Privacy Policy

Who We Are

Thirstyfish Consultancy Limited, trading as Fairway Masters, is responsible for deciding how and why personal information collected through Fairway Masters is used. For applicable data protection law, we act as the Data Controller.

This Privacy Policy applies to visitors to our website, customers, event participants, prospective customers and other people who interact with Fairway Masters.

Data Protection Laws

We process personal information in accordance with applicable data protection and privacy laws, including:

• UK General Data Protection Regulation ("UK GDPR")
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations 2003 ("PECR"), as amended
• Data (Use and Access) Act 2025
• EU General Data Protection Regulation ("EU GDPR"), where it applies to our activities

Information We May Collect

Depending on how you use Fairway Masters, we may collect:

Identity and Contact Information

• Name
• Email address
• Telephone number
• Postal or billing address

Golf and Event Information

• Golf club
• Handicap
• Golf preferences
• Tournament or event registrations
• Competition details
• Attendance information
• Other information reasonably required to administer an event

Payment and Transaction Information

We may collect:

• Billing information
• Transaction references
• Payment status
• Purchase or booking history

Payments are processed using third-party payment service providers.

We do not intend to store complete payment-card details on Fairway Masters systems where payment processing is handled directly by our payment provider.

Website and Technical Information

We may automatically collect:

• IP address
• Browser type
• Device information
• Approximate location
• Operating system
• Pages visited
• Referral information
• Cookie identifiers
• Advertising identifiers
• Website interaction and analytics information

Marketing Information

We may record:

• Whether you have agreed to receive marketing
• Your marketing preferences
• Communication history
• When and how consent was provided or withdrawn

Account Information

When user accounts are introduced, we may process information associated with registration, login, account preferences and account activity.

How We Collect Information

We may obtain personal information:

• Directly from you when completing a form
• When registering for an event
• When contacting us
• When making a payment
• When subscribing to marketing
• When creating an account
• Automatically through cookies and similar technologies
• From payment providers
• From golf clubs, venues and event partners where appropriate
• From other service providers where lawful

Why We Use Your Information

Where we rely on legitimate interests, we will consider our business need against your privacy rights and interests.

Marketing Communications

Fairway Masters may send information about:

• Forthcoming golf events
• Tournaments
• Special events
• Promotions
• Offers
• Fairway Masters services
• Future products

Marketing may be sent by:

• Email
• SMS
• WhatsApp

Where required, we will obtain consent before sending electronic marketing. Where applicable law permits us to contact an existing customer without fresh consent, we may do so only where the relevant legal requirements are satisfied. Every marketing communication will provide an appropriate method of opting out.

You may also withdraw your marketing consent at any time by contacting Connect@thirsty-fish.com. Withdrawing marketing consent does not affect service or transactional communications that we legitimately need to send regarding an event, booking or account.

Children and Under-18 Participants

Fairway Masters may permit participants under the age of 18 to register for appropriate events with the involvement and consent of a parent or legal guardian where required. Where information about a child is collected, we will take additional care regarding:

• Transparency
• Data minimisation
• Security
• Marketing
• Profiling
• Retention

Where applicable law requires verified parental consent, we will take reasonable steps to obtain it. Fairway Masters will not intentionally use children's personal information for behavioural advertising.

Parents or legal guardians may contact us concerning information held about a child at Connect@thirsty-fish.com.

Sharing Your Information

We may share personal information where reasonably necessary with:

Event and Golf Partners

Including:

• Golf clubs
• Tournament venues
• Event venues
• Competition administrators
• Service partners involved in providing the event

Only information reasonably required for the relevant purpose should be shared.

Payment Providers

Payment information may be processed by the payment service provider selected by Fairway Masters. Their own privacy terms may also apply.

Technology Providers

We may use providers for:

• Website hosting
• Cloud storage
• Email services
• Databases
• Security
• Customer communications
• Website development
• IT support

Analytics and Advertising Providers

Subject to your cookie and consent choices, we may use services provided by organisations such as:

• Google for analytics and advertising measurement
• Meta for advertising measurement and Meta Pixel functionality

These technologies will not be used for advertising tracking until any legally required consent has been obtained.

Professional and Regulatory Parties

Information may also be disclosed to:

• Accountants
• Lawyers
• Professional advisers
• Insurers
• Regulators
• Courts
• Law-enforcement authorities

where reasonably necessary or legally required.

Fairway Masters does not sell personal information as a standalone commercial product.

International Data Transfers

Some of our technology, payment, analytics or advertising providers may process information outside the United Kingdom or European Economic Area, including in the United States.

Where international data-transfer restrictions apply, we will use an appropriate lawful transfer mechanism. Depending on the circumstances, this may include:

• An applicable adequacy decision or adequacy regulation
• Approved Standard Contractual Clauses
• The UK International Data Transfer Agreement
• The UK Addendum to EU Standard Contractual Clauses
• Another legally permitted safeguard

How Long We Keep Information

We do not retain personal information indefinitely. Retention depends upon why the information was collected. As a general guide:

Information may be deleted earlier where it is no longer required.

Security

We use reasonable technical and organisational measures designed to protect personal information against:

• Unauthorised access
• Loss
• Misuse
• Alteration
• Disclosure
• Destruction

Access to personal information should be limited to people and service providers who reasonably need access for legitimate business purposes. No internet-based system can be guaranteed to be completely secure.

Your Data Protection Rights

Depending on the circumstances and applicable law, you may have the right to:

• Request access to your personal information
• Request correction of inaccurate information
• Request deletion of your information
• Request restriction of processing
• Object to certain processing
• Request transfer of certain information
• Withdraw consent
• Object to direct marketing
• Complain about how your information has been handled

Some rights are subject to legal exceptions. To exercise a right, contact Connect@thirsty-fish.com.

Data Protection Complaints — you may also use the above email address to make a formal data-protection complaint. We will acknowledge a data-protection complaint within the period required by applicable law and investigate and respond without undue delay.

UK users also have the right to complain to the Information Commissioner's Office (ICO). Where EU GDPR applies, individuals may also have the right to complain to the appropriate data-protection supervisory authority in the relevant EEA country.

Automated Decision-Making

Fairway Masters does not currently intend to make decisions producing significant legal or similarly significant effects solely through automated processing. If this changes, we will provide additional information and safeguards where required.

EU Representative

Where Fairway Masters is legally required to appoint a representative within the European Union under the EU GDPR, the representative's contact details will be made available in this Privacy Policy.

Changes to This Privacy Policy

We may update this Privacy Policy where our services change, website technology changes, suppliers change, or legal or regulatory requirements change. The latest version will be published on the Fairway Masters website with an updated revision date.