This Privacy Policy sets out how we, North & West Coast Links Golf Limited, collect, store and use information about you when you use or interact with our websites, www.northandwestcoastlinks.com, (our website) and where we otherwise obtain or collect information about you.
This Privacy Policy is effective 10/05/2018.
Contents
- Summary
- Our details
- Information we collect when you visit our websites
- Information we collect when you contact us
- Information we collect when you interact with our websites
- Information we collect when you make a payment
- Our use of automated decision-making and profiling
- How we collect or obtain information about you from third parties
- Disclosure and additional uses of your information
- How long we retain your information
- How we secure your information
- Transfers of your information outside the European Economic Area
- Your rights in relation to your information
- Your right to object to the processing of your information for certain purposes
- Sensitive Personal Information
- Changes to our Privacy Policy
- Children’s Privacy
- California Do Not Track Disclosures
- Copyright
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Details
- Data controller: North & West Coast Links Golf Limited
- How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us and by signing up to our e-newsletter
- from your use of our website, using cookies and similar technologies, and
- occasionally, from third parties.
- Information we collect: name, name, contact details, email address, payment information, IP address, information from cookies, information about your computer or device (e.g. device and browser type) and information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address).
- How we use your information: for administrative and business purposes (particularly to contact you and process your CV for job applications), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.
- Use of automated decision-making and profiling: we use automated decision-making and profiling through our use of remarketing advertisements and web analytics. For further information, please see the main section below entitled Our use of automated decision-making and profiling.
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, and only granting access to your information where necessary.
- Use of cookies and similar technologies: we use cookies including functional, analytical and advertising cookies. For more information on which cookies we use on each of our websites, please visit our cookies policy here.
- Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, e.g. the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
- Your rights in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- not to have significant decisions made about you based solely on automated processing of your information, including profiling
- to complain to a supervisory authority
- Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
Our details
The data controller in respect of our website is North & West Coast Golf Links Limited. (company registration number 0536971) of 9 An Fuaran, Moycullen, Co. Galway, H91 CR26.
You can contact the data controller by writing to North & West Coast Links Golf Limited, 9 An Fuaran, Moycullen, Co. Galway, H91 CR26 or sending an email to sales@northandwestcoastlinks.com.
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website called Heaventree, the privacy policy of which is available here. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system. Our server is located in Amsterdam.
Use of website server log information for IT security purposes:
Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
- Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
- Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
- Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
- Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes. We use cookies on our website, including functional, analytical and advertising cookies. For further information on how we use cookies, please see our cookies policy which is available here.
You can reject some or all of the cookies we use on or via our website by changing your browser settings by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.
For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
- Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
- Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
- Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information:
Emails you send us will be transferred and stored outside the European Economic Area on our third-party email provider’s (Google, Inc.’s) servers in the United States of America or any of their other data centres around the world. Their privacy policy is available here.
For further information about the safeguards used when your information is transferred outside the European Economic Area, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Contact form
When you contact us using our contact form, we collect your name, email address, phone number and any information you provide in the ‘query’ field. We also collect any other information you provide to us when you complete the contact form. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
- Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
- Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
- Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
- Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information:
Messages you send us via our contact form will be transferred and stored outside the European Economic Area on our third-party email provider’s (Google, Inc.’s) servers in the United States of America or any of their other data centres around the world. Their privacy policy is available here.
For further information about the safeguards used when your information is transferred outside the European Economic Area, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
- Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
- Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
- Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information:
Information about your call, such as your phone number and the date and time of your call, is processed by one of our telephone providers and stored within the European Economic Area in Ireland or the United Kingdom.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
- Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
- Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
- Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
- Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include tour operators, transport companies, state bodies, hotels and golf courses.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you.
Our legitimate interest is the performance of our obligations under our sub-contract. Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one). In certain circumstances, we will also obtain information about you from private sources, both EU and non-EU.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard. For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
Our use of automated decision-making and profiling
We use automated decision-making and profiling.
You have the right to object to our use profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here
Automated decision making: Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision-making for display advertising
We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.
How to object: you can block these cookies by using the cookies control management tool on your site (if you use one) or by opting out of seeing personalised ads by following the instructions here.
For further information, please see our cookie policy.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you consent to our use of automated decision-making by turning on remarketing cookies using our cookie control tool.
Profiling: Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics service, Google Analytics uses and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on).
We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy.
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: we have a legitimate interest in getting to know our website visitors’ preferences and improving our website’s effectiveness.
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