Golfposer Ltd are committed to protecting the privacy of your personal data. For the purpose of the UK Data Protection Act 1998 and the General Data Protection Regulation 2016 (the Law), the data controllers for any personal information we hold about you are Golfposer Ltd, 12 e-Net Park, Mill Road, Linlithgow, Scotland, United Kingdom, EH49 7SF.
This privacy notice explains how your data is collected, used & stored. It applies to data collected when you use our website, when you interact with us through social media, email, or phone, or when you participate in our competitions. It covers:
- The personal data we collect
- How we collect your data
- How we use your data
- Marketing preferences, adverts and cookies
- Links to other websites and third parties
- How we share your data
- Your rights
- Changes to this privacy notice
- How to contact us
If you would like further information about how we collect, use and store your personal data, you can contact us at any time by emailing email@example.com, calling +44 1506 238765 or writing to our Privacy Officer at Golfposer Ltd, 12 E-Net Park, Mill Road Industrial Estate, Linlithgow, Scotland, United Kingdom, EH49 7SF.
Our commitment to you
We take the protection of your personal data seriously and will process your personal data lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used.
We will only collect and use your personal data for the following purposes, to:
- complete your order(s)
- keep you up to date with the latest offers and trends
- give you a better shopping experience
- help us to make our marketing more relevant to you and your interests
- improve our services
- meet our legal responsibilities
How we keep your data safe and secure
We have appropriate safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved. We encrypt your data and store it on secure servers hidden behind a firewall.
We require any third party who is contracted to process your personal data on our behalf (such as payment providers) to have security measures in place to protect your data and to treat such data in accordance with the law.
In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.
The personal data we collect
Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed.
While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 13, you are not permitted to use or submit your data to the website.
The following groups of personal data are collected:
- Identity Data includes information such as: first name, last name, title & date of date of birth (optional).
- Contact Data includes information such as: email address, billing address, delivery address, location, country, telephone number and social media id (if you log in by social media).
- Financial Data includes information such as: payment card details.
- Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as order number, subtotal, title, currency, discounts, shipping, number of items, product number, single item price, category, tax etc.); payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any loyalty rewards.
- Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
- Profile Data includes information such as: purchases or orders made by you, product and style interests, preferences, feedback, and survey responses.
- Usage Data includes information such as: how and when you use our website, how you moved around it, what you searched for; website performance statistics, traffic, location, weblogs and other communication data; loyalty programme activities; and details of any other Golfposer products and services used by you.
- Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
How we collect your data
We may collect personal data about you in the following ways:
- Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:
- Create an account or purchase products on our website;
- Subscribe to our newsletter, social media sites or create outfits & favourites;
- Enter a competition;
- Join our Golfposer loyalty programme;
- Complete a voluntary market research survey;
- Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service);
- When you log in to our website via social media.
- Third parties – we may receive personal data about you from various third parties, including:
- Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’.
- Technical Data from affiliate networks through whom you have accessed our website;
- Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
How we use your data
The legal basis for processing your personal data
We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it.
We will only collect personal data from you when:
- we have your consent to do so, or
- we need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or
- the processing is in our legitimate interests and not overridden by your rights, or
- we have a legal obligation to collect or disclose personal data from you.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.
If you have any questions about how Golfposer use any of your personal data, please contact our Data Protection Officer, Andrew Coulter at firstname.lastname@example.org .
How long we keep your data for
We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.
Marketing preferences, adverts and cookies
Marketing - your preferences
We may send you marketing communications and promotional offers:
- if you have opened an account with us or purchased goods from us, or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below);
- by email if you have signed up for email newsletters;
- if you have provided us with your details when you entered a competition and you have consented to receiving such marketing (in accordance with your preferences, as explained below).
We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data and Marketing and Communications Data to form a view on what we think you may like, or what may be of interest to you, and to send you details of products and offers which may be relevant for you.
We will ask you for your preferences in relation to receiving marketing communications by email and other communication channels.
You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:
- you can unsubscribe or ‘opt-out’ by using the unsubscribe button and following the link included in the footer of any marketing email; or
- account holders may withdraw their consent by simply logging in to My Account and editing your preferences.
- Contact us with any concerns directly via emailing email@example.com
We will process all opt-out requests as soon as possible & normally within 1 business day.
Links to other websites and third parties
Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.
How we share your data
Golfposer will not share any of your date to any 3rd parties other than for normal business activities such as processing your payment & delivering your goods. We may disclose and share your personal data with the parties set out below:
- payment processing services (including Worldpay, PayPal) to process your payment to us. Golfposer does not store your payment information. Your payment details are provided to the payment processing service you have selected, who are compliant with necessary regulations;
- sharing contact information with our courier partners in order to deliver & track your orders;
- affiliate networks through whom you have accessed our website;
- to any third party to whom we may choose to sell 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 notice.
- to protect our customers and website from fraud and theft, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your, name and location), together with account information, with organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
Your data and countries outside of Europe
The personal data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. This may include using specific contractual clauses approved by the European Commission which give personal data the same protection as it has in Europe.
You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:
- request access to your personal data
- request correction of your personal data
- request erasure of your personal data
- request restriction of processing of your personal data
- request the transfer of your personal data
- object to processing of your personal data
- object to automated decision making
Brief details of each of these rights are set out below. If you wish to exercise any of these rights, please email us at firstname.lastname@example.org.
Request access to your personal data
You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.
Request correction of your personal data
You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at email@example.com.
Request erasure of your personal data
This enables you to request that Golfposer delete your personal data, where there is no good reason for us continuing to process it. 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.
Request restriction of processing of your personal data
You have a right to ask Golfposer to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future.
Request the transfer of your personal data
You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.
Object to processing of your personal data
You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
Right to lodge a complaint
If you have any concerns or complaints regarding the way in which we process your data, please email us directly at firstname.lastname@example.org. You also have the right to make a complaint to the ICO (the data protection regulator in the UK). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance.
Changes to this privacy notice
From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.
This privacy notice was last updated May 2018.
How to contact us
We are happy to answer any questions you may have about your data.
Please send any questions, comments or requests for more information to our nominated representative and Data Protection Officer Andrew Coulter, who can be contacted at email@example.com.
Registered Company Number: 296775.
UK VAT Number: 878156577.