Legal Risks in Mel Sole Golf Schools’ Privacy Policy: Key Gaps and Compliance Solutions | Erayaha

## Uncovering Legal Risks in Mel Sole Golf Schools’ Privacy Policy

When we examined Mel Sole Golf Schools’ Privacy Policy, our analysis revealed several legal and logical vulnerabilities that could expose the company to significant regulatory fines and litigation costs. For example, non-compliance with GDPR or CCPA could result in penalties up to €20 million or 4% of annual global turnover. Below, we highlight four key issues and provide actionable improvements to strengthen enforceability and compliance.

1. Ambiguous Data Usage Purposes The policy states that personal data may be used for "other purposes" such as data analysis and improving services, without specifying the legal basis or providing opt-out mechanisms. This ambiguity increases the risk of regulatory scrutiny and user complaints, especially under GDPR Article 5, which requires purpose limitation and transparency. A recent enforcement action by the UK ICO resulted in a £500,000 fine for similar vague language.

Legal Analysis

high Risk

Removed

Added

For other purposes: We may use Your information only for other purposesspecific, suchclearly defined purposes as data analysisoutlined in this policy, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Serviceonly where we have a lawful basis under applicable data protection laws. Any additional processing will require your explicit consent or a new legal basis, products, services, marketing and your experienceyou will be informed of such processing in advance.

Legal Explanation

The original clause is overly broad and lacks specificity, violating GDPR’s purpose limitation and transparency requirements. The revision limits use to defined purposes and requires lawful basis and user notification for any new processing, reducing regulatory risk.

2. Inadequate International Data Transfer Safeguards The Privacy Policy allows for transfer of personal data to jurisdictions with differing data protection standards, but does not specify safeguards like Standard Contractual Clauses (SCCs) or adequacy decisions. This omission could lead to enforcement actions under GDPR Chapter V, with potential fines reaching millions of euros for improper cross-border transfers.

Legal Analysis

critical Risk

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Added

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers locatedprocessed in jurisdictions outside of Your stateyour own. Where such transfers occur, provincewe will implement appropriate safeguards, countrysuch as Standard Contractual Clauses or other governmental jurisdiction where therely on adequacy decisions, to ensure your data is protected in accordance with applicable data protection laws may differ than those from Your jurisdiction.

Legal Explanation

The original clause fails to specify required safeguards for international data transfers under GDPR Chapter V. The revision introduces SCCs and adequacy decisions, ensuring legal compliance and reducing enforcement risk.

3. Insufficient Children’s Data Protection Procedures While the policy states that the service is not intended for children under 13, it lacks a robust verification mechanism or parental consent process, as required by COPPA and similar laws. Failure to implement these measures could result in FTC penalties of up to $43,792 per violation.

Legal Analysis

high Risk

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Added

Our Service doesis not address anyoneintended for children under the age of 13. We do not knowingly collect personally identifiable information from anyone underimplement reasonable measures to verify the age of 13. If You are a parent or guardianusers and You are aware that Your child has provided Us with Personal Data, please contact Uswhere applicable, obtain verifiable parental consent before collecting personal information from children, in accordance with COPPA and similar laws. If Wewe become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that informationunauthorized data collection from Our serverschildren, we will promptly delete such data and notify affected parents or guardians.

Legal Explanation

The original clause lacks a clear verification or parental consent mechanism, as required by COPPA. The revision adds specific procedures for age verification and parental consent, reducing risk of regulatory penalties.

4. Vague Data Retention Terms The policy indicates data will be retained "only for as long as is necessary," but does not define specific retention periods or criteria. This lack of specificity can lead to non-compliance with GDPR Article 13(2)(a) and increased risk of data subject complaints or regulatory action.

Legal Analysis

medium Risk

Removed

Added

The Company will retain Youryour Personal Data only for as long as is necessary fordefined periods based on the specific purposes set outoutlined in this Privacy Policy, or as required by applicable law. We will retainRetention periods and use Your Personal Datacriteria will be communicated to the extent necessary to comply with our legal obligations (for exampleyou, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce ourdata will be securely deleted or anonymized once no longer necessary for the stated purposes or legal agreements and policiesobligations.

Legal Explanation

The original clause is vague and does not specify retention periods or criteria, risking non-compliance with GDPR Article 13(2)(a). The revision introduces defined retention periods and transparency, reducing regulatory and litigation risk.

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Conclusion: Proactive Legal Protection is Essential Our analysis shows that Mel Sole Golf Schools faces substantial legal and financial risks due to ambiguous, incomplete, or non-compliant privacy terms. Addressing these issues with precise language and robust procedures can reduce exposure to regulatory fines, litigation, and reputational harm.

How confident are you that your privacy policy can withstand a regulatory audit?
Are your data practices transparent and defensible in court?
What proactive steps can you take to close compliance gaps before they become costly liabilities?

This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai’s terms of service for liability limitations.