Privacy Policy - Protecting your Privacy

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy gives you information about how we collect and use your personal data when you visit this website or our online booking portal and purchase goods or services from us, including (without limitation) any data you may provide when you sign up to one of our newsletters or engage with us on social media.

This website and our online booking portal are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

THE CONTROLLER

We are the controller and responsible for your personal data we collect as set out in this privacy policy.

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

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, marital status, date of birth, gender and title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account details and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or our suppliers.
• 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 or our online booking portal.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, your handicap ability, feedback and survey responses.
• Usage Data includes information about how you interact with and use this website, our online booking portal, our products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. 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 (such Identity, Contact and Marketing and Communications Data) by filling in online forms on this website or our online booking portal or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • browse our website or our online booking portal;
  • are a customer and enquire about or become one of our customers, in which circumstances you may:
    • have access to our online booking portal;
    • purchase products from us; or
    • receive services from us;
  • sign up to one of our newsletters; or
  • engage with us on social media.
• Automated technologies or interactions. As you interact with this website or our online booking portal, 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 for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties, such as set out below:
  • Technical Data is collected from analytics providers such as Google and HotJar:
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and AI meeting assistant services, such as Signable and Dojo.
  • Identity and Contact Data is collected from publicly available sources, such as Companies House and the Electoral Register.

4. HOW WE USE YOUR PERSONAL DATA

The law requires us to have a legal basis for collecting and using your personal data. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer or supplier experience (or those of a third party). 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal or regulatory obligation we are subject to. We will identify the relevant legal obligation when we rely on this basis.
• Consent: Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Direct marketing

During the registration process on our website or any of our other portals when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Thid 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 logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us via the details set out in paragraph 10 below.

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 relating to order confirmations for updates to our Terms and Conditions 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 cookie policy.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with:

• External Third Parties (as set out below) for the purposes set out in paragraph 4 above. We only provide the information they need to perform their specific service. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times. If their services are terminated any data held by them will be deleted.
• 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.

• Foremost Golf Limited, who handles data as our processor in the provision of retail, infrastructure and marketing services for us.
• Golf equipment suppliers or service providers acting as processors based in the EEA who provide marketing, technical, payment and retail services, such as Adestra Ltd, Signable, Dojo and Golf Clubs 4 Cash.

6. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

7. 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.

8. DATA RETENTION

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 the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary below to find out more about these rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. 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.

Object to processing of your personal data 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. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 above for details of how to object to receiving direct marketing communications).

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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.

Withdraw consent at any time where we are relying on consent to process your personal 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.

If you wish to exercise any of the rights set out above, you can contact us via the details set out in paragraph 10 below.

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 may 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 may 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.

10. 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 by using the following email address: Trevor.Underwood@foremostgolf.com

11. 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.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on the date set out at the front.

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.

13. THIRD-PARTY LINKS

This website and our online booking portal 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.