Privacy Policy GDPR Compliance

Summary -

Stephen Packer Golf Ltd is committed to protecting your personal data and handling it responsibly.

This policy covers the personal data that ‘Stephen Packer Golf Ltd’ collects whenever you interact with us, including when you use our websites, take a Golf Lesson, and when you correspond with us (such as by email or over the phone).  It also covers personal data that we may receive from third parties such as Facebook, Mailchimp and other media platforms.

The policy will cover the bullet points below in order:

  • the types of personal data we collect from you
  • the types of personal data we receive from third parties
  • why we process your personal data
  • who we share your personal data with
  • how long we retain your personal data
  • your rights to withdraw your consent and to object (including to direct marketing)
  • your other personal data rights
  • how to contact us and exercise your rights

If you would like to know how we collect information about your use of our websites, apps and social media sites, you can read our Cookies Policy below

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Personal data Stephen Packer Golf Ltd collects from you
We collect personal data from your interactions with us, such as when you engage with our websites, take a Golf Lesson or when you email or phone us.

The personal data we collect from you includes:

  • the name and contact details that you provide when you register as a client
  • your payment and address details
  • your marketing preferences, including any consents you have given us
  • your browser or device information
  • information about your use of our websites
  • your communications with us
  • information about your lessons with Stephen Packer Golf Ltd, such as times, dates and spend.  Photos and video footage of you may be taken at these events
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Personal data Stephen Packer Golf receives from third parties
Sometimes we receive personal data from third parties, in particular:

  • online personalisation providers tell us how you engage with our websites and social media accounts
  • data specialists provide us with insights about our customers, based on their own aggregated data sets
  • if you respond through using your social media account, the social media platform provides us with information that you have consented to share with us
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Why Stephen Packer Golf Ltd processes your personal data
This section explains the reasons why we process your personal data and our legal bases for doing so.

Consent
If you’ve opted-in to receive information and offers relating to Stephen Packer Golf (for example by ticking a box on one of our websites), then we’ll provide this information to you by email, text, or phone.

We also rely on your consent to process information about your use of our websites, apps and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you.

Wherever we rely on your consent to process personal data, you have a right to withdraw that consent.  See Section on how to exercise your rights below.

Legitimate interests
We process your personal data when necessary to pursue our legitimate interests in the following:

  • tailoring our websites and communications for you.  We collect information about your engagement with us online (such as pages that you have visited on our websites) and combine that with aggregated insights we have about our customer base, to build a fuller understanding of your individual preferences
  • monitoring, improving and protecting our products, content and services
  • checking the credit or debit card details you provide (to process your payments and prevent fraudulent transactions)
  • sending you some types of direct marketing, including by email and post
  • responding to your comments or complaints
  • undertaking, or inviting you to take part in, market research
  • querying whether you have had an issue completing an online form
  • using incident reports and CCTV footage to: protect the security of our customers and staff; and to help detect and prevent unlawful activity
  • managing legal claims, compliance, regulatory and investigative matters
  • processing job applications received through third party organisations

You have a right to object to any processing that we undertake for our legitimate interests.  See Section on how to exercise your rights below.

Contract
We process your personal data when necessary for contractual reasons, such taking out a lesson course.

Legal obligation
We are legally required to process your personal data in cases where we need to:

  • obtain parental consent to provide services directly to children
  • respond to certain requests by government or law enforcement authorities
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Who Stephen Packer Golf Ltd shares personal data with
We will share your personal data with the following recipients:

  • Facebook, so that we can display relevant advertising to you on their platform (your data is converted into a unique ID before it is shared with Facebook)
  • Mailchimp, an email platform that provides us with the ability to send emails to our past, current and potential customers
  • third party suppliers involved in: data insights; website hosting; online personalisation; and advertising.
  • government authorities or law enforcement officials, to assist with their official requests and comply with our legal obligations
  • our advisers, any prospective purchaser’s advisers, and any new owners of the business (in the event our business is sold or integrated with another business)

See Facebook’s Privacy Policy – https://www.facebook.com/full_data_use_policy
See Mailchimp’s Privacy Policy – https://mailchimp.com/legal/privacy/

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How long Stephen Packer Golf retains personal data
We retain personal data about your Golf Lessons for as long as your participation remains active (lessons left in the course), and for a limited period of time afterwards (in case you decide to renew your package or have queries about it).

We retain personal data relating to your purchases for several years from the date of the relevant transaction.  This is to understand your purchasing preferences and to meet our legal and contractual obligations.

Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in future.

We keep a record of all CCTV security footage for 30 days, unless we need to hold this data for longer to resolve an issue or to meet a legal requirement.

We also retain information with the potential to give rise to legal disputes for 7 years.

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Your rights to withdraw consent and to object (including to direct marketing)
Wherever we rely on your consent to process personal data, you always have a right to withdraw that consent.  See where we rely on your content in the section above

You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our legitimate interests (including profiling). 

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Your other personal data rights
In addition to your rights to withdraw your consent and to object, you have the right to ask us:

  • for access to information about your personal data or for a copy of your personal data
  • to correct or delete your personal data
  • to restrict (i.e. stop any active) processing of your personal data
  • to provide you with certain personal data in a structured, machine readable format and to transmit that data to another organisation

These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping.  If this is the case then we’ll let you know when we respond to your request.

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How to contact us and exercise your rights
The easiest way to stop receiving information from us is by opting out of emails by using the unsubscribe link at the bottom of each email. You can also call us on 07733432779 or visit us in person to discuss your concerns.

We will do our best to assist with any queries you have about your personal data.  You can contact our Data Protection Officer at any time using the contact details below.  When you do so, please provide your full name, your preferred contact information, and a summary of your query.

If you have unresolved concerns, you also have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner’s Office in the UK.

 

Cookies Policy

When you visit our websites (the “Websites”) or social media sites, you may provide us with two types of information: (i) Personal Information – which you knowingly choose to disclose, that is collected on an individual basis and is used in accordance with our Privacy Policy; and (ii) Website Use Information which is collected on an aggregate basis as you and others browse the Websites or interact with our social media sites, and is used as set out in this Cookies Policy.

You can surf the Websites anonymously and access important information without revealing your identity. However, for the purposes described in this policy, we use “cookies” to measure your visits to our Websites. A cookie is a small text file that our Websites store on your device or web browser and can later retrieve. These cookies allow us to distinguish you from other users of the Websites, but this information only allows us to identify you personally if you have previously logged on to the Websites from that device as a member of a Stephen Packer Golf membership scheme, or where you have visited a Website by clicking through from a Club communication (such as an email) that you have received as a member.

We also use cookies on our Websites and social media sites which are used when you share information using a sharing button or “like” button, or when you click on links on the official Stephen Packer Golf social media pages on sites such as Facebook, Twitter or Google+. The companies that deliver this functionality, and the operators of the sites, will record that you have done this and this information may be linked to targeting/advertising activities.

If you choose not to delete and/or block cookies from the Websites, and continue to use the Websites, you are thereby consenting to our use of such cookies.

A description of the type of cookies that we use, and their purpose, is below:

Category 1: Strictly necessary cookies
These are required for the operation of the websites. For example, to remember the previous actions so you can navigate back to previous pages These cookies are essential in order to move around the websites and use their features, such as accessing areas of the websites. Without these cookies, services you have asked for, like shopping baskets, cannot be provided
Category 2: analytical/performance cookies
These cookies collect anonymous information about how visitors use the Websites. These cookies collect information about how you use the Websites, for instance which pages you go to most often. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Websites work and understand what interests our users.
Category 3: functionality cookies
These are used to recognise users when they return to the Websites. They remember user choices and enable the personalisation of content. These cookies allow the Websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services such as remembering whether you have already responded to a questionnaire. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Category 4: Targeting Cookies
These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember which websites you have visited and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You may delete and block all cookies from the Websites, but parts of the Websites may not then work. Most web browsers and devices allow some control of most cookies through the browser or device settings, for example you can set up your web browser to inform you when you receive a cookie, giving you the chance to decide whether or not to accept it. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To manage cookies linked to targeting/advertising activities, visit www.youronlinechoices.com. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Copyright 2018 Stephen Packer Golf Ltd. Permission to use quotations from this article is granted

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