This notice applies to you if we process your personal information and you are not an employee, volunteer or worker of ours, a prospective candidate employee, volunteer or worker or an individual to whom we have provided a specific privacy notice. You may be, for example, an individual that works at a supplier or customer of ours or another organisation that we deal with, an attendee at one of our events, a user of our website or someone who is affected by any of our activities.
References to we, our or us in this privacy notice are to the Royal Cinque Ports Golf Cub Limited Golf Road Deal Kent CT14 6RF
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection we will be the controller of any of your personal information.
PERSONAL INFORMATION WE COLLECT
We may collect the following types of personal information about you:
SPECIAL CATEGORIES OF PERSONAL INFORMATION
We do not generally collect, store and use the following “special categories” of more sensitive personal information regarding you:
SOURCES WE COLLECT YOUR PERSONAL INFORMATION FROM
We will collect personal information from a number of sources. These may include the following:
WHAT WE USE YOUR PERSONAL INFORMATION FOR
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.
Purpose
Personal information used
Lawful basis
Identity and money laundering checks and passing details of our money laundering checks to third parties and to carry out credit checks
All the personal information we collect
We may have a legal obligation to undertake identification and money laundering checks and to provide those details to third parties 3 We and a third party also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid
To enter into and perform contracts, where we may be supplying products/services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties
All the personal information we collect
To enter into and perform contracts with either yourself or the organisation that you represent We have a legitimate to properly perform contracts with third parties
Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you
All the personal information we collect
This may be necessary to perform a contract with you or the organisation that you represent We have a legitimate interest to improve the services and/or products we provide To defend, bring or establish legal claims
Maintain and improve our services and/or products
All the personal information we collect
We have a legitimate interest to improve the services and/or products we provide
Data analytics and statistical analysis to help us improve our online services
How you use our website
We have a legitimate interest to improve the online services we provide and user experience
Determine services and/or products that may be of interest to you
All personal information we collect
We have a legitimate interest to improve the services and/or products we provide and to determine which products and/or services you may be interested in
To provide you with requested information
Contact details and services and products or other information that you have requested we provide to you or your organisation
Contact details and services and products or other information that you have requested we provide to you or your organisation
For the purposes of promoting the sport, our events and membership packages.
Images in video and/or photographic form.
Where you have given us your consent to do so.
Direct marketing
Contact details and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past
We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively if you or your organisation has purchased similar services or products from us previously we may market similar products or services as a legitimate interest in developing our organisation. You have the right to opt out from such marketing at any time
Holding any events
Your contact details, details of attendance, your comments in response to any surveys or forms and dietary requirements
We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements
To comply with our legal obligations
All the personal information we collect
To comply with any legal obligation or requirement
Fraud, crime prevention and debt collection
All the personal information we collect
We have a legitimate interest to detect and prevent crime and to collect debts.
To manage our relationship with you and to operate our organisation
All the personal information we collect
We have a legitimate interest to operate our organisation in an efficient way and to expand our organisation To enter into and perform contracts with either yourself or the organisation that you represent
Storage of records relating to you and also records relating to our organisation
All the personal information we collect
To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records
For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.
We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We may share personal information with the following parties: Any party approved by you.
DIRECT MARKETING
Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products or services we believe you may be interested in. We will only send marketing messages to you in accordance with the marketing preferences you set when you either create your account, that you tell us you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously.
You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at office@royalcinqueports.com or by using the by using the details set out in the “Contacting us” section below. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.
TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union
The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.
Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.
In limited circumstances the people to whom we may disclose personal information as mentioned in section 0 above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.
If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.
HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:
For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years. For individuals attending an event it will generally be a period of [6] years after the event.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address.
You can contact us by using the details set out in the “Contacting us” section below.
SECURITY
We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
You have the following rights in relation to your personal information:
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
1. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
2. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please email office@royalcinqueports.com or write to us at Data Processor Royal Cinque Ports Golf Club Limited Golf Road Deal Kent CT14 6RF
Version dated 14 July 2020
Golf Bookings & Enquiries: Telephone: 01304 374007 | Email: office@royalcinqueports.com