General Data Protection Regulation Policy for Fairwayfirstgolf.com

Introduction

Welcome to Fairway First Golf’s privacy notice.

Fairway First Golf respects your privacy and is committed to protecting your personal
data. This privacy notice will inform you as to how we look after
your personal data when you visit our website (regardless of where
you visit it from) and tell you about your privacy rights and how the
law protects you.

  1. Important
    information and who we are

Purpose of
this privacy notice

This privacy
notice aims to give you information on how Fairway First Golf collects
and processes your personal data through your use of this website,
including any data you may provide through this website when you sign
up to our newsletter, blog or purchase a product or service.

This website is
not intended for children and we do not knowingly collect data
relating to children.

It is important
that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions
when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to
override them.

Controller

Fairway Firsy Golf is the controller and responsible for your personal data
(collectively referred to as “Fairway First Golf”, “we”,
“us” or “our” in this privacy notice).

If you have any
questions about this privacy notice, including any requests to
exercise your legal rights, please contact us using the details set
out below.

Contact
details

Our full details
are:

Full name of
legal entity: Fairway First Golf

Email address: nick@fairwayfirstgolf.com

Postal address:
20 Allée Maurice Ravel, 01000 bourg-en-bresse, France

You have the
right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first
instance.

Changes to
the privacy notice and your duty to inform us of changes

It is important
that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your
relationship with us.

Third-party
links

This website may
include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third
parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the
privacy notice of every website you visit.

  1. The data we
    collect about you

Personal data,
or personal information, means any information about an individual
from which that person can be identified. It does not include data
where the identity has been removed (anonymous data).

We may collect,
use, store and transfer different kinds of personal data about you
which we have grouped together follows:

  • Identity
    Data
    includes first name, ,
    last name, username or similar identifier, title,
    date of birth and gender.
  • Contact Data
    includes  delivery address, email address
  • Technical
    Data
    includes internet protocol (IP) address, your login data,
    browser type and version, time zone setting and location, browser
    plug-in types and versions, operating system and platform and other
    technology on the devices you use to access this website.
  • Profile Data
    includes your username and password, purchases or orders
    made by you, your interests, preferences, feedback and survey
    responses.
  • Usage Data
    includes information about how you use our website, products and
    services.
  • Marketing
    and Communications Data
    includes your preferences in receiving
    marketing from us and our third parties and your communication
    preferences.

We also collect,
use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from
your personal data but is not considered personal data in law as this
data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage
of users accessing a specific website feature. However, if we combine
or connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy
notice.

We do not
collect any Special Categories of Personal Data about you
(this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and
genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.

If you fail
to provide personal data

Where we need to
collect personal data by law, or under the terms of a contract we
have with you and you fail to provide that data when requested, we
may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the
time.

  1. How is your
    personal data collected?

We use different
methods to collect data from and about you including through:

  • Direct
    interactions
    . You may give us your Identity or Contact  by filling in forms or by corresponding with us by
    post, phone, email or otherwise. This includes personal data you
    provide when you:
  • apply for our
    products or services;
  • create an
    account on our website;
  • subscribe to
    our service or publications;
  • request
    marketing to be sent to you;
  • enter a
    competition, promotion or survey; or
  • give us some
    feedback.
  • Automated
    technologies or interactions.
    As you interact with our website,
    we may automatically collect Technical Data about your equipment,
    browsing actions and patterns. We collect this personal data by
    using cookies, server logs and other similar technologies. We
    may also receive Technical Data about you if you visit other
    websites employing our cookies.Please see our cookie policy for further details.
  • Third
    parties or publicly available sources.
    We may receive personal
    data about you from various third parties and public sources as
    set out below:
  • Technical Data
    from the following parties:
  1. analytics
    providers;
  2. advertising
    networks based inside OR
    outside the EU; and
  3. search
    information providers based inside OR
    outside the EU.
  • Contact,
    Financial and Transaction Data from providers of technical, payment
    and delivery services based inside OR
    outside the EU.
  • Identity
    and Contact Data from data brokers or aggregators based inside OR
    outside the EU.
  • Identity
    and Contact Data from publicly availably sources.
  1. How we use
    your personal data

We will only use
your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances:

  • Where we need
    to perform the contract we are about to enter into or have entered
    into with you.
  • Where it is
    necessary for our legitimate interests (or those of a third party)
    and your interests and fundamental rights do not override those
    interests.
  • Where we need
    to comply with a legal or regulatory obligation.

Generally we do
not rely on consent as a legal basis for processing your personal
data other than in relation to sending third party direct marketing
communications to you via email or text message. You have the right
to withdraw consent to marketing at any time by contacting us on
nick@fairwayfirstgolf.com.

Purposes for
which we will use your personal data

We have set out
below, in a table format, a description of all the ways we plan to
use your personal data, and which of the legal bases we rely on to do
so. We have also identified what our legitimate interests are where
appropriate.

Note that we may
process your personal data for more than one lawful ground depending
on the specific purpose for which we are using your data. Please
contact
us if you need details about
the specific legal ground we are relying on to process your personal
data where more than one ground has been set out in the table below.

Purpose/Activity Type
of data
Lawful
basis for processing including basis of legitimate interest
To
register you as a new customer
(a)
Identity(b)
Contact
Performance
of a contract with you
To
process and deliver your order including:(a)
Manage payments, fees and charges

(b)
Collect and recover money owed to us

(a)
Identity(b)
Contact

(c)
Financial

(d)
Transaction

(e)
Marketing and Communications

(a)
Performance of a contract with you(b)
Necessary for our legitimate interests (to recover debts due to
us)
To
manage our relationship with you which will include:(a)
Notifying you about changes to our terms or privacy policy

(b)
Asking you to leave a review or take a survey

(a)
Identity(b)
Contact

(c)
Profile

(d)
Marketing and Communications

(a)
Performance of a contract with you(b)
Necessary to comply with a legal obligation

(c)
Necessary for our legitimate interests (to keep our records
updated and to study how customers use our products/services)

To
enable you to partake in a prize draw, competition or complete a
survey
(a)
Identity(b)
Contact

(c)
Profile

(d)
Usage

(e)
Marketing and Communications

(a)
Performance of a contract with you(b)
Necessary for our legitimate interests (to study how customers use
our products/services, to develop them and grow our business)
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
(a)
Identity(b)
Contact

(c)
Technical

(a)
Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or
group restructuring exercise)(b)
Necessary to comply with a legal obligation
To
deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we
serve to you
(a)
Identity(b)
Contact

(c)
Profile

(d)
Usage

(e)
Marketing and Communications

(f)
Technical

Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to
inform our marketing strategy)
To
use data analytics to improve our website, products/services,
marketing, customer relationships and experiences
(a)
Technical(b)
Usage
Necessary
for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant,
to develop our business and to inform our marketing strategy)
To
make suggestions and recommendations to you about goods or
services that may be of interest to you
(a)
Identity(b)
Contact

(c)
Technical

(d)
Usage

(e)
Profile

Necessary
for our legitimate interests (to develop our products/services and
grow our business)

Marketing

We strive to
provide you with choices regarding certain personal data uses,
particularly around marketing and advertising:

Promotional
offers from us

We may use your
Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to
you. This is how we decide which products, services and offers may be
relevant for you (we call this marketing).

You will receive
marketing communications from us if you have requested information
from us or purchased goods or services from us or if you provided us
with your details when you entered a competition or registered for a
promotion and, in each case, you have not opted out of receiving that
marketing.

Third-party
marketing

We will get your
express opt-in consent before we share your personal data with any
third party company for marketing purposes.

Opting out

You can ask us
or third parties to stop sending you marketing messages at any time
by contacting us.

Where you opt
out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service
purchase, product/service experience or other transactions.

Cookies

You can set your
browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies,
please note that some parts of this website may become inaccessible
or not function properly.

Change of
purpose

We will only use
your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to
get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact
us.

If we need to
use your personal data for an unrelated purpose, we will notify you
and we will explain the legal basis which allows us to do so.

Please note that
we may process your personal data without your knowledge or consent,
in compliance with the above rules, where this is required or
permitted by law.

  1. Disclosures
    of your personal data

We may have to
share your personal data with third parties to whom we may choose to
sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may
use your personal data in the same way as set out in this privacy
notice.

We require all
third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third-party
service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified
purposes and in accordance with our instructions.

  1. International
    transfers

We do not
transfer your personal data outside the European Economic Area (EEA).

OR

Many of our
external third parties are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a
transfer of data outside the EEA.

Whenever we
transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of
the following safeguards is implemented :

  • We will only
    transfer your personal data to countries that have been deemed to
    provide an adequate level of protection for personal data by the
    European Commission. For further details, see European
    Commission: Adequacy of the protection of personal data in non-EU
    countries.
  • Where we use
    certain service providers, we may use specific contracts approved by
    the European Commission which give personal data the same protection
    it has in Europe. For further details, see European
    Commission: Model contracts for the transfer of personal data to
    third countries.
  • Where we use
    providers based in the US, we may transfer data to them if they are
    part of the Privacy Shield which requires them to provide similar
    protection to personal data shared between the Europe and the US.
    For further details, see European
    Commission: EU-US Privacy Shield.

Please contact
us if you want further
information on the specific mechanism used by us when transferring
your personal data out of the EEA.

  1. Data
    security

We have put in
place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised
way, altered or disclosed. In addition, we limit access to your
personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of
confidentiality.

We have put in
place procedures to deal with any suspected personal data breach and
will notify you and any applicable regulator of a breach where we are
legally required to do so.

  1. Data
    retention

How long will
you use my personal data for?

We will only
retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.

To determine the
appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential
risk of harm from unauthorised use or disclosure of your personal
data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.

  1. Your legal
    rights

Under certain
circumstances, you have rights under data protection laws in relation
to your personal data and to access the same as set out in the
Glossary. If you wish to exercise any of these rights then please do
contact us.

No fee
usually required

You will not
have to pay a fee to access your personal data (or to exercise any of
the other rights). However, we may charge a reasonable fee if your
request is clearly unfounded, repetitive or excessive. Alternatively,
we may refuse to comply with your request in these circumstances.

What we may
need from you

We may need to
request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to
exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

Time limit to
respond

We try to
respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly
complex or you have made a number of requests. In this case, we will
notify you and keep you updated.

  1. Glossary

LAWFUL BASIS

Legitimate
Interest
means the interest of our business in conducting and
managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data
for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted
to by law). You can obtain further information about how we assess
our legitimate interests against any potential impact on you in
respect of specific activities by contacting
us

Performance
of Contract
means processing your data where it is necessary for
the performance of a contract to which you are a party or to take
steps at your request before entering into such a contract.

Comply with a
legal or regulatory obligation
means processing your personal
data where it is necessary for compliance with a legal or regulatory
obligation that we are subject to.

YOUR LEGAL
RIGHTS

You have the
right to:

Request
access
to your personal data (commonly known as a “data
subject access request”). This enables you to receive a copy of
the personal data we hold about you and to check that we are lawfully
processing it.

Request
correction
of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new
data you provide to us.

Request
erasure
of your personal data. This enables you to ask us to
delete or remove personal data where there is no good reason for us
continuing to process it. You also have the right to ask us to delete
or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have
processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure
for specific legal reasons which will be notified to you, if
applicable, at the time of your request.

Object to
processing
of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your
rights and freedoms.

Request
restriction of processing
of your personal data. This enables you
to ask us to suspend the processing of your personal data in the
following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or
defend legal claims; or (d) you have objected to our use of your data
but we need to verify whether we have overriding legitimate grounds
to use it.

Request the
transfer
of your personal data to you or to a third party. We
will provide to you, or a third party you have chosen, your personal
data in a structured, commonly used, machine-readable format. Note
that this right only applies to automated information which you
initially provided consent for us to use or where we used the
information to perform a contract with you.

Withdraw
consent at any time
where we are relying on consent to process
your personal data. However, this will not affect the lawfulness of
any processing carried out before you withdraw your consent. If you
withdraw your consent, we may not be able to provide certain products
or services to you. We will advise you if this is the case at the
time you withdraw your consent.

Leave a Comment