Privacy Policy

How Foremates collects, uses and protects personal data

Luduslabs Ltd · Company no. 16312935 · England & Wales

Version: October 2026

Foremates is operated by Luduslabs Ltd. This Privacy Policy applies to the Foremates app, website and related services and is designed for users and customers internationally.

At a glance

• We do not sell personal data.
• We do not use personal data for cross-context behavioural advertising.
• You can request access, correction or deletion of your data where applicable.
• Foremates may act as a controller for direct user relationships and as a processor when handling data on behalf of a club or business customer.
• Payments are handled by specialist payment or app-store providers; Foremates does not store full payment-card numbers.
• Our current service-provider list is available in the Foremates Subprocessor List.

1. Who this policy covers

This Policy covers individual golfers, website visitors, app users, society members, event participants, club staff and other people whose personal data is handled through Foremates.

“Foremates”, “we”, “us” and “our” mean Luduslabs Ltd, company number 16312935, registered at 132 Kennel Lane, Billericay, England, CM11 2SU.

2. Our roles: controller and processor

For personal data we collect directly to run Foremates — for example your account, support interactions, security logs, product analytics and direct communications — Luduslabs is generally the data controller.

When a golf club, company, event organiser or other business customer uses Foremates to manage its players, members, guests or events, that customer may be the controller and Luduslabs may act as its processor for the customer data it instructs us to handle.

In those cases, the customer decides the purposes of the relevant processing and its own privacy notice may also apply. Our Data Processing Agreement governs processor activity where required.

Some third parties, such as app stores, payment providers and social-login providers, may act as independent controllers for data they process for their own purposes.

3. Personal data we collect

Information you provide

• account details such as name, email address, profile photo, date of birth or age information and login details;
• golf profile information such as home course, preferred tees, handicap or handicap index and golf statistics;
• event information such as registrations, team or tee-time details, scoring, leaderboard data and competition participation;
• user content such as posts, photos, comments, messages, scorecards and event media;
• social and group information such as friends, groups, society membership or club affiliation;
• support, feedback and other communications;
• payment-related records such as purchase identifier, amount, status and transaction reference, but not full card details where payment is handled directly by a payment provider; and
• information you submit to optional AI-enabled features, such as prompts, instructions or event content.

Information collected automatically

• device type, operating system, app version, language and time zone;
• device or installation identifiers used for security, notifications and app functionality;
• IP address and approximate IP-derived location;
• feature usage, interaction events and session information;
• crash logs, diagnostics and performance data; and
• security and audit information needed to protect accounts and the Service.

Information from others

We may receive information from:

• Apple, Google, Meta/Facebook or other login providers, depending on the permissions you choose;
• a club, organiser or group that adds or invites you to an event;
• app stores and subscription platforms confirming purchase or subscription status;
• payment providers confirming transaction status;
• golf-course, mapping or facility-data providers; and
• other users where they invite, tag, message or otherwise interact with you.

4. How we use personal data

We use personal data to:

• create, authenticate and manage accounts;
• provide groups, events, tournaments, tee sheets, scoring, leaderboards, stats and social features;
• enable club and organiser workflows;
• process or confirm subscriptions and payments;
• provide GPS, course and location-based features when enabled;
• send service messages, invitations, event reminders and push notifications;
• provide support and respond to requests;
• moderate content and enforce our Terms;
• prevent fraud, abuse and security incidents;
• maintain, troubleshoot, analyse and improve Foremates;
• provide optional AI-enabled functionality;
• comply with legal, tax, accounting, regulatory and law-enforcement obligations; and
• establish, exercise or defend legal claims.

We do not sell personal data. We do not use Foremates user data for third-party advertising profiles or cross-app advertising tracking.

5. Legal bases for UK and EEA users

Where UK GDPR or EU GDPR applies, we rely on one or more of the following:

• contract — where processing is necessary to provide the Service you requested;
• legitimate interests — for security, fraud prevention, service improvement, business administration and reasonable product analytics, balanced against your rights;
• consent — for optional activities that legally require consent, such as certain marketing, precise or background location, device permissions or other optional processing;
• legal obligation — where we must process information to comply with law; and
• legal claims or other special legal bases where relevant.

You may withdraw consent at any time where we rely on consent. Withdrawal does not affect earlier lawful processing.

6. Clubs, organisations and business customers

A club or organiser may upload or create information about players, members, guests or staff. Where we process that data only on the customer’s instructions, the customer is responsible for providing any required notices and establishing a lawful basis.

If you believe information held in Foremates was supplied by a club or organiser, you may contact that organisation directly or contact us and we will assist as appropriate.

7. AI-enabled features

Foremates may offer AI-enabled tools that help users or organisations create, summarise, organise or analyse content.

If an AI feature sends content to a third-party model provider, we will use providers under appropriate contractual and data-protection terms and identify applicable providers in our Subprocessor List before production use with customer personal data.

Do not include unnecessary sensitive or confidential personal data in prompts.

Unless we clearly tell you otherwise, Foremates does not use solely automated AI decisions that produce legal or similarly significant effects about individuals.

8. Payments

Consumer subscriptions may be processed by Apple, Google and subscription-management providers. We generally receive purchase identifiers, product details and subscription status rather than full payment-card information.

Society, event or other direct payments may be processed by Stripe or another disclosed payment provider. Card and bank details entered into the payment provider’s interface are handled by that provider.

Where organisers connect their own payment accounts, the organiser and payment provider may independently determine how payment or identity-verification data is used.

9. Analytics, diagnostics and tracking

We use product analytics, crash reporting and performance monitoring to understand how Foremates works and to improve reliability.

We do not use Apple’s App Tracking Transparency framework to track users across unrelated apps or websites for advertising, unless this Policy is updated and any required permission is obtained.

Our app-store privacy and Google Play Data Safety disclosures should be read together with this Policy and must be kept consistent with the actual SDKs and data flows in each released app version.

10. Location data

With permission, Foremates may use location to show nearby clubs or courses and provide GPS yardages.

If an optional feature uses background location or device geofencing, we will provide the required in-app disclosure and permission flow. Where a background geofence operates entirely on the device, background location is not transmitted to our servers for that feature unless we tell you otherwise.

You can change location permissions in device settings.

11. Camera, photos and media

If you give permission, Foremates may access your camera or photo library so you can upload profile images, scorecards, event photos or other media. We use media for the feature you choose and store uploaded content with your account or relevant event.

12. Push notifications

With permission, we may send notifications about account activity, invitations, events, scoring or other Service features. You can control notifications in device settings and, where available, within Foremates.

13. Who we share data with

We may share personal data:

• with other Foremates users according to the feature and your settings;
• with a club, organiser or business customer where you participate in its event or service;
• with service providers and subprocessors that host, secure, analyse, support or deliver Foremates;
• with payment, app-store or authentication providers as needed for the service you choose;
• with professional advisers, insurers, auditors or prospective transaction counterparties under appropriate confidentiality controls;
• with law-enforcement, regulators, courts or public authorities where required or legally justified; and
• as part of a merger, financing, restructuring, acquisition or sale, subject to appropriate safeguards.

Our current processor list is published separately. Providers may change as the Service evolves.

14. International transfers

Foremates is operated from the United Kingdom and uses service providers in multiple countries.

Where personal data is transferred internationally and a legal transfer mechanism is required, we use an applicable safeguard such as an adequacy decision, the EU Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, together with any required transfer-risk assessment or supplementary measure.

Business customers can review further transfer terms in our Data Processing Agreement.

15. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, including to provide the Service and meet legal, tax, accounting, fraud-prevention and dispute requirements.

Account and user-content data is generally deleted or de-identified after a valid deletion request, subject to limited information we must or are permitted to retain.

Different records may have different retention periods. Backup copies, where used, are deleted or overwritten in line with our backup lifecycle and are protected from ordinary use.

16. Account deletion

You can initiate account deletion in the Foremates app through Settings → Account → Delete account, or use foremates.com/account-deletion.

Deletion is permanent after completion. We may verify identity before acting on a request.

Deleting an account does not automatically cancel an Apple App Store or Google Play subscription.

More detail is available in our Account Deletion page.

17. Your privacy rights

Depending on where you live, you may have rights to:

• access personal data;
• correct inaccurate data;
• request deletion;
• restrict or object to processing;
• receive portable data;
• withdraw consent;
• object to certain direct marketing; and
• complain to a privacy regulator.

UK users may complain to the Information Commissioner’s Office. EEA users may complain to their local supervisory authority.

We may need to verify identity and may refuse or limit a request where the law permits.

18. United States privacy rights

Residents of certain US states may have additional rights under applicable state privacy laws, including rights to know or access, correct, delete or obtain a portable copy of personal data and to appeal certain privacy decisions.

Foremates does not sell personal data and does not share personal data for cross-context behavioural advertising as those terms are commonly used in US state privacy laws.

Where a state law provides an applicable opt-out or appeal right, you may exercise it by contacting us. We will not discriminate against you for exercising a privacy right.

19. Children

Foremates is not directed to children under 13 and we do not knowingly create accounts for children under 13.

For users under 18, parental or guardian permission may be required by our Terms or local law. Where local law sets a higher age for valid consent to data processing, we will apply the relevant rule.

20. Security

We use technical and organisational safeguards designed to protect personal data, including encryption in transit, access controls, least-privilege practices, secure credential management, monitoring, security updates and incident-response processes.

Where supported by our hosting provider, stored data is encrypted at rest.

No system is completely secure. If you believe your account or data has been compromised, contact us promptly.

21. Changes to this Policy

We may update this Policy when our Service, technology, providers or legal obligations change. If a change materially affects how we use personal data, we will provide notice where required.

22. Contact and complaints

Luduslabs Ltd, trading as Foremates

Company number: 16312935

Registered office: 132 Kennel Lane, Billericay, England, CM11 2SU

Privacy contact: info@luduslabs.net

General support: info@foremates.com

Website: foremates.com

If you are in the UK, you also have the right to complain to the Information Commissioner’s Office. If you are elsewhere, you may contact the privacy or data-protection authority responsible for your jurisdiction.