Privacy Policy

How EPSza (Pty) Ltd collects, uses, shares and protects personal information in the S19LABS Players Coaching App and on the Studio19 website at s19labs.web.app, where you can also create an account. S19LABS is part of Studio19, a product and service of EPSza (Pty) Ltd.

Effective date: 28 July 2026  ·  EPSza (Pty) Ltd — Studio19  ·  Version 1.1

This Privacy Policy should be read together with the S19LABS Terms of Use, and is published at https://s19labs-privacy.web.app.

1. Responsible Party

1.1 EPSza (Pty) Ltd, Registration Number 2014/099878/07, VAT Number 432 028 0391, of 359 Pienaar Street, Brooklyn, Pretoria, 0181, is the responsible party under the Protection of Personal Information Act 4 of 2013 ("POPIA") for personal information processed through S19LABS, the Players Coaching App forming part of Studio19.

1.2 The Information Officer is W.A. Burger (Chief Executive Officer). The Information Officer can be reached by emailing william.erasmus@eps.ch or ian.deale@eps.ch, marked for the attention of the Information Officer.

1.3 Two types of account. For self-registered adults, EPSza is the responsible party as set out in clause 1.1. For coach-managed accounts (players, including minors, whose profiles are created by a Studio19 Certified Coach or academy), the coach or academy is the responsible party and EPSza acts as an operator, processing that personal information on the coach's documented instructions under a data processing agreement. Section 9 explains this in more detail.

2. Information We Collect

• Account information: first name, last name, email address, phone number (with country code), gender, handedness, and an optional golf handicap, provided at registration or by your coach; and a user ID processed through Google Firebase Authentication for sign-in. If you create your account on the website we collect less: first name, last name, email address and gender only. Gender is collected because your Swing Blueprint is benchmarked against the matching tour reference, and is not used for any other purpose. Phone number, handedness and handicap are not collected at website registration; handedness defaults to right-handed and both it and a handicap can be set later in the App. Your password is set directly with Google Firebase Authentication and is never seen or stored by EPSza. We send a verification email to the address you provide.
• Profile photo (optional): if you choose to set a profile picture, the image you select from your device’s photo library is uploaded and stored with your account so that it can appear in the App. Setting a photo is entirely optional — the App works normally without one — and you can replace or remove it at any time. We access your photo library only at the moment you pick an image, and we do not otherwise browse or collect anything from it.
• Coaching and performance data: your recordings, launch monitor data (such as carry, speed and spin), feedback videos, coach voice and text annotations, ratings, coaching notes, drills and bookings. This content is created by your Studio19 Certified Coach using Studio19 tools and made available to you through the App. The App does not itself record or upload video or audio. Session recording (video, audio and session data) takes place under a recording consent obtained by your coach at onboarding — from you if you are an adult, or from a parent or guardian if you are under 18 — which applies to your ongoing sessions until withdrawn.
• Technical and diagnostics data: collected via Google Firebase Crashlytics to keep the App stable — standard device model, operating system, app version, a Crashlytics installation identifier, and crash reports. Crash reports are associated only with opaque identifiers (a random Firebase user ID that is cleared on sign-out, non-personal build flags, and an internal player identifier), not with your name, email, phone number or other personal details. We do not use advertising or product-analytics SDKs and do not collect advertising identifiers.

You can self-register either in the App or on the website at s19labs.web.app. Either way you must accept the Terms of Use and confirm you have read this Privacy Policy before an account is created, and a self-registered account is always a plain player account — it never carries coach or administrator permissions.

Self-registration is for adults only, in the App and on the website alike. When you self-register you are asked to confirm that you are 18 or older. We do not knowingly allow anyone under 18 to self-register or knowingly collect their personal information through self-registration; if we become aware that a self-registered account belongs to a person under 18, we will delete it. Minors may use the App only through a coach-managed account (see section 9), where the coach is the responsible party and holds the required parental or guardian consent.

3. How and Why We Use It

• To provide the Service (profile, recording, storage, coaching analysis and feedback) — necessary to perform our contract with you.
• Service communications (account, security and coaching notifications by in-app message, email or WhatsApp) — necessary to perform our contract.
• Marketing by email or WhatsApp — only with opt-in consent, as required by section 69 of POPIA. WhatsApp is used, if at all, as an off-app business communication channel, not within the App. Every message includes an opt-out, and you can opt out at any time without affecting service messages.
• Public use of content (Studio19 Activations, marketing, social media, public livestreams) — only with the required opt-in consent (see section 5). For coach-managed accounts, this consent is held by the coach (see section 9).
• Security, debugging and improvement, and compliance with law — our legitimate interests and legal obligations.

4. Who We Share It With

• Studio19 Certified Coaches and academies, to deliver coaching. For coach-managed accounts, the coach is the responsible party and EPSza processes the data as operator on the coach's instructions (see section 9).
• Service providers (operators): Google Cloud Platform (backend, video storage and streaming, hosted in the africa-south1 / Johannesburg region), Google Firebase Authentication (sign-in and password-reset emails), and Google Firebase Crashlytics (crash diagnostics). These providers process data on our behalf under their own security and privacy terms. We do not use advertising or product-analytics providers.
• Apple and Google, which process certain data (such as purchases and crash data) under their own terms.
• The public, only for content covered by the applicable consent under section 5.
• Authorities or other parties where disclosure is required by law, and a successor business in a merger or sale, under equivalent protection.

We do not sell your personal information.

5. Livestreams and Public Content

5.1 With the required opt-in consent, recordings or live footage may be publicly displayed and livestreamed, including on third-party platforms. For self-registered adults, you give this consent yourself. For coach-managed accounts, including minors, the consent (including any parental or guardian consent) is obtained and held by the coach as responsible party. Consent may be withdrawn at any time — by the adult, or for a coach-managed account through the coach; withdrawal stops future use and we will remove content from channels under our control, but it cannot retract content already broadcast or copied by third parties.

6. Cross-Border Transfers

6.1 Our primary application and video data are hosted in South Africa (Google Cloud, africa-south1 / Johannesburg). Authentication is provided by Google Firebase, which may process limited account and security data (such as IP address, for security and abuse prevention) outside South Africa, including in the United States. Any such transfer complies with section 72 of POPIA, through recipients bound by law or contract to a substantially similar level of protection, or with your consent.

7. Retention

7.1 We keep your account and coaching data while your account is active. On account deletion, we delete your sign-in credentials and account and profile details. Coaching records made available through the App — recordings, launch monitor data, feedback videos and coach annotations — are created and held by your coach and are retained after account deletion unless you or your coach separately request their removal, in which case we will delete them; requests are actioned within 30 days. Anonymised or aggregated data that no longer identifies you may be retained. We also keep records we are required to keep by law.

8. Security

8.1 We apply reasonable and appropriate technical and organisational safeguards as required by section 19 of POPIA, including: encryption of data in transit (HTTPS/TLS); access controls so that only authorised personnel and your coach can access your information; secure, access-controlled cloud hosting with a reputable provider; regular backups; and staff confidentiality obligations. If a breach creates a risk of harm, we will notify the Information Regulator and affected users as required by section 22 of POPIA.

9. Coach-Managed Accounts and Minors

9.1 A Studio19 Certified Coach or academy may create profiles in the App for their players — including minors — from their coach dashboard and issue login details to those players. This is the only route by which a person under 18 may use the App.

9.2 For these coach-managed accounts, the coach or academy is the responsible party for the players' personal information, and EPSza acts as an operator under section 20 of POPIA, processing that information only on the coach's documented instructions and under a signed data processing agreement.

9.3 The coach or academy is responsible for obtaining and holding all consents required for their players, including the consent of a parent or legal guardian where the player is a minor, and any consent required for public, social media, activation or livestream use of a player's content. EPSza relies on the coach's confirmation that these consents are in place.

9.4 If you are a parent, guardian or player with a coach-managed account and wish to access, correct or delete personal information, or to withdraw a consent, please contact your coach or academy in the first instance, as the responsible party. You may also contact EPSza, and we will assist the coach as operator and act on their instructions.

10. Your Rights

10.1 Subject to law, you may: access the personal information we hold about you; request correction or deletion; object to processing, including direct marketing; and withdraw any consent at any time with future effect. For self-registered accounts, contact us at william.erasmus@eps.ch or ian.deale@eps.ch, marked for the attention of the Information Officer; we may verify your identity first. For coach-managed accounts, see section 9.4. You may also complain to the Information Regulator (South Africa): complaints.IR@justice.gov.za / inforeg.org.za.

10.2 You can delete your account and data using the Delete account option in your profile, or at https://s19labs-privacy.web.app/delete-account (or by emailing ian.deale@eps.ch from your account address). For coach-managed accounts, your coach can also remove your profile.

11. Changes and Contact

11.1 We may update this Privacy Policy; material changes will be notified in the App or by email before they take effect. The current version is available at https://s19labs-privacy.web.app.

11.2 EPSza (Pty) Ltd (Registration Number 2014/099878/07, VAT Number 432 028 0391) — Studio19 | Address: 359 Pienaar Street, Brooklyn, Pretoria, 0181 | Information Officer: W.A. Burger | Contact (all enquiries, including privacy): william.erasmus@eps.ch or ian.deale@eps.ch