Privacy Policy - American Golf

1.0 INTRODUCTION

We, American Golf Trading Limited (owner of American Golf and Online Golf), take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-UK).

This privacy notice gives you information on how we collect and process your personal data through your use of this site, other outlets, and any data you may provide if you contact us regarding our products and services.

We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.

2.0 WHY WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal data for one of the following purposes:

To manage communications between you and us

Where we need to perform the contract we have entered into with you

To improve products and services, make your experience more efficient and relevant and provide you with a personalised service

To provide you with information you have requested or which we may feel may be of interest to you

To ensure the safe operation of our website and to monitor the performance of our website

For marketing and advertising purposes

3.0 LAWFUL BASIS OF PROCESSING INFORMATION

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

The data subject (you) has given consent to the processing activity taking place.

If the processing is necessary for the performance of a contract

If the processing is necessary for compliance with a legal obligation to which the controller is subject

If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

The purpose test – to identify the legitimate interest

Necessity test – to consider if the processing is necessary for the purpose identified

Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified

4.0 WHAT INFORMATION WE COLLECT AND WHERE FROM

We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:

Name, address, telephone number, email and date of birth.

IP address

Marketing preferences

CCTV footage

4.1 THIRD PARTY COLLECTION OF PERSONAL DATA

Your Personal Data will not be shared, sold or distributed with unrelated third parties, except under these circumstances:

1. 1. Personal Data may occasionally be transferred to third parties for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented.
2. 2. Personal Data will be transferred to third parties for further processing in order to fulfil orders placed by you via this Web Site and to provide an after sales service.
3. 3. Third parties are engaged to perform services or functions in order to manage and improve this website, merchandising, marketing and promotional efforts, communications or other services. Those third parties include authorized contractors, consultants, legal advisors and other companies (collectively, "agents"). They only have access to personal information needed to perform their functions, and may not share any personal information with others or use it for any other purposes than that which is contractually agreed. Where appropriate, before disclosing Personal Data to a third party, that third party is contractually required to take adequate precautions to protect that data and maintain confidentiality. Information about you may also be received from other sources (such as demographic information and purchase history) and it may be added to records about you in order to make marketing efforts more efficient.
4. 4. The information in this websites databases' may be shared or transferred to comply with a legal requirement, for the administration of justice, to protect your vital interests, to protect the security or integrity of the databases or this website, to take precautions against legal liability, or in the event of a sale, merger, reorganisation, dissolution or similar event.
5. 5. Where you have consented, your information may be disclosed to partners or other businesses who may contact you about their products or services that may interest you.
6. 6. During the purchase process, your information may be shared with certain intermediaries (e.g., UPS) strictly to process and ship your order.

Third party sites

This website may contain hyperlinks to web sites operated by third parties. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. Such websites are controlled by third parties and as such you should review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself. The information practices of those websites linking from or to this website are not covered by this Policy, and you are encouraged to be very cautious before you disclose your personal information to others.

5.0 HOW LONG WE KEEP INFORMATION FOR

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collected has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 16 of this policy.

6.0 SECURITY OF PERSONAL INFORMATION

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.

We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 16 of this policy.

7.0 CHILDREN'S INFORMATION

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.

8.0 YOUR INDIVIDUAL RIGHTS

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under General Data Protection Regulation are:

Right to Object

Right of Access

Right to be informed

Right to Rectification

Right to Erasure

Right to Restrict Processing

Right to Data Portability

The right to object

1. You can exercise this right if:
2. 1. Processing relies on legitimate interest
3. 2. Processing is for scientific or historical research
4. 3. Processing includes automated decision making and profiling
5. 4. Processing is for direct marketing purposes

The right of access

1. 1. You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge
2. 2. We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you

The right to be informed

1. 1. We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.

The right of rectification

1. 1. If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.

The right to erasure

1. 1. If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.

The right to restrict processing

1. You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
2. 1. Processing is unlawful
3. 2. We no longer need the personal data, but it is required for a legal process
4. 3. You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made
5. 4. If you are exercising your right to rectification

The right to data portability

1. You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
2. 1. Processing is based on consent
3. 2. Processing is by automated means (i.e. not paper based)
4. 3. Processing is necessary for the fulfilment of a contractual obligation

If you have any question about these rights, please see "additional information", section 16 of this policy.

9.0 CONSENT

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

To ensure that your credit, debit or charge card is not being used without your consent, we will validate name, address and other personal information supplied by you during the order process against appropriate third-party databases. By accepting these terms and conditions you consent to such checks being made. In performing these checks personal information provided by you may be disclosed to a registered Credit Reference Agency which may keep a record of that information. You can rest assured that this is done only to confirm your identity, that a credit check is not performed and that your credit rating & will be & unaffected. All information provided by you will be treated securely and strictly in accordance with the UK GDPR and the Data Protection Act 2018.

10.0 FAILURE TO PROVIDE PERSONAL INFORMATION

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

11.0 COOKIES

Our website uses cookies. Please see our cookies policy for full details of the cookies used.

12.0 AUTOMATED DECISION MAKING

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.

13.0 TRANSFERS TO THIRD PARTIES

American Golf may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:

Business partners, suppliers, contractors for the performance of any contract we enter into with them or you

Companies within our group where necessary for administrative purposes and to provide services to you

Third parties that support us to provide products and services e.g., IT support, cloud-based software services, providers of telecommunications equipment)

Marketing services providers

Payment service providers

Recruitment service providers

Professional advisors e.g., lawyers, auditors

Web analytics and search engine provider to ensure the continued improvement and optimisation of our website

14.0 TRANSFERS OUTSIDE OF THE UK

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside of the United Kingdom (UK).

We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

International Data transfer Agreement and Addendum

Standard Contractual Clauses

Binding Corporate Rules

An exception as defined in Article 49 of the EU GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 16.

15.0 RIGHT TO COMPLAINT

We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email on ag.gdpr@americangolf.co.uk

Alternatively, you can contact us:

By Post: Data Protection Officer, American Golf, 1st Floor Westbrook House, Westbrook Centre, Warrington, WA5 8UH

By Phone: 01925 939 999

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here

By Email: Click Here

By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)

16.0 ADDITIONAL INFORMATION

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on ag.gdpr@americangolf.co.uk

17.0 POLICY REVIEW AND AMENDMENTS

We keep this Policy under regular review. This Policy was last updated on 01/03/2023.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.