HandicapMaster Privacy Statement
We ('HandicapMaster Ltd', 'us') are committed to protecting the privacy of our customers. We treat information you provide to us, and your privacy with care.
This Privacy Policy Statement and related documents including Terms of Service and Contracts explains how we collect, store and use the personal information you provide.
If you have any questions/comments about privacy, you should
contact us, or use the 'contact us' link
located at the bottom of this page. There you will find provided full contact details.
We are committed to protecting your privacy. We will only use the information that we collect about you lawfully in accordance
with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and from 25 May 2018
the General Data Protection Regulation (GDPR).
GDPR - General Data Protection Regulation
This section covers a number of GDPR specific items for clarity to our customers. It references a number of items in the following document:
'
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016'
This document is
available from here (and is an 88 page PDF document).
Definitions
Please see Article 4 of the above document for a full list of definitions used in GDPR.
For clarity the following definitions are noted here from Article 4 of the above regulation
- 'Personal data' means any information relating to an identified or identifiable natural person ('data subject')
- Controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
- 'Processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
Rights
GDPR provides the following rights for individuals and their personal information.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
Our Responsibilties - a Summary
- Under Article 28 paragraph 2 we will not engage another processor without your consent.
Note that some of our products do use other processors to provide services.
Further details are contained on the relevant contracts which you must review and agree to when using our services.
- Under Article 28 paragraph 3 processing is governed by our contract which you must review and agree to when using our services.
- Under Article 29 where HandicapMaster Ltd are operating as a 'processor' we will only process data under instructions of the Data Controller.
- Under Article 30 paragraph 5 of the above regulation it is stated that: as HandicapMaster Limited has less than 250 staff and as processing of data for
support purposes is an occasional activity requested by data controllers we shall not
apply paragraphs 1 & 2 of Article 30 with regard to records of processing activities.
- Under Article 31, On request, cooperate with the UK's supervisory authority i.e. the Information Commissioner's Office (https://ico.org.uk).
- Under article 32 we will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
- Under Article 33 notify the data 'controller' of any personal data breaches.
Basis of data collection & processing
Under GDPR, HandicapMaster Ltd is a 'Controller' and collects data on the lawful basis of contract
i.e. to fulfil your contract when you purchase HandicapMaster Ltd products.
HandicapMaster Ltd is registered with the Information Commissioner's Office
(
https://ico.org.uk) Reference number: ZA366381.
Under GDPR, HandicapMaster Ltd is a 'Processor' and processes data on behalf of the 'Controller' under the lawful basis of contract
i.e. to fulfil your support requests when you use HandicapMaster Ltd products and services.
Profiling and automated decision making
With respect to GDPR and specifically profiling and automated decision making the following statement is made for clarity:
- Your personal information is NOT used for automatic decision making or profiling.
Privacy in relation to customer information, orders & support
What we do with your information
We collect information about you to process:
- Enquiries about our services and products
- your order
- your requests for service and support
- notify you of changes to our services
If your contact details change we ask you to inform us so we may keep our records up to date.
Information we collect and how.
The type of information we will collect about you includes:
- your name
- address
- phone number
- e-mail address
- how you wish to be contacted
- details of purchases and orders
- interaction with our forum pages (optional)
- interaction with Master Scoreboard website (optional)
- interaction with Club Website Service (optional)
If you contact us on behalf of an organisation we will store details of that organisation.
Online payments - Card details are NOT stored or retained by HandicapMaster Ltd. When you order,
your details are processed securely by our payment processor.
We may use technology to track the patterns of behaviour of visitors to our site and to assist with the processing of orders.
This can include using a 'cookie' which would be stored on your browser.
You can usually modify your browser to prevent this happening. We may also record your IP Address.
This information does not tell us who you are and where you live.
This data is used to improve services for you, for example:
- enabling our website services to recognise your device so you don't have to give the same information several times during one task
- recognising that you may already have given a login name and password so you don't need to do it for every web page requested.
We do NOT offer advertising from third parties on our websites and therefore do NOT pass aggregate information on.
We will never knowingly collect sensitive information about you without your explicit consent.
Communications
We will not e-mail you in the future unless you have given us your consent.
We may e-mail you if you have purchased a registration code, in order to provide you with support
regarding HandicapMaster software or (where applicable) in connection with the periodic renewal of the registration.
We will give you the chance to refuse any marketing or support e-mail from us in the future.
Where we offer an e-mail mailing list service, e.g. such as offering an email notification when software updates are available,
any such e-mail notification service will be by way of an 'opt in'.
Once opted-in, you may opt out at any time by contacting us via the usual methods or specific opt-out methods provided in the communication.
Who has access to the information you provide?
Our staff will have access to your data where they are providing a service to you as a customer.
We will not pass the personal information we hold about you to any third party without your consent,
except:
- If HandicapMaster Ltd were to be acquired by a third party then personal data held by us about our customers will be one of the assets transferred.
- This is a required function of the services we are providing. An example of this is the regulatory requirement for publishing data provided by Golf Clubs in the UK and Ireland
to the Central Databases of Handicaps (CDH) systems operated by the national Golf Authorities.
We will only share your personal information where:
- We are legally required to, or as a result of a lawful request by a governmental or law enforcement authority.
- We have engaged a supplier or contractor to carry out services on our behalf.
We only work with trusted suppliers who have agreed to treat your information as respectfully as we do and
in accordance with the requirements of the Data Protection Act 1998 and the GDPR Regulations from 25 May 2018.
Our website contains links to websites that are outside of our control and are not covered by this privacy statement.
These other sites may collect information about you, we recommend that you consult those website privacy statements.
Keeping your information safe and for how long?
The personal information which we hold will be held securely in accordance with our internal security policy and the law.
If you have a password to access certain parts of our website, you must keep that password safe and not share it with anyone or your personal information could be at risk.
Data that is sent via the internet or in email, is not 100% secure. As the internet is a global environment, sending data to us may take place outside the European Economic Area.
We will take every reasonable precaution to keep your information safe but it cannot be guaranteed. So please be aware that any information you do transmit to us is at your own risk.
Once we have received your information we will use our best effort to ensure its safety within our network, which is within the European Economic Area.
We will retain the data while you have a contract with us.
We will also retain the data for a time period to meet legal requirements, such as for company accounting purposes (6 years),
UK Government Accounting Regulations.
There may be other such legal requirements for example taxation reasons.
The time period for such retention will be based on current legislation and regulatory requirements.
Understanding your rights
The information we hold will be accurate and up to date.
To request details of your data you should
contact us or use the 'contact us' link
located at the bottom of this page. There you will find provided full contact details.
If you find any inaccuracies, we will delete or correct it promptly.
You also have the right to object to further processing of your personal information for direct marketing.
For wider advice and guidance about data protection you may contact the data protection regulator the UK's supervisory authority,
this is the Information Commissioner's Office (
https://ico.org.uk).
Complaints
In the first instance, you should
contact us or use the 'contact us' link
located at the bottom of this page with the nature of your complaint.
Notification of changes to this statement
HandicapMaster Ltd reserves the right to change this statement over time to reflect changes
in privacy and data protection regulations and to post the updated version to this website.
We may also contact you by e-mail where you have agreed to be contacted, to notify you of updates to this policy.