PRIVACY POLICY AND COOKIES POLICY

 
We at the LADIES EUROPEAN TOUR LIMITED (registered in England, number 2222839) whose registered office is at Buckinghamshire Golf Club, Denham Court Drive, Denham, Buckinghamshire, UB9 5PG, England (“we” or “our” or “us”) want to make sure all the personal information we have collected about you, is safe and secure whether we collect it through our website at www.dev-let.ocs-software.com (“Site”) or from other sources.  This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation.  If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the “Contact LET” section below.
 

PRIVACY NOTICES

Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our customers and members or just managing our relationship with you.
When we hold or use your personal information as a data controller (see below for a description of what this is) you are entitled to know in detail what information we hold about you (such as your contact details, address, etc.), how your personal information may be used and the reasons for these uses, together with details of your rights.
Where we collect personal information from you directly, we will provide this privacy notice at the time we collect the personal information from you.  Where we receive your personal information indirectly, we will provide this privacy notice when we first contact you, first pass the data to someone else or within a month, whichever is the earlier.
We will only provide this privacy notice to you once, generally at the start of our relationship with you.  However if the applicable privacy notice is updated substantially, then we may provide you with details of the updated version.  You are encouraged to check back regularly for updates.
 

THE DIFFERENCE BETWEEN DATA CONTROLLERS/PROCESSORS

A data controller is a person who controls how personal information is processed and used.  A data processor is a person who processes and uses personal information in accordance with the instructions of a third party, i.e. the data controller.
This distinction is important.  You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten (see below to see what rights you have).  These rights can generally only be exercised against a data controller of your information.
In most cases we will be a data controller of your personal information.  In any case where we are not a data controller this means that you cannot exercise these rights against us directly (i.e. where we only act as a data processor), but you can do so against the data controller (i.e. the person who controls how we process the personal information).  In these cases we will endeavour to inform you who is the data controller of your personal information so that you can direct any such requests to them.
Also it is only a data controller that will provide you with a privacy notice about your personal information, so where we process your personal information as a data controller we will provide you with a privacy notice.  Where we process your personal information as a data processor for a third party, that third party should provide you with a privacy notice which will set out details regarding the processing of your personal information, which should also include the processing to be carried out by us on their behalf.
 

(1) PERSONAL INFORMATION WE MAY COLLECT FROM YOU

In order to provide you with our services, we may collect personal information about you from our Site, telephone conversations, emails, and written and verbal communications. You may provide us with or we may obtain personal information about you, such as information regarding your:
o    personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
o    date of birth;
o    gender;
o    records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
o    any credit/debit card and other payment details you provide so that we can receive payments from you and details of the financial transactions with you;
o    records of your attendance at any events or competitions hosted by us;
o    images in video and/or photographic form and voice recordings; and
o    your marketing preferences so that we know whether and how we should contact you.
Information related to your visit to our Site (such as which pages you visit, how often you visit and which competitions you enter) and the information you supply when becoming a registered user or when entering our competitions (such as your name and e-mail address) will be held and stored worldwide by us.
 

(2) WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information when you sign up on our site at www.dev-let.ocs-software.com to receive newsletters or become a member of Ladies European Tour, purchase any services or products we offer online, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information.  Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it.  They also have the same rights as set out in the “Your rights in relation to personal information” section below.
 

(3) USES MADE OF THE INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
 

Purpose Personal information used Lawful basis
All Members
To enter into any contracts or meet our contractual obligations to you. All contact details.
Transaction and payment information.		 This is necessary to enable us to properly administer and perform any contract.
 
To send you information, including newsletters, information about Membership, events, participation, products and information about our commercial partners, advanced ticket information, competitions and events, partner offers and discounts and any updates on golf All contact details
 		 Where you have given us your explicit consent to do so.
To answer your queries or complaints Contact details and records of your interactions with us
 		 We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.
 
Retention of records All the personal information we collect We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and in some cases, we may have legal or regulatory obligations to retain records.
The security of our IT systems Your usage of our IT systems and online portals.
 		 We have a legitimate interest to ensure that our IT systems are secure.
To conduct data analytics studies to better understand event attendance and trends within the sport Records of your attendance at any events or competitions hosted by us. We have a legitimate interest in doing so to ensure that our marketing is targeted and relevant.
For the purposes of promoting the sport, our events and membership packages. Images in video and/or photographic form. Where you have given us your explicit consent to do so.
To comply with health and safety requirements Records of attendance We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in sport.

 

(4) CONSENT

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contact LET” section below.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain member benefits to you.
 

(5) DIRECT MARKETING

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by emailing us (see the “Contact LET” section below. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.
 

(6) LINKING WITH THIRD PARTY SITES

Our Site may, from time to time, contain links to and from the websites of our commercial partners, other sports bodies, advertisers and clubs.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
 

(7) DISCLOSURE OF YOUR PERSONAL INFORMATION

We share personal information with the following parties:
o    Any party approved by you by active opt-in or consent.
o    Other service providers: for example, email marketing specialists, payment processors, data analysis promotional advisors, contractors or suppliers and IT services (including CRM, website, video- and teleconference services);
o    Our Commercial Partners: for the purposes of providing you with information on any tickets, special offers, opportunities, products and services and other commercial benefits provided by our commercial partners where you have given your express for us to do so;
o    The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
o    Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
We do not disclose personal information to anyone else except as set out above, unless necessary  to protect the rights, property or safety of the members of the LET, our partners, customers and/or others.
We do not sell, trade or rent your personal information to others.
 

(8) TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in.
We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third party processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.
For further details please contact us by using the details set out in the “Contact LET” section below.
 

(9) HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years, in accordance with usual commercial practice and regulatory requirements.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.
You can contact us using by using the details set out in the “Contact LET” section below.
 

(10) YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:
o    the right to be informed about how your personal information is being used;
o    the right to access the personal information we hold about you;
o    the right to request the correction of inaccurate personal information we hold about you;
o    the right to request the erasure of your personal information in certain limited circumstances;
o    the right to restrict processing of your personal information where certain requirements are met;
o    the right to object to the processing of your personal information;
o    the right to request that we transfer elements of your data either to you or another service provider; and
o    the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contact LET” section below.
If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
 

(11) UPDATING OR CORRECTING YOUR INFORMATION

You may correct your personal information by emailing us (see “Contact LET”). Please include your name, address, and/or email address when you contact us. We would encourage you to promptly update your personal information if it changes.
 

(12) CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
 

(13) SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.
 

(14) COOKIES

Certain parts of our Site use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.
We use cookies on our Site to enable us to deliver content that is specific to your interests and gives us an idea of which parts of the Site you are visiting and to recognise you when you return to the Site. Reading cookies does not give us access to other information on your computer’s hard-drive and our Site will not read cookies created by other websites that you have visited.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Site. There is more information about cookies, including how to delete them on the website www.aboutcookies.org
Please note providers of third party content may also use cookies over which we have no control.
 

(15) CONTACT LET

In the event of any query or complaint in connection with the information we hold about you, please email enquiries@dev-let.ocs-software.com or write to us at:
Buckinghamshire Golf Club
Denham Court Drive
Denham
Buckinghamshire UB9 5PG
 
Version dated May 2018