Privacy Policy

1. Introduction

Welcome to The Nineteenth (“we”, “our”, “us”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (“The Nineteenth” or “the App”).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the App.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

2. Information We Collect

2.1 Personal Information You Provide

When you register for an account or use our App, you may provide us with:

2.2 Information Collected Automatically

When you use the App, we may automatically collect:

• Device Information: Device type, operating system, unique device identifiers
• Usage Data: Features used, screens viewed, time spent in app
• Log Data: Error logs, crash reports, performance data

2.3 Location Information

If you grant permission, we may collect your device’s location to:

• Help you find nearby golf courses
• Pre-fill course search results based on your area

Location data is processed locally on your device and is not stored on our servers or shared with third parties. You can disable location access at any time through your device settings.

2.4 Information from Third Parties

We may receive information about you from:

• Competition Organisers: If you’re added to a competition by an organiser
• Other Players: When they score your round or add you to a group

2.5 Legal Bases for Processing

Where the EU General Data Protection Regulation (GDPR) or UK GDPR applies, we rely on the following lawful bases under Article 6 for processing your personal data:

Where we rely on consent, you may withdraw your consent at any time by adjusting your device settings (for push notifications and location) or by contacting us at support@thenineteenth.golf. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

3. How We Use Your Information

We use the information we collect to:

3.1 Provide Core App Functionality

• Create and manage your account
• Enable you to join and participate in golf competitions
• Calculate scores and handicap adjustments
• Display leaderboards and standings
• Facilitate communication between competition members

3.2 Improve the App

• Analyse usage patterns to improve features
• Fix bugs and technical issues
• Develop new features based on user behaviour

3.3 Communicate with You

• Send competition updates and notifications
• Respond to your inquiries and support requests
• Send important service announcements

3.4 Ensure Safety and Security

• Detect and prevent fraud or abuse
• Enforce our Terms of Service
• Protect the rights and safety of our users

4. How We Share Your Information

4.1 With Other Competition Members

When you join a competition, the following information is visible to other members of that competition:

• Your display name
• Your profile photo (if provided)
• Your golf handicap
• Your scores and standings

Important: Your email address is never shared with other users.

4.2 With Service Providers

We may share your information with third-party service providers who perform services on our behalf:

All service providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

4.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent.

5. Data Storage and Security

5.1 Data Storage

Your data is stored on secure servers provided by Supabase, located in Australia. We implement appropriate technical and organisational measures to protect your personal information.

5.2 Offline Data

The App stores certain data locally on your device to enable offline functionality:

• Competition details you’ve accessed
• Scores you’ve entered (until synced)
• Course information

This local data is stored securely on your device and syncs with our servers when you have an internet connection.

5.3 Security Measures

We employ industry-standard security measures including:

• Encryption of data in transit (TLS/SSL)
• Encryption of data at rest
• Secure authentication protocols
• Regular security assessments
• Access controls and authentication for our systems

5.4 Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. If you delete your account, we will delete or anonymise your personal information within 30 days, except where we are required to retain it for legal purposes.

6. Your Privacy Rights

6.1 Access and Portability

You have the right to:

• Access the personal information we hold about you
• Request a copy of your data in a portable format
• View and edit your profile information within the App

6.2 Correction

You can update or correct your personal information at any time through the App’s settings or by contacting us.

6.3 Deletion

You have the right to delete your account and personal information. You can do this:

• Through the App (Profile > Privacy & Data > Delete Account)
• By contacting us at support@thenineteenth.golf

Note: Deleting your account will remove you from all competitions. Historical scores may be retained in anonymised form for competition records.

6.4 Opt-Out

You can opt out of:

• Push Notifications: Through your device settings
• Email Communications: Via unsubscribe links in emails
• Location Access: Through your device settings

6.5 Australian Privacy Rights

If you are a resident of Australia, you have rights under the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You may:

• Request access to your personal information
• Request correction of inaccurate information
• Make a complaint about a breach of the Australian Privacy Principles

6.6 EU/EEA Privacy Rights

If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (GDPR):

• Right of Access (Article 15): You have the right to obtain confirmation as to whether your personal data is being processed and, if so, to access that data along with information about the processing.
• Right to Rectification (Article 16): You have the right to have inaccurate personal data corrected and incomplete data completed.
• Right to Erasure (Article 17): You have the right to request the deletion of your personal data where it is no longer necessary for the purpose it was collected, or where you withdraw consent.
• Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object (Article 21): You have the right to object to the processing of your personal data where processing is based on legitimate interests, including profiling.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the EU/EEA Member State of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these rights, please contact us at support@thenineteenth.golf. We will respond to your request within 30 days.

6.7 UK Privacy Rights

If you are located in the United Kingdom, you have equivalent rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018:

• Right of Access: Obtain confirmation and access to your personal data and processing information.
• Right to Rectification: Have inaccurate personal data corrected and incomplete data completed.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary or where you withdraw consent.
• Right to Restriction of Processing: Request restriction of processing in certain circumstances.
• Right to Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: Object to processing based on legitimate interests, including profiling.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection.
  Website: https://ico.org.uk
  Helpline: 0303 123 1113

To exercise any of these rights, please contact us at support@thenineteenth.golf. We will respond to your request within 30 days.

6.8 US Privacy Rights

California Residents (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You have the right to know what personal information we collect, use, disclose, and sell or share.
• Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioural advertising. No opt-out is necessary.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Categories of Personal Information Collected (as defined by the CCPA):

• Identifiers (name, email address, unique device identifiers)
• Internet/electronic network activity (usage data, features used)
• Geolocation data (approximate, only when permitted)

We do not sell personal information. We do not use sensitive personal information for purposes other than providing our services.

To exercise your rights, contact us at support@thenineteenth.golf or use the in-app features (Profile > Privacy & Data). We will verify your identity and respond within 45 days.

Other US States

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with consumer privacy laws may have similar rights to access, delete, and correct their personal information. To exercise these rights, contact us at support@thenineteenth.golf.

7. Children’s Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete that information promptly.

If you believe we have inadvertently collected information from a child under 13, please contact us immediately at support@thenineteenth.golf.

8. International Data Transfers

Your personal data is primarily stored and processed in Australia by Supabase, which is hosted on Amazon Web Services (AWS) in the Sydney (ap-southeast-2) region.

Some of your data may also be processed in the United States by the following service providers in connection with their services:

• Expo/EAS (React Native OTA updates, build services, crash reporting)
• RevenueCat (subscription and purchase management)

8.1 Transfers from the EU/EEA

Australia has been recognised by the European Commission as providing an adequate level of data protection (Commission Decision 2001/497/EC). For transfers to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission (Commission Implementing Decision (EU) 2021/914) to ensure your data receives an equivalent level of protection.

8.2 Transfers from the United Kingdom

For transfers of personal data from the United Kingdom to Australia, the UK recognises Australia as providing adequate data protection. For transfers to the United States, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as approved by the UK Secretary of State and the Information Commissioner’s Office.

8.3 Safeguards

Regardless of where your data is processed, we ensure that appropriate safeguards are in place, including contractual obligations on our service providers to protect your personal data in accordance with applicable data protection laws.

9. Third-Party Links and Services

The App may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date and the updated version will be effective as soon as it is accessible.

We will notify you of any material changes by:

• Posting the new Privacy Policy in the App
• Sending you a notification (if you have enabled notifications)
• Updating the “Last Updated” date at the top of this policy

11. Contact Us

If you have questions or comments about this Privacy Policy, or if you wish to exercise your privacy rights, please contact us at:

For complaints regarding the handling of your personal information, you may also contact the Office of the Australian Information Commissioner (OAIC):

• Website: https://www.oaic.gov.au
• Phone: 1300 363 992

12. Summary of Key Points