Privacy Policy

GLOSSARY: DEFINITIONS

Defined Term

Definition

Automated Decision Making

a decision which has a significant effect on an individual, and is taken solely on the basis of automated Processing of Personal Data.  This means processing using, for example, software code or an algorithm, which does not require human intervention. A 'significant' effect includes, but is not limited to, a legal effect ‑ e.g. an individual loses a contractual right (such as their employment) as a result of the automated decision.  

Data Controller

is the person (ie company / legal entity / person) who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, Processed.

Data Subject

an identified or identifiable natural person whose Personal Data is being Processed.

Personal Data

any information capable of identifying a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their his or her physical, physiological, mental, economic, cultural or social identity.  Data is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link.

Profiling

using automated processes without human intervention (such as computer programmes) to analyse Personal Data in order to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Processing

any operation or set of operations that is performed upon Personal Data, whether or not by automatic means, including, but not limited to collection, recording, organisation, storage, access, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, making available, alignment, combination, blocking, deleting, erasure, or destruction.

Sensitive Personal Data or Special Category Data

are data considered to be "sensitive", requiring additional care when handling, including health, racial or ethnic origin, sexual life or orientation, religious or philosophical opinions, political opinions, trade union membership, or genetic or biometric data (for the purpose of uniquely identifying a living individual.  Also considered within the Special Categories of Personal Data are criminal history/ criminal convictions and data of children (13 (thirteen) years of age and under) and personal bank, credit card or other financial information.
 
SMARTGOLFGEAR.CO.UK PRIVACY NOTICE
Smartgolfgear.co.uk ("Company", "we" or "us") based at Aughton Common, Aughton, York, YO42 4PW  is responsible for your personal information and we take our data protection and privacy responsibilities seriously.
Important information about The Oaks Golf Club:
The Smartgolfgear.co.uk entity responsible for your personal information will be the member of  The Oaks Golf Club that originally collects information from or about you. This will be explained in separate privacy notices made available when your personal information are first collected by that Smartgolfgear.co.uk entity, for example where you or the business you work for engages us to provide a service.
You can find out more about our Group at http://theoaksgolfclub.co.uk/ or by contacting us using the information in the contact us section.
 
This privacy notice explains how we collect, use and share personal information in the course of our business activities, including:
What personal information we collect and when and why we use it.
How we share personal information within Company and with our service providers, regulators and other third parties
Explaining more about Direct Marketing, [Profiling], [and] [Automated Decision Making]
[Transferring personal information globally]
How we protect and store personal information
https://smartgolfgear.co.uk/pages/cookies
Legal rights available to help manage your privacy
How you can contact us for more support
Updates
We may amend this privacy notice from time to time to keep it up to date with legal requirements and the way we operate our business, and will place any updates on this webpage. [This privacy notice was last updated on 1st November 2018. Please regularly check these pages for the latest version of this notice.  If we make fundamental changes to this privacy notice, we will seek to inform you by notice on our website or email. 
Third Party Websites
You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site. We accept to no responsibility if you access any third party websites; if you click on to any such sites, you do so at your own risk.
WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT
In this section you can find out more about
  • the types of personal information we collect
  • when we collect personal information
  • how we use personal information
  • the legal basis for using personal information
 
When we collect information
We collect information about you if you:
  • register with or use our website or online services;
  • purchase one of our products or services;
collectively ("you").
Personal information we collect and use if you [use our websites or online services]
  • types of Personal Data you collect and use for each of these core relationships;
  • why you use it (i.e. for what purposes / processes);
  • that you collect data from the individual directly and (if relevant) what specific types of data you collect from third party sources and who those sources are; and
  • anything unusual or additional to explain specific aspects of the processing to make sure you are being fair and transparent ‑ e.g. use of Special Category Data, Auto Decision Making, Profiling, Direct Marketing.
Personal information we collect and use if you purchase one of our products or services.
Legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
  • we need to use your personal information to perform a contract or take steps to enter into a contract with you.  For example, to take payment for the product you ordered and arrange delivery to your home address.
  • we need to use your personal information for our legitimate interest as a commercial organisation. For example, we may record calls to our customer service centre so that we can review how we handle calls and make any necessary improvements.  In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in our Terms and Conditions.
  • we need to use your personal information to comply with a relevant legal or regulatory obligation that we have.  
  • we have your consent to using your personal information for a particular activity.  
If you would like to find out more about the legal basis for which we process personal information please contact us 
SHARING PERSONAL INFORMATION WITH OTHERS
In this section you can find out more about how we share personal information:
  • within Company
  • with third parties that help us provide our products and services; 
  • government organisations and agencies, law enforcement and regulators
 
We share your personal information in the manner and for the purposes described below:
  • within our The Oaks Golf Club where such disclosure is necessary to provide you with our products and services or to manage our business. 
  • with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
  • with government organisations and agencies, law enforcement, regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  • banks and payment providers to authorize and complete payments;
  • with credit reference agencies and organisations working to prevent fraud in financial services;
  • we may share in aggregate, statistical form, non‑personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.
 
EXPLAINING MORE ABOUT DIRECT MARKETING 
In this section you can find out more about:
  • how we use personal information to keep you up to date with our products and services
  • how you can manage your marketing preferences
  • when and how we undertake profiling and analytics
  • when and how we carry out automated decision making
 
How we use personal information to keep you up to date with our products and services
We may use personal information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. 
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
  • we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
  • at any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communicate with you, including how you receive details of latest offers or news updates from us
  • if you have an online account with us, the easiest way to make updates to your marketing preferences and/or change your personal details is to log onto your account.  You can also click the "unsubscribe" link that you find on any online newsletters you receive or contact our customer support team.
  • you can ask us to stop direct marketing at any time ‑ you can ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively you can contact us at [link]. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
  • you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained.
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
In this section you can find out more about:
  • how we operate as a global business and transfer data internationally.
  • the arrangements we have in place to protect your personal information if we transfer it overseas.
 
We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU, that are subject to different standards of data protection.
We will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
  • we ensure transfers within The Oaks Golf Club will be covered by an agreement entered into by members of The Oaks Golf Club (an intra‑group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within The Oaks Golf Club;
  • where we transfer your personal information outside The Oaks Golf Club or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU ‑ US Privacy Shield for the protection of personal information transferred from within the EU to the United States; or
  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above. 
 
 
HOW WE PROTECT AND STORE YOUR INFORMATION
Security
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.
Measures we take include:
  • placing confidentiality requirements on our staff members and service providers;
  • destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
  • following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it;
  • using secure communication transmission software (known as "secure sockets layer" or "SSL") that encrypts all information you input on our website before it is sent to us.  SSL is an industry standard encryption protocol and this ensure that the information is reasonably protected against unauthorized interception.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information.
Storing your personal information
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy notice. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting  requirements. 
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
COOKIES
A cookie is a small text file containing small amounts of information which is downloaded to/stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your country, language and other settings. Cookies allow us to understand who has seen which web pages [and advertisements], to determine how frequently particular pages are visited and to determine the most popular areas of our website.They can also help us to operate our website more efficiently and make your next visit easier. Cookies can allow us to do various other things, as explained further in our Cookie Policy which you can access by clicking on the link below. 
For more information about how our cookies work and information about how to manage your cookie settings please visit our Cookie Policy.
 
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Contact us about any of the following:
To access personal information
  • To rectify / erase personal information
  • To restrict the processing of your personal information
  • To transfer your personal information
  • To object to the processing of personal information
  • To object to how we use your personal information for direct marketing purposes
  • To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
  • To lodge a complaint with your local supervisory authority
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. 
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
 
Right to access personal information
You have a right to request that  we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information  may be transferred.
Right to rectify or erase personal information
You have a right to request that  we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information  before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where the data processing was based on consent); or
  • following a successful right to object  or
  • it has been processed unlawfully; or
  • to comply with a legal obligation to which the Company is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims;
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
  • we have your consent; or
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine‑readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
  • the processing is based on your consent or on the performance of a contract with you; and
  • the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection,  we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that  we not transfer your personal information  to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information  is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time. 
CONTACT US
The primary point of contact for all issues arising from this privacy notice is our Data Protection Officer. The Data Protection Officer can be contacted in the following ways:
info@smartgolfgear.co.uk
01757 288007
Aughton Common, Aughton, York, YO42 4PW.
If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact [our Data Protection Officer] or [us]. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement)[, which in the UK is the Information Commissioner's Office] at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.
Issue Date of Privacy Notice: 31st October 2018