MyPathway2Golf Privacy Statement
At GolPhin, we take the privacy of our customers and users extremely seriously. This policy (together with our terms and conditions) sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us. We encourage all customers and users to read the following carefully to understand our views and practices regarding your personal data and how we will treat it. When we refer to “you” in this policy, this:
- includes all users of our website, parents, guardians, coaches, Golf Club managers or any other individual about whom we collect or receive personal data;
- but does not include any Golf Club operator or owner or other user which is a company.
Data Controller
For the purpose of the General Data Protection Regulation (the GDPR), the data controller is GolPhin Limited. Please note that we may also pass your data and information on to the operators or owners of the golf club that purchases a license fee to operate the version of this site with which you are assigned. Where we do this, the Golf Club or PGA Professional or Manager of the Facility will be the data controller in respect of that data or information, and you should contact them (or consult the privacy policy for that Golf Club or Facility) if you have any queries in relation to any use or disclosure that they may make of your information or data.
Information we may collect from you
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site at www.MyPathway2Golf.com (our site) or uploading any content to it. This includes:
- Name of coach/parent/student
- Role of account (coach, parent or student)
- mail address assigned to the account (If a student account does not have an email address assigned, we will assign an encrypted and tokenised email address to the account which we can not access or handle data within)
- Any profile picture uploaded to the account
- Golf course which the account is assigned to or associated with
- Coach account to which the parent/student account is assigned
- Phone number and date of birth is listed on account profile, but we at GolPhin do not have any way of accessing this information
- If you contact us, we may keep a record of any communication between you and us. This includes
- Any email records regarding your conversation
- Any notes taken regarding your conversation
- If you contact us by phone, we do not record any incoming or outgoing calls for any purpose
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. These will be provided either through the service (MyPathway2Golf) or through email using the address provided at registration.
IP addresses
We may collect information about the equipment you use to access our site, including where available your IP address, operating system and browser type. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
Cookies
We use cookies when you log in to MyPathway2Golf to ensure that the browser remembers your username on future logins. We do not store this data at GolPhin Ltd, as the cookies assign them exclusively to the browser.
We do not use cookies in any malicious or subversive way that we feel would compromise your trust in us. We hold good ethics at the heart of our business practice.
What legal basis do we have for processing your personal data?
We will not process any personal data without users expressing their consent and agreeing to our privacy policies. Individuals can withdraw their consent by contacting us at info@golphin.co.uk where we can handle the query personally and ensure all personal data is removed.
When do we share personal data?
All personal data is treated confidentially and handled with the utmost discretion. Coaches you are assigned to on MyPathway2Golf can access your profile details if you assign your account to that coach, however no other third-party accounts or entities can access your details, nor do we share your personal data with third parties. All your personal data is locked behind valid registered accounts which must be taken through our approval process before becoming activated.
Where we store your personal data
All information you provide to us is stored on our secure servers.
How we secure personal data
The servers on which we store your personal data is located within the United Kingdom, which is currently a member of the European Union and must abide by security laws which apply to member states. As such, we have taken every measure to ensure that the servers we use are encrypted and highly secure. We have measures in place to:
- Protect against accidental loss of data with encrypted cloud server backups.
- Prevent unauthorised access by using secure login verification.
- Restricting access to personal information by exclusively allowing access to this information to authorised personnel.
- Train staff on data security and it’s importance with mandatory training courses regarding data handling.
- Manage third party risks through usage of signed contracts kept on file and security reviews.
How long we keep your personal data for
We store your personal information for as long as the following three requirements are all met:
- We have the consent of the user
- The golf club assigned to the account is an active and valid MyPathway2Golf user
- The user is an active member of a MyPathway2Golf facility
If any of these three requirements are not met, we will destroy the personal data of the user with immediate effect. This means that access would be terminate to the MyPathway2Golf service.
Uses made of the information
We use information held about you in the following ways:
- To ensure that content from our site is presented in what we consider to be the most effective manner for you and for any equipment you may use to access our site.
- To provide you with information, services that you request from us or which we consider may interest you, where you have consented to be contacted for such purposes.
- To consider and communicate with you in relation to any updates, changes of service, or amendments to our site.
- To notify you about changes to our services.
This information is required in order to assign users to the platform and to allow full access to be granted to the resources and facilities provided by the MyPathway2Golf service.
We may also use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by email.
Where we propose to make any goods or services available to you in accordance with the previous paragraph, we will give you the opportunity for us not to use this data in this way.
Disclosure of your information
We will provide your personal information and data to the owners or operators of the relevant Golf Club or Facility associated to your account. Please also see the section headed “Data Controller” above.
If we sell or buy (or propose to sell or buy) any business or assets, we may disclose and transfer your personal data to the seller or buyer (or prospective seller or buyer) of such business or assets.
We will also disclose personal information if we are under a duty or are required by law or regulation to disclose or share your personal data.
Your rights in relation to personal data
Under the GDPR, we respect the right of users to access and control their personal data. You have the right to:
- Access your personal information
- Correct and/or delete your personal data
- Withdraw your consent
- Receive information regarding your data on any platform
- Restrict or object to processing of data
- Lodge a complaint with regards to the handling of personal data
You can exercise your rights by contacting us directly at the contact details below, and we will respond to any queries within 24 working hours UK time (09.00-17.00 Monday – Friday, excluding national holidays).
Exemptions to the above apply if the personal data we are asked to modify or delete is required to remain unchanged or intact by law, or if the data may expose personal data about another person over whom you do not have legal guardianship.
Use of automated decision-making and profiling
The personal data collected on MyPathway2Golf is used to create your personal profile on the system to improve the user experience and allow your coach to identify you. Decision making regarding access to account information are made using a manual approval and activation process and are restricted to accounts relating to the golf club to which the account in question is assigned.
Linked sites
Our site may, from time to time, contain links to and from third party websites. 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.
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page
Contact
Any questions, comments and requests regarding this privacy policy should be addressed to by email at info@golphin.co.uk or in writing to GolPhin Limited, Unit 11 Ailsa Business Park, Ailsa Road, Irvine KA12 8LN.
