Privacy Policy

Welcome to Golfmanager.com, web site property of GOLFMANAGER, S.L. (hereinafter referred to as the “Provider”). This Privacy Policy (“Policy”) explains in detail what type of information we collect through the Platform and website, how we use and disclose it and the steps we take to protect it. By visiting our website, or by purchasing on or using the Platform, you agree to the privacy practices and measures described in this Policy. This Policy supplements and is subject to the Golfmanager Terms and Conditions of Service. The concepts and definitions explained in those Terms will also be used throughout this document.

1.- DEFINITIONS

Public area: area of the website that can be accessed by both Users and Visitors, without having to log in. Restricted area: area of the platform to which only Users can access, that is, where access requires logging in.

Client: a natural or legal person who has accepted these Terms with the Provider.

Cookies: small files that are stored on your computer. Cookies store information about you, such as username or registration information, or user preferences, but do NOT spy, such as spyware.

Account: The primary means of accessing and using the Golfmanager Services, subject to payment of a Fee according to the Plan selected;

Customer Data: Personal data, reports, addresses and other files, folders or documents in electronic form that the Platform User stores within the Platform. Golfmanager S.L.: Spanish Limited Liability Company, with CIF. B88096292 and fiscal address in C/ Orense nº 64 – 2ºE, 28020, Madrid.

Personal information: means any information related to an identified or identifiable natural person.

Platform: the application of integral management of sports centers and the realization of reservations and services through the Internet.

Integrated Service: services, tools or applications of third parties not related to Golfmanager but integrated in the Platform, so that Users or Visitors can use them or to complement the Services offered by Golfmanager.

User: an employee, agent or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the various Services.

Visitor: means an individual other than a User, who uses the public area, but does not have access to the restricted areas of the Platform.

2. INFORMATION COLLECTED ON THE PLATFORM

We collect different types of information through the different services we offer. The processing of that information is necessary to provide the services in accordance with the Golfmanager Terms and Conditions. This processing is done in accordance with Golfmanager’s legitimate interests, which are further explained in Section 3 “How We Use the Information We Collect” of this Policy. We may also process data with your consent, requesting it if necessary.

2.1 User-Supplied Information. When you use the Platform, both as a User or as a Visitor, you may be required to provide personal data, or we may collect such data. Some of the personal data we process includes name, email address, mailing address, cell phone number and credit card or other billing information. Personal Data may also include other information, such as geographic area, hobbies, tastes or preferences, when such information is linked to information that identifies a specific individual. You can provide us with Personal Data in several ways on the Platform: when you register and create an Account, by simply using the Platform, by posting or uploading Customer Data, while interacting with other users of the Platform through various media or messaging, or by sending us customer service related requests.

2.2 Information collected by customers. A Customer or User can store or upload the Customer Data on the Platform, through themselves or their respective customers who enter the data. In this case, each Customer is responsible for providing notice to their respective customers and third parties regarding the purpose for which the Customer 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 through the use of various types of technology, including cookies, transparent gifs or “web beacons”. This information collected automatically may include IP address or other address or device identification, web browser and / or device type, web pages or sites visited just before or after using the Platform, pages or other content that the User or Visitor sees or interacts on the Platform, as well as dates and times of visit, access or use of the Platform. We can also use these technologies to collect information about the interaction of a Visitor or User with messages from your email: receipt, reading or forwarding of messages. This information is collected from all Users and Visitors.

2.4 Information from outside sources. We may obtain information, including personal data, from third parties and sources outside the Platform, such as our partners, advertisers, credit rating agencies and Integrated Services. If we combine 3 or associate information from other sources with personal data we collect through the Platform, we will treat the combined information as personal data in accordance with this Policy.

3. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect in various ways, all to provide users and visitors to the services and for the proper functioning of the platform. Specifically, some of these uses are for:

3.1 Operations. We use the information collected, in addition to Customer Data, to operate, maintain, improve and provide all functions of the Platform, to provide services and information requested, to respond to comments and questions, and to provide assistance to Users. We process Customer Data only in accordance with the instructions provided by the relevant Customer or User.

3.2 Improvements. We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service and to develop new products, services, features and functions. If Golfmanager is required to process Customer Data for this purpose, then the data will only be used in an anonymous or aggregate form.

3.3 Communications. We may use a Visitor’s or User’s email address or other information, other than Customer Data, to communicate with that Visitor or User (i) for administrative purposes, such as customer service, for intellectual property infringement issues, the right of violation of privacy or defamation problems related to Customer Data or Personal Data published on the Platform or (ii) with updates on promotions and events, related to products and services offered by us and by third parties with whom we work or (iii) with updates on the Platform, its features and modes of use or (iv) with updates to the Terms and Conditions of the Platform. You have the option to opt out of receiving promotional communications as described below in paragraph 5 (Your choices).

3.4 Cookies and tracking technologies. We use automatically collected information and other information collected on the Platform through cookies and similar technologies to: (i) personalize our Services, such as remembering a user or visitor’s information so that they do not have to re-enter it during subsequent visits; (ii) provide content and information; (iii) monitor and analyze the effectiveness of the marketing activities of the Service and third parties; (iv) monitor aggregate web usage metrics, such as total number of visitors and pages visited; and (v) track your entries, submissions and status on any promotions or other activities on the Platform. You have all the information about cookies 4 that we use in section 8. If you want to know more information about cookies in general you can visit http://www.allaboutcookies.org

3.5 Analytics. We use Google Analytics to measure and evaluate access and traffic in the public area of the website, and create user navigation reports for our site administrators. Google operates independently from us and has its own privacy policy, which we strongly recommend you to review. Google may use the information collected through Google Analytics to evaluate the activity of Users and Visitors on our Platform. For more information, see Google Analytics Privacy and Data Exchange.

We take steps to protect the technical information collected by our use of Google Analytics. The data collected will only be used when necessary to solve technical problems, administer the Platform and identify the preferences of visitors and Users, but in this case, the data will be in non-identifiable format. We do not use any of this information to identify Visitors or Users.

3.6 Additional limits on the use of your Google user data Notwithstanding anything else in this Privacy Policy if you provide Platform access to your Google data, the use of that information by the Platform will be subject to these additional restrictions:

  • The Platform will only use the access to read, write, modify or control the bodies of Gmail messages (including attachments), metadata, headers and settings to provide a web email client that allows users to write, send, read and process emails. Under no circumstances do we transfer this data from Gmail to outside third parties, unless it is necessary to provide and enhance these functions, comply with applicable law, or as part of a spin-off, merger, acquisition, or sale of assets.
  • The Platform will not use this data from Gmail to publish advertisements.
  • The Platform will not allow other people to read this data unless we have your authorization for specific messages, a requirement for security reasons, such as investigating abuse or fraud, to comply with applicable law or for internal operations of the application and even then only when the 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 collected or stored on the Service to third parties without the consent of the relevant Visitor, User or Customer. We will only disclose such information to third parties with your authorization, or if one of the following circumstances occurs: 5

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 in Your Company Account. Certain information about your use of the Golfmanager Services is available to your Golfmanager Account administrators and, as configured by Account Users, to other Users for the purpose of providing the Golfmanager Services.

4.3 Service Providers. We work with third-party service providers who provide web services, application development, hosting, maintenance and other services. These third parties may access or process Personal Data or Customer Data as part of the services they provide to us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. Our primary service providers are:


4.4 Non-Personally Identifiable Information.
We may make available to third parties certain information collected automatically, aggregated or otherwise that prevents personal identification, for various purposes, including (i) compliance with various information obligations; (ii) to help those third parties understand the interests, habits and usage patterns of our Customers, Users and Visitors for certain programs, content, services and / or features available through the Platform.

4.5 Law enforcement, legal process and contractual compliance. We may disclose Personal Data or other information if required to do so by law or in the good faith belief that such action is necessary to comply with applicable law, in response to a court order, or to otherwise cooperate with law enforcement or other government agencies. We also reserve the right to disclose Personal Information 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 unlawful uses or activities, (iii) investigate and defend against claims or accusations 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 agreements or protect the rights, property or safety of others.

4.6 Change of Ownership. Information about Users and 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 an insolvency, bankruptcy, or other insolvency situation, where the information is transferred to one or more third parties as one of our business assets. The same happens in cases of insolvency, bankruptcy or receivership. The information mentioned above is transferred to one or more third parties as one of our commercial assets, with the sole purpose of continuing with the operation of the Platform, and only if the recipient of that information transmitted is committed to carrying a Privacy Policy that is well regulated and preserves the integrity of the information and its security.

5. YOUR RIGHTS

5.1 Basic Rights in Data Protection. You may exercise your rights of access, rectification, deletion, limitation of processing, portability, opposition and automated decisions, including profiling, at any time. You only have to contact us through the e-mail info@golfmanager.com. You can also communicate with us as established in section 15 about how to contact us. We will process your request and execute it as diligently as possible. You will receive a confirmation once it has been carried out. We also remind you that you have the right to file a complaint with any of the data protection authorities, if you consider it appropriate. In the case of section 2.2, customers of our Customer who wish to exercise their rights must do so directly with the Customer in question, who is responsible for the Customer Data.

5.2 Modification of your account data. You may update, correct or delete your Account information and preferences at any time by accessing your Account settings page on the Platform. We remind you that any changes you make will be reflected in active user databases instantly or for a reasonable period of time, and we may retain any information you submit for backup, archiving, fraud and abuse prevention, analysis, compliance with legal obligations or where we reasonably 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 influence some of the features and functionality of the Platform. 7

5.3 Navigation 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 function.

6. THIRD PARTY SERVICES

The Platform may contain features or links to websites and services provided by third parties. Any information you provide on those third-party sites or services is provided directly to the operators of those services, and is therefore subject to the policies governing the privacy and security of those operators. We are not responsible for the content or the privacy and security policies and practices of the third party sites or services to which links or access are provided through our Platform. We recommend that you review the privacy and security policies of those third parties before providing them with information.

7. PROTECTION OF PRIVACY

Golfmanager, S.L. is always looking after the privacy and security of the data of its Clients, Users and Visitors. Therefore, we follow all the legal guidelines regarding Data Protection, mainly the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD). On the other hand, for all international transfers of personal data, Golfmanager will ensure, as far as possible, to comply with the requirements established by the above mentioned regulations, as well as the Privacy Shield for the case of the United States, or other similar provisions for other countries.

8. COOKIES 

On our website or platform we use cookies to provide better service and operation. These cookies are for the proper functioning of the platform, and does not mean any harm to you, since it does not collect any personal data or sensitive information, nor is installed any type of malware or virus on your computer. Under no circumstances do we share with third parties any type of information that may identify you (such as your email address). 8.1 The following types of cookies are used on the Web:

  1. Strictly necessary/essential cookies: these cookies are essential to allow you to move around the website and use its features, such as access to secure areas. Without these cookies, the services you have requested cannot be provided. These Cookies do not collect information that would allow a Visitor to be identified.
  2. Performance Cookies: These cookies collect information about how Visitors use a website, for example, which pages they visit most frequently and whether they receive error messages from the web pages. These cookies do not collect information that identifies a Visitor. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the operation of a website.
  3. Functionality Cookies: These cookies allow the website to remember the choices you make (such as your username, language, or the region you are in) and provide enhanced and more personal features. For example, a website can provide you with local weather reports or traffic news by storing the region you are currently in in a cookie. These cookies can also be used to remember changes you have made to text size, fonts, and other options that web pages can customize. They may also be used to provide services you have requested, such as viewing a video or commenting on a blog. The information collected by these cookies may be anonymous and thus prevent tracking of your browsing activity on other websites.


9. PRIVACY OF MINORS AND CHILDREN

Protecting the privacy of children who are minors is especially important. Therefore, minors may be Visitors to the website, but not Customers or Users. Our Services are not directed to children under the age of 18, and we do not knowingly collect Personal Data from underage children without obtaining parental consent, but we do collect data that is inherent in merely browsing the web as a Visitor. If we learn that there is Personal Data of minors on the Platform without express parental consent, we will take appropriate steps to delete this information.

10. DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us on the Site and the Platform, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical measures to protect Personal Data and to prevent accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and other unlawful forms of processing of Personal Data. This includes, for example, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission over the Internet, and we also employ application-level security features to further anonymize Personal Data. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. So if you send us information, please be aware that it is at your own risk. We cannot guarantee the absolute and total security of any information you transmit to us or store on the Platform. Nor can we guarantee that such information cannot be accessed, disclosed, altered or destroyed due to a breach of any of our physical, technical or administrative security measures. If you believe that your personal data has been compromised, please contact us by emailing info@golfmanager.com or following the provisions of paragraph 15 “How to contact us”. In the event that we become aware that there has been a breach or violation of security systems, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

11. DATA RETENTION

We only retain Personal Data collected from a User for as long as the User’s account is active or for a limited period of time, as long as we need it to fulfill the purposes for which we initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements as follows:

  • the contents of closed accounts are deleted within 6 months of the date of closure;
  • backups are kept for 3 months;
  • Billing information is retained for a period of 5 years from your entry into Golfmanager in accordance with Spanish accounting and tax laws.


12. PRIVACY SETTINGS

While we may allow you to adjust your privacy settings to limit access to certain Personal Information, please note that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Platform. In addition, we cannot control the actions of other users with whom you choose to share your information. Even after information posted on the Service is deleted, caching and archiving services may have saved that information and other users or third parties may have copied or stored the information available on the Platform. We cannot absolutely guarantee that the information you post or transmit on the Platform will not be viewed by unauthorized persons. 10

13. RESPONSIBLE AND IN CHARGE OF THE TREATMENT

Golfmanager acts as a data processor for the client, provided that the data has been entered by the client. The said Customer will be responsible for such data and for determining the purposes for which it has been collected. Therefore, Golfmanager does not own, control or direct the use of any of the Customer Data stored or processed by a Customer or User on the Platform. Only Customer or Users have the right to access, retrieve and direct the use of such Customer Data. Golfmanager does not directly access or monitor such Customer Data unless authorized by Customer, or as necessary to provide certain Services to Customer and Users. We do not know to a large extent what Customer Data is being stored or made available by Customer or User on the Platform. Golfmanager is also not responsible for how Customer or User collects, communicates, distributes or otherwise processes such information. More information about this is available in the Terms and Conditions, section 9.

14. CHANGES AND UPDATES TO THIS POLICY

We will keep this Policy up to date, so please revisit this page periodically to keep abreast of any changes. If we change the Policy, we will make it available through the Platform and indicate the date of the last revision. Your continued use of the Platform after the revised Policy has become effective indicates that you have read, understood and accepted the current version of the Policy.

15. HOW TO CONTACT US

Please contact us if you have any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent options by emailing info@golfmanager.com.