Foresight Sports Europe Privacy Policy

This policy explains how Optimum Golf Technologies Limited (“OGT”, “we”, “us” or “our”) collects and uses your personal data, and your rights in relation to it. If you have any questions about this privacy notice, please contact us using the details set out below.

Our full details are:

• Registered company: Optimum Golf Technologies Limited, registered in England & Wales, company no. 07471211.
• Registered office: Unit 17 The Pines Business Park, Broad Street, Guildford, Surrey, GU3 3BH.
• Email address: privacy@foresightsports.eu
• Postal address: Unit 17 The Pines Business Park, Broad Street, Guildford, Surrey, GU3 3BH

Optimum Golf Technologies Limited is the authorised European distributor of Foresight Sports and Bushnell Golf products and operates the Foresight Sports Europe and Bushnell Golf Europe websites and related customer support services, including our AI support assistant. Optimum Golf Technologies Limited is the controller responsible for the websites and for the processing of personal data described in this Privacy Policy.

We process personal data in accordance with the UK GDPR and the Data Protection Act 2018, and, where we offer goods or services to individuals in the EU, the EU GDPR.

This policy applies when you buy from our store, contact us for sales, support or a general enquiry (including requesting a quote), use our AI support assistant, sign up to our marketing, or browse our websites.

Depending on how you interact with us, we may collect personal data including your name, business name, business tax identification or VAT number, email address, telephone number, billing, delivery and postal addresses, payment details (as set out in section 4.1), account, authentication information, details of products and services you purchase, and records of your communications with us.

We may also collect information about your preferences, interests, feedback and survey responses; your use of our websites, products and services (including our AI support assistant); content you submit or generate through our websites or AI support assistant (such as photos, messages, conversation histories and related metadata (for example date or location information)); and information about how you found us, including the marketing campaign, website or social media platform that referred you.

When you use our websites, we automatically collect certain technical information, including your IP address, device type and browser information, session identifiers, operating system, location and usage data, together with information collected through cookies and similar technologies.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate information about how you interact with and use our website, products and services (including our AI support assistant), and the resources that you access and the actions we and you take in relation to them, to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

4.1 When you place an order (our online store)

We operate our store on WooCommerce. We collect your name, email address, telephone number, billing and delivery address, business name, business tax identification or VAT number, details of products and services you purchase, and payment details (card payments are processed by our payment provider (Stripe) and we do not store your full card details; where you pay by bank transfer, we collect the bank details needed to take that payment). Our store uses guest checkout, and we do not create customer accounts and do not store account passwords.

4.2 When you use our AI support assistant

Through the AI support assistant we may collect your first name, the content you submit or generate (such as photos, messages, conversation histories and related metadata), the device details you provide (such as serial number, firmware and software version), any photos you upload. If your query is escalated to a member of our support team, your email address will be collected.

We also automatically process technical data when you use the assistant. This includes collecting the session identifier, your device type (mobile or desktop), message timestamps, and the language detected from your messages. Photos you upload may contain embedded metadata (for example date or location information). Cloudflare, which hosts the assistant, may process your IP address at network level.

Please find more information on how we use AI in section 6 below.

4.3 When you contact us for support, sales or a general enquiry

When you contact us for support, sales or a general enquiry, by phone, email, or a form on our websites, we hold the details of your enquiry and our correspondence in our customer-support and CRM systems, and we may open a support ticket. Where you use a form on our websites (which use Elementor Forms), we collect the details you provide, such as your name, email address, phone number and message; form submissions are stored on our website and sent to us by email.

4.4 When you sign up to marketing

If you opt in, we hold your email address, name and marketing preferences, and engagement data (such as whether you opened an email).

4.5 When you browse our websites

We collect data using cookies and other similar technologies. Please see section 4.7 for more information on our use of cookies and similar technologies.

We also collect internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our websites, and information about how you interact with and use our website, products and services (including our AI support assistant), and the resources that you access and the actions we and you take in relation to them.

4.6 When you request a quote

If you ask us for a price or proposal, we collect your name, business contact details (including your emails address), business name, business tax identification or VAT number and the details of your enquiry so we can prepare and send you a quote. We use Quotient to create and send quotes, which you can view and accept through Quotient’s secure online system.

4.7. Cookies & analytics

We use essential cookies to run our websites and store, and to help us improve your experience. With your consent, we use analytics and lead-tracking cookies (Google Analytics and WhatConverts) to understand how our sites are used. Google Analytics is not loaded until you accept analytics cookies via our cookie banner, and you can change your preferences at any time.

The information collected through the cookies and similar technologies is listed in our Cookies Notices. Our Group operates a number of websites. Each website uses its own cookies and similar technologies and has a separate Cookie Policy setting out the cookies used on that website, their purposes and retention periods. Please refer to the Cookie Policy available on the relevant website you are visiting for further information.

We use a cookie consent management tool (Termly) to present our cookie banner and record your choices across our sites.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We use AI powered tools and features across our websites and services and expect to introduce more over time. This section applies to all of them, now and in the future. Wherever one of our AI tools processes your personal data, the following applies:

• You'll always know when you're dealing with AI — where you're interacting with AI rather than a person, we make that clear before you start.
• AI generated responses may occasionally be inaccurate — please check anything important.
• A human is always available — you can ask to deal with a person, and our support assistants will escalate to our team.
• Please do not enter passwords, payment card details, account credentials or other sensitive information into our AI tools — they are not designed to collect it. We do not monitor what you type, so anything you enter is stored and processed as part of your conversation, like the rest of your message. If you've shared something you shouldn't have, contact us and we'll delete it where we're able to.
• What we may collect through our AI tools: your name; the content of your messages and conversations; any files or photos you provide (and their metadata); device details you give us (such as serial number, firmware and software version); and technical data such as a session identifier, device type, timestamps, the language detected and your IP address (at network level).
• Your inputs are processed on our behalf by third party AI service providers. Under our agreements with them, your data is used only to generate your result and is not used to train their AI models.
• Our AI tools do not make automated decisions that produce legal or similarly significant effects about you. If that ever changes for a particular tool, we'll tell you and explain your rights.
• Our use of AI reflects our obligations under the EU AI Act transparency rules and our internal Generative AI Policy.
• Where a support assistant passes your query to our team, we share only what's needed to help you — for example your email address and any device details, and (only if you choose to share it) your chat transcript and any photo you've uploaded.

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

We do not sell your personal data. We share it with the categories of service providers (“processors”) and recipients set out below, who act on our instructions under a data processing agreement (except where they act as independent controllers, as noted). A full, current list of the specific providers within each category is maintained in our processor register and is available on request.

The couriers, freight forwarders and delivery partners listed above handle your delivery details to complete carriage of your order; depending on the arrangement they act as our processors or as independent controllers under their own privacy policies. We may also disclose personal data to our bank and to regulators and tax authorities (such as the Financial Conduct Authority (FCA), HM Revenue & Customs (HMRC) and, for our Dutch VAT, the Netherlands tax authority (Belastingdienst)) where required by law, to our professional advisers (including our accountants and VAT/tax representatives), or in connection with a business sale or reorganisation.

Where we transfer your personal data between the UK and the EEA those transfers are made pursuant to the UK government's adequacy decision in favour of countries in the EEA and the European Commission's adequacy decision in favour of the UK.

Where we transfer personal data outside the UK / European Economic Area, we put appropriate safeguards in place — typically the UK International Data Transfer Addendum (Addendum) and/or the EU Standard Contractual Clauses (SCCs) within our agreements with those providers.

Your order data, backups, CRM/support records and payments are held in the UK or EU. Our internal Microsoft 365 email, calls and documents are held in the United Kingdom (with email filtering in the EU), and personal data we host or back up on Microsoft Azure is held in the UK or EU. Transfers outside the UK/EEA are limited to the AI and email layer of the support assistant (Google, Groq, Resend and Cloudflare’s global network), Google Analytics, our lead-tracking and attribution provider WhatConverts (United States), our accounting system Xero (United States, Australia and New Zealand), our quoting system Quotient (hosted on Amazon Web Services in the United States), and limited Microsoft service telemetry — each covered by the safeguards above. Where you order for delivery outside the UK/EEA, your delivery details are shared with the relevant international courier as necessary to complete that delivery.

We keep personal data for the periods above. We may retain certain data for longer only where necessary for legal, accounting, warranty, dispute-resolution or regulatory reasons. When data is no longer needed we delete or anonymise it.

You have the following rights under data protection laws in relation to your personal data.

• Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
• Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
• Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.)
• Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
• Restriction. Request that we restrict or suspend our processing of your personal data:
• if you want us to establish the data's accuracy;
• where our use of the data is unlawful, but you do not want us to erase it;
• where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
• you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
• Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Complain to us. If you are unhappy with how we process your personal data, please contact us first using the details below so that we have the chance to put it right. We will deal with all complaints in line with our complaints procedure, including to keep you informed about the progress and outcome of your complaint.
• Complain to the UK data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first, as described above so that we have the chance to put it right. However, you also have the right to make a complaint to the ICO at any time

You can exercise any of these rights at any time by contacting us at privacy@foresightsports.eu, or by post at Optimum Golf Technologies Limited, Unit 17 The Pines Business Park, Broad Street, Guildford, Surrey, GU3 3BH.

We take appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit, endpoint protection on company devices, and agreements with our processors. No system is completely secure, but we work to protect your data and to notify you and the regulator of any breach where required.

Our services are intended for adults and are not directed at children. We do not knowingly collect personal data from children.

We may update this policy from time to time; the “last updated” date shows the latest version. For any privacy question or to exercise your rights, contact us at privacy@foresightsports.eu, or by post at Optimum Golf Technologies Limited, Unit 17 The Pines Business Park, Broad Street, Guildford, Surrey, GU3 3BH.