How we handle your data.

1. Who We Are

HAMER Golf Consulting is a golf consulting firm operating internationally. We provide collegiate placement services, year-round player development, and camp program architecture.

For data protection matters, you may contact us at: info@hamergolfconsulting.com.

2. What Personal Data We Collect

Depending on the services you request, we may collect:

• Identification and contact data: name, email, phone number, postal address, country of residence
• Beneficiary data (for Recruit and Consult): the junior athlete's name, age, school, grade level, academic records, athletic profile, handicap, ranking, tournament history
• Family data: parent or guardian identification, contact details, relationship to the Beneficiary
• Payment data: processed by Stripe; HAMER does not store credit card numbers. We receive only the transaction confirmation and the email associated with the purchase
• Communications: emails, messages, call recordings (only with prior consent), and meeting notes
• Website data: IP address, browser type, pages visited, referral source — collected via standard server logs and (where applicable) analytics tools

3. Why We Collect Personal Data (Legal Basis)

We process personal data on the following legal grounds:

• Contract performance: to deliver the services you have purchased
• Legitimate interests: to run and improve our business, prevent fraud, ensure security, and communicate with clients
• Consent: where you have given us specific consent (for example, to record a video call or to send marketing communications)
• Legal obligation: where required by law, including tax record-keeping and responding to lawful requests from authorities

4. How Long We Keep Personal Data

We retain personal data for as long as needed to provide services and to meet legitimate business and legal requirements. Specifically:

• Active client records: for the duration of the engagement, plus 7 years after termination (to address potential disputes and meet tax-record-keeping obligations)
• Beneficiary athletic profiles and recruitment materials: for 5 years after engagement end, then deleted or anonymized
• Payment records: 10 years, as required by applicable tax and accounting law
• Website analytics: aggregated and anonymized data may be retained indefinitely; individual visitor data is retained for 26 months

5. With Whom We Share Personal Data

We share personal data only with the parties below, and only to the extent necessary:

• Service providers: payment processor (Stripe), email and website infrastructure (Google, Hostinger), scheduling and video tools — each bound by their own data protection obligations
• NCAA programs, coaches, and admissions officers: only with the Client's express direction, for the purpose of college placement
• Professional advisors: legal counsel, accountants — bound by professional confidentiality
• Authorities: when required by law, court order, or to defend our legal rights
• We do not sell personal data. We do not share personal data with advertisers.

6. International Data Transfers

HAMER operates internationally. Client data may be transferred to and processed in countries other than the country of residence, including the United States, Mexico, and the European Union.

For transfers from the European Economic Area or the United Kingdom to countries that have not been recognized as providing an adequate level of protection, we rely on the European Commission's Standard Contractual Clauses and on the data protection contractual commitments of our service providers (notably Stripe and Google).

Where you are resident in Mexico, transfers are made in accordance with Article 36 of the LFPDPPP, on the basis of the contract for services.

7. Your Rights

Depending on your country of residence, you have the following rights regarding your personal data:

• Access: to know what personal data we hold about you and to receive a copy
• Rectification: to correct inaccurate or incomplete data
• Deletion: to request the deletion of your data, subject to our legal retention obligations
• Restriction: to ask us to limit how we process your data
• Portability: to receive your data in a structured, commonly used, machine-readable format
• Objection: to object to processing based on legitimate interests
• Withdrawal of consent: where processing is based on consent, you may withdraw it at any time
• Complaint: to lodge a complaint with the data protection authority in your country (in Spain: AEPD; in Mexico: INAI; in the EU: the supervisory authority of your member state)

8. How to Exercise Your Rights

To exercise any of the rights above, please email info@hamergolfconsulting.com from the email address associated with your account, indicating the right you wish to exercise. We will respond within 30 calendar days (or sooner where required by applicable law).

We may ask for proof of identity before responding, to protect your data from unauthorized access.

9. Cookies and Tracking

Our website uses essential cookies required for functionality and (subject to your consent) analytics cookies that help us understand how the site is used. Where required by law, we will request your consent before placing non-essential cookies.

You can manage cookie preferences through your browser settings.

When you proceed to checkout, payment processing is handled by Stripe, which sets its own cookies in accordance with the Stripe Privacy Policy (stripe.com/privacy).

10. Children and Minors

Our services frequently involve minors (junior golf athletes). We collect data about minors only with the consent of, and through, the parent or legal guardian, who is the contracting party for these Terms.

We do not direct marketing communications to minors. The parent or legal guardian is responsible for sharing relevant information with the minor in an age-appropriate manner.

11. Security

We implement commercially reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These include access controls, encryption in transit (TLS), and reliance on reputable service providers (Stripe, Google Workspace) with their own robust security programs.

No system is perfectly secure. We will notify affected individuals and the competent authorities, as required by applicable law, in the event of a personal data breach likely to result in a high risk to the rights and freedoms of data subjects.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Material changes will be communicated by email to active clients at least 30 days before they take effect. The "Effective" date at the top of this notice reflects the most recent update.

13. Contact

For any privacy-related question or to exercise your rights, contact us at info@hamergolfconsulting.com.