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Wales Golf WHS Privacy Policy

Updated 09/06/2021

Wales Golf WHS Privacy Policy

The Golf Union of Wales Limited, trading as Wales Golf (“Wales Golf”), are committed to safeguarding the privacy of the users of our World Handicap System (“WHS”) and Player Portal and this policy sets out how we will treat your personal information in relation tothis system or portal.

This page informs you of our policies regarding the collections, use and disclosure of personal information we receive from users of the site.

What information does Wales Golf collect?

If you are a member of a Wales Golf affiliated golf club, we may collect the following information about you:

  • your name, date of birth, email address, phone number, membership number, membership type (18 or 9 hole), home club, gender and age;
  • information about the courses you play, dates you play, your scores and information relating to your handicap;
  • information about competitions you play and your results from such competitions;
  • your Wales Golf player portal login details; and
  • we may also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type. We do this to help us analyse how members use the member login area (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience.

How we collect personal data?

We collect some of your information directly from you, either through information that you give to us or information that we collect through your communications with us. We also obtain some information from your golf club or contractors or suppliers acting on behalf of your golf club and other organisations involved in the calculation of your handicap.

Where is your personal data stored?

Your personal data will be stored and processed in the UK and / or the European Economic Area. Your data may be transferred to our platform developer which is based in New Zealand, a country that the European Commission has deemed to provide an adequate level of data protection in line with the GDPR.

 How long will we keep your data?

We will retain your data for as long as it is necessary to fulfil the purposes set out in “Why do we need your personal data?” in this privacy notice. This means that we will keep your personal data for the duration of your club membership. We also keep your personal data for a period of time following your membership ceasing. Once the data is no longer required for the purposes set out above, the period of retention will be calculated in accordance with our Data Protection Policy. When determining the relevant retention periods, we consider guidelines issued by relevant data protection authorities, as well as the time periods needed to comply with applicable regulations or laws, to meet regulatory and financial reporting obligations, for tax, accounting and audit purposes, and to fulfil and protect our contractual obligations and rights.

Security

We place great importance on keeping your personal data safe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage.

The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal data.

Why do we need your personal data?

The main purpose for which we use your information is to provide you with your handicapping and web services via the player portal platform and app.

We use your information:

  • to calculate your handicap;
  • to run golf competitions;
  • to provide you with information that you request from us or which may be of interest to you;
  • to notify you about changes to our services;
  • to provide club member support;
  • to develop and improve our services, website and platforms.
  • administer the platform;
  • enable your use of the services available on the website;
  • send you email notifications which you have specifically requested;
  • send to you our newsletter and other marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you by email or similar technology (you can inform us at any time if you no longer require marketing communications);
  • deal with enquiries and complaints made by or about you relating to the platform.
  • We will provide aggregated anonymised data to bodies such as Sport Wales to facilitate research about our club members and services generally.

Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the terms of use.

We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.

Performance of a contract

Processing may also be necessary for the performance of our contract with you. In order for us to fulfil our obligations under such contract (e.g. to provide you with and maintain an accurate handicapping system), we will need to collect, process and share (as further detailed below) your personal data.

Basis for using your personal data

Legitimate business interests

We have a legitimate interest in processing certain personal data. We use your personal data as set out in this privacy policy for our legitimate interests to enable us to:

  • administrate and maintain the integrity of the WHS;
  • maintain appropriate membership records;
  • maintain records of disciplinary, anti-doping or safeguarding cases; and
  • operate in a safe and lawful manner.

Where we rely on legitimate interests as the legal basis for processing your personal data, we have considered whether or not those interests are overridden by your interests, fundamental rights and freedoms. We won’t use your information if we believe your interests should override ours, unless we have other lawful grounds to do so (such as if we have a legal obligation to process your personal data). If you have any concerns about our processing please refer to details of “Your rights” section below.

As we outline in “Your rights” section below, you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing will affect our ability to carry out the tasks that we have set out above.

Compliance with a legal obligation

Processing of your personal data may be necessary for compliance with our legal obligations.

Who do we share your personal data with?

We may share your personal data with:

  • your home club and its members, or contractors or suppliers acting on behalf of your home club;
  • competition organisers and officials involved in competitions in which you take part, including contractors or suppliers acting on behalf of those organisations;
  • other organisations involved in the calculation of your handicap, for example where you play at a club other than your home club we may provide them with your current handicap;
  • carefully selected third parties which supply us with products and services, such as website and platform developers and cloud computing services. We will only share your information with these suppliers where it is necessary for them to provide us with the services we need;
  • our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);
  • organisations with whom we have a legal obligation to share your data, which may include regulators, fraud prevention agencies, police, the courts or law enforcement agencies; and
  • HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations.

 Your rights

You have the right to

  • obtain access to, and copies of, the personal data that we hold about you;
  • require us to correct the personal data we hold about you if it is incorrect;
  • require us to erase your personal data in certain circumstances;
  • require us to restrict our data processing activities in certain circumstances;
  • receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
  • object to our processing of personal data held by us about you; and
  • withdraw your consent, in circumstances where we rely on it to use your personal data.

We want to make sure that your personal data is accurate and up to date. You have the right to ask for inaccuracies in your data to be corrected, and in certain circumstances for us to stop processing your data or for your data to be erased. Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

If you wish to access or amend your data please contact us at office@walesgolf.org. If you are not satisfied with how we are processing your personal data, you can complain to the Information Commissioner’s Office (ICO). You can also find out more about your rights under the GDPR (and other data protection legislation) from the Information Commissioner’s Office website available at: www.ico.org.uk.

Contact us If you have any queries about this privacy notice or how we process your personal data you may contact our data protection officer: