VICARS CROSS GOLF CLUB
PRIVACY POLICY
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1. INTRODUCTION
a) Vicars Cross Golf Club Ltd (The Club) is committed to safeguarding the privacy of our members, website visitors and staff; in this policy we explain how we will treat your personal information.
b) We ask that you consent to our use of cookies in accordance with the terms of this policy.
c) You have the option of setting your privacy choices as set out in the policy.
2. WHO ARE WE
a) Vicars Cross Golf Club Ltd is registered in England and Wales under registration number 509576 and our registered office is at Tarvin Road Great Barrow, Chester CH3 7HN
b) We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration number is Z7449950
c) You can contact us by using our website contact form, by telephone on 01244 335174 or by email manager@vicarscrossgolf.co.uk.
3. OUR WEBSITE
i – The Club currently uses several software systems, the main ones that comprise the Web Services offered by the Club are:-
ii – A Website www.vicarscrossgolf.co.uk which is owned and managed by Club Systems International Ltd based at The Lexicon, Floor 2,, 49 Peter St, Manchester M2 3NG.
iii – A Tee Booking system http://www.vicarscrossgolf.co.uk/brs.aspx which is is owned and managed by BRS Golf based at 7 Clarendon Road, City Quays 1, Belfast BT1 3BG.
iv – A payments module owned and operated by WorldPay Ltd, Manchester M3 3EB.
4. OTHER COMPUTERISED SYSTEMS
a) The Club holds personal data in several computerized systems to enable it to administer its duties including systems for:-
i – Security Barriers and door entry.
ii – Bar management and members’ balances and purchase activity.
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iii – Membership and Handicap management.
iv – Employees remuneration, PAYE and NI.
5. WHAT PERSONAL INFORMATION IS COLLECTED BY THE CLUB
a) We may collect, store and use the following kinds of personal information:
i – Information that you provide to us when using our services, or that is generated in the course of the use of those services.
ii – Information relating to any purchases you make of our services.
iii – Information contained in or relating to any communications that you send to us or send through our website (including the communication content and meta data associated with the communication).
iv – Information about your visits to and use of the Club’s websites.
v – Information about staff employed by the Club to manage their employment
vi – Any other personal information that you choose to provide to us.
6. HOW WE USE YOUR PERSONAL INFORMATION
a) We may use your personal information to:
i – Send statements, invoices and payment reminders to you, and collect payments from you.
ii – Send you non-marketing commercial communications.
iii – Send you email notifications that you have specifically requested.
iv – Deal with enquiries and complaints made by or about you relating to our website or any other service provided.
v – To support your rights under Data Protection law in relation to our use of your personal information.
vi – Manage your employment (where you are a member of staff employed by the Club)
vii – Administer our website and business including:
– personalising our website for you,
– enabling your use of the services available on our website,
– keeping our website secure and preventing fraud.
b) Personal information submitted to us through our website will be used for the purposes
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specified in this policy or on the relevant pages of the website.
c) The personal data we hold about you will only be used in line with the purposes detailed above: The legal basis for this will be either for the administration of a contract we have in place with you; or in line with the legitimate interests of our business in providing information governance and IT Security services (ensuring that this does not impact on your rights or freedoms in relation to privacy) or disclosed as required by law.
d) The Club has no reason to process or hold sensitive information about you in relation to special categories or criminal convictions. The Club will adhere to the relevant legal requirement as regards any checks needed for those employed to work with junior members.
7. MARKETING
a) For Members and Visitors: The BRS Tee Booking website enables you to select your marketing preferences when you first use it. If you want to subsequently change this, please email membership@vicarscrossgolf.co.uk with your request.
b) For Members: The Club’s Membership system holds your marketing preferences which you can change by clicking on the preferences link at the bottom of any email sent to you from the Club or by contacting manager@vicarscrosscolf.co.uk. You can chose whether or not to receive:-
i – Club Promotions: Promotions relating to our Club which we think may be of interest to you by post or if you have opted in, by email or similar technology.
ii – Third Party Marketing – the default is set to Opt Out: The Club will not, without your consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
8. DISCLOSING PERSONAL INFORMATION BETWEEN CLUB MEMBERS
a) The Club Website provides a list of Members and their telephone number for Club Members to login and view so as to be to arrange their social activity, golf games or knockout golf matches. These details are repeated in the Club Diary which is issued to Club Members.
b) Members can use the Club Website’s “Members’ Hub” to optionally allow other Club Members to view their email address, postal address, mobile and works telephone numbers and allow messages to be sent to them from other Members through the Club Website.
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c) Any Club Member who wishes to be excluded from the Club Diary or not have their Home Telephone number displayed should email manager@vicarscrossgolf.co.uk.
9. DISCLOSING PERSONAL INFORMATION – GENERAL
a) We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
b) We may disclose your personal information:
i – To the extent that we are required to do so by law.
ii – In connection with any ongoing or prospective legal proceedings.
iii – In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
iv – To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
c) Except as provided in this policy, we will not provide your personal information to third parties
10. INTERNATIONAL DATA TRANSFERS
a) Information that we collect will only be stored and processed within the UK and is protected by UK Data Protection laws.
11. RETAINING PERSONAL INFORMATION
a) This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
b) Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
c) Notwithstanding the other provisions of this section, we will retain documents (including electronic documents) containing personal data:
i – To the extent that we are required to do so by law
ii – If we believe that the documents may be relevant to any ongoing or prospective
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legal proceeding
iii – In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
iv – To support the ongoing business purposes of the Club with due consideration for the rights and freedoms of individuals privacy.
v – Please contact the Club if you would like further details of how personal data is retained.
12. SECURITY OF YOUR PERSONAL INFORMATION
a) We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
b) We will store personal information you provide either on our secure servers or in the case of web based services, those of our service providers.
c) You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent to us over the Internet.
13. YOUR RIGHTS
a) You have a number of rights under the General Data Protection Regulation (GDPR) (EU) 2016/67 and Data Protection Act including:
i – The right to be informed about the collection and use of your personal data e.g. via this privacy notice.
ii – The right to access your personal data.
iii – The right to have any inaccurate personal data rectified, or completed if it is incomplete.
iv – The right to have your personal data erased in certain circumstances.
v – The right to request the restriction or suppression of their personal data in certain circumstances.
vi – The right to data portability — to obtain and reuse your personal data for your own purposes across different services.
vii – The right to object to our use of your information in certain circumstances e.g. for marketing or profiling purposes.
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14. EXERCISING YOUR RIGHTS
a) If you would like to access your own personal information or exercise any of the rights detailed above please email the Club at manager@vicarscrosscolf.co.uk or telephone on 01244 335174.
b) In the majority of cases, we will respond to your request within 30 days after receiving the necessary information required to deal with your request
c) We may ask you to supply appropriate evidence of your identity .
d) There may be some exemptions to dealing with your rights as specified in Data Protection law, but the Club will ensure you are fully informed of this within 30 days of receiving your request.
e) We do not carry out any profiling or automated decision making based on your personal data
f) Full information on your rights under the Data Protection Act can be found from the following link: https://ico.org.uk/.
15. THIRD PARTY WEBSITES
a) Our website includes hyperlinks to, and details of, third party websites.
b) We have no control over, and are not responsible for, the privacy policies and practices of third parties.
16. COOKIES
a) 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.
b) Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
c) We use both first party, session and persistent cookies on our website. First party cookies are set by the website you are visiting and they can only be read by that site. Session cookies are stored only temporarily during a browsing session and are deleted from the user’s device when the browser is closed. Persistent cookies are a type of cookie that is saved on your computer for a fixed period (usually a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to know who
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you are for more than one browsing session. For example, this type of cookie is used to store your preferences, so that they are remembered for the next visit.
d) Most browsers allow you to refuse to accept cookies and you can delete cookies already stored on your computer. The manner of doing this varies with the browser you use so please consult the browser’s technical guidance.
e) Blocking all cookies will have a negative impact upon the usability of many websites and in particular the BRS Tee Booking service will not operate correctly for members if this option is chosen. This is a technical issue known to BRS and Club System International and currently there is no fix for this. Therefore if you block cookies, you will not be able to use all the features on our website.
17. AMENDMENTS
a) We may update this policy from time to time by publishing a new version on our website.
b) You should check this page occasionally to ensure you are happy with any changes to this policy.
c) This policy will be updated in line with the EU General Data Protection Regulation once these have been translated into UK law
18. IF YOU HAVE A CONCERN ABOUT HOW YOUR DATA IS BEING HANDLED
a) If you are unhappy about the use of your personal data, then please contact us directly and we will try to resolve your concern. You can also raise a concern directly with the Information Commissioner’s Office and more detail on how to do this can be found from the following link: https://ico.org.uk
19. FURTHER INFORMATION
a) If you have any questions which you feel have not been answered by this Privacy Notice and Cookies Policy you can contact us by email manager@vicarscrosscolf.co.uk, through our website http://www.vicarscrossgolf.co.uk/contactform.aspx or by telephone on 01244 335174.
Vicars Cross Golf Club Ltd
First Issued 25th May 2018
Revised 30th May 2018