1. Who is responsible for the treatment of data?
In compliance with the provisions of the General Data Protection Regulation (EU) 2016/679 and Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of digital rights (hereinafter “LOPDGDD”) , and Law 34/2002 of July 11, Services of the Information Society and Electronic Commerce, and other applicable regulations, be informed that the Person Responsible for the processing of personal data processed on the Website http://www.golfinenglish.com is:
Company name: Golf In English (hereinafter The Company)
Telephone: 620482058
Email: info@golfinenglish.com
The Company is committed to keeping the information provided in the strictest confidence, avoiding unauthorized access, manipulation of information and the loss, destruction or theft of information. To do this, security measures are applied and established by the applicable regulations and all those that resources and modern technology allow. In many cases, it is essential that information requested is provided in order to enjoy the benefits of the website.
2. Objective
The purpose of this Privacy Policy is to inform the user about how their Personal Data is treated. If the user does not agree with the terms contained in this Policy and does not accept them in their registration process, they will not be able to continue with the use and access to the web. If the user has any questions regarding the content they can contact The Company via the email indicated in the heading.
3. Who does it apply to?
This Policy applies to all users who use the services of our website, regardless of the place and time in which they operate.
4. What data is requested as Responsible?
On the website basic information could be requested through the contact form, such as full name, email address, telephone number, level of English, use of English, where the user first found information about The Company, leaving a space for the user to send queries, requests, complaints or suggestions. Through the ‘Golf Directo’ platform, your name and surname, email address, ID or passport, and your license number will be requested and are necessary to complete the payment form on the platform. The data that is identified with the symbol * will be essential for the purpose of the completed form. All the data entered in ‘Golf Directo’ will remain in The Company.
Images may be processed under the conditions set forth in section 5.h. of this Privacy Policy.
Data could also be processed and obtained through cookies, which the user can consult in more detail in our Cookies policy.
5. For what purpose is the data processed?
The purposes for which information is automatically requested or collected, in response to the different channels through which users have provided their personal data, are the following:
- Properly manage the website and ensure the safety of its users.
- Facilitate navigation and guide it to the preferences of the user, based on the Cookies policy.
- Verify in certain cases the veracity of users’ information.
- Answer questions or requests through the contact form. Manage the requested service by responding to users’request or queries and processing said requests.
- Register users on the website.
- Manage users’ registration in tournaments and events, as well as the payment of said registrations through ‘Golf Directo’. Management of payments, collections and claims. For more information see the Terms of service.
- Complete the ranking in the different circuits and tournaments with the data of the participants registered as users and their scores in each of them. This means that users’ personal data could be published on the web and in the media that publicize the event, for example- the results obtained in the competition and the prizes obtained. If a user has an objection regarding this purpose, refrain from making any purchase and contact The Company to assess this circumstance.
- Photography and videos may be taken during the event for publication on social networks and The Company’s website for the promotion of said events and activities. If the user objects to this use of the images or videos in which they appears, they must refrain from making the purchase and thus participation in said event.
- Carry out marketing actions, send promotional messages, and commercial communications about The Company’s services and products and those of third-party companies that maintain commercial relations or collaborations with The Company, as well as notifying users about english events and activities, provided that the user authorizesThe Company or there is a legitimate interest for this end. *The commercial communications that are sent about third-party services or products do not imply in any case that these third parties know users’ data, since data will not be transferred to any third party without the users’ authorisation. These are simply collaboration agreements that are signed with third parties, to obtain discounts and special promotions that can be accessed exclusively for being a client.
- Give information about English classes, English courses or events in English. If a user has an objection regarding this purpose, refrain from filling in their data and contact The Company to assess this circumstance.
6. What is the legitimacy for the treatment?
The unequivocal consent of the user for the processing of their personal data in accordance with the purposes described above, at the time of data collection through our forms.
The express consent of the user at the time of data collection through our forms, for the sending of commercial information, by checking the box enabled for this purpose, in order to receive communications and notifications about events and activities that may be of interest.
7. How long will the data be stored for?
Personal data will be kept for the period of time necessary to fulfill the purposes for which they were collected and as long as the right of deletion is not requested, and, in any case, not for longer than the legally established deadlines.
8. Commercial and promotional communications.
One of the purposes for which the company processes the personal data provided by users is to send them electronic communications with information regarding goods, services, promotions, offers, events or news relevant to users. Whenever any communication of this type is made, it will be addressed solely and exclusively to those users who have not previously expressed their refusal to receive them.
In the event that the user wishes to stop receiving commercial or promotional communications from the company, they can request the cancellation of the service by sending an email to the following email address: info@golfinenglish.com as well as indicating their refusal to receive them, through the box thus provided in the data collection form or indicating it through the unsubscribe option provided in each of the commercial communications sent.
9. Are services subcontracted?
The user expressively authorizes The Company to subcontract a service in whole or in part with third parties whose intervention it deems appropriate for the proper development of the services. In this case, the Company signs a contract with the subcontracted third party that stipulates the obligations that it must comply with in relation to the protection of personal data, in particular it will be required to comply with the same obligations of protection of data to which the Company has committed to its users, as well as sufficient guarantees of application of appropriate technical and organizational measures so that the treatment is in accordance with the applicable regulations.
The Company will be diligent in the selection of providers through the application of regulatory compliance verification mechanisms, with the aim of minimizing as much as possible any risk that may affect the security of the information that the third party may access.
10. To whom will this data be communicated to?
Personal data will not be transferred to third parties, except for compliance with legal obligations. Nor are international data transfers made to third countries, except when necessary for the trips offered by The Company to make hotel reservations or golf outings for the proper development of the service.
If a reservation is made, it is possible that to guarantee the reservation we must communicate personal data such as name, surname and ID / Passport number of the registered participants to the management companies of the contracted event and / or to the golf course, since in many cases it is required to guarantee participation and identify the participants on the day of the event.
The photos and data of the participants in events will also be published in the media, such as social networks, the website and other media, in order to promote the event and publish the points and prizes obtained, as described in section 5.
11. What rights do users have?
The LOPDGDD and the RGPD collect a series of rights in favor of the people whose personal data is processed. Rightscan be exercised by sending a request by email as indicated in section 1, accompanying a copy of your identity document. The maximum term to resolve said request is one month from the receipt of said request. Please note that additional information may be requested to verify users’ identity before proceeding said request.
Right of access:
a. The right of access allows the user to know and obtain free information about their personal data and how it is used.
b. Right of rectification: This right is characterized by the fact that it allows errors to be corrected, data that turns out to be inaccurate or incomplete to be modified and guarantees the certainty of the information being processed. Changes indata must be informed and the user will be responsible for updating their information.
c. Right to cancellation/deletion/forget: The right of deletion allows the deletion of data that turns out to be inadequate or excessive without prejudice to the duty of blocking, included in the LOPDGDD.
d. Right of opposition: The right of opposition is the right of the user not to carry out the processing of their personal data or to cease the use of it for certain purposes. The processing of users’ data indicating the specific purposes object of opposition.
e. Right of Portability: The right of portability will allow the user to request a copy in a structured format, commonly used and mechanical reading of their personal data.
f. Right of Limitation of Treatment: By exercising this right, the users’ data may only be processed, with the exception of its conservation, for the formulation, exercise or defense of claims.
g. Right to file a claim with the control authority: The user may file a claim with the Spanish Agency for Data Protection (www.aepd. es ) when they consider that their rights have not been adequately addressed. In the same way, the user will have the right not to be subject to decisions based solely on the automated processing of their data, including profiling, which produces legal effects on the user or significantly affects them in a similar way. The user will have the right to revoke their consent at any time.
12. What security measures are applied?
In the processing of personal information, the appropriate technical and organizational security measures are applied according to the type of data and technical advances, and physical and legal means. The Company’s goal is to prevent unauthorized third party access, theft, loss, or disclosure of users’ information. However, the Internet is not a completely secure environment, so even if all possible security measures are applied, the risk of incidents regarding the information will never completely disappear. For this reason, if the user detects any incidents or has indications that their information may be at risk, they should please contact The Company so that the matter can be investigated and a solution obtained.
13. Can the Privacy Policy be modified?
The Company could in the future modify this Privacy Policy. In case of modification, in addition to publishing the updated version, the user will be informed about said modification with a specific announcement on the website. The user must read these modifications before continuing to use the web.
14. What is the applicable law and jurisdiction?
This Policy, as well as the use of the Website, will be governed by Spanish law. Any dispute will be resolved before the courts corresponding to the user’s address.
In the event that any stipulation is unenforceable or nulled by virtue of the applicable legislation or as a consequence of a judicial or administrative resolution, said unenforceability or nullity will not make this Policy unenforceable or null as a whole. In such cases, the Company will proceed to modify or replace said stipulation with another that is valid and enforceable and that, as far as possible, achieves the objective and claim reflected in the original stipulation.