Privacy Policy

This privacy notice sets out how GEM Golf collects and processes your personal data through your use of our website.

GEM (Golf Essential’s Move) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). References to “you”, “your”, “yours” means you, the data subject.

Contact Details

Full name of legal entity: Golf’s Essential Move

Registered Office: 101 Rose Street South Lane, Edinburgh, EH2 3JG

Email address: [email protected]

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 by emailing us at [email protected]

This policy is intended to help you understand:

THE DATA WE COLLECT

ABOUT YOU
HOW YOUR PERSONAL DATA IS COLLECTED
COOKIES
MARKETING
OPTING OUT
DISCLOSURE OF DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR RIGHTS
WHAT WE MIGHT NEED FROM YOU
IF YOU ARE NOT SATISFIED
THIRD-PARTY LINKS

THE DATA WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include data where the identity has been removed (anonymised data).

We may process the following categories of personal data about you:

The data we collect Why we process this data Our lawful grounds

Communication Data that includes any communication that you send to us through our website contact form, through email, text, social media messaging, social media posting or any other communication that you send us. For the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Legitimate interests to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. To supply the goods and/or services you have purchased and to keep records of such transactions. Performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. To operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Legitimate interests to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. To analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Legitimate interests to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. To enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Legitimate interests to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve you.

Legitimate interests to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

Sensitive data refers to data that 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. We do not collect any sensitive data about you, or any information about criminal convictions and offences.

We do not carry out automated decision making or any type of automated profiling.

HOW YOUR PERSONAL DATA IS COLLECTED

We may collect data about you by you providing the data directly to us, for example by filling in forms on our website or emailing us. We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy on the footer of our website for more details about this

We may receive data from third parties as set out below:

• analytics providers such as Google based outside the EU
• social and advertising networks such as Facebook based outside the EU
• search information providers such as Google based outside the EU
• providers of technical, payment and delivery services, such as data brokers or aggregators
• publicly available sources such as Companies House and the Electoral Register based inside the EU

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. For more information about the cookies we use, please see the footer of our website

MARKETING

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. You can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the unsubscribe link on any marketing message sent to you OR by emailing us at [email protected] at any time.

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.

DISCLOSURE OF DATA

We may have to share your personal data with the parties set out below:

Service providers acting as processors who provide IT and system administration services.
Government bodies that require us to report processing activities in certain circumstances.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

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

INTERNATIONAL TRANSFERS

Limited subscription data (email, first name, last name and interest categories) are processed using the Mailchimp email hosted system. Mailchimp is an email service provider with servers based in the USA. An international transfer requires us to ensure your data is safe and respected as it is in the EU or UK. This international transfer using the Mailchimp email hosted system is protected under data protection law by Mailchimp having signed up to the EU-US Privacy Shield. Read further information on how Mailchimp secures and stores your information.

DATA SECURITY

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

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

DATA RETENTION

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, the processing purposes and whether these can be achieved by other means, and the applicable legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

You have the right to request access to the data we hold about you. You also have the right to request correction, erasure, restriction, transfer, to object to processing, to portability of data, or to withdraw consent at any time (where the lawful ground for processing is consent).

If you would like more information on these rights, please visit

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You can exercise any of the rights set out above by emailing us at [email protected]

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

WHAT WE MIGHT 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.

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.

IF YOU ARE NOT SATISFIED

You have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) if you are unhappy with any aspect of how we collect and use your data. If you do have a complaint, we should be grateful if you would please contact us first so that we can try to resolve it for you.

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. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. When you leave our website, we encourage you to read the privacy notice of every website you visit. An example of this is STRIPE, who we use to facilitate online ordering. Their Privacy Policy can be found here.