1. a) to respond to any query that you may submit to us
2. b) to manage our relationship with you including by maintaining our database of clients

3. c) to send you any relevant information on our services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent to do so or we are otherwise able to do so in accordance with applicable European Data Protection Legislation
4. d) to ensure that our website’s content is presented in the most effective manner for you and your device
5. e) to customise our website according to your interests
6. f) to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses
7. g) to allow you to participate in interactive features on our website when you choose to do so
8. h) as part of our efforts to keep our website safe and secure
9. i) to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you
10. j) to comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place
11. k) as we feel is necessary to prevent illegal activity or to protect our interests.

1. a) Performance of, or entry into, a contract. The personal data that we are required to collect in order to comply with any other professional, legal and regulatory obligations which apply to us must be provided to us in order for us to perform this contract – we would not be able to act for you without this personal data.
2. b) Compliance with a legal obligation to which we are subject.
3. c) We have a legitimate interest in doing so as a friendly golf group (and where our legitimate interests are not overridden by your (or the relevant individual’s) own interests or fundamental rights or freedoms). These legitimate interests will include our interests in managing our relationship with our players and compliance with policies, practices or procedures.
4. d) Where processing of ‘special category data’ is necessary in the context of the establishment, exercise or defence of legal claims.

• you specifically request this
• if our website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of our website, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

6.4 The third parties include:

6.5 Our website may, from time to time, contain links to and from the websites of partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6.6 We will not rent or sell our users’ or other contacts’ details to any other organisation or individual.

7 Storage and retention of your personal data
7.1 We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on our website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot absolutely guarantee the security of your data.
7.2 We will keep your information stored on our systems for as long as it takes to provide the services to you and in accordance with our Terms of Use. We may keep your data for longer than our stated retention period if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research, preventing conflicts of interests or statistical purposes. If we do, we will ensure that appropriate safeguards are in place to protect your privacy and only used for those purposes.
7.3 Any contact details stored on our client relationship management database will be removed from our mailing lists if they do not interact with our emails (i.e. open emails or click on links within them) for a certain period following which they will be moved to an archive folder before being deleted permanently.
on their systems for as long as is necessary to provide the services to you.
7.4 We will, subject to paragraph 7.2, not store your information for longer than is reasonably necessary or required by law.

8 Sending your information outside of the EEA
8.1 If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) (e.g. a professional advisor or third party engaged by us or you as part of our work under an engagement letter) we will ensure we do so in compliance with European Data Protection Legislation, including where applicable by ensuring that the transfer is necessary to perform a contract in place with you or a contract entered into in your interests.

9 Withdrawal of consent
9.1 Where we process your personal data we do so on the basis that you have provided your consent for us to do so for the purposes set out in this Policy when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at asc@santjordigolf.com or via our Contact Us page
9.2 If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.

10 Your information rights
10.1 European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.
10.2 You can access the personal information we hold on you by writing to us at:
Adrian Cox
Calle Castillejos 363,5,2
08025
Barcelona
NIE: X0577019H
Tel: (00 34) 934 568 301
Mobile: (00 34) 691 805 744
E-Mail: asc@santjordigolf.com

10.3 We will ask you to provide proof of identity before we show you your personal information – this is so we can prevent unauthorised access.
10.4 You have the additional rights to request rectification and erasure of your personal data and to request restriction of, and to otherwise object to, our processing of your personal data and you can exercise these rights at any time by contacting E-Mail: asc@santjordigolf.com  or via our Contact Us page.
From 25 May 2018, you will also be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise this right fromm 25 May 2018 by contacting us at E-Mail: asc@santjordigolf.com  or via our Contact Us page.

11 Complaints
11.1 If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.
11.2 You also have the right to make a complaint to the Information Commissioner’s Office. For more details please visit the ICO website.

12 Contact
Questions, comments and requests regarding this Policy should be addressed to our Data Protection Officer:
Adrian Cox
Calle Castillejos 363,5,2
08025
Barcelona
NIE: X0577019H
Tel: (00 34) 934 568 301
Mobile: (00 34) 691 805 744
E-Mail: asc@santjordigolf.com
Alternatively, you can contact us through the Contact Us section of our website. www.santjordigolf.com