Privacy Policy

Last updated: March 2026

1. Introduction

FairwayPass ("we", "us", "our") operates a golf membership platform that provides discounted access to golf courses across Denmark and Scandinavia. This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with the General Data Protection Regulation (GDPR) and Danish data protection laws.

FairwayPass is operated via the Polsia platform. By using our services, you agree to the practices described in this policy.

2. Data Controller

FairwayPass (operated via Polsia)
Email: fairwaypass@polsia.app

3. What Data We Collect

We collect the following types of personal data:

3.1 Account Information

• Email address — used for account creation, login, and communication
• Name — used for membership identification and booking records
• Password — securely hashed and stored

3.2 Membership & Payment Information

• Membership tier (Free or Premium) — determines your access level
• Subscription status — whether you have an active paid membership
• Payment transactions — processed securely via Stripe (we do NOT store your full credit card details)

3.3 Usage Analytics

• Page visits — which pages you view on our site
• Session data — anonymized visitor tracking to understand site usage
• Device information — browser type, operating system, screen size (for optimization)

3.4 Cookies & Similar Technologies

We use cookies to:

• Keep you logged in (session cookies)
• Remember your preferences
• Analyze site traffic and performance

See our Cookie Consent banner for more details. You can manage cookie preferences in your browser settings.

4. How We Use Your Data

We use your personal data for the following purposes:

• Provide our service — manage your account, process membership subscriptions, enable course bookings
• Communication — send transactional emails (booking confirmations, membership updates), customer support responses, and optional marketing updates (you can opt out anytime)
• Improve our platform — analyze usage patterns to enhance features and user experience
• Legal compliance — meet regulatory requirements, prevent fraud, enforce our Terms of Service

5. Legal Basis for Processing (GDPR)

We process your data based on:

• Contractual necessity — to provide the FairwayPass membership service you signed up for
• Legitimate interest — to improve our platform, prevent fraud, and ensure security
• Consent — for marketing communications (you can withdraw consent anytime)
• Legal obligation — to comply with EU/Danish laws (e.g., tax records, anti-fraud measures)

6. Third-Party Services

We share your data with trusted third-party services necessary to operate FairwayPass:

6.1 Stripe (Payment Processing)

• What we share: Email, name, payment method (handled securely by Stripe)
• Why: To process your €9/month Premium membership payments
• Privacy Policy: stripe.com/privacy

6.2 Polsia Platform (Infrastructure)

• What we share: All data collected by FairwayPass (as FairwayPass operates on the Polsia platform)
• Why: Hosting, database management, analytics infrastructure
• Security: Data is stored on secure cloud servers with encryption in transit and at rest

6.3 Email Service Providers

• What we share: Email address, name
• Why: To send transactional emails (booking confirmations, password resets) and optional marketing updates

7. Data Retention

We retain your personal data for as long as necessary to provide our services:

• Active accounts: Data retained while your account is active
• Deleted accounts: Data deleted within 30 days, except where required by law (e.g., payment records retained for 5 years for tax compliance)
• Marketing data: Deleted immediately upon opt-out request

8. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Access: Request a copy of all personal data we hold about you
• Rectification: Correct inaccurate or incomplete data
• Erasure ("Right to be Forgotten"): Request deletion of your data (subject to legal obligations)
• Portability: Receive your data in a machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to data processing based on legitimate interest
• Withdraw consent: Opt out of marketing emails or data processing based on consent

To exercise any of these rights, email fairwaypass@polsia.app. We'll respond within 30 days.

9. Data Security

We take data security seriously:

• Encryption: All data transmitted between your browser and our servers is encrypted via HTTPS
• Password protection: Passwords are hashed using industry-standard algorithms (never stored in plain text)
• Access controls: Only authorized personnel can access personal data
• Regular audits: We monitor for security vulnerabilities and update systems regularly

10. International Data Transfers

FairwayPass primarily operates within the EU/EEA. If we transfer data outside the EU, we ensure adequate safeguards are in place (e.g., Standard Contractual Clauses, GDPR-compliant processors).

11. Children's Privacy

FairwayPass is not intended for users under 16 years old. We do not knowingly collect data from children. If we discover data from a child under 16, we will delete it immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Significant changes will be communicated via email.

13. Contact & Complaints

For privacy-related questions or to exercise your rights, contact us at:

Email: fairwaypass@polsia.app

If you're not satisfied with our response, you have the right to lodge a complaint with your national data protection authority (in Denmark: Datatilsynet).