Privacy Policy
ALNMOUTH GOLF CLUB LTD
VISITORS PRIVACY POLICY AND COOKIES POLICY
We at the Alnmouth Golf Club Ltd (“we” or “our” or “us”) want to make sure all the personal
information we have collected about you is safe and secure whether we collect it through our website
at www.alnmouthgolfclub.com (“Site”) or from other sources. This Policy set outs our commitments
to you, in compliance with and beyond the General Data Protection Regulation (commonly known as
the GDPR) and explains how we collect, store and use your personal information.
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 Club Manager has overall responsibility for data protection
compliance in our organisation. If you have any questions about this Policy or what we do with your
personal information, their contact details are set out in the "Contact" section below.
PRIVACY NOTICES
Collecting specific, relevant personal information is a necessary part of us being able to provide you
with any services you may request from us or in providing services to our customers and members or
just managing our relationship with you.
When we hold or use your personal information as a data controller (see below for a description of
what this is) we will provide you with a privacy notice which sets out in detail what information we hold
about you (such as your contact details, address, etc.), how your personal information may be used
and the reasons for these uses, together with details of your rights.
Where we collect personal information from you directly, we will provide this privacy notice at the time
we collect the personal information from you. Where we receive your personal information indirectly,
we will provide this privacy notice when we first contact you, first pass the data to someone else or
within a month, whichever is the earlier.
We will only provide this privacy notice to you once, generally at the start of our relationship with you.
However if the applicable privacy notice is updated substantially, then we may provide you with
details of the updated version. You are encouraged to check back regularly for updates.
THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS
A data controller is a person who controls how personal information is processed and used. A data
processor is a person who processes and uses personal information in accordance with the
instructions of a third party, i.e. the data controller.
This distinction is important. You have certain rights in relation to your personal information, for
example the right to be provided with the personal information held about you and details of its use
and the right to have certain of your personal information either erased or anonymised, commonly
referred to as the right to be forgotten (see below to see what rights you have). These rights can
generally only be exercised against a data controller of your information.
In most cases we will be a data controller of your personal information. In any case where we are not
a data controller this means that you cannot exercise these rights against us directly (i.e. where we
only act as a data processor), but you can do so against the data controller (i.e. the person who
controls how we process the personal information). In these cases we will endeavour to inform you
who is the data controller of your personal information so that you can direct any such requests to
them.
Also it is only a data controller that will provide you with a privacy notice about your personal
information, so where we process your personal information as a data controller we will provide you
with a privacy notice. Where we process your personal information as a data processor for a third
party, that third party should provide you with a privacy notice which will set out details regarding the
processing of your personal information, which should also include the processing to be carried out by
us on their behalf.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use your personal information as described in the privacy notice provided to you, but, for
example, we may use your personal information to administer any account(s) you have with us or to
send you information we think you might find useful, provided you have indicated that you are happy
to be contacted for these purposes.
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WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Details of how we disclose your personal information are set out in the relevant privacy notice
provided to you, but generally it is where we need to do so in order to run our organisation (e.g. where
other people process information for us). In such circumstances, we will put in place arrangements to
protect your personal information. Outside of that we do not disclose your personal information
unless we are required to do so by law.
If we transfer personal information about you outside the European Economic Area (EEA), we will let
you know and ensure that all reasonable security measures are taken and that any third party
processers will be required to process the information in accordance with information protection laws
and we will notify you in your privacy notice if we are the information controller.
We do not sell, trade or rent your personal information to others.
HOW LONG DO WE HOLD ON TO YOUR PERSONAL INFORMATION?
Further details of how long we hold onto your personal information for are set out in the relevant
privacy notice provided to you, but we will only hold your information for as long as is necessary or
where you ask us to delete records we may delete it earlier.
The duration for which we retain your personal information will differ depending on the type of
information and the reason why it was collected. However, in some cases personal information may
be retained on a long term basis: for example, personal information that we need to retain for legal
purposes will normally be retained for at least six years in accordance with usual commercial practice
and regulatory requirements.
WHAT ARE YOUR RIGHTS?
Full details of your rights set out in the relevant privacy notice provided to you, but you are entitled by
law to ask for a copy of your personal information at any time. You are also entitled to ask us to
correct, delete or update your personal information, to send your personal information to you or
another organisation and to object to automated decision making. Where you have given us your
consent to use your personal information in a particular manner, you also have the right to withdraw
this consent at any time.
To exercise any of your rights, or if you have any questions relating to your rights, please contact us
by using the details set out in the "Contact" section below. You can also unsubscribe from any direct
marketing by clicking on the unsubscribe link in the marketing messages we send to you.
You should note that some of your rights may not apply as they have specific requirements and
exemptions which apply to them and they may not also apply to personal information recorded and
stored by us. However your right to withdraw consent or object to processing for direct marketing are
absolute rights.
If you are unhappy with the way we are using your personal information you can complain to the UK
Information Commissioner’s Office or your local data protection regulator. More information about
your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-thepublic/.
However, we are here to help and would encourage you to contact us to resolve your
complaint first.
LINKING WITH THIRD PARTY SITES
Our Site may, from time to time, contain links to and from the websites of our commercial partners,
other regional bodies, advertisers and clubs. If you follow a link to any of these websites, please note
that these websites have their own privacy policies and they will be a data controller of your personal
information. We do not accept any responsibility or liability for these policies and you should check
these policies before you submit any personal information to these websites.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy
policies and practices of the owners or operators of that third-party site and recommend that you
check the policy of that third party site and contact its owner or operator if you have any concerns or
questions.
SECURITY
We employ a variety of technical and organisational measures to keep your personal information safe
and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information
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transmission over the Internet is guaranteed 100% secure nor is any storage of information always
100% secure, but we do take all appropriate steps to protect the security of your personal information.
COOKIES
Certain parts of our Site use "cookies" to keep track of your visit and to help you navigate between
sections. A cookie is a small data file that certain websites store on your computer's hard-drive when
you visit such websites. Cookies can contain information such as your user ID and the pages you
have visited. The only personal information a cookie contains is information that you have personally
supplied.
We use cookies on our Site to enable us to deliver content that is specific to your interests and gives
us an idea of which parts of the Site you are visiting and to recognise you when you return to the Site.
Reading cookies does not give us access to other information on your computer's hard-drive and our
Site will not read cookies created by other websites that you have visited.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse
the setting of cookies. If, however, you select this setting you may be unable to access certain parts of
the Site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will
issue cookies when you access the Site.
Please note providers of third party content may also use cookies over which we have no control. For
detailed information on the cookies we use and the purposes for which we use them see the table at
the end of the policy.
LOG FILES
In common with most websites, our Site logs various information about visitors, including internet
protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit
pages and date / time stamp.
We may use this information to analyse trends, administer the Site, track your movement around the
Site and gather broad demographic information.
CHANGES TO THIS POLICY
Any changes we may make to this Policy in the future will be posted on our Site and, where
appropriate, notified to you by e-mail. When we change this Policy in a material way, we will update
the version date at the bottom of this page. Please check back frequently to see any updates or
changes to this Policy and should you object to any alteration, please contact us as set out in the
"Contact" section below.
CONTACT
In the event of any query or complaint in connection with the information we hold about you, please
email
[email protected] or write to us at Alnmouth Golf Club Ltd, Foxton Hall,
Alnmouth, Northumberland, NE66 3BE
Our Club Manager can be contacted at Alnmouth Golf Club Ltd, Foxton Hall, Alnmouth,
Northumberland, NE66 3BE
Whilst this privacy policy 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/.
11th May 2018
MEMBERS PRIVACY POLICY
ALNMOUTH GOLF CLUB LTD
PRIVACY NOTICE FOR OUR MEMBERS
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 membership with us. This notice applies to you if you have registered to become or are a member of our
club. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data
protection we will be the controller of any of your personal information.
References to we, our or us in this privacy notice are to the Alnmouth Golf Club, Foxton Hall
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.
1. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
Depending on the type of membership you register for with us, you may initially provide us with or we may obtain
personal information about you, such as information regarding your:
o personal contact details that allows us to contact you directly such as name, title, email addresses and telephone
numbers;
o date of birth;
o gender;
o membership start and end date;
o any credit/debit card and other payment details you provide so that we can receive payments from you and details
of the financial transactions with you;
o CCTV footage obtained through electronic means such as images in video and/or photographic form;
o use of and movements through our online portals, passwords, personal identification numbers, IP addresses, user
names and other IT identifying information.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding
you:
o information about your health, including any medical condition and health professional information
We may not collect the above types of special category personal information about you. In relation to the special
category personal data that we do process we do so on the basis that
o it is necessary for the establishment of and administering our Buggy Policy
o it is necessary for the consideration of a suspension of membership for medical reasons
o based on your explicit consent.
In the table below’ we refer to these as the “special category reasons for processing of your personal data”.
3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our members when you apply to become a member of the club, you
register an account with us at www.alnmouthgolfclub.com when you purchase any services or products we offer, when
you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
We also may collect personal information about you from any third party references you provide as part of the
application process for membership.
If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they
have a right to know and to be aware of how what personal information we hold about them, how we collect it and how
we use and may share that information. Please share this privacy notice with those of them whom you feel are
sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to
personal information” section below.
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4. USES MADE OF THE INFORMATION
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.
Purpose Personal information used Lawful basis
To administer any membership you
have with us and managing our
relationship with you, including
dealing with payments and any
support, service or product enquiries
made by you
All contact and membership
details, transaction and
payment information,
records of your interactions
with us, and marketing
preferences.
This is necessary to enable us to properly manage
and administer your membership contract with us
and includes the email of subscription invoices,
newsletters and general club information.
To arrange and manage any contracts
for the provision of any services or
products
Contact details, transaction
and payment information.
Records of your interactions
with us.
This is necessary to enable us to properly
administer and perform any contract for the
provision of any services and products you have
purchased from us.
To send you information which is
included within your membership
benefits package, including details
about advanced ticket information,
competitions and events, partner
offers and discounts and any updates
on Golf Club business
Contact and membership
details.
This is necessary to enable us to properly manage
and administer your membership contract with us.
To answer your queries or complaints Contact details and records
of your interactions with us
We have a legitimate interest to provide complaint
handling services to you in case there are any
issues with your membership.
Retention of records All the personal information
we collect.
We have a legitimate interest in retaining records
whilst they may be required in relation to complaints
or claims. We need to retain records in order to
properly administer and manage your membership
and run our club and in some cases we may have
legal or regulatory obligations to retain records.
We process special category personal data on the
basis of the “special category reasons for
processing of your personal data” referred to in
section 2 above.
The security of our IT systems Your usage of our IT
systems and online portals.
We have a legitimate interest to ensure that our IT
systems are secure.
To conduct data analytics studies to
better understand event attendance
and trends within the sport
Records of your attendance
at any events or
competitions hosted by us.
We have a legitimate interest in doing so to ensure
that our membership is targeted and relevant.
For the purposes of promoting the
club, our events and membership
packages.
Images in video and/or
photographic form.
Where you have given us your explicit consent to
do so.
To use information about your
physical or mental health (including
any injuries) or disability status, to
ensure your health and safety and to
assess your fitness to participate in
any events or activities we host and
to provide appropriate adjustments to
our sports facilities.
Health and medical
information
We process special category personal data on the
basis of the “special category reasons for
processing of your personal data” referred to in
section 2 above.
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For some of your personal information you will 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 admit you as a member or we may not be able to properly perform our contract with you or comply with legal
obligations and we may have to terminate your membership. 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 contract with
you.
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.
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 certain member benefits to
you.
5. DIRECT MARKETING
Email, Post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about
products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let
us know at any time that you do not wish to receive marketing messages by completing this form emailing us at
[email protected]. You can also unsubscribe from our marketing by clicking on the unsubscribe link in
the marketing messages we send to you.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties:
o To any governing bodies or regional bodies for the sports covered by our club: to allow them to properly
administer the sports on a local, regional and national level, this includes England Golf and NUGC.
o Other service providers: BRS Online Booking, payment processors Secure Collections, CCTV, Handicapmaster
Competition software, Croft membership adminstration. These providers have their own privacy policies and the
Club does not accept any responsibility or liability for these policies.
o Police, law enforcement and security services: to assist with the investigation and prevention of crime and the
protection of national security.
7. 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.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain your personal information will differ depending on the type of information and the
reason why we collected it from you. However, in some cases personal information may be retained on a long-term
basis: for example, personal information that we need to retain for legal purposes will normally be retained in
accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal
requirement we retain all physical and electronic records for a period of 6 years after your last contact with us or the
end of your membership. Exceptions to this rule are:
o CCTV records which are held for no more than 7 days unless we need to preserve the records for the purpose of
prevention and detection of crime;
o Details regarding unsuccessful membership applicants where we hold records for a period of not more than 12
months;
o Information that may be relevant to personal injury or discrimination claims may be retained until the limitation
period for those types of claims has expired. For personal injury or discrimination claims this can be an extended
period as the limitation period might not start to run until a long time 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 change your phone number or email address. You can contact us by
using the details set out in the "Contacting us" section below.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
o the right to be informed about how your personal information is being used;
o the right to access the personal information we hold about you;
o the right to request the correction of inaccurate personal information we hold about you;
o the right to request the erasure of your personal information in certain limited circumstances;
o the right to restrict processing of your personal information where certain requirements are met;
o the right to object to the processing of your personal information;
o the right to request that we transfer elements of your data either to you or another service provider; and
o the right to object to certain automated decision-making processes using 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.
10. 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 and post the new policy on our website www.alnmouthgolfclub.com. 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.
11. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please email the Club
Manager at
[email protected] or write to us at Alnmouth Golf Club Ltd, Foxton Hall, Alnmouth,
Northumberland, NE66 3BE
Version dated 10th May 2018