Privacy Policy

PRIVACY POLICY

We are committed to protecting your personal data. This privacy policy will inform you as to how we 18Group Ltd look after your personal data when you use our website www.dailygolfjournal.com (“Site”) and our Mobile App (“Mobile App”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

  1. PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your personal data through your use of this Site or Mobile App, including any data you may provide through this Site or Mobile App.

This Site or Mobile App is not intended for children and we do not knowingly collect data relating to children.

This privacy policy will inform you how you can verify which of your personal information is collected by us through the Site or Mobile App and how you can request that we delete, update, or transfer it.

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.

  1. 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, last name, username or similar identifier, title, date of birth, and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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, and other technology on the devices you use to access this Site or Mobile App.
  • Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our Site or Mobile App, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site or Mobile App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
  • apply for our services;
  • create an account on our Site or Mobile App;
  • subscribe to our service or publications;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Site or Mobile App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies 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 and public sources as set out below:
  • Technical Data from analytics providers
  • Contact and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly available sources
  1. HOW WE USE 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:

  • 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.

  1. USE OF COOKIES

Our Site or Mobile App uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. You can opt out of this at any time by changing the settings on your device. 

  1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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 with 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.

  1. OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into the Site or Mobile App and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.

  1. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules, and technical measures to protect the personal information that we have under our control from:

    • unauthorized access;
    • improper use or disclosure;
    • unauthorized modification; and
    • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.

  1. CHANGE TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy policy periodically to be informed of how we use your personal information.