OUR PRIVACY MISSION STATEMENT
“At Elmgreen Golf Club, we value the trust placed in us by customers, suppliers and colleagues who give us their personal data. Data security is one of our highest priorities and we aim to be as clear as possible about what we do with personal data and why we do it.”
OUR PRIVACY STATEMENT FOR ELMGREEN GOLF CLUB
Your privacy is really important to us, and we understand how important it is to you. Our aim is to be as clear and open as possible about what we do and why we do it. Elmgreen Golf Club is committed to the privacy of all its users and customers.
WHO ARE WE
Elmgreen Golf Club Limited, trading as Euro Golf Services (referred to in this Policy as “Elmgreen Golf Club”, “we”, “us” and ”our”), a limited company (company registration number: 161540) whose registered address is Elmgreen Golf Club, Dunsink Lane, Dunsink, Dublin 15.
WHO THIS POLICY APPLIES TOO
WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
For the purpose of the EU General Data Protection Regulation 2016/679 (“GDPR”), the data controller is Elmgreen Golf Club Limited whose registered office is Elmgreen Golf Club, Dunsink Lane, Dunsink, Dublin 15.
WHO CAN YOU CONTACT IF YOU HAVE QUESTIONS OR REQUESTS?
Our Data Protection Officer can handle any questions or requests relating to this Policy or your Personal Data. For any questions or requests or complaints concerning the application of this Policy or to exercise your rights, as described in this Policy, you may contact us at the Data Protection Manager at:
Phone: 00353 01 820 0797
Post: Elmgreen Golf Club, Dunsink Lane, Dunsink, Dublin.
We value your Personal Data entrusted to us and we are committed to processing your Personal Data in a fair, transparent and secure way. The key principles that Elmgreen Golf Club applies when dealing with your personal are as follows:
INFORMATION WE COLLECT
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We collect the personal data that you may volunteer while using our services. We do not collect information about our visitors from other sources, such as public records or bodies, or private organisations. We do not collect or use personal data for any purpose other than the specific services.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
LAWFUL BASIS FOR PROCESSING
Please note that in accordance with applicable data protection law, your Personal Data can be processed if:
HOW WE USE YOUR INFORMATION / PURPOSES OF PROCESSING
We will only process your Personal Data for specified, explicit and legitimate purposes and we will not process your Personal Data further in a way that is incompatible with those purposes.
DISCLOSURE OF PERSONAL DATA
Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, which will then process your Personal Data only within the framework of these purposes:
VISITORS TO OUR WEBSITES
When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
We use a third-party service, Black Knight, to publish our website. This site is hosted by Servers in Ireland. We use a standard service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it.
STORAGE OF DATA
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 of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will not store your personal information for any longer than we need to, however we may be obliged by law to store your communications and personal information including activity logs and we may need to show details of these to government or authorised officials upon request. Like many websites, we use log files to monitor the effectiveness of our website.
The data we collect from you will be stored within the EU. By providing us with this data, you agree to this storing and/or processing.
All our data is stored on our secured servers or on secure servers that are operated by a third party.
If we have provided you with a password which enables you access to our website, you are responsible for keeping this password confidential.
We use appropriate technical, organisational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:
All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our members’ and visitors’ personal data. We ensure that your personal data will not be disclosed to State institutions and authorities except if required by law, other regulation or for funding purposes.
In the event that any personal information is accessed without authorization, Elmgreen Golf Club will refer the information to the office of the Data Protection Commissioner within two working days of becoming aware of the incident, outlining the circumstances surrounding the incident. Further steps will be taken in consultation with the office of the Data Protection Commissioner thereafter.
ACCESS TO THE PERSONAL DATA WE MAY HOLD ABOUT YOU
You can ask us whether we are keeping personal data about you upon request, which you can indicate by:
Sending an email to firstname.lastname@example.org
Post: Elmgreen Golf Club, Dunsink Lane, Dunsink, Dublin
We will provide you with a readable copy of the personal data which we keep about you, within one month of receipt of this request – although we will before require proof of your identity. This can be extended by two months where the request for rectification is complex. We will provide this information free of charge.
We will however charge a reasonable fee when a request for information is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with the requests for further copies of the same information. This fee is based on the administrative cost to provide this information.
We allow you to challenge the data that we hold about you and, where appropriate, you may have the data erased, rectified or amended if it is incorrect or inaccurate. We reserve the right to refuse to provide our visitors with a copy of their personal data if the request is manifestly unfounded or excessive, but we will give reasons for our refusal. We do, however, allow you to challenge our decision to refuse to provide you with a copy of your personal data. You have the right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
ERASURE OF DATA
You have a right to have your personal data erased to prevent processing in the following specific circumstances:
KEEPING YOUR INFORMATION SECURE – TO HELP US KEEP YOUR INFORMATION CONFIDENTIAL YOU SHOULD:
NOTIFICATION OF CHANGES TO THIS POLICY
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Elmgreen Golf Club’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address email@example.com.