List of processors and data recipients
golfactive.eu — SELKANO KANIEWSKI SP.J.
1. Why this list is so short
The Golf Active app has no server storing player data. There are no accounts, no user database, no payment system, no SMS delivery and no analytics — so there are no suppliers to entrust with such data. The list below is complete, not abbreviated.
For comparison: our Camp2Find platform, which handles campsite reservations, relies on seven sub-processors. Here there are two, one of which concerns e-mail only.
2. Processors
A processor acts on our documented instructions under a contract meeting the requirements of Article 28(3) GDPR.
| Entity | Location | Purpose | Data categories | Processing region | Transfer safeguard | DPA |
|---|---|---|---|---|---|---|
| Cloudflare, Inc. | 101 Townsend Street, San Francisco, CA 94107, USA | static hosting (Cloudflare Pages), content delivery network, protection against volumetric attacks | connection data: IP address, HTTP headers, requested resources, response code | global edge network, EU locations preferred | standard contractual clauses (Implementing Decision (EU) 2021/914) + EU-US Data Privacy Framework | cloudflare.com/cloudflare-customer-dpa |
SEOhost.pl [1] (server h74.seohost.pl) |
Poland | e-mail hosting — operating the hello@golfactive.eu mailbox | e-mail addresses, content and metadata of correspondence | Poland | not applicable — processing within the EEA | hosting provider's data processing agreement |
[1] The provider's full registration details will be completed on publication. Selection criteria for the mail provider: processing exclusively within the EEA and a data processing agreement compliant with Article 28 GDPR.
3. Recipients acting as separate controllers
These entities are not our processors — they determine their own purposes and means and carry their own responsibility.
| Entity | Location | When disclosure occurs | Data | Transfer safeguard |
|---|---|---|---|---|
| OpenStreetMap Foundation | St John's Innovation Centre, Cowley Road, Cambridge CB4 0WS, United Kingdom | when the player's browser fetches a basemap tile — the connection is made directly from the player's device, not through our servers | IP address, request headers, tile coordinates | European Commission adequacy decision for the United Kingdom (Article 45 GDPR) |
| Accountants / tax advisers | Poland | settlement of contracts with golf clubs | contact and billing data of club representatives (never player data) | not applicable |
| Public authorities | Poland / EU | only where required by law | as required by the request | not applicable |
How to avoid disclosure to the OpenStreetMap Foundation: the basemap can be switched off in the app settings. The app then makes no connection to any external server at all — the course drawing, distances and scorecard remain fully functional.
4. What is not on this list
For the avoidance of doubt, we do not use:
| Category | Status |
|---|---|
| Web analytics (Google Analytics, Matomo, Plausible, PostHog) | ❌ not used |
| Ad networks and remarketing platforms | ❌ not used |
| Error monitoring tools collecting user data (Sentry, Datadog RUM) | ❌ not used |
| Authentication providers and account systems | ❌ not used — there are no accounts |
| Payment providers | ❌ not used — players pay nothing |
| SMS gateways and push notification providers | ❌ not used |
| External font libraries, script CDNs | ❌ not used — everything is served from our own domain |
| Mapping services other than OpenStreetMap (Google Maps, Mapbox, MapTiler) | ❌ not used |
5. Change procedure
Applies to golf clubs that have concluded a data processing agreement with us:
- We give at least 30 days' notice by e-mail before adding or replacing a sub-processor.
- The notice states the entity's name and location, purpose, data categories, processing region and transfer safeguard.
- The club has 30 days to raise a reasoned objection.
- If an objection is raised, we look for an alternative; if none is found within 30 days, the club may terminate without early termination costs.
- Silence within the period constitutes acceptance.
Details: section 6 of the Data Processing Agreement.
6. Change history
| Date | Version | Change |
|---|---|---|
| 2026-08-04 | 1.0 | List created |
Every change to this list is recorded above together with its effective date.
7. Contact
SELKANO KANIEWSKI SP.J. ul. Poznańska 11, 78-100 Kołobrzeg, Poland hello@golfactive.eu
_SELKANO KANIEWSKI SP.J., Kołobrzeg, 4 August 2026_