VPAR Ltd Privacy Notice
Who We Are
We are VPAR, your golfing technology partner. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.
VPAR’s head office is at Rosedale Studios, Rosedale Road, Richmond, TW9 2SX, UK and we are a company registered in England and Wales under number 06581897. We are registered on the Information Commissioner's Office Register under number ZA239625. VPAR Inc is our fully owned US subsidiary and operates out of New Jersey and both businesses can be contacted at firstname.lastname@example.org
Our designated Data Protection Officer for the organisation is William Walsh, who can be contacted at the Rosedale Studios address, on +44207 524 7800 or email@example.com.
Information That We Collect
VPAR processes your personal information in order that we may provide you with the best golfing technology. To provide you with a personal service we ask for your personal data, such as your name, date of birth, email address, golf handicap. To fully utilise our services we also encourage you to upload information about your activities such as your location, date, time and time spent on your activity. All the above mentioned data will be available to you on our website. We will never collect any unnecessary personal data from you and we do not process your information in any way, other than as specified in this notice.
The personal data that we collect includes:
- First and Last Name, Home Address and Date of Birth
- Email and Telephone Number
- Preferred Tees, home golf club and golfing handicap
We collect information online through our VPAR app and other websites.
How We Use Your Personal Data
We take your privacy very seriously and other than to provide our services, we will never disclose or share your data without your consent. Or unless required to do so by law.
We only retain your data for as long as is necessary. And where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for us and our partners processing your personal data are detailed below:
- We collect your personal data to provide golf scoring technology and other related services you are experiencing, ultimately to ensure that you have the very best experience on the golf course
- Our notification, email and SMS providers use your personal data to keep you updated on the progress of your round, your year and other players around you
- Our advertising platform will use data to deliver adverts that we think are of interest
- We will occasionally send you marketing information where we have assessed it is beneficial to you as a VPAR user. We will ensure it is non-intrusive
- Our payment provider will need to store your personal data as part of its legal obligation for business accounting and tax purposes
- Where you consent, we will contact you for other promotional purposes that we think will be genuinely interesting to you, including other golf related news.
You have the right to access any personal information that we process about you and to request information about:
- What personal data we hold about you
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing in accordance with the data protection laws; to exercise your data portability rights and to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Occasionally, we would like to contact you with promotions. If you consent to us using your contact details for these purposes, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting us directly.
We will occasionally send you product or service updates by email that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.
Automatically Collected Data
When you use the service, we automatically collect data about your usage. This may include:
- Your IP address
- Pages of the website or sections of the app that you view and the order thereof
- Duration and time of your visit
- Your device, operating system, preferred language
- Your screen resolution and quality
- Your browser type and version, if appropriate
- Website or search engine you came from
- Keyword(s) you entered in the search engine
This information can be combined with information you have provided to us (for instance by registering), and will enable us to analyse and customise our services to you.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent other than as described here. We will share with specific partners to ensure we are running the very best possible service for you, which includes for the purposes specified below.
If you provide us with personal data about a third party, for instance if you invite your friends to join you in using VPAR, we will only use such third-party data for the specific purpose (delivering the invitation) and for providing the Service.
Where you register as the result of a partner collaboration of ours and you download the app directly through a partner promotion or collaboration then we may well ask on their behalf for you to consent to hear from them. You do not have to.
We use some third-parties to provide the below specific and skilled services and we have checked that all these processors acting on our behalf are complying with this privacy notice and the data protection laws.
VPAR use Stripe for taking payment; they are payment experts and they will process your payment seamlessly and securely; see https://stripe.com/gb/privacy for their privacy notice.
VPAR use Sendgrid to send you functional emails, e.g. invites to games, round summaries. Sending emails on behalf of companies is their whole business; see https://sendgrid.com/policies/privacy/ for their privacy notice.
VPAR use Microsoft Azure to host the services that power VPAR at our back-end. They provide secure ‘cloud’ infrastructure. Their privacy notice can be found at https://azure.microsoft.com/en-gb/support/legal/
Google DoubleClick For Publishers
Where you have consented to us using your data for marketing purpose, we may share with:
VPAR use MailChimp to send you marketing emails, e.g. new challenge or competition, new product updates or golf news. Sending emails on behalf of companies is their whole business; see https://mailchimp.com/legal/privacy/ for their privacy notice.
VPAR use Sendgrid to send you marketing emails, e.g. new challenge or competition, new product updates or golf news. Sending emails on behalf of companies is their whole business; see https://sendgrid.com/policies/privacy/ for their privacy notice.
We take every reasonable precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including
- Encryption of passwords and key IDs.
- Encryption when sending over public networks to prevent interception and tampering, i.e. secure connections between the iOS/Android apps and the server, using HTTPS/SSL.
- Up to date security software to prevent malware and external threats
- Strict permission controls to ensure access only by authorised persons
Transfers Outside the EU
VPAR use some services that are hosted/stored in the USA, which means that we may transfer any information which is submitted by our users through the website and/or apps outside the European Economic Area ("EEA") for the below partners / purposes:
- Urban Airship
Therefore, the personal information submitted may be stored on servers which are hosted in the USA. Where this is the case, we are taking steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures equivalent to Europe’s GDPR, to protect your data and comply with the relevant data protection laws.
How Long We Keep Your Data
We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.
Where you have taken part in one of our or our services, we will keep your data for a maximum of 6 years in order that we can reference the event for you, for the data controller or for ourselves.
Where you have made a purchase, we are required under tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Lodging a Complaint
We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
The Studios, Rosedale Road,
Phone: +44 (0)207 524 7800
Information Commissioner's Office - https://ico.org.uk
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 or go online https://ico.org.uk/global/contact-us/
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