Privacy Policy

This Privacy Policy sets out how we, Dungannon Golf Club, collect, store and use information about you when you use or interact with our website, dungannongolfclub.com (our website) and where we otherwise obtain or collect information about you.

 

Contents

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • Our use of automated decision-making and profiling
  • Information collected 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
  • Copyright, credit and logo

 

 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.

  • Data Controller: The Council of Dungannon Golf Club.
  • How we collect or obtain information about you:
    • when you provide it to us e.g. by contacting us, by applying for membership or signing up for our blog Mid Ulster Golfer,
    • from your use of our website, using cookies and similar technologies, and
    • occasionally from third parties.
  • Information we may collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), 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, and 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 membership applications and tee time bookings you place on our website), 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 golf club, to our service providers Club Systems and BRSGolf, to fulfill any contracts we enter into with you, and where required by law or to enforce our legal rights.
  • We do not sell your information to third parties (other than in the course of a business sale or purchase or similar event).
  • 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). 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, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: https://dungannongolfclub.com/cookies.
  • Use of automated decision making and profiling: we use automated decision making and profiling].  This includes the use of web analytics, cookies and targeting cookies to display advertisements to people who visit your website on other websites around the internet.
  • 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 following countries: USA and Canada. Appropriate safeguards are in place. 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
    • 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 is Dungannon Golf Club. We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Bar and Services Manager,  Denis  Monaghan has overall responsibility for data protection compliance in our organisation. You can contact the Denis by writing to Dungannon Golf Club or sending an email to dataprotection@dungannongolfclub.com.

 

 

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 Krystal Hosting Ltd, the privacy policy of which is available here: https://krystal.co.uk/terms. 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 the UK.

Use of website server log information for IT security purposes

Our third party hosting provider collects and stores 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. 

Use of website server log information to analyse website use and improve our website 

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used. 

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

 

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 and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: https://dungannongolfclub.com/cookies 

You can reject some or all of the cookies we use on or via our website by changing your browser settings 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.

 

 

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.

Email 

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: We use a third party email provider to store emails you send us. Our third party email provider is Krystal Hosting Ltd located in the UK. Their privacy policy is available here: https://krystal.co.uk/terms. 

Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in UK.

 

Online Membership Application form. 

When you apply for membership using our online application form we collect name, email address, parental email in the case of under 18s, mobile no., address, gender, address and date and time submitted and IP address. We also collect other information you provide to us when you complete the Membership Application form, including any optional information, such as members that you already know. If you do not provide the mandatory information required by our Application form, you will not be able to submit the contact form and we will not receive your application. 

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:  your message relates to us providing you with goods or services.

Transfer and storage of your information: Membership Applications you send us via our online form will be stored within the European Economic Area on our third party servers in Spain. Our third party provider is Typeform. Their privacy policy is available here: https://admin.typeform.com/to/dwk6gt

 

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 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. 

 

Email

 

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 

We use a third party email provider to store emails you send us. Our third party email provider is located in the United Kingdom. Their privacy policy is available here: https://krystal.co.uk/terms . 

Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in the United Kingdom.

 

Contact Form 

When you contact us using our contact form, we collect your name, email address, phone number and IP address. 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 stored within the European Economic Area on our third party hosting servers in the United Kingdom. Their privacy policy is available here: 

We use a third party contact form provider to store messages you send us. Our contact form provider is located in Spain. Their privacy policy is available here: https://admin.typeform.com/to/dwk6gt. Messages you send to us via our contact form will be stored  within the European Economic Area on our contact form provider’s servers in Spain.

 

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls. 

 

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 we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information. 

Mid Ulster Golfer 

When you sign up for our blog, The Mid Ulster Golfer, which is included on our website or opt to receive news, information, offers and humour from us by entering your name and email address on our website and clicking subscribe, we collect and store your name and email address. 

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). 

Consent: you give your consent to us sending you Mid Ulster Golfer by signing up to receive it using the steps described above. 

Transfer and storage of your information: We use a third party service to send out Mid Ulster Golfer and administer our mailing list, MailChimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/ 

Information you submit to subscribe for Mid Ulster Golfer will be stored within the European Economic Area on our third party mailing list provider’s servers.

We use technologies such as web beacons in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. 

 

Our use of automated decision-making and profiling

Our use of automated decision-making and profiling

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of automated decision making and 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: https://dungannongolfclub.com/cookies/

 

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: https://dungannongolfclub.com/cookies/

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 altering your cookie preferences by clicking on the circles icon on the bottom left of your screen or by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB].

Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: Our legitimate interest is appropriate given the valvalue of ads we bring to you.

 

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 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 https://dungannongolfclub.com/cookies/

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 clicking the circles icon in the bottom left of your screen) 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 interestanalysing the level of engagement and effectiveness of our marketing emails and content

 

 

Information collected about you from third parties

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business [and who process your information for us on our behalf These include the following:

Apart from BRSGolf, Golf Now and Tee Off Times which provide some of their services from USA, our service providers are located in UK.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us. 

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us by emailing dataprotection@dungannongolfclub.com and we will provide you with such information where you have a legitimate reason for requesting it. 

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest relied on: where we share your information with these third parties in a context other than where it is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently. 

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). 

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.  

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below. 

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/ 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html) 

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout 

Transfer and storage of your information 

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America. 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our business partners, and insurers. 

Further information on each of these third parties is set out below. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: running and managing our business efficiently. 

Insurers 

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them. 

Administrative purposes, including membership, customer and employee information. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: running and managing our business effectively. 

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). 

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract.

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly via by email to datprotection@dungannongolfclub.com and we will provide you with such information where you have a legitimate reason for requesting it.

 

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential. 

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

 

Disclosure and use of your information for legal reasons.

Indicating possible criminal acts or threats to public security to a competent authority. 

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).  

In connection with the enforcement or potential enforcement our legal rights 

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law). 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

 

In connection with a legal or potential legal dispute or proceedings 

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes. 

 

For ongoing compliance with laws, regulations and other legal requirements 

We will use and process your information in order to comply with legal obligations to which we are subject. 

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). 

Legal obligation(s): legal obligations to disclose information which are part of the laws of Northern Ireland or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed). 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

 

 

 

How long we retain your information

 

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period. 

Retention periods: 

On line Membership Application: when you apply for Membership online, we retain that information for six years following the end of the financial year in which you placed you applied, in accordance with our legal obligation to keep records for tax purposes. 

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for further 12 months after which point we will delete your information. 

Mid Ulster Golfer: will retain the information you used to sign up for The Mid Ulster Golfer for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our Mid Ulster Golfer, whichever comes earlier. 

Criteria for determining retention periods 

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following: 

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you). 

 

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including: 

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information; and
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.

Transmission of information to us by email 

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

 

 

Transfers of your information outside the European Economic Area

 

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place. 

Google Analytics 

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/ 

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission. 

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Dungannon Golf Club or sending an email to dataprotection@dungannongolfclub.com 

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. 

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/ 

 

Further information on your rihts in relation to your personal data as an individual 

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further iinformation about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website: 

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf 

Verifying your identity where you request access to your information 

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information. 

 How we verify your identity 

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.  

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. 

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request. 

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Dungannon Golf Club or sending an email to dataprotection@dungannongolfclub.com: 

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by: 

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

or 

  • sending an email to privacy@dungannongolfclub.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see our cookies policy, which is available here: dungannongolfclub.com/cookies 

 

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. 

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.  

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it. 

 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time. 

Minor changes to our Privacy Policy 

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards. 

Major changes to our Privacy Policy or the purposes for which we process your information 

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website. 

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose. 

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it. 

 

 

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18. 

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to privacy@dungannongolfclub.com.

 

 

Copyright, credit and logo

 

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org 

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved. 

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy. 

 

Last updated: 31 May 2018

 

 

CONTACT INFO

Tel No 028 8772 2098

34 Springfield Lane, Dungannon,

Co Tyrone, BT70 1QX

Email info@dungannongolfclub.com