaints

For any privacy-related questions or concerns, contact us at [email protected].

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk if you are unhappy with how we handle your data.