Updated August 3rd 2023
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers, and customer personnel.
1.2 This policy applies where we act as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of processing that personal data.
1.4 In this policy, “we,” “us,” and “our” refer to GLF.Connect.
2. The Personal Data We Collect
2.1 In this Section 2, we have set out the general categories of personal data that we process.
2.2 We may process contact data, which includes your name, email address, telephone number, and postal address, enabling us to get in touch with you.
2.3 We may process your account data, which includes your account identifier, name, email address, account creation and modification dates, website settings, and marketing preferences.
2.4 We may process transaction data, including your name, contact details, payment card details (or other payment details), and transaction details, related to any purchases of goods and/or services that you enter into with us and/or through our website. The source of the transaction data is you and/or our payment services provider.
2.5 We may process communication data, including the content and metadata associated with any communication you send to us or that we send to you. Our website will generate metadata associated with communications made using the website contact forms.
2.6 We may process usage data, including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system.
3. Purposes of Processing and Legal Bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases for processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, processing and fulfilling orders, providing our services, supplying goods, generating invoices, bills, and other payment-related documentation, and credit control.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services, and business.
3.3 Publications – We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4 Relationships and Communications – We may process contact data, account data, transaction data, and/or communication data for the purposes of managing our relationships, communicating with you (excluding direct marketing) by email, SMS, post, fax, and/or telephone, providing support services, and handling complaints. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers, and customer personnel, maintaining relationships, and the proper administration of our website, services, and business.
3.5 Research and Analysis – We may process usage data and/or transaction data for the purposes of researching and analyzing the use of our website and services, as well as researching and analyzing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our website, services, and business generally.
3.6 Record Keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases, and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis for this processing is our legitimate interests, namely the protection of our website, services, and business, and the protection of others.
3.8 Insurance and Risk Management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal Claims – We may process your personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
3.10 Legal Compliance and Vital Interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
4. Providing Your Personal Data to Others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.
4.2 Your personal data held in our website database will be stored on the servers of our hosting services providers.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International Transfers of Your Personal Data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2 The hosting facilities for our website are situated in the USA. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.
5.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and Deleting Personal Data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
7. Your Rights
7.1 In this Section 7, we have listed the rights that you have under EU data protection law, including the California Consumer Privacy Act (CCPA).
7.2 Your principal rights under EU data protection law are:
(a) The right to access – You can ask for copies of your personal data.
(b) The right to rectification – You can ask us to rectify inaccurate personal data and to complete incomplete personal data.
(c) The right to erasure – You can ask us to erase your personal data.
(d) The right to restrict processing – You can ask us to restrict the processing of your personal data.
(e) The right to object to processing – You can object to the processing of your personal data.
(f) The right to data portability – You can ask that we transfer your personal data to another organization or to you.
(g) The right to complain to a supervisory authority – You can complain about our processing of your personal data.
(h) The right to withdraw consent – To the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en, https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/,
For California Residents, your rights under the California Consumer Privacy Act (CCPA) are:
(a) The right to access – You can ask for copies of your personal data, including the specific pieces of information we have collected about you under the CCPA.
(b) The right to deletion – You can ask us to delete your personal data, subject to certain exceptions under the CCPA.
(c) The right to opt-out – You can opt-out of the sale of your personal data to third parties if applicable under the CCPA.
(d) The right to non-discrimination – You have the right not to be discriminated against for exercising your rights under the CCPA.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://oag.ca.gov/privacy/ccpa.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. About Cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies That We Use
10. Managing Cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11.1 We may update this policy from time to time by publishing a new version on our website.
11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
11.3 We may notify you of significant changes to this policy by email.
12. Our Details
12.1 This website is owned and operated by Orbis Golf Limited.
12.2 We are registered in England and Wales under registration number 07646018, and our registered office is at Orbis Golf Limited, 7 Bell Yard, London, WC2A 2JR.
12.3 You can contact us:
(a) by post, at the postal address given above;
(c) by email, using the email address published on our website.
13.1 Our representative within the EU with respect to our obligations under data protection law is Robert Spurrier, and you can contact our representative at [email protected].
Data Protection Officer
14.1 Our data protection officer’s contact details are: [email protected].