This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with the provision of the HandiCaddie application/platform (“App”).
Please read the following carefully to understand how we will use any personal data that you upload on to our app when you register as a user or make your caddying services available via the App and also by visiting our website https://www.handicaddie.com/.
For the purposes of the Data Protection Act 2018 and UK GDPR (together the “Data Protection Legislation”), HandiCaddie Limited is the data controller.
It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
PERSONAL DATA WE MAY COLLECT FROM YOU
We may collect and process the following personal data:
- Identity data. You may provide personal data when signing up to the App, using the App or by corresponding with us via telephone, email or otherwise. The information you give us may include your name, address, e-mail address and phone number.
- Profile Data. Username and password, session bookings, preferences, feedback and survey responses.
HOW WE USE THE INFORMATION WE COLLECT
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Performance of a contract with you
- To enable us to connect you with golf clubs for your caddying services to be utilised.
- To contact you (whether via SMS text message, email or otherwise) about notifications on your HandiCaddie Account.
- To manage our relationship with you.
- To notify you about changes to our website or App.
- To ensure that content from the App and website is presented in the most effective manner for you and for your computer.
- To keep your account secure and to protect our services.
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Golf Clubs affiliated with HandiCaddie that are listed on the App so that your caddying services can be utilised.
Golfers – Golf Clubs may share your personal data with individual golfers who have requested a caddying service.
Selected third parties – if you consented to be contacted by email or other means by selected third parties, we may provide your information to the third parties we select, and these third parties may use this information for their marketing or advertising purposes.
Our third party service providers – we may share your information with third parties so that they can provide services to us but where we do we will put in place a written agreement protecting your information.
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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA and UK
We may transfer your personal information to parties which are located outside the United Kingdom (UK) and European Economic Area (EEA)in order to allow golfers to view the caddie profiles on the App and select you as a caddie.
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The recipient country has been deemed to provide an adequate level of protection for personal data; or
- Specific contracts approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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 associated with HandiCaddie 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.
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.
Under the Data Protection Legislation you have a number of important rights free of charge. In summary, those include rights to:
- require us to correct any mistakes in your information which we hold;
- require the erasure of personal information concerning you in certain situations;
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- object at any time to processing of personal information concerning you for direct marketing;
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and/or
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances.
Please contact firstname.lastname@example.org if you have any questions about this privacy notice or the information we hold about you.