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Golfbreaks.com

Privacy Policy

At Golfbreaks, we are strongly committed to your right to privacy and to providing a safe, enjoyable and productive customer experience both off-line and on-line. Our Privacy Policy has been drawn up with those aims in mind, as well as to ensure compliance from 25 May 2018 with the General Data Protection Regulations (EU) 2016/679, as well as the Data Protection Act 1998 (and any amendment of or replacement for that Act) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (and any amendment of or replacement for those Regulations), as well as any other data protection laws that apply from time to time (together the “Data Protection Laws”).

In this Privacy Policy, references to ‘Golfbreaks’, ‘we’, or ‘us’ or ‘our’ mean Golfbreaks Limited trading as Golfbreaks.com, a company registered in England and Wales, with company number 03571913, with its registered office address at Minton Place, Victoria Street, Windsor, SL4 1EG. Golfbreaks is a data controller in that we determine the purposes and means of the processing of the personal data that we collect and are responsible for your data. We are registered with the Information Commissioner’s Office.

Any questions concerning personal data should be addressed to the Data Protection Officer by email to [email protected] or by post to Golfbreaks.com, Minton Place, Victoria Street, Windsor, SL4 1EG. Additionally, you can adjust your preferences at any stage via your online Golfbreaks account.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We reserve the right to modify or amend this Policy at any time and will display the effective date at the end of this Policy. Previous versions can be obtained by contacting us.  

It is important that you read this Policy together with any other privacy notice or fair processing notice that 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 Policy supplements the other notices and is not intended to override them.

This Policy is organised into sections which you can click through to :

  1. What personal data we collect
  2. How we use your personal data
  3. Security and storage
  4. Your rights
  5. Sharing your personal data
  6. Cookies and other tracking technologies
  7. Third party websites

1. What Personal Data we collect


As a travel business, we need to collect certain personal data (such as name, address and contact details) from you to ensure that we can make the arrangements for your golf break with the golf, hotel and other suppliers, and in order to perform your golf break contract services. We will also collect your personal data to able to provide you with details of future golf breaks and for the other purposes set out in this Policy. We will ask for your consent or rely on another legal basis for processing before we process your personal data, in accordance with the Data Protection Laws. 

Under the Data Protection Laws, personal data means any information relating to an identified or identifiable natural person.  An identifiable natural person is one who can be identified, directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural or social identity of that natural person.

We will collect personal data, such as your full name, address, email address and telephone number when you:

  • make an enquiry with our sales team;
  • make a booking for a golf break;
  • make a payment for a golf break;
  • make a service case or ask a question to our customer service team;
  • start a live chat session with our contact centre;
  • register for an account in our secure customer portal;
  • enter a competition;
  • register for events; or
  • subscribe to our email newsletter;

If you make a booking with us we will also ask you to provide us with the name and contact details of the other members of your party. Where we make flight bookings as part of your golf break, we may also need to ask you for your passport details.

Health and mobility information: When you make an enquiry or a booking with us, we will ask you to disclose whether you have a medical condition or health issue or have any restrictions on your mobility. See the Section below on “How we use your Personal Data" for information for details of why we need to process this information and how we will obtain your consent. If you choose not to disclose this information to us or do not give us your consent to use it for the outlined purposes, we may not be able to provide the services you have requested due to our legal responsibility to provide you with a safe holiday.

Group data: If you provide us with the personal data of any other parties, for example, any other individuals included in your booking, you must ensure that you have the consent of those other parties to provide their information to us. We will use their personal data as necessary to perform the booking contract.  

Automated technologies: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. Technical data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions we collect from the devices you use to access our website. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. 

Aggregated Data: We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your information about how you use our website, products and services to calculate the percentage of users accessing a specific website feature and to improve our website service using this information. 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.

2. How we use your Personal Data


Enquiries
:

When you make an enquiry about a golf break, we will use the personal data that you provide to us, such as name and contact details, to enable us to service your enquiry and take the steps that you request towards making a possible booking with us.

Bookings:

When you make a booking for a golf break, we will need to use your personal data such as name and address to make the travel arrangements for your break and otherwise as necessary to ensure that your booking contract is performed. This will usually require us to pass your personal data on to relevant third party suppliers of your travel arrangements such as hotels, airlines, transport providers, ground agents and destination management companies.

In order to effect your booking, we may also need to provide your personal data: to security or credit checking companies and/or credit and debit card companies in order to take payment for your booking; and to regulatory or public authorities such as customs or immigration if required by them, or as required by law.

Where we need to disclose your information to a third party for the fulfilment of your travel booking, we require that third party to have appropriate technical and organisational measures in place to protect your personal data and to process your data in accordance with our instructions and the Data Protection Laws.

Data transfers outside of the EEA: If necessary to perform your booking contract, we may need to transfer your personal data to third parties, such as travel suppliers, located outside of the European Economic Area (EEA). This will be the case where you book a golf break or tour that is based outside of the EEA, such as the USA or one of our other worldwide destinations.  See the Section on “Sharing your Personal Data” for details of how we ensure adequate safeguarding of your personal data when transferring it outside of the EEA.

Health and Mobility information: We will use the health and mobility information that you provide to us to enable us (and the suppliers of your golf break) to ensure your health, safety and welfare during your break, which is our legal responsibility. We will ask for your explicit consent for our use of this information at the time of requesting it, including our sharing of your information with the suppliers of your break only for the purposes set out above.

Breakpoints loyalty scheme:

When you a make a booking with us and register for an online account in our secure customer portal, you will automatically earn points under our Breakpoints loyalty scheme which may be redeemed against future golf breaks. See the terms and conditions of the Breakpoints scheme for further details.

We will use your name, email address or postal address to contact you to tell you what points you have accumulated and when your points will expire. If you opt in to receiving marketing communications from us (see next paragraph),  we will send you details of offers for redeeming your Breakpoints and earning additional Breakpoints.

Marketing communications:

We would like to be able to send you details of our offers and promotions by email, telephone, text message and/or post according to your choice. We have established a preference centre as part of your Golfbreaks online account so that you can tell us what marketing communications you would like to receive.  You can change your preferences at any time by simply updating your preferences in your online account. We will not send you any marketing communications unless you have expressly opted in to receive them.

You can also opt in by:

  • Subscribing online for our email newsletters;
  • Telephoning us on 01753 752900;
  • Emailing us on [email protected];
  • Writing to us at Golfbreaks.com, Minton Place, Victoria Street, Windsor, SL4 1EG

If you have opted-in to receive marketing communications from us, you can opt out at any time by:

  • Updating your preferences in your online account;
  • Clicking the unsubscribe link in our email newsletters;
  • Telephoning us on 01753 752900;
  • Emailing us on [email protected];
  • Writing to us at Golfbreaks.com, Minton Place, Victoria Street, Windsor, SL4 1EG

Where you have consented to do so, we may also use your personal data to keep you informed about the selected partner offers that may be of interest to you.

For other lawful purposes:

We will use your personal data for such other lawful purposes as are permitted under the Data Protection Laws and we will always obtain consent where required.

3. Security and storage


We take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. This includes, as appropriate: the pseudonymisation and encryption of personal data; the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

When you provide your personal data through our website, this information is transmitted across the internet securely using high-grade encryption. In addition to this, we are a PCI DSS compliant company. This means we adhere to high security standards in order to protect your payment card details when you make a booking over the phone or pay your balance through your online account in our secure customer portal.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The information that you provide to us will be held securely in our systems, which are located on our premises or those of an appointed third party. We will only allow access to your personal data by third parties who act for us for the purposes described in this privacy policy or for other purposes approved by you.

We will only retain your personal data for as long as is appropriate and necessary to the fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, taking into account the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, and whether we can achieve those purposes through other means.  We will limit the period for which personal data is stored to a minimum. We will set time limits for erasure or periodic review.  You may request details of our retention policy and in addition, you have a right to have your personal data restricted or erased – see more details under “Your Rights” below.

4. Your rights


Your rights under the Data Protection Laws in relation to your personal data include (but are not limited to) the following:

You have the legal right to ask us to supply you with a copy of the personal data that we hold about you at any time free of charge.  This could include booking information relating to breaks that you have booked through us. Further copies may incur a reasonable fee and also if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances).

You can also ask us to rectify any errors in your personal data or complete any incomplete data that we hold or you can update your own details at any time by accessing your online account in our secure customer portal.

Where you have given your consent to our processing your data, you have the right to withdraw your consent at any time. If you withdraw your consent and there is no other legal ground for us to process your data, you can ask us to erase your personal data. You can also require us to erase your data if we have processed your data unlawfully or if the law requires us to erase your data.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You may also restrict the processing of your data: This enables you to ask us to suspend the processing of your personal data if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it..

You may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

5. Sharing your personal data


We will share your personal data with suppliers or other third parties only on the legal basis indicated in this Privacy Policy.

Transfers outside of the EEA: Where we need to transfer your data to a third party supplier or service provider based in a country located outside of the EEA, either in order to fulfil your booking, or for the purposes of the third party providing us with a service, we will ensure that either the country to which the data is to be transferred has an adequate level of protection for data (as determined by the European Commission) or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe or where a supplier or service provider is based in the US, we may transfer data to them if they have certified to the Privacy Shield Framework Principles which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We will share your personal data with any member of our group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) for internal administrative purposes including processing of personal data on the basis of being in our legitimate interests to do so.  We ensure that our group companies follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

If the shares in Golfbreaks or substantially all of our assets are sold to a third party, your personal data may be disclosed to the prospective buyer during the sale negotiations and on conclusion of the sale will be transferred as a company asset to the third party. This is necessary for our legitimate interests to be able to sell the company or its assets in the future, provided that we take all appropriate steps to keep your personal data confidential and secure at all times in accordance with this Policy and the Data Protection Laws, including requiring the third party to sign a confidentiality and non-disclosure agreement.

Other than as previously stated, we will only disclose or share your personal data if necessary to comply with any legal obligation or in order to enforce or apply our Terms of Use, Booking Conditions and other agreements with you, or to protect the rights, property or safety of Golfbreaks, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Golfbreaks will not give or sell any personal data to any third party companies, organisations or individuals without your prior consent.

6. Cookies and other tracking technologies


We use cookies and other tracking technologies on our site. These allow you to use our site and specific parts of the site, such as your Golfbreaks account, effectively, as well as give us information about your use of our site which we use to develop and improve our site. A list of all the cookies that we use and what we use them for are set out in our Cookie Policy (see Cookie Policy tab). We will ask for your consent to cookies unless they are strictly necessary for the purpose of enabling the use of our website or a specific service that you request. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

7. Third party websites


Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

Privacy Policy last updated on 21st May 2018

Introduction


www.golfbreaks.com
("the Site") is operated by Golfbreaks Limited ("we" and "us").

Use of the Site is on the terms and conditions contained in this document (“Terms of Use”). If you do not agree to these Terms of Use, stop using the Site immediately. By using this Site you are indicating your acceptance to be bound by these Terms of Use. They are a legal agreement between you and us and can only be amended with our consent. They should be read in conjunction with the details provided on the Site about how the Site operates and the products and services which are available.

Any bookings for golf breaks are also subject to our Booking Conditions. You should also read our Privacy Policy.

We reserve the right to change these Terms of Use from time to time without prior notice by changing them on the Site.

Accuracy of information


We are committed to using all reasonable endeavours to ensure that information on the Site or any other information we provided you with is accurate. However, except to the extent that our Booking Conditions apply, we make no representation or warranty that such information is accurate and up to date or complete and we accept no liability for any loss or damage caused by inaccurate information to the fullest extent permitted by law.

If you find any inaccurate information on the Site please let us know and we will correct it, where we agree, as soon as we can.

Your use of information on this site


All materials on this Site including but not limited to text, software, photographs and graphics are protected by copyright. We, or our licensors, own copyright and/or database rights in the selection, coordination, arrangement and enhancement of such content, as well as in the original content. You may not modify, publish, transmit, participate in the transfer or sale, create derivative works, or in any way exploit, any of the content, in whole or in part except as provided in these Terms of Use.

You may download information from the Site for your own personal non-commercial use only. Except as otherwise expressly permitted under copyright law, no copying, redistribution, retransmission, publication or commercial exploitation of downloaded material will be permitted without our express permission and that of the copyright owner. In the event of any permitted copying, redistribution or publication of copyright material, no changes in or deletion of author attribution, trademark legend or copyright notice shall be made. You acknowledge that you do not acquire any ownership rights by downloading copyright material.

Members’ Area


The Golfbreaks.com Members’ Area allows you to manage your bookings online. You can access current and past bookings, pay balances online and update personal details, as well as email and share photos and videos with other members of your group.

In order to access the Members’ Area you will need to create a Member’s Account. You may never use another Member’s Account without permission. When creating your account, you must provide accurate and complete information. You are solely responsible for the activity that occurs on your Member’s Account and you must keep your password secure. You must notify Golfbreaks.com immediately of any breach of security or unauthorised use of your Member’s Account. Golfbreaks.com will not be liable for any loss caused by any unauthorised use of your Account, but you may be liable for losses of Golfbreaks.com or others due to unauthorised use. We have the right to disable any user ID code or password at any time if in our opinion you have failed to comply with these Terms of Use .

You acknowledge that all information, data, text, photographs, video, messages and other materials, whether publicly posted or privately transmitted via the Members’ Area, (“Submissions”), are the sole responsibility of the person from whom such Submissions originated. This means that you, and not Golfbreaks.com, are entirely responsible for all Submissions that you upload, post, email or otherwise transmit via the Members’ Area. Golfbreaks.com does not control the Submissions posted via the Members’ Area and does not guarantee the accuracy, integrity or quality of such Submissions. You warrant that any Submission complies with these Terms of Use and you indemnify us for any breach of that warranty. Golfbreaks.com is not liable in any way for any Submissions, including, but not limited to, any errors or omissions in any Submissions, or for any loss or damage of any kind incurred as a result of the use of any Submissions posted, emailed or otherwise transmitted via the Members’ Area.

You agree not to use the Members’ Area to upload, post, email or otherwise transmit any Submissions that are unlawful, harmful, threatening, abusive, harassing, tortuous, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable.

You acknowledge that Golfbreaks.com does not pre-screen Submissions but has the right, but not the obligation, in its sole discretion to refuse or remove any Submissions and/or terminate a Member’s Account for uploading such material in violation of these Terms of Use at any time, without prior notice and at its sole discretion.

Trade marks


“Golfbreaks.com” and certain of our other logos on this Site are UK registered trade marks of Golfbreaks.com and may not be reproduced without our express permission unless otherwise permitted under these Terms of Use. Other organisations and company names referred to on this Site may be trade marks of their respective owners as indicated.

Links to this and other websites


We provide hyperlinks to other sites which are operated by other organisations. We are not responsible for external websites that link to this Site or which are linked from it. That we include these hyperlinks does not imply any endorsement of the material on such sites or any association with their operators, unless otherwise stated.

We reserve the right at our discretion to prohibit any link from another internet site to materials or information on this Site. Without prejudice to that right, any link to material or information on this Site for which you are responsible must be neither misleading nor deceptive and must fairly indicate golfbreaks.com as the destination of the link.

Availability of our site


Whilst we are committed to providing you with an excellent service by making our Site available we cannot guarantee that our Site will operate continuously or without interruptions or be error free. You must not attempt to interfere with the proper working of our Site and, in particular, you must not attempt to circumvent security, tamper with, hack into, or otherwise disrupt any computer system, server, our Site, router or any other internet-connected device. You are responsible for ensuring that your computer system meets all relevant technical specifications necessary to use our Site and is compatible with our Site. You also understand that we cannot and do not guarantee or warrant that any material available for downloading from our Site will be free from infection, viruses and/or other code that has contaminating or destructive properties. You are responsible for implementing sufficient procedures and virus checks (including anti-virus and other security checks) to satisfy your particular requirements for the accuracy of data input and output.

Viruses, hacking and other offences


You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.

By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.

Our liability


Although we hope this Site will be of interest to users (and except to the extent that our Booking Conditions apply) we accept no liability and exclude all warranties, conditions or other terms that might be implied by law in relation to this Site and its content, to the fullest extent that such liability can be excluded by law.

In no event shall we be liable for any direct, indirect or consequential loss or damage incurred by any user in connection with the use, inability to use, or results of the use of the Site, any information on the Site, any websites linked to the Site and any materials posted on it, including, without limitation, any loss of income, revenue or profits. We accept liability for death or personal injury caused by our negligence and responsibility for fraudulent misrepresentation or misrepresentation as to a fundamental matter that cannot be excluded under English law.

General


Golfbreaks.com is a company registered in England and Wales. Our company number is 03571913 and our registered office address is Minton Place, Victoria Street, Windsor, SL4 1EG. In the event of any inconsistency between these terms and conditions, our Privacy Policy and our Booking Conditions then the Booking Conditions shall take first precedence, our Privacy Policy shall take second precedence and these Terms of Use shall take third precedence.

Any formal legal notices should be sent to us at the address at the end of these Terms of Use by email confirmed by post.

Failure by us to enforce a right does not result in waiver of such right. You may not assign or transfer your rights under this Agreement.

You and we agree that English law applies to these Terms of Use and that any dispute between us regarding the Site will only be dealt with by the English courts.

Problems


If you experience problems with our Site or would like to comment on it, please email us at [email protected].

Updates


We may revise these Terms of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these Terms of Use may also be superseded by provisions or notices published elsewhere on our site. These Terms of Use were last updated on 6 January 2017.

What is a Cookie?


Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and Golfbreaks account, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

We use cookies and other tracking technologies on our site. A list of the types of cookie we use and what we use them for can be found below.

Necessary Cookies


These cookies are necessary for some parts of the website to work correctly, for example viewing and posting reviews, and ensuring we provide you with the best phone number to call should you want to enquire about a golf break.

Site Performance & Analytics


These cookies allow us to measure traffic sources and visits, so we can monitor the performance of our website. They let us know which pages are being used or not, and how our visitors use the website.

Search Cookies


These cookies enable us to measure referred searches and traffic sources, so we can monitor the performance of our search partners. They let us know how easy it is for you to find us, and how we can make it easier for you to find what you’re looking for on our website.

Advertising Cookies

These cookies may be set through our site by carefully selected advertising partners. They can be used and shared by them to build a profile of your interests and display relevant adverts to you on other websites. This is done by uniquely identifying your browser and device.

Social Cookies


These cookies enable us to measure social network traffic sources, so we can monitor the performance of our social media partners. They let us know whether you’re interacting with us on social media, and help ensure we recognise you when you visit.

You’re in Control


We will ask for your consent to cookies unless they are strictly necessary for the purpose of enabling the use of our website or a specific service that you request.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Policy created under guidance from the International Chamber of Commerce ‘ICC UK Cookie Guide’ Second edition (Nov 2012).