Privacy Policy - Edge Golf College

Privacy and Cookies Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process.

2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address and/or telephone number. The source of the contact data is you.

2.3 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.4 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purpose of providing our services. The legal basis for this processing is our legitimate interests, namely services and business.

3.3 Relationships and communications - We may process contact data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, and/or telephone. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services.

3.4 Direct marketing - We may process contact data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages to our website visitors and service users.

3.5 Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.8 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under [UK data protection law] OR [EU data protection law] OR [UK and/or EU data protection law].

5.2We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

6. Retaining and deleting personal data

6.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2 We will store your personal data on personal computers and mobile devices and in secure manual record-keeping systems.

7.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8. Your rights

8.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.

8.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

10.1 Our website is targeted at persons over the age of 12.

10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. About cookies

12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

13. Cookies that we use

13.1 We use cookies for the following purposes:

(a) we use cookies to help us to analyse the use and performance of our website and services; and

(b) we use cookies to store your preferences in relation to the use of cookies more generally.

14. Cookies used by our service providers

14.1 Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.

14.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google's use of information by visiting https://policies.google.com/technologies/partner-sites and you can review Google's privacy policy at https://policies.google.com/privacy. The cookies used by Google Analytics are named _ga and _ga+container-id.

14.4 We use a Meta (Facebook) pixel on our website. Using the pixel, Meta collects information about the users and use of our website. The information is used to personalise Meta advertisements and to analyse the use of our website. To find out more about the Meta pixel and about Meta's use of personal data generally, see the Meta cookie policy at https://www.facebook.com/privacy/policies/cookies/ and the Meta privacy policy at https://www.facebook.com/privacy/policy. The Meta cookie policy includes information about controlling Meta's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

15. Managing cookies

15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);

(d) https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and

(e) https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd (Edge).

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If you block cookies, you will not be able to use all the features on our website.

16. Amendments

16.1 We may update this policy from time to time by publishing a new version on our website.

16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

17. Our details

17.1 This website is owned and operated by Edge Golf College Limited.

17.2 We are registered in England and Wales under registration number 11556341, and our registered office is at 22-24 Harborough Road, Kingsthorpe, Northampton, NN2 7AZ.

17.3 You can contact us:

(a) by post, to the registered office address given above;

(b) using our website contact form;

(d) by email, using the email address published on our website.

18. Data protection registration

18.1 We are registered as a data controller with the UK Information Commissioner's Office.

18.2 Our data protection registration number is ZB008606.