This policy explains how Optimisation Australia Pty Limited (ABN 94 116 927 354), trading as oa agency ("HoleMarked", "we", "us") handles personal information. It is written with the UK GDPR, the EU GDPR and the Australian Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), in mind.
1. Our role
Club members: each club is the controller of its members' personal information. HoleMarked acts as a processor on the club's behalf under our Data Processing Agreement. Members should contact their club first about their information.
Website visitors and club account contacts: HoleMarked is the controller for information about visitors to holemarked.com and about committee officials and other club contacts who manage accounts.
2. Information we collect
- Names and email addresses of members and club contacts.
- Quiz progress, scores, leaderboard positions and Holemark Pass status.
- Sign in data, such as login times, device and browser details and IP address.
- Messages you send us, including through the live chat on our website.
- Optional cookies and analytics data, only with your consent.
We do not receive full card details. Payments are handled by Paddle.
3. Purposes and lawful bases
- Providing the Service to clubs and members (contract with the club; for members, the club's chosen lawful basis, and our processing on its instructions).
- Managing club accounts and billing (contract; legitimate interests).
- Security, fraud prevention and keeping the Service working (legitimate interests).
- Service emails and invites (contract; legitimate interests).
- Optional analytics and cookies (consent).
- Meeting legal obligations (legal obligation).
Under the Privacy Act, we collect personal information only where reasonably necessary for these functions and use it for the purpose collected or a related purpose you would reasonably expect.
4. Sharing
We share personal information only with:
- hosting and infrastructure providers that store and run the Service;
- email delivery providers that send invites and service emails;
- our live chat provider, for messages you send us through the chat window;
- Paddle.com, our Merchant of Record, for checkout, payments, invoicing, tax and refunds;
- professional advisers and authorities where required by law.
We do not sell personal information.
5. International transfers
Our providers may store or process information outside your country, including outside Australia, the UK and the EU. Where we transfer personal information from the UK or EU, we use safeguards such as adequacy decisions, the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses. For Australian information, we take reasonable steps so that overseas recipients handle it consistently with the APPs.
6. Retention
We keep member data for as long as the club's subscription is active, then delete or return it as set out in the Data Processing Agreement. We keep account and billing records for as long as needed for legal, tax and accounting purposes. Sign in and security logs are kept for a limited period.
7. Security
We use reasonable technical and organisational measures to protect personal information, including encryption in transit, access controls and limiting staff access to those who need it. No system is completely secure, and we will notify affected parties of eligible data breaches as required by law.
8. Your rights
Depending on where you live, you may have the right to:
- access your personal information;
- correct inaccurate information;
- ask for erasure;
- object to or restrict certain processing;
- receive your information in a portable format;
- withdraw consent at any time, where we rely on consent.
Club members should contact their club, and we will help the club respond. Others can contact us at get@holemarked.com. We will respond within the time required by law.
You can complain to us first. You may also complain to the UK Information Commissioner's Office (ICO), your local EU data protection authority, or the Office of the Australian Information Commissioner (OAIC).
9. Cookies
We use essential cookies needed to sign in and run the Service. We use optional cookies, such as analytics, only if you consent, and you can change your choice at any time.
10. Children
HoleMarked is not directed at children under 16 without club oversight. Where a club invites junior members, the club is responsible for obtaining any parental or guardian consent required.
11. Changes
We may update this policy and will post the new version here with a new date.
12. Contact
Privacy questions or requests: get@holemarked.com.