Privacy Policy
Effective date: 01/09/2026 · Last updated: 01/09/2026
Family Golf Club is committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and Lithuania’s Law on Legal Protection of Personal Data. This policy covers Members, Junior Profiles, Coaches, Partner Clubs and Federations, Sponsors, and website visitors. Where your child’s data is involved, read this alongside our Children & Parental Consent Notice.
1. Who controls your data
The data controller for personal data collected through FGC services is Famico VšĮ, a non-profit public institution registered in the Republic of Lithuania. Contact: [email protected]. for Data protection queries.
Where you interact with FGC through a Partner Club or Partner Federation, that partner’s role is set out in section 4 below and in our published Partner Data Sharing summary.
2. What data we collect and why
Postal address: collected where we ship a physical reward (Junior Golf Passport, Family Flag, medals). Purpose: fulfilment. Legal basis: performance of contract. Shared only with our fulfilment/courier provider — see Subprocessors.
Payment data: billing information processed by Stripe, our payment processor. We do not store full card details. Purpose: to process membership payments and referral credits. Legal basis: performance of contract.
Achievement and recognition data: rounds logged, practice sessions, digital badges unlocked, Family Cup and event participation, and Junior Profile activity within the eight development dimensions (short game, putting, tee shots, physical fitness, confidence & resilience, commitment, growth mindset, engagement), including brief self-reported check-ins on focus and resilience after a round. Purpose: to power the private, family-visible achievement and recognition system. Legal basis: performance of contract. This data is never used to create a public ranking or leaderboard, is never used for automated decisions with legal or similarly significant effect, and is never used for advertising or sold to any third party, including Sponsors.
Event participation data: family names, handicap information, and scores submitted at Family Cup events and the Championship. Purpose: to run these competitions and inform the Family Golf Awards. Legal basis: performance of contract.
Communications data: emails, enquiry form submissions, WhatsApp community participation (phone number, group membership, messages visible to other group members and admins). Purpose: to respond to enquiries, run the community, and communicate service updates. Legal basis: legitimate interest and, where required, consent.
Website analytics data: browsing behaviour, pages visited, device/browser type, anonymised IP address, session duration, via Google Analytics through Google Site Kit. Purpose: to understand and improve site usage. Legal basis: consent, via the cookie banner.
Marketing data: your preferences for newsletters and updates, sent via Brevo. Purpose: to send relevant communications. Legal basis: consent, withdrawable at any time via unsubscribe.
Referral data: name and contact details of a person referred to us by an existing Member, before that person has a relationship with us directly. Purpose: to process the referral. Legal basis: legitimate interest, for the short period until we contact the referred person directly with this policy.
3. Google Site Kit and Analytics
This website uses Google Site Kit, connecting Google Analytics and Google Search Console to our WordPress site. Google Analytics collects anonymised data about your visit, transmitted to and stored on Google’s servers, with IP anonymisation enabled. Google acts as a data processor under a Data Processing Agreement and may also use this data for its own purposes per Google’s privacy policy at policies.google.com. Analytics cookies are only placed with your explicit consent via our cookie banner.
4. How we share your data
We do not sell personal data. We share it only as follows:
- Stripe (payment processor) — to process membership payments and referral credits.
- Wember OÜ (Estonia) — the FamilyGolf.club app provider WemberOU processes achievement/recognition data, event scoring, and app activity on Famico’s behalf. Wember is incorporated in Estonia, an EU/EEA member state.
- Event host clubs — family name and entry information, for events you register for. Host clubs act only on our instructions, solely to run the event you’ve registered for, and are contractually prohibited from using this data for their own membership, marketing, or other purposes.
- Google — anonymised analytics data, as above.
- Brevo — email marketing and newsletter communications you’ve consented to. Brevo is EU-based (France), so this is intra-EU processing with no additional transfer safeguard required.
- Meta (WhatsApp) — phone number and group activity, for anyone joining a community group. FGC sets up and administers these groups.
- Legal authorities — where required by law, court order, or regulator.
All processors are subject to data processing agreements and required to handle data securely and in line with GDPR.
5. International transfers
Most of our processing is intra-EU/EEA: Wember (Estonia), Stripe (EU-region processing), and Brevo (France) all process data within the EU. Google and Meta (WhatsApp) may process data outside the EEA; where this occurs, we rely on Standard Contractual Clauses, UK equivalents, or adequacy decisions as applicable — see our Subprocessors list for the specific safeguard used by each.
6. UK users
Some of our members and event participants are based in the UK. For those users, this policy also serves as our UK GDPR notice. Transfers of UK personal data outside the UK rely on the UK’s international data transfer framework, reviewed as it develops.
7. How long we keep your data
| Category | Retention |
|---|---|
| Account and membership data | Active membership + 3 years after cancellation |
| Event/competition records | Retained for the ongoing life of the relevant competition or Awards programme, reviewed every 3 years — not indefinitely |
| Achievement/recognition data (Junior Profiles) | Active membership + 3 years after cancellation, or deleted sooner on request |
| Analytics data | 26 months (Google Analytics default) |
| Marketing data | Until consent is withdrawn |
| Payment records | 7 years (accounting/legal requirement) |
| WhatsApp community data | For as long as you remain in the group; removed on leaving or on request |
| Event photography/video | Reviewed annually; removed from active promotional use on request |
| Referral data (non-member) | Deleted if the referral does not convert within 90 days |
| Coach/club/camp directory data (sourced publicly) | Reviewed annually; removed or corrected on request |
8. Your rights
Under GDPR you have the right to: access a copy of your data; rectify inaccurate data; request erasure; restrict processing; receive your data in a portable format; object to processing based on legitimate interest, including marketing; and withdraw consent at any time without affecting prior lawful processing. To exercise any of these, email [email protected] with subject line “Data Rights Request.” We respond within 30 days. You may also complain to the State Data Protection Inspectorate of Lithuania (Valstybinė duomenų apsaugos inspekcija — ada.lt) or, for UK-based concerns, the ICO (ico.org.uk).
9. Data about non-members (coaches, clubs, camps)
Our club, coach, and camp directories include personal data (names, professional contact details) about individuals we have not collected data from directly — sourced from public listings. If you are one of these individuals and want to review, correct, or object to your listing, email [email protected]; we will action this within 30 days.
10. Children’s data
Junior Profiles are managed within an adult Member’s account; children do not hold independent accounts or provide consent themselves. Full detail is in our standalone Children & Parental Consent Notice.
11. As the platform grows
FGC is expanding from a membership website toward a broader platform serving partner clubs, federations, and coaches. As new partner relationships launch, personal data may be shared with them under a separate Partner Data Sharing Agreement or, where a partner also determines its own purposes for that data, a joint-controller arrangement — the essence of either will always be summarised in our published Subprocessors & Partners list and available on request.
12. Subprocessors
See our separate, regularly updated Subprocessors & Partners list for the current full vendor roster, what each processes, and its transfer safeguard.
Questions about your data?
Email [email protected] with the subject line “Data Rights Request.” See also the full Legal & Privacy hub.