Privacy Policy
PRIVACY POLICY
Last updated: August 31, 2026
This Privacy Policy explains how Žiga Mlakar s.p., operating under the CleverGolfer brand, collects, uses, stores, and protects personal data when you visit clevergolfer.com, use our Website, purchase our Products or Services, create an account, subscribe to our communications, or otherwise interact with us.
The Website and Services are operated by:
Žiga Mlakar s.p.
Rospoh del 85g
2351 Kamnica
Slovenia
Email: [email protected]
In this Privacy Policy, "CleverGolfer," "we," "us," and "our" refer to Žiga Mlakar s.p. "You" and "your" refer to the user, visitor, customer, subscriber, or other individual whose personal data we process.
1. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to personal data collected through:
- clevergolfer.com
- Our subdomains
- Our checkout pages
- Our online courses and digital products
- Our customer accounts
- Our coaching services
- Our email communications
- Our forms and questionnaires
- Our analytics and advertising technologies
- Our customer support communications
- Any other CleverGolfer service that refers to this Privacy Policy
This Privacy Policy does not apply to independent third-party websites or services that have their own privacy policies.
2. WHAT PERSONAL DATA WE MAY COLLECT
Depending on how you interact with us, we may collect the following categories of personal data.
2.1 CONTACT AND IDENTIFICATION INFORMATION
This may include:
- Name
- Email address
- Telephone number
- Billing address
- Country or region
- Other contact information you voluntarily provide
2.2 ACCOUNT INFORMATION
If you create or use a customer account, we may process information such as:
- Email address
- Account identifier
- Login and authentication information
- Account status
- Products or Services associated with your account
- Course progress
- Access history
- Customer preferences
2.3 PURCHASE AND TRANSACTION INFORMATION
When you make a purchase, we may process information such as:
- Products or Services purchased
- Purchase date
- Purchase amount
- Currency
- Payment status
- Refund status
- Payment-plan information
- Transaction identifiers
- Billing information
- Discount or promotional information
We generally do not directly store complete credit card numbers.
Payment information is normally processed by third-party payment providers such as Stripe, PayPal, Kajabi Payments, or other payment processors.
2.4 GOLF AND COACHING INFORMATION
If you participate in a CleverGolfer program, coaching service, assessment, or personalized analysis, we may collect information that you voluntarily provide relating to your golf game.
This may include:
- Handicap
- Scores
- Round statistics
- Fairways hit
- Greens in regulation
- Putting statistics
- Penalty shots
- Miss patterns
- Shot tendencies
- Practice habits
- Golf goals
- Strengths and weaknesses
- Equipment information
- Practice availability
- Improvement priorities
- Responses to coaching questionnaires
- Other golf-related information you choose to provide
2.5 PHOTOS, VIDEOS, AND OTHER CUSTOMER-SUBMITTED CONTENT
For certain Services, you may choose to submit content such as:
- Golf swing videos
- Golf photographs
- Scorecards
- Screenshots
- Practice videos
- Written notes
- Progress reports
- Other materials relevant to your coaching or training
We use this information for the purpose of providing the Product or Service you requested.
We will not publicly use identifiable customer videos, photographs, testimonials, or similar content for marketing purposes without an appropriate legal basis or permission.
2.6 COMMUNICATIONS
If you contact us, we may collect and retain information contained in your communications.
This may include:
- Emails
- Customer support requests
- Questions
- Feedback
- Survey responses
- Coaching updates
- Testimonials
- Reviews
- Other communications you send to us
2.7 MARKETING INFORMATION
We may process information relating to your marketing preferences, such as:
- Whether you have subscribed to marketing emails
- When and how consent was provided
- Your unsubscribe status
- Email engagement
- Links clicked in emails
- Campaign interactions
- Marketing source or referral information
Where required by law, we will obtain appropriate consent before sending marketing communications.
2.8 TECHNICAL AND DEVICE INFORMATION
When you use the Website, certain technical information may be collected automatically.
This may include:
- IP address
- Browser type and version
- Device type
- Operating system
- Screen or device characteristics
- Language settings
- Approximate geographic location
- Referring website
- Pages viewed
- Links clicked
- Date and time of visits
- Session information
- Cookie identifiers
- Advertising identifiers
- Other technical information relating to your use of the Website
2.9 ANALYTICS AND WEBSITE USAGE INFORMATION
We may collect information about how visitors interact with the Website.
This may include:
- Pages visited
- Time spent on pages
- Website navigation
- Clicks
- Scroll activity
- Referral sources
- Marketing campaign attribution
- Conversion events
- Purchases
- Technical errors
- General website usage patterns
For more information about cookies and tracking technologies, please review our Cookie Policy:
https://www.clevergolfer.com/cookies
3. HOW WE COLLECT PERSONAL DATA
We may collect personal data in several ways.
3.1 INFORMATION YOU PROVIDE DIRECTLY
You may provide information when you:
- Purchase a Product or Service
- Create an account
- Complete a form
- Subscribe to our email list
- Contact customer support
- Apply for or purchase coaching
- Complete a golf assessment
- Submit a swing video
- Provide statistics or progress updates
- Submit a testimonial or review
- Communicate with us by email or another channel
3.2 INFORMATION COLLECTED AUTOMATICALLY
Certain information may be collected automatically when you use the Website through:
- Cookies
- Analytics technologies
- Server logs
- Advertising pixels
- Tracking technologies
- Website functionality tools
Non-essential tracking technologies are used subject to applicable consent requirements.
3.3 INFORMATION FROM THIRD PARTIES
We may receive information from third-party services we use.
These may include:
- Kajabi
- Stripe
- PayPal
- Other payment providers
- Google
- Meta
- Analytics providers
- Advertising platforms
- Email service providers
- Scheduling tools
- Other technology providers
The information received depends on the provider, your interaction with the service, and your privacy settings.
4. PURPOSES FOR WHICH WE USE PERSONAL DATA
We may use personal data for the following purposes.
4.1 PROVIDING PRODUCTS AND SERVICES
We may process personal data to:
- Process purchases
- Provide access to digital Products
- Create and administer customer accounts
- Deliver online courses
- Provide coaching
- Review golf data
- Review swing videos
- Prepare personalized recommendations
- Provide improvement plans
- Deliver purchased materials
- Provide customer support
- Communicate with you about your purchase
4.2 PROCESSING PAYMENTS
We may process information necessary to:
- Process payments
- Manage payment plans
- Process refunds
- Detect failed payments
- Manage billing
- Prevent fraud
- Resolve payment disputes
4.3 CUSTOMER SUPPORT
We may use personal data to:
- Respond to questions
- Resolve technical problems
- Provide account assistance
- Handle refund requests
- Resolve complaints
- Communicate about Products or Services
4.4 IMPROVING OUR PRODUCTS AND WEBSITE
We may use information to:
- Understand how visitors use the Website
- Improve Website functionality
- Improve our courses and Services
- Understand customer needs
- Identify technical problems
- Develop new Products or features
- Analyze customer experience
4.5 MARKETING AND ADVERTISING
Subject to applicable law, we may use personal data to:
- Send marketing emails
- Promote CleverGolfer Products and Services
- Measure advertising effectiveness
- Analyze marketing campaigns
- Build advertising audiences
- Retarget Website visitors
- Measure conversions
- Personalize marketing communications
Where required, marketing and advertising activities will be based on your consent.
You may unsubscribe from marketing emails at any time.
4.6 SECURITY AND FRAUD PREVENTION
We may process personal data to:
- Protect customer accounts
- Prevent unauthorized access
- Detect fraud
- Investigate suspicious activity
- Protect our Website
- Enforce our Terms and Conditions
- Protect our intellectual property
- Protect our legal rights
4.7 LEGAL AND ADMINISTRATIVE PURPOSES
We may process personal data where necessary to:
- Maintain business records
- Comply with tax and accounting obligations
- Respond to lawful government requests
- Comply with legal obligations
- Establish, exercise, or defend legal claims
- Resolve disputes
- Enforce contracts
5. LEGAL BASES FOR PROCESSING
Where the General Data Protection Regulation or similar data protection laws apply, we process personal data only where we have an appropriate legal basis.
Depending on the circumstances, this may include the following.
5.1 PERFORMANCE OF A CONTRACT
We may process personal data where necessary to enter into or perform a contract with you.
For example, this may include:
- Processing your order
- Giving you access to a purchased course
- Providing coaching
- Processing a refund
- Responding to a request connected to your purchase
5.2 LEGITIMATE INTERESTS
We may process personal data where necessary for our legitimate business interests and where those interests are not overridden by your rights.
These interests may include:
- Improving our Website
- Improving Products and Services
- Protecting our business
- Preventing fraud
- Managing customer relationships
- Understanding Website performance
- Maintaining security
- Establishing or defending legal claims
5.3 CONSENT
We may rely on your consent where required.
This may include:
- Certain marketing communications
- Non-essential analytics cookies
- Advertising cookies
- Certain tracking technologies
- Certain optional uses of your personal data
Where processing is based on consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.
5.4 LEGAL OBLIGATION
We may process personal data where necessary to comply with a legal obligation.
This may include obligations relating to:
- Tax
- Accounting
- Consumer protection
- Fraud prevention
- Regulatory requirements
- Legal proceedings
6. MARKETING COMMUNICATIONS
If you subscribe to our email list, purchase certain Products or otherwise lawfully receive marketing communications from us, we may send information about CleverGolfer Products, Services, content, promotions, or related topics.
Where required by applicable law, we will obtain your consent before sending marketing communications.
You may unsubscribe from marketing emails at any time by:
- Clicking the unsubscribe link in any marketing email
- Contacting us at [email protected]
Unsubscribing from marketing emails does not prevent us from sending transactional or service-related communications necessary to administer a Product or Service you purchased.
7. COOKIES, ANALYTICS, AND ADVERTISING TECHNOLOGIES
We use cookies and similar technologies on the Website.
These technologies may be used for:
- Website functionality
- Customer authentication
- Checkout functionality
- Analytics
- Conversion measurement
- Advertising
- Marketing attribution
- Security
- Fraud prevention
Depending on the Website page and your cookie preferences, third-party technologies may include services provided by:
- Kajabi
- Google
- Meta
- Stripe
- PayPal
- Other technology providers
Where required by law, non-essential cookies and tracking technologies will only be used after you provide consent.
For more information, including how to manage your preferences, please review our Cookie Policy:
https://www.clevergolfer.com/cookies
8. HOW WE SHARE PERSONAL DATA
We do not sell personal data to advertisers.
We may share personal data with third parties where reasonably necessary to operate our business, provide Services, comply with the law, or protect our rights.
8.1 SERVICE PROVIDERS
We may share information with service providers that help us operate our business.
These may include providers of:
- Website hosting
- Online course delivery
- Customer account management
- Payment processing
- Email delivery
- Analytics
- Advertising
- Scheduling
- Video hosting
- Customer support
- Cloud storage
- Security
- Accounting
- Legal or professional services
8.2 KAJABI
We use Kajabi to provide Website, checkout, customer account, email, online course, and digital product functionality.
Kajabi may process personal data on our behalf or in connection with its own services.
8.3 PAYMENT PROCESSORS
Payment information may be processed by providers such as:
- Stripe
- PayPal
- Kajabi Payments
- Other payment providers
These providers may process transaction and payment information under their own privacy policies and terms.
8.4 ANALYTICS AND ADVERTISING PROVIDERS
Subject to your consent where required, we may share or allow collection of certain technical and usage information by analytics and advertising providers.
These may include:
- Google
- Meta
- Other analytics or advertising providers
8.5 PROFESSIONAL ADVISERS
We may disclose information where reasonably necessary to professional advisers such as:
- Accountants
- Lawyers
- Tax advisers
- Insurance providers
- Other professional consultants
8.6 LEGAL REQUIREMENTS
We may disclose personal data if required to do so by law or where reasonably necessary to:
- Comply with legal obligations
- Respond to a lawful request
- Protect our legal rights
- Prevent fraud
- Investigate wrongdoing
- Protect customers or the public
- Establish, exercise, or defend legal claims
8.7 BUSINESS TRANSFERS
If our business, brand, assets, or part of our operations are sold, transferred, reorganized, or merged, personal data may be transferred as part of that transaction where legally permitted.
Any new owner or operator would be required to handle personal data in accordance with applicable data protection law.
9. INTERNATIONAL DATA TRANSFERS
Some of the service providers we use may process personal data outside Slovenia or the European Economic Area, including in the United States.
This may include providers such as:
- Kajabi
- Google
- Meta
- Stripe
- Other cloud or technology providers
Where personal data is transferred internationally and applicable law requires safeguards, we will rely on appropriate legal mechanisms.
These may include:
- An adequacy decision
- Standard Contractual Clauses
- The EU-U.S. Data Privacy Framework where applicable
- Other legally recognized safeguards
Where required, additional safeguards may also be used.
10. DATA RETENTION
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, tax, contractual, and legitimate business requirements.
Retention periods may vary depending on the type of information.
10.1 CUSTOMER AND TRANSACTION RECORDS
Purchase and transaction records may be retained for the period required by applicable accounting, tax, and legal obligations.
10.2 CUSTOMER ACCOUNTS
Account information may be retained while your account or Product access remains active and for a reasonable period afterward where necessary for legal, operational, or customer support purposes.
10.3 COACHING INFORMATION
Golf statistics, coaching submissions, swing videos, questionnaires, progress reports, and related information may be retained while necessary to provide the coaching Service and for a reasonable period afterward for customer support, record keeping, or legal purposes.
10.4 MARKETING INFORMATION
Marketing information may be retained until you unsubscribe or object to the relevant processing, subject to limited retention where necessary to maintain a suppression record so that we do not accidentally contact you again.
10.5 TECHNICAL AND ANALYTICS DATA
Retention periods for technical data, analytics information, cookies, and advertising identifiers may depend on the provider and configuration used.
For more information, see our Cookie Policy.
11. DATA SECURITY
We take reasonable technical and organizational measures to protect personal data against:
- Unauthorized access
- Accidental loss
- Misuse
- Alteration
- Disclosure
- Destruction
These measures may include appropriate use of:
- Secure service providers
- Access controls
- Authentication
- Encryption where appropriate
- Payment security measures
- Account security
- System monitoring
However, no internet-based system can be guaranteed to be completely secure.
You are responsible for keeping your own account credentials confidential and should contact us promptly if you believe your account has been compromised.
12. YOUR DATA PROTECTION RIGHTS
Depending on where you live and the law that applies to you, you may have certain rights regarding your personal data.
Where the GDPR applies, these rights may include the following.
12.1 RIGHT OF ACCESS
You may request information about whether we process your personal data and request a copy of that data.
12.2 RIGHT TO RECTIFICATION
You may ask us to correct personal data that is inaccurate or incomplete.
12.3 RIGHT TO ERASURE
You may ask us to delete personal data in certain circumstances.
This right is not absolute.
We may retain information where necessary to comply with legal obligations, establish or defend legal claims, prevent fraud, or for other lawful reasons.
12.4 RIGHT TO RESTRICT PROCESSING
You may ask us to restrict the processing of your personal data in certain circumstances.
12.5 RIGHT TO DATA PORTABILITY
Where applicable, you may request certain personal data in a structured, commonly used, machine-readable format or ask for it to be transferred to another provider.
12.6 RIGHT TO OBJECT
You may object to processing based on legitimate interests in certain circumstances.
You also have the right to object to direct marketing at any time.
12.7 RIGHT TO WITHDRAW CONSENT
Where processing is based on your consent, you may withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing before the withdrawal.
12.8 RIGHT TO COMPLAIN
If you believe that your personal data has been processed unlawfully, you may have the right to lodge a complaint with a competent data protection supervisory authority.
If you are in Slovenia, the relevant supervisory authority is the Information Commissioner of the Republic of Slovenia.
You may also have the right to complain to the supervisory authority in the EU or EEA country where you live or work.
13. HOW TO EXERCISE YOUR RIGHTS
To exercise a data protection right, contact:
Please provide enough information for us to identify you and understand your request.
We may ask for additional information where reasonably necessary to verify your identity and protect your personal data.
We will respond within the time period required by applicable law.
We generally do not charge a fee for exercising data protection rights, although a reasonable fee may be permitted where a request is manifestly unfounded, excessive, or repetitive.
14. CHILDREN'S PRIVACY
Our Products and Services are not intended to be purchased directly by children under 18 without the involvement of a parent or legal guardian.
We do not knowingly seek to collect personal data from children in a manner prohibited by applicable law.
If you believe that a child has provided personal data to us improperly, please contact:
15. THIRD-PARTY WEBSITES
Our Website may contain links to third-party websites.
We are not responsible for the privacy practices, security, or content of independent third-party websites.
We encourage you to review the privacy policy of any third-party website you visit.
16. AUTOMATED DECISION-MAKING
We do not currently use personal data to make solely automated decisions that produce legal effects or similarly significant effects on individuals.
We may use automated tools for purposes such as:
- Email segmentation
- Marketing analytics
- Advertising audiences
- Fraud detection
- Website personalization
These activities do not ordinarily constitute solely automated decision-making with significant legal effects.
If this changes, we will update this Privacy Policy as required.
17. UNITED STATES AND OTHER INTERNATIONAL CUSTOMERS
CleverGolfer serves customers internationally, including customers in the United States.
Depending on your location, additional privacy rights may apply under local law.
Where applicable, we will respect mandatory privacy rights provided by the laws that apply to you.
We do not sell personal data to advertisers.
We may use analytics and advertising technologies as explained in this Privacy Policy and our Cookie Policy, subject to applicable law and consent requirements.
18. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time.
Changes may be necessary because of:
- Changes to our Products or Services
- Changes to the Website
- Changes to our technology providers
- Changes to our business practices
- Changes to applicable law or regulatory guidance
The current version will be published on the Website with an updated "Last updated" date.
We encourage you to review this Privacy Policy periodically.
19. CONTACT INFORMATION
If you have questions about this Privacy Policy, how we use personal data, or your data protection rights, please contact:
Žiga Mlakar s.p.
Rospoh del 85g
2351 Kamnica
Slovenia
Email: [email protected]
20. RELATED POLICIES
Terms and Conditions:
https://www.clevergolfer.com/terms
Cookie Policy:
https://www.clevergolfer.com/cookies
