Version last revised: 26 July 2019
1. Purpose of this Privacy Notice
As a member, or candidate for membership, of Les Bordes Golf Club SAS, doing business as Les Bordes Golf Club (the "Golf Club"), you and others will provide certain personal data that concerns you, which will be processed by the Golf Club.
In addition, because the financial aspects of your membership, debenture and dues will be handled by Les Bordes Golf International SAS (the "Company"), you will provide certain personal data that concerns you to the Company, and the Company will obtain certain personal data that concerns you from other sources, which will be processed by the Company.
Both the Golf Club and the Company are ‘controllers’ of this personal data that concerns you, as that term is defined in Regulation (EU) 2016/679 – The General Data Protection Regulation ("GDPR").
This Privacy Notice (the “Privacy Notice”) sets out the personal data the Golf Club and the Company receive from you, and others, how we process it, our legal obligations as controllers, and your rights in relation to your personal data.
Throughout this Privacy Notice, “Les Bordes”, “we” and “us” shall refer to both the Golf Club and the Company. Where some information applies to only one of the Golf Club or the Company, or applies differently, this has been made clear.
3. Personal Data we Will Collect from You
As part of your invitation for membership process, and during your time as a member, we will collect and process the following personal data concerning you:
- Your, your family and guest’s name, address, residency and contact details, date of birth, fiscal identification including credit card and banking information and other identification information.
- Information and documents you have provided in order to confirm your identity
- Information provided by your sponsors and other contacts in the Golf Club.
- Details of your visits to the club and use of club facilities.
- Any other information provided through your use of club facilities and involvement in club activities.
- If you contact us, we may keep a record of that correspondence.
The Company will collect the following personal data concerning you:
- Information on your financial and employment status.
- Any other financial and biographical information you provide.
- Information provided by third party reference agencies on your financial status.
4. Purposes of Processing
We use personal data concerning you in the following ways:
To manage your membership and use of club services.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To process any communication you send us (which includes answering any queries and dealing with any complaints or feedback you have).
- To conduct internal research to improve the way we interact and communicate with you.
- To carry out our obligations arising from any contracts entered into between you and us.
- To get in contact with you should we need to.
- To do anything which you authorise or consent to us doing.
- To take any action we are required or authorised by law to take.
- To notify you about changes to the services we provide.
- For the defence and management of any legal claims.
The Company will use the personal data concerning you as follows:
- To assess your suitability for membership.
- To collect your dues and any other charges arising from your membership.
- To send you formal notifications as an member.
- To maintain a record of members.
- To process any communication concerning your investment.
5. Lawful Basis of Processing
We need to carry out the processing of personal data concerning you as set out above in order to perform our contractual obligations to you as a member, to perform certain legal obligations, and in some cases, to further the legitimate interests of the club acting on behalf of its members, their families and guests.
6. Duration of Processing
We will carry out the processing activities set out above for the duration of your membership or invitation for membership process, and shall continue to store your personal data for an appropriate period thereafter based on the applicable legal basis, but in each case not longer than seven (7) years from the later of your application or your ceasing to be a member, unless you object and there are no compelling reasons or other lawful basis on which to continue processing.
7. Storage of Your Personal Data
We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing we carry out to protect the confidentiality, integrity and availability of your personal data and to protect against unauthorised or unlawful processing and accidental loss, destruction or damage.
8. International Data Transfers
We do not transfer your personal data outside the EEA. Should this change and it becomes necessary to do so, we will inform you and provide details of the safeguards applied.
9. Third-Party Processors
In some circumstances, we may provide personal data concerning you to third-party processors in order to perform the processing set out above. In such cases we shall take appropriate measures to ensure that each third-party processor puts in place technical and organisational measures at least as protective of your rights and freedoms as a data subject as those we apply, and that such processing is at all times in accordance with applicable data protection law.
10. Disclosure of Your Information
We may disclose your personal information to third parties:
- If we sell or buy any business or assets, or raise external investment, in which case we may disclose certain of your personal data to the prospective member, seller or buyer of such business or assets under suitable conditions of confidentiality.
- If we or substantially all our assets are acquired by a third party, in which case personal data held by us about the members will be one of the transferred assets.
11. Changes to our Privacy Notice
We may need to update this Privacy Notice to reflect changes to our data processing practices. If we do this and the changes are material, we will post a notice on the club website for at least seven (7) days before the changes are made. You can see the date this Privacy Notice was last revised at the top of the page.
12. Your Rights
The GDPR, and other applicable data protection legislation gives you certain specific rights relating to your personal data which are set out below.
Please note that not all these rights are absolute, and they do not apply in all circumstances. However, you are always welcome to contact us with any request relating to processing of your personal data and, even if we are not obliged by law to comply with your request, we will try to accommodate your wishes.
(a) Access – you have the right to access your personal data and certain information about how and why we are processing it;
(b) Rectification – you have the right to have any inaccurate or incomplete personal data rectified without undue delay;
(c) Erasure – Sometimes called the ‘right to be forgotten’, in certain circumstances, you have the right to have your personal data erased without undue delay;
(d) Restriction - in certain circumstances, you have the right to have our processing of your personal data restricted;
(e) Data Portability - in certain limited circumstances, you have the right to receive the personal data concerning you that you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit those data to another controller without hindrance; and
(f) Objection - in certain circumstances, you have the right to object to the processing of your personal data carried out by us or on our behalf.
13. Contact Us
If you would like further information on anything in this Privacy Notice, for all questions or concerns you have about your personal data, or if you think you would like to exercise any of your rights as a data subject, please contact us using the following contact details.
Controller Name and Address:
If to Golf Club:
Les Bordes Golf Club SAS, Saint Laurent-Nouan, 41220 France
If to Company:
Les Bordes Golf International SAS Saint Laurent-Nouan, 41220 France
GDPR Central Representative:
14. Making A Complaint
If you think we have not complied with the requirements of the GDPR as it applies to your personal data, you have a right to lodge a complaint with any data protection supervisory authority in the EU. For example:
- In France – the Commission Nationale de l'Informatique et des Libertés – CNIL: Tel. +33 1 53 73 22 22; http://www.cnil.fr/ *
- In the UK - the Information Commissioner’s Office (ICO) UK: email@example.com or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk.
You can find details of other EU Supervisory Authorities here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
*. Please note these details are subject to change outside our control, so please check online for up-to-date contact information.