This privacy policy sets out how Fitter Better Golf CIC (referred to as “we”, “us”, “our” or “Fitter Better Golf” throughout this privacy policy) uses and protects your personal data.

Important Information and Who We Are

This privacy policy gives you information about how Fitter Better Golf collects and uses your personal data through your use of this website, or if you otherwise deal with us as a user of our services, including any data you may provide when you register with us, when you contact us or when you use our service 

Fitter Better Golf CIC is a community interest company incorporated in England and Wales, under company number 13015460. Our registered office address is 48 Roedean Crescent, Brighton, England, BN2 5RH. 

We will be the controller for the purposes of the UK General Data Protection Regulation and Data Protection Act 2018 when you use this website or purchase a service from us, or deal with us as a supplier. 

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

This website is not intended for children and we do not knowingly collect data relating to children.

The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier and gender.
• Contact Data includes email address.
• Transaction Data includes information relating to the courses subscribed to.
• Membership Data includes the name of the golf club you are a member of. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences and feedback .
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and/or our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• create an account on our website;
• subscribe to our service or publications; or
• give us feedback or contact us in any other manner.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [LINK] for further details.
• Third parties or publicly available sources. We may receive Contact, Technical, Membership and Transaction Data from providers of technical services such as Thinkific Labs Inc, based in Canada.

How We Use Your Personal Data

What are our legal bases for processing the personal data?

 The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Contractual obligations: If we have negotiated or are negotiating a contract in order to provide services to you, or to receive products or services from you, we will need to use your personal data in order for us to fulfil our contractual obligations to you. 

• Legitimate interests: Legitimate interest means our interest in conducting and managing our business to enable us to give you the best service and the most secure client experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). For example, we may send you information of a new service or offer. 
• Legal or regulatory obligation: We must comply with a number of statutory provisions when providing our services, which necessitate the processing of personal data. For example, we are required to comply with statutory and regulatory obligations relating to business such as HMRC and fraud/crime prevention. 
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details set out in paragraph 10.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes - for example, emails from us relating to updates to our contractual documents or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see Our Cookies Policy

who will your data be shared with?

We may share your personal data with third parties in order to carry out your requests, respond to your enquiries, fulfil your orders, or make various other features, services available to you through our website. We share your personal data with specific third party service providers that perform functions on our behalf, such as Thinkific Labs Inc, a company which provides the website platform, based in Canada.

We may also share your personal data where necessary to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. 

This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at using the Contact details (paragraph 10).

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

 How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider:

• any statutory, legal regulatory, tax, accounting or other obligations (for example 6 years +1 for HMRC);
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the potential risk of harm from unauthorised use or disclosure of your personal data; 
• the amount and sensitivity of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

In some circumstances you can ask us to delete your data: see paragraph 0 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data.

• Right of access – you have the right to access your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• Right of rectification – you have a right to request the correction of personal data that we hold about you. This enables you to have any inaccurate or incomplete data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object to processing –where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Right of portability – you have the right to have the personal data we hold about you transferred to a third party, or to you. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to object-
  1. You have the right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in paragraph Error! Reference source not found. for details of how to object to receiving direct marketing communications).
  2. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to withdraw consent – you have the right to withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph Error! Reference source not found. for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Right to request restriction of processing of your personal data- this enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful, but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. 

If you wish to exercise any of the rights set out above, please contact us using the Contact details (paragraph 10)

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: [email protected].
• Postal address: 48 Roedean Crescent, Brighton, England, BN2 5RH.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

To report a concern to the ICO, please use one of the following:

• Online at: ico.org.uk/make-a-complaint/
• Call: 0303 123 1113

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Third-party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Fitter Better Golf CIC