Welcome to Golfmanager.com, a website owned by GOLFMANAGER, S.L. (hereinafter the “Provider”).
This Privacy Policy (“Policy”) provides comprehensive information about the data we collect through the Platform and website, our practices regarding its usage and disclosure, and the measures in place to safeguard your information. By visiting our website or using the Platform for shopping or other services, you signify your agreement with the privacy practices and safeguards outlined in this Policy.
This Policy serves as a complementary document to Golfmanager’s Terms and Conditions of Service. The terms and definitions elucidated in the Terms shall apply to this document as well.
1.- DEFINITIONS
Public area: The section of the website accessible to both Users and Visitors without requiring login.
Restricted area: The segment of the platform accessible exclusively to Users, requiring login for access.
Customer: A natural or legal person who has agreed to these Terms with the Provider.
Cookies: Small files stored on your computer. Cookies store information about you, such as usernames, registration details, or user preferences, but they do not engage in spying activities like spyware.
Account: The primary means for accessing and utilizing Golfmanager Services, subject to the payment of a Fee in accordance with the chosen Plan.
Customer Data: Personal data, reports, addresses, and other electronic files, folders, or documents stored within the Platform by the User.
Data Processor: The natural or legal person, public authority, service, or other entity processing personal data on behalf of the Controller.
Golfmanager S.L.: A Spanish Limited Liability Company with CIF (Tax Identification Number) B-88096292 and fiscal address at C/ Orense nº 64 – 2ºE, 28020, Madrid.
Personal information: Refers to any information pertaining to an identified or identifiable natural person.
Platform: The application designed for the comprehensive management of sports centers and the facilitation of reservations and services over the Internet.
Data Controller: The natural or legal person, public authority, service, or other entity that, either alone or jointly with others, determines the purposes and methods of processing.
Integrated Service: Services, tools, or applications from third parties external to Golfmanager but integrated into the Platform. These allow Users or Visitors to utilize them or enhance the Services provided by Golfmanager.
User: An employee, agent, or representative of a Customer, or the Customer directly, who primarily utilizes the restricted areas of the Site to access various Services.
Visitor: Refers to an individual, distinct from a User, who utilizes the public area of the Platform but does not have access to the restricted areas.
2.- INFORMATION COLLECTED ON THE PLATFORM
We collect various types of information through the diverse services we offer. The processing of this information is essential for providing the services in compliance with Golfmanager’s Terms and Conditions. This processing aligns with Golfmanager’s legitimate interests, which are elaborated on in greater detail in section 3, “How we use the information we collect,” of this Policy. Additionally, we may process data based on your consent when required.
2.1 Information provided by you. When you use the Platform, whether as a User or Visitor, you may be required to provide personal data, or we may collect such data. Personal Data that we process may include your name, email address, mailing address, cell phone number, credit card or other billing information. It may also encompass other information, such as geographic location, hobbies, likes, or preferences, provided that such data is linked to information identifying a specific individual. You can provide Personal Data to us through various means on the Platform: during registration and Account creation, by simply using the Platform, by posting or uploading Customer Data, during interactions with other Platform users through various communication or messaging channels, or when you submit customer service-related requests.
2.2 Information Collected by Customers. A Customer or User may store or upload Customer Data to the Platform, either personally or by having their respective customers enter the data. In this scenario, each Client is responsible for notifying their respective customers and third parties about the purpose for which the Client collects their Personal Data and how this Personal Data is processed through the Platform as part of the Customer Data.
2.3 Information Collected Automatically. When a User or Visitor uses the Platform, we may automatically record certain information from the User’s or Visitor’s device using various types of technology, including cookies, clear gifs, or web beacons. This automatically collected information may include the IP address or other device identifier, web browser and/or device type, the web pages or sites visited immediately before or after using the Platform, the pages or other content that the User or Visitor views or interacts with on the Platform, as well as the dates and times of the visit, access, or use of the Platform. Additionally, we may utilize these technologies to gather information about a Visitor’s or User’s interaction with email messages, including receiving, reading, or forwarding messages. This information is collected from all Users and Visitors.
2.4 Information from External Sources. We may acquire information, including Personal Data, from third parties and sources external to the Platform, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we merge or link information from other sources with Personal Data gathered through the Platform, we will handle the combined information as Personal Data in accordance with this Policy.
3.- HOW WE USE THE INFORMATION WE COLLECT
We employ the information we gather in several ways, all aimed at delivering the Services to Users and Visitors and ensuring the correct operation of the Platform. Specifically, some of these uses include:
3.1 Operations. In addition to Customer Data, we utilize the collected information to operate, maintain, enhance, and deliver all aspects of the Platform. This includes providing requested services and information, addressing comments and inquiries, managing payments, and offering assistance to Users. We handle Customer Data strictly in accordance with the instructions provided by the respective Customer or User.
3.2 Improvements. We utilize this information to comprehend and assess usage patterns and preferences among our Visitors and Users. This analysis aids us in enhancing the Service, as well as in the development of new products, services, features, and functions. When Golfmanager processes Customer Data for this purpose, it will only be utilized in an anonymous or aggregated format.
3.3 Communications. We may utilize a Visitor’s or User’s email address or other information, excluding Customer Data, to establish communication with the Visitor or User for the following purposes: (i) administrative matters, including customer service, addressing issues related to intellectual property infringement, privacy law violations, or defamation arising from Customer Data or Personal Data posted on the Platform, (ii) updates regarding promotions and events related to products and services offered by us and our affiliated third parties, (iii) updates about the Platform, its functionalities, and modes of use, or (iv) updates to the Platform’s Terms and Conditions. You have the option to opt out of receiving promotional communications, as detailed in Section 5 (Your Choices) below.
3.4 Cookies and Tracking Technologies. We utilize automatically collected information and other data gathered on the Platform through cookies and similar technologies for the following purposes: (i) personalizing our Services, such as retaining a user’s or visitor’s information to eliminate the need for re-entry during subsequent visits; (ii) delivering content and information; (iii) evaluating and analyzing the effectiveness of the Service and third-party marketing activities; (iv) monitoring aggregate web usage metrics, such as the total number of visitors and pages visited; and (v) tracking your entries, submissions, and status in any promotion or other activity on the Platform. For detailed information about the cookies we use, please refer to our website’s cookie policy section: https://golfmanager.com/legal/cookies-policy/. If you wish to learn more about cookies in general, you can visit http://www.allaboutcookies.org.
3.5 Analytics. We utilize Google Analytics to assess and analyze access and traffic in the public area of the website, and to generate user navigation reports for our site administrators. Google functions independently from us and maintains its own privacy policy, which we highly recommend you review. Google may employ information collected via Google Analytics to assess User and Visitor interactions on our Platform. For additional details, please refer to Google Analytics Privacy and Data Sharing.
We implement measures to safeguard the technical information collected through our utilization of Google Analytics. The data collected will exclusively be utilized as required to address technical concerns, manage the Platform, and recognize visitor and User preferences; however, in such instances, the data will be in a non-identifiable format. We refrain from employing any of this information for the purpose of identifying Visitors or Users.
3.6 Additional Restrictions on the Use of Your Google User Data. espite any other provisions in this Privacy Policy, if you grant the Platform access to your Google Data, the use of that information by the Platform will be subject to these additional restrictions:
- The Platform will utilize access solely for reading, writing, modifying, or controlling Gmail message bodies (including attachments), metadata, headers, and settings. This access is used to offer a webmail client that enables users to compose, send, read, and manage emails. Under no circumstances do we share this Gmail data with external third parties, except when necessary to support and improve these features, adhere to relevant laws, or as part of a divestiture, merger, acquisition, or asset transfer.
- The Platform will not use this Gmail data to serve ads.
- The Platform will not grant access to others to read this data unless we obtain your explicit permission for specific messages. Such access may be necessary for security purposes, like investigating abuse or fraud, compliance with relevant laws, or for the internal operations of the application. Even in such cases, access is only granted after data has been aggregated and anonymized.
4.- TO WHOM WE DISCLOSE INFORMATION
Except as described in this Privacy Policy, we will not intentionally disclose Personal Data or Customer Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Customer. We will only disclose such information to third parties with your permission, or if any of the following circumstances apply:
4.1 Information in Public Areas. Any information that you voluntarily choose to include in a public area of the service, such as a public profile page, will be available to any visitor or user who has access to that content.
4.2 Other Users on Your Company Account. Administrators of your Golfmanager Account have access to specific information regarding your use of the Golfmanager Services. Depending on the settings configured by Account Users, this information may also be accessible to other Users, all in order to facilitate the provision of Golfmanager Services.
4.3 Service Providers. We collaborate with external service providers and partners who offer various services to Golfmanager, including website and application development, hosting, maintenance, payment processing, and other services related to our client relationships. These third parties may have access to or process Personal Data or Customer Data as part of their services to us, acting as Processors under Article 28.3 of the GDPR. We strictly limit the information shared with these service providers to what is necessary for them to carry out their functions. Our contractual agreements with them mandate the confidentiality of such information and strict adherence to relevant data protection regulations. Our primary service providers are:
- Amazon Web Services (AWS): you can view their privacy policy here: https://aws.amazon.com/compliance/data-privacy/
4.4 Non-Personally Identifiable Information. We may share certain information, collected automatically or in aggregated and non-personally identifiable forms, with third parties for various purposes, which include: (i) fulfilling various reporting obligations; and (ii) assisting these third parties in gaining insights into the interests, behaviors, and usage patterns of our Customers, Users, and Visitors regarding specific programs, content, services, and functionalities offered through the Platform.
4.5 Law Enforcement, Legal Process and Contractual Compliance. We may disclose Personal Data or other information if we are required to do so by law or if we have a good faith belief that such action is necessary to comply with applicable laws, respond to a court order, or cooperate with law enforcement or other government agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves from other fraudulent, abusive, or illegal uses or activities, (iii) investigate and defend ourselves against claims or allegations by third parties, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other rights, enforce our contracts, or protect our rights, property, or equipment, or (vi) protect our rights, property, or equipment, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or any of our other rights, enforce our agreements or protect the rights, property, or safety of others.
4.6 Change of Ownership. Information about Users, Visitors, Personal Data, and Customer Data may be disclosed and transferred to an acquirer, successor, or assignee as part of any spin-off, merger, acquisition, debt financing, sale of assets, or similar transactions, as well as in the event of insolvency, bankruptcy, or receivership. In these cases, the information is transferred to one or more third parties as one of our business assets. The same principles apply in cases of insolvency, bankruptcy, or receivership, where the aforementioned information is transferred to one or more third parties as one of our business assets. This transfer is solely for the purpose of continuing the operation of the Platform and is contingent upon the recipient committing to a well-regulated Privacy Policy that safeguards the integrity and security of the information.
5.- YOUR RIGHTS
5.1 Basic Data Protection Rights. You may exercise your rights of access, rectification, erasure, restriction of processing, portability, objection, and automated decisions, including profiling, at any time by simply contacting us via email at info@golfmanager.com.
You may also contact us as outlined in Section 15 on how to reach us. We will process your request and execute it as promptly as possible. You will receive a confirmation once it has been completed.
We also want to remind you that you have the right to file a complaint with any of the data protection authorities if you believe it is necessary.
In the case of paragraph 2.2, Our Client’s customers who wish to exercise their rights must do so directly with the Customer in question, as they are the controller of the Customer Data.
5.2 Modification of Your Account Information. You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Platform. Please note that any changes you make will be reflected in the active user databases instantly or within a reasonable period of time. We may retain any information you submit for backup, archival, fraud and abuse prevention, analysis, compliance with legal obligations, or where we believe we have a legitimate reason to do so.
You decide at your own discretion what Personal Data you share with us, but this may affect some of the features and functionality of the Platform.
5.3 Browsing Information. You may opt out of the collection of navigational information during your visit to the website by Google Analytics by using the Google Analytics Opt-Out Feature.
6.- THIRD PARTY SERVICES
The Platform may include features or links to websites and services provided by third parties. Any information you provide on those third-party sites or services is directly provided to the operators of those services and is subject to the privacy and security policies governing those operators. We are not responsible for the content or the privacy and security policies and practices of third-party sites or services that are accessible through our Platform. We recommend reviewing the privacy and security policies of those third parties before providing them with any information.
7.- PRIVACY PROTECTION
Golfmanager, S.L. consistently ensures the privacy and security of data belonging to its Clients, Users, and Visitors. To achieve this, we adhere to all relevant legal guidelines on Data Protection, with a primary focus on the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons concerning the processing of personal data and the free movement of such data, as well as the Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
Furthermore, for all international transfers of personal data, Golfmanager will take all reasonable measures to ensure compliance with the requirements outlined in the aforementioned regulations, as well as the Data Privacy Framework (“DPF”) for the United States, or equivalent provisions for other countries.
The hosting of information will depend on the Customer’s location and will be done on servers located in the United States (when the Customer is in Canada, the United States, or Latin America), Asia (when the Customer is in Asia or Australia), or the European Union (when the Customer is in the European Union). For servers located in Asia, Golfmanager ensures that its hosting provider adheres to appropriate security measures and complies with the SCC (“Standard Contractual Clauses“) to ensure GDPR compliance. This applies to countries outside the EU, the USA (only companies adhering to the “DPF”), or those not on the list of countries considered safe by default by the European Data Protection Commission, ensuring that their level of GDPR compliance meets the minimum standards set by this regulation.”Top of Form
8.- COOKIES
On our website or Platform, we use Cookies to enhance your experience and ensure the proper functioning of the Platform. These Cookies do not collect any Personal Data or sensitive information, nor do they install malware or viruses on your computer. They are solely for the functionality of the Platform and pose no harm to you. For more information, please refer to our website’s section: https://golfmanager.com/legal/cookies-policy/.
9.- PRIVACY OF MINORS AND CHILDREN
Safeguarding the privacy of minor children is of paramount importance. Consequently, minors may visit the Website as Visitors but cannot become Customers or Users. Our Services are not intended for individuals under the age of 18, and we do not knowingly collect Personal Data from minor children without parental consent. However, we do collect data that is inherent to simply browsing the website as a Visitor.
If we become aware of Personal Data of minors on the Platform without express parental consent, we will take appropriate steps to remove this information.
10.- DATA SECURITY
We adhere to widely accepted industry standards to safeguard information provided to us through the Site and Platform, both during its transmission and after we receive it. We maintain suitable administrative, technical, and physical safeguards to prevent accidental or unlawful destruction, loss, unauthorized alteration, disclosure, or access, as well as any other unlawful processing of Personal Data. This includes measures such as password protection and other access controls. Additionally, we utilize SSL technology to encrypt data when it’s transmitted over the Internet, and we employ application-level security features to further enhance the anonymity of Personal Data.
However, it’s important to note that no method of transmission over the Internet or electronic storage can be guaranteed to be 100% secure. Therefore, when you send us information, please be aware that there is a certain level of risk involved. While we implement robust security measures, we cannot provide an absolute guarantee of the complete security of any information you transmit to us or store on the Platform. Additionally, we cannot ensure that such information cannot be accessed, disclosed, altered, or compromised by breaches of our physical, technical, or administrative security measures. In the event that you suspect your personal information has been compromised, please don’t hesitate to contact us at info@golfmanager.com or via the details provided in section 15, “How to contact us”.
If we become aware of a security breach or violation of our systems, we will promptly notify you and the relevant authorities in accordance with applicable laws and regulations.
11.- DATA RETENTION
We only retain Personal Data collected from a User for the duration of the User’s active account or for a limited period, as needed to fulfill the original purposes of collection, unless otherwise mandated by law. We will retain and utilize information as required to meet our legal obligations, resolve disputes, and enforce our agreements as outlined below:
- the contents of closed accounts are deleted within 6 months after the closing date
- Backups are kept for 3 months
- Billing information is kept locked for a period of 5 years from the time it is entered into Golfmanager in accordance with the accounting and tax laws of Spain.
12.- PRIVACY SETTINGS
While we may offer the option to customize your privacy settings to restrict access to specific Personal Data, it’s important to understand that no security measures are infallible. We cannot be held responsible for the circumvention of any privacy settings or security measures on the Platform. Additionally, we have limited control over the actions of other users with whom you choose to share your information. Even if you delete information from the Service, it’s possible that caching and archiving services may have retained that information, and other users or third parties may have copied or stored the data available on the Platform. We cannot provide an absolute guarantee that information you post or transmit on the Platform will not be viewed by unauthorized individuals.
13.- DATA CONTROLLER AND DATA PROCESSOR
Golfmanager serves as the Data Controller for the Client’s Data when the Client is a natural person using the Platform through Golfmanager’s Website or App designed for this purpose.
When Golfmanager acts in the name and on behalf of a legal entity Client (e.g., a ‘Club’) under instructions from the latter, Golfmanager will be acting as a Data Processor for the Client’s Data, provided that these have been entered by the latter. In this second case, the legal entity Client will be responsible for such data and for determining the purposes for which it has been collected.
When one of the parties acts as the Processor for the other, the parties agree to be bound by the Data Processing Agreement available at the following link: https://golfmanager.com/legal/data-processing-agreement/
14.- CHANGES AND UPDATES TO THIS POLICY
We will keep this Policy up to date, so please check back here periodically to stay informed of any changes. If we modify the Policy, we will make it available through the Platform and indicate the date of the latest revision. Your continued use of the Platform after the revised Policy has become effective indicates that you have read, understand, and agree to the current version of the Policy.
15.- HOW TO CONTACT US
Please feel free to contact us if you have any questions or comments about this Policy, your personal data, our use and disclosure practices, or your consent choices by emailing us at info@golfmanager.com.