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Privacy Policy of ClubNet

ClubNet collects some Personal Data from its Users.
Updated May 27th 2018

Policy summary

Personal Data collected for the following purposes and using the following services:

  • 1. Access to third-party accounts
    Stripe account access and Twitter account access Personal Data: various types of Data as specified in the privacy policy of the service

  • 2. Analytics
    Google Analytics Personal Data: Cookies and Usage Data

  • 3. Contacting the User
    Contact form Personal Data: email address, first name and last name

  • 4. Device permissions for Personal Data access
    Personal Data: Approximate location permission (non-continuous) and Storage permission

  • 5. Displaying content from external platforms
    Google Maps widget and Vimeo video Personal Data: Cookies and Usage Data

  • 6. Handling payments
    Stripe Personal Data: various types of Data as specified in the privacy policy of the service

  • 7. Hosting and backend infrastructure
    Amazon Web Services (AWS)

  • Personal Data: various types of Data as specified in the privacy policy of the service
  • 8. Location-based interactions
    Geolocation Personal Data: geographic position

  • 9. Managing contacts and sending messages
    SendinBlue Email Personal Data: Cookies, email address and Usage Data 10. Registration and authentication Stripe OAuth Personal Data: various types of Data as specified in the privacy policy of the service

Further information about Personal Data

  • 1. Push notifications ClubNet may send push notifications to the User.

  • 2. Selling goods and services online The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by ClubNet depends on the payment system used.

  • 3. The Service is not directed to children under the age of 13 Users declare themselves to be adult according to their applicable legislation. Minors may use ClubNet only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use ClubNet.

  • 4. Unique device identification ClubNet may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • 5. User identification via a universally unique identifier (UUID) ClubNet may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

  • 6. Contact information App Owner and Data Processor Golfgraffix Ltd. Registered Offices at Guinness Enterprise Centre, Taylors Lane, Dublin 8, Ireland. App Owner contact email: info@golfgarffix.com

Full policy


App Owner and Data Processor

Golfgraffix Ltd. Registered Offices at Guinness Enterprise Centre, Taylors Lane, Dublin 8, Ireland. App Owner contact email: info@golfgarffix.com Types of Data collected

1. Among the types of Personal Data that ClubNet collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, email address, Approximate location permission (non-continuous), Storage permission and geographic position. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using ClubNet.

Unless specified otherwise, all Data requested by ClubNet is mandatory and failure to provide this Data may make it impossible for ClubNet to provide its services. In cases where ClubNet specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by ClubNet or by the owners of third-party services used by ClubNet serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through ClubNet and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

1. Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of ClubNet (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

1. The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

  • 1. The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

  • 2. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

  • 3. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

  • 4. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


Retention time

  • 1. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

  • 2. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

  • 3. The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

  • 4. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.



The purposes of processing

  • 1. The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to third-party accounts, Analytics, Contacting the User, Device permissions for Personal Data access, Displaying content from external platforms, Handling payments, Hosting and backend infrastructure, Location-based interactions, Managing contacts and sending messages and Registration and authentication.

  • 2. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.



Device permissions for Personal Data access

  • 1. Depending on the User's specific device, ClubNet may request certain permissions that allow it to access the User's device Data as described below.

  • 2. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.

  • 3. The exact procedure for controlling app permissions may be dependent on the User's device and software.
    Please note that the revoking of such permissions might impact the proper functioning of ClubNet.



If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by ClubNet.

1. Approximate location permission (non-continuous) Used for accessing the User's approximate device location. ClubNet may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for ClubNet to derive the approximate position of the User on a continuous basis. 2. Storage permission Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • 1. Access to third-party accounts
    This type of service allows ClubNet to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User. o Stripe account access (Stripe Inc) This service allows ClubNet to connect with the User's account on Stripe, provided by Stripe, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • 2. Contacting the User
    o Contact form (ClubNet) By filling in the contact form with their Data, the User authorises ClubNet to use these details to reply to requests for information or any other kind of request as indicated by the form’s header. Personal Data collected: email address, first name and last name.

  • 3. Displaying content from external platforms
    This type of service allows you to view content hosted on external platforms directly from the pages of ClubNet and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
    o Google Maps widget (Google Inc.) Google Maps is a maps visualization service provided by Google Inc. that allows ClubNet to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy Privacy Shield participant.
    o Vimeo video (Vimeo, LLC) Vimeo is a video content visualization service provided by Vimeo, LLC that allows ClubNet to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy
    o Masterscoreboard (Handicapmaster Ltd) Masterscoreboard is a handicap and results content service provided by Handicapmaster that allows ClubNet to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: UK – Privacy Policy

  • 4. Hosting and backend infrastructure
    This type of service has the purpose of hosting Data and files that enable ClubNet to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of ClubNet. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. o Lets Host Lets Host is a hosting and backend service provided by Digital Media Internet Services Ltd t/a registered number 404150. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

  • 5. Managing contacts and sending messages
    This type of service makes it possible to manage a database of email contacts, allowing the app to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. o SendinBlue Email (SendinBlue SAS) SendinBlue is an email address management and message sending service provided by SendinBlue SAS. Personal Data collected: Cookies, email address and Usage Data. Place of processing: France – Privacy Policy

  • 6. Analytics
    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour. o Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of ClubNet, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy Opt Out Privacy Shield participant.

  • 7. Device permissions for Personal Data access
    ClubNet requests certain permissions from Users that allow it to access the User's device Data as described below. o Device permissions for Personal Data access (ClubNet) ClubNet requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document. Personal Data collected: Approximate location permission (non-continuous) and Storage permission.

  • 8. Handling payment
    Payment processing services enable ClubNet to process payments by credit card, bank transfer or other means. To ensure greater security, ClubNet shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment. o Stripe (Stripe Inc) Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy Privacy Shield participant.

  • 9. Location-based interactions
    ClubNet may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by ClubNet. Personal Data collected: geographic position.

  • 10. Registration and authentication
    By registering or authenticating, Users allow ClubNet to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, ClubNet will be able to access some Data, stored by these third-party services, for registration or identification purposes. o Stripe OAuth (Stripe Inc) Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy Privacy Shield participant. o Masterscoreboard (Handicapmaster Ltd) Masterscoreboard is a handicap and results content service provided by Handicapmaster that allows ClubNet to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: UK – Privacy Policy



Further information about Personal Data


  • 1. Push notifications
    ClubNet may send push notifications to the User. Push notifications can be turned off at device level by the user and maybe customised by topics in the App Settings.

  • 2. User identification via a universally unique identifier (UUID)
    ClubNet may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

  • 3. Unique device identification
    ClubNet may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • 4. Selling goods and services online
    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by ClubNet depends on the payment system used.

  • 5. The Service is not directed to children under the age of 13
    By using ClubNet users declare themselves to be adult according to their applicable legislation. Minors may use ClubNet only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use ClubNet.



The rights of Users



Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
  • 1. Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

  • 2. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

  • 3. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

  • 4. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

  • 5. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

  • 6. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

  • 7. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

  • 8. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

  • 9. Details about the right to object to processing

  • 10. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.



Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights


Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing


Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of ClubNet or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, ClubNet may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, ClubNet and any third-party services may collect files that record interaction with ClubNet (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
ClubNet does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within ClubNet and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references



Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through ClubNet (or third-party services employed in ClubNet), which can include: the IP addresses or domain names of the computers utilized by the Users who use ClubNet, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using ClubNet who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of ClubNet. The Data Controller, unless otherwise specified, is the Owner of ClubNet.

ClubNet (or this Application)
The means by which the Personal Data of the User is collected and processed.


Service
The service provided by ClubNet as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User's device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to ClubNet, if not stated otherwise within this document.

Address

Finnabair Industrial Estate
Dundalk
County Louth
Ireland

Contacts

Email: info@golfgraffix.com 
Phone: +353 (0) 42 9611171 

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