1. Who is responsible for your information
CoachTalk is a personal golf coaching service operated by Quantum Surprise, Unipessoal Lda, a company registered in Portugal, NIPC 518 139 247 (the Company, we, us or our). CoachTalk is the name of the service. FoCoCo is another brand of the same Company; it is not a separate data controller merely because its name appears on an older page or app.
Registered office: Caminho dos Picoitos 798x, Santo Estêvão, Tavira, 8800-506, Portugal.
Privacy requests: privacy@coachtalk.golf. General support: support@coachtalk.golf.
For the personal data described in this policy, the Company is generally the controller. Other organisations, such as app stores or payment providers, may act as independent controllers for particular transactions or activities.
2. What this policy covers
This policy covers coachtalk.golf, the CoachTalk WebApp at app.coachtalk.golf, the CoachTalk iOS and Android Phone Apps, and related account, coaching, GameTalk, practice, subscription, customer-support and email services. The older app.fococo.ai remains a legacy application address for as long as it is accessible. fococo.ai is the Company's information-only brand website. See our Cookie Policy for differences in website tracking.
The connected Phone App and WebApp support golf conversations, play and practice capture, and review of your golf information. The features available to you depend on the released version, device and membership. Descriptions of future or experimental functions do not mean those functions are currently available.
3. Eligibility
CoachTalk 1.5 is for people aged 18 or older. We do not knowingly offer this version to children. If we discover that an account was created by someone younger than 18, we will assess and take appropriate protective action in accordance with applicable law.
4. Information we process
Account and profile
We may process your name, email address, account identifiers, age confirmation, language and country settings, authentication and security information, handicap, golf goals, home club and other golf preferences you choose to provide.
Golf activity and coaching content
We process information you enter or capture, which may include rounds, scores, holes, shots, practice sessions, GameTalk inputs, MindSnaps, notes, reflections, goals, routines, reactions and feedback. CoachTalk conversations, transcripts and relevant context may be associated with your account so the service can respond using information from your own golf history. The system may generate summaries, possible patterns, coaching observations and recommendations from this information.
Personalisation does not mean perfect or permanent recall. Available context can vary by feature and over time. You should check important details and correct responses that misunderstand your experience.
Audio and device permissions
When you use voice functions, audio may be sent to the relevant speech or AI provider to recognise, generate or deliver a response. Voice-led onboarding means CoachTalk may speak instructions to you. It does not mean the microphone is always recording. We request device permissions when needed for the relevant feature; denying a permission can make that feature unavailable.
Audio, transcripts and provider logs can have different retention conditions. They may be processed for delivery of the requested feature, service security and provider operations. Do not assume that voice processing has zero retention or excludes every form of provider review or model improvement. You can ask our privacy contact about the conditions applicable to a particular interaction.
Location and optional connected information
If you enable a location-based feature, we may process approximate or precise location to find nearby golf places or support the function you request. Related search details may be sent to a maps provider. You can change location permission in device settings. If a released feature lets you connect another source of information, its relevant notice and choice apply; a general device permission is not permission for unrelated advertising.
Payments, technical and support data
We process purchase and entitlement status, subscription identifiers, transaction references, billing country, device information, IP address, diagnostics, support enquiries, and records of notices or communications. Apple, Google and Stripe may process payment details independently; we do not need your full payment card number to provide CoachTalk.
Optional website analytics and marketing
The public website may process analytics data only when the necessary consent has been given. CoachTalk.golf uses Cookiebot to manage cookie choices. Optional advertising or social-media tracking, if introduced, must be disclosed and controlled separately. See the Cookie Policy.
5. Why we use the information and the legal bases
- Provide CoachTalk and manage your account: registration, sign-in, golf capture, conversation history, cross-device access, subscriptions and support necessary for the service. Legal basis: performance of a contract, or steps requested before a contract.
- Personalise your requested coaching: connect relevant golf information, generate reflections and provide continuity across your own sessions. Legal basis: performance of the service contract to the extent this processing is necessary for the coaching service. Processing that goes beyond what is necessary requires a separately assessed legal basis.
- Protect the service: prevent misuse, secure accounts, investigate incidents and enforce proportionate safeguards. Legal basis: legitimate interests and, where applicable, legal obligations.
- Meet legal obligations: invoices, accounting, consumer rights and lawful requests. Legal basis: legal obligation.
- Understand website use and measure campaigns: optional analytics and marketing technologies. Legal basis: consent where required for cookies and other device access, and an appropriate GDPR basis for subsequent personal-data processing.
- Send optional marketing: product news, offers and the MindGame Journal when you opt in or another lawful basis applies. Legal basis: consent or another basis permitted by applicable electronic-marketing law. You can opt out.
- Respond to requests and disputes: manage complaints, data-rights requests and legal claims. Legal basis: legal obligation or legitimate interests, as relevant.
If we rely on legitimate interests, these include service security, fraud prevention, support and proportionate reliability improvements. We assess the impact of these activities on your rights and interests.
6. Personal coaching, automated processing and AI
CoachTalk uses AI to help respond to conversations and to organise or interpret the golf context available to the service. Its output can be inaccurate, incomplete or unsuitable. It is not a human PGA professional, medical professional or emergency service. CoachTalk is not intended to make decisions about employment, credit, insurance or other matters with legal or similarly significant effects.
Relevant text, speech-related information and coaching context may be shared with contracted technology providers to deliver a requested response. Provider identity, role, processing location and terms are described or linked from our Service Provider Register, for the relevant service.
7. Sensitive disclosures
CoachTalk is for golf coaching and is not designed to obtain medical histories, diagnoses or other sensitive information. Please avoid entering health or other special-category information that is not necessary to discuss your golf. A free-text or voice conversation may nevertheless contain information about anxiety, injury or other personal circumstances.
We must identify a valid legal condition before processing any special-category data within the meaning of Article 9 GDPR. Where we cannot lawfully process information of that kind, we may need to restrict or remove it.
8. Who receives the information
Depending on the feature, we may use providers of cloud hosting, authentication, databases, AI, voice technology, email delivery, analytics, consent management, payments, subscriptions and customer support. We may also disclose information to professional advisers or competent authorities where lawfully required. We do not make users' private coaching content available to a golf club, instructor, federation or other member by default. Any future connected-sharing feature needs its own controls and disclosure.
We do not sell private coaching conversations as a customer-data product.
9. Processing outside the EEA
Some service providers may process data outside Portugal or the European Economic Area. Where GDPR requires safeguards, we rely on the relevant adequacy decision, standard contractual clauses or other lawful transfer mechanism, with additional protections where appropriate. You can ask our privacy contact for information about the recipients, processing locations and applicable transfer safeguards for your data, including a copy of relevant safeguards where the law provides that right.
10. How long we keep data
We keep personal data only for as long as necessary for the purposes described here, subject to legal obligations. The criteria include:
- Account, golf and coaching data: generally while your account exists and as needed to deliver the service, subject to your rights and technical/legal deletion processes.
- In-progress rounds and other drafts: while needed for the capture or recovery function, subject to actual application deletion settings.
- Support and security records: for an appropriate period to respond, prevent abuse, establish what happened and defend legal claims.
- Marketing preferences: until you opt out, with a minimal suppression record where needed to honour that choice.
- Payment, invoicing and tax records: for the retention period required by the applicable law.
- Backups and provider logs: copies may remain until the applicable backup or log cycle ends, or longer where a specific lawful preservation obligation applies. They may not disappear immediately when an active record is deleted. We do not promise a universal 90-day erasure period.
11. Your data rights
Subject to applicable law, you may ask for access, correction, erasure, restriction or portability of your data; object to certain processing; withdraw consent; and raise a concern about certain automated decisions. Consent withdrawal does not affect processing that was lawful before withdrawal.
Send a request to privacy@coachtalk.golf or use the Account & Data Deletion page where applicable. We may need to verify your identity without asking for your password. We normally respond within one month, subject to lawful extensions. You may lodge a complaint with Portugal's Comissão Nacional de Proteção de Dados (CNPD) or another competent supervisory authority.
Sending a deletion request begins a review process. It does not itself confirm that all account data has already been erased. See the Deletion page for the process and its limitations.
12. Security
We take technical and organisational measures proportionate to the information and risks involved. These may include access controls, secure connections, provider-managed storage safeguards, monitoring and account-verification measures. No service can guarantee complete security. More information appears in our Data Security Statement.
13. Changes and contact
We may update this policy when the service, our providers or applicable law changes. Material changes will be communicated where required, and new consent will be requested where necessary.
Controller: Quantum Surprise, Unipessoal Lda, Portugal. NIPC: 518 139 247. Privacy: privacy@coachtalk.golf. Support: support@coachtalk.golf.