Privacy Policy
Golfer Sweden AB, organisation number
559091-7745, (“Golfer”, “we”, “our” or “us”) value your
privacy and are committed to protecting your personal data. Therefor we want you to be aware of how
we use and process your personal data, provided in a readable and transparent
manner and otherwise in accordance with applicable data protection laws and
regulations, including but not limited to the General Data Protection
Regulation (“GDPR”). This privacy policy is applicable
when you create or have created a user account in order to book a tee time to
play golf through our mobile application Fade (the “Application”). Golfer keeps this privacy policy under regular
review and might amend this privacy policy from time to time in our sole
discretion, so we recommend you review this privacy policy occasionally to stay
informed about our personal data practices and to make sure where you stand. If
we make any updates to this privacy policy that will affect you significantly,
we will notify you about the changes before any new processing activities
begin.
1.1
When you use the Application, the following personal data
will be collected and processed:
a)
App Account and Profile Information: When you create a
user account through the Application to become a registered user, we collect
your first and last name, age, email address, golf handicap, phone number (if
provided), postal address (if provided) and other similar contact data. We also
collect the information that you give to us when responding to an optional
survey or questionnaire via the Application (e.g. to provide feedback on our
services and the Application);
b)
Credentials: We collect passwords and
similar security information related to your user account;
c)
Location Information: We collect information from
cellular, Wi-Fi, GPS networks and Bluetooth to determine you approximate location,
see section 2.2 below for more information;
d)
Mobile Device Data: We may collect device
information (such as your mobile device ID, model and manufacturer), operating
system, version information, mobile carrier, IP address and signal strength
relation to Wi-Fi or Bluetooth.
2.1
We collect your personal data through various methods,
primarily by information you yourself provide when you create your user account
via the Application.
2.2
You may tell us your approximate location if you
choose to enable your mobile device to send us location information. When
searching for golf courses on the Application, your location information will
be sent to our servers in order to provide you with the golf courses nearest
you and to view offers near your location.
2.3
We may collect personal data from our collaborative partners
which we have entered into agreements with in order to provide the services to
you.
3.1
Golfer uses your personal data for the following
purposes:
a)
to fulfil our contractual obligations towards you as a
user of the Application, such as completing your booking with the applicable
golf club. For this purpose, Golfer relies on the legal basis that the
processing of personal data is necessary for the performance of a contract,
specifically to finalise and administer your booking with the applicable golf
club;
b)
to administer your user account in the Application and
monitor your compliance with our terms and conditions http://fade.privacy.s3-website-eu-west-1.amazonaws.com/. For this purpose,
Golfer relies on the legal basis that the processing is necessary for the
purposes of the legitimate interests pursued by Golfer or its third parties;
c)
to locate nearby golf facilities and view offers near
your location. Golfer relies on the legal basis that you have given consent
to the processing of your personal data for this specific purpose;
d)
to inform you about new updates to the services or the
terms and conditions. For this purpose, Golfer relies on the legal basis that the
processing is necessary for the purposes of the legitimate interests pursued by
Golfer or its third parties;
e)
to send you notifications and messages by text, email
or in the Application (including marketing and information from us and the golf
clubs you book tee times with) and process user survey’s you have answered
about the Application and our services. You can always shut off notifications
in your device’s settings and you always have the right to opt-out of receiving
direct marketing (see section 6.6 below). For this purpose, Golfer relies on
the legal basis that the processing is necessary for the purposes of the
legitimate interests pursued by Golfer or its third parties; and
f)
to ensure the stability, security and the development of
the services or new services in the Application. This includes carrying out
data analysis to test the Application in order to make sure the technical
functions within the services are properly functioning and to prevent use in
violation with the terms and conditions. For this purpose, Golfer relies on the
legal basis that the processing is necessary for the purposes of the
legitimate interests pursued by Golfer or its third parties.
3.2
We may also aggregate and anonymise your personal data
and use such anonymised data for statistical purposes and to improve our
services. Please note that such anonymised aggregated data generally cannot be
traced back to you as an individual. Any aggregation and anonymization of your
personal data relies on the legal basis that the processing is necessary for
the purposes of the legitimate interests pursued by Golfer or its third parties.
3.3
In regards to the above, if your personal data is
being processed on the legal basis that the processing is necessary for the
purposes of the legitimate interests pursued by Golfer or its third parties,
Golfer will always balance your rights and interests in the protection of your
personal data against Golfer’s rights and interests or those of the third
party. You have the right to object, at any time, to processing of personal data
which is based on a legitimate interest, see section 6.6 below.
4.1
Golfer will store your personal data as long as the
data is necessary for the purpose for which the data was collected, or if
necessary for another purpose which is not in conflict with the original
purpose for collection. Golfer will erase the personal data that is no longer
needed, but may retain certain personal data where laws and regulations may
require a minimum period during which we must keep your personal data.
4.2
Location information is only processed when the
Application is running and assuming you have not withdrawn your consent, see
section 6.7 below. However, historical logs of location information may be
stored and processed in aggregated or anonymised form.
4.3
If you unsubscribe from direct marketing or other
information, the personal data will no longer be processed for this purpose.
5.1
We may share your personal data with other companies
that process data on our behalf in order to perform our services, such as
analysis, distribution or other services to maintain and apply our terms and
conditions. We have, where appropriate, entered into data processing agreements
with such other companies, ensuring that your personal data is processed in a
secure and confidential manner.
5.2
We
may share your personal data with third parties in order to complete your
booking and provide our services in accordance with our terms and conditions.
As stated in our terms and conditions http://fade.privacy.s3-website-eu-west-1.amazonaws.com/, all payments are administered via
our partner Greenfee365 Europe AB (“Greenfee”), and via their payment
provider Stripe. You can read more regarding the conditions for payment here: https://greenfee365.com/sv-SE/info/terms-of-service and regarding Greenfee’s processing
of personal data here: https://greenfee365.com/sv-SE/info/privacy-policy.
5.3
We may also share your personal data with third
parties who help us with marketing. We always ensure that these third parties
only use the personal data to market our services according to our
instructions.
5.4
The personal data we collect from you is processed
within a country of the European Union or the European Economic Area (“EU/EEA”),
but may also, whenever necessary, be transferred to and processed in a country outside
of the EU/EEA in order to complete a booking with a golf club located outside
the EU/EEA. Any such transfer of your personal data will be carried out in
compliance with applicable data protection legislation that have requirements
of adequate level of protection.
5.5
We will not share, sell, transfer or otherwise
disclose personal data to third parties except as described in this privacy policy
or if we are required to do so by law, other regulation or by decision from a
court or competent authority.
Golfer
would like to make sure you are fully aware of all of your data protection
rights. You are entitled to the following, as stated below in section 7.1–7.8.
6.3
The right to erasure (“right to be forgotten”)
You have the right to have
your personal data erased without undue delay and we are obligated to erase
personal data without undue delay where one of the following grounds applies:
a)
the personal data are no longer necessary in relation
to the purposes for which they were collected or otherwise processed;
b)
the processing is based on your consent and you
withdraw your consent, unless there are any other legal grounds for the
processing;
c)
you object to processing based on a weighing of
interests and there are no overriding legitimate grounds for the processing
(note however that you always have the right to erasure of your personal data
used for direct marketing purposes);
d)
the personal data have been unlawfully processed; or
e)
the personal data have to be erased for compliance
with a legal obligation in Union or Member State law to which we are subject.
Please note however, that the
right to erasure does not always apply, for example if the processing is
necessary for compliance with a legal obligation under EU law or the laws of
any member state of the EU to which we (Golfer) are subject. Furthermore, if
the processing is necessary for us to establish, exercise or defend legal
claims, your right to erasure does not apply.
a)
the accuracy of the personal data is contested by you,
for a period enabling us to verify the accuracy of the data;
b)
the processing is unlawful and you oppose the erasure
of the personal data and request that the use of the data is instead
restricted;
c)
we no longer need the personal data for the purposes
of the processing, but they are required by you for the establishment, exercise
or defence of legal claims;
d)
you have objected to processing based on a weighing of
interests, pending the verification whether our legitimate grounds to process
the data override yours.
You have the right to request access to personal data in a structured,
generally used and machine-readable format regarding such data that you have
provided to Golfer and you have the right to transmit those data to another
controller if the data is processed with your content or on the basis of the
performance of a contract and the processing is carried out by automated means.
Where
technically feasible, you shall have the right to have the personal data
transmitted directly from Golfer to another controller.
If you have provided Golfer consent, you may withdraw
it at any time. When you withdraw your consent, the processing that the consent
referred to will cease to occur and the personal data collected on the basis of
your consent will be deleted, if the personal data is not needed for another
purpose for which Golfer has the right to process your personal data.
Golfer currently primarily relies on your consent to process location
information (see section 3.1.c above). The consent is gathered from you in the
application and if you wish to withdraw the consent, you can do so by following
the instructions below. Please note that if you choose to withdraw the consent
by disabling the location services feature on your mobile device, this will
limit the performance of the Application in the sense that the Application will
no longer be able to provide information on nearby golf courses. Please feel free to contact us if you have any
issues.
For
iOS: You should be able to adjust the settings on your iOS mobile device to
prevent our collection of location information by disabling the location services
feature on your device. For more detailed information on how to choose which
applications use your iOS device’s location, please click here.
For
Android: You should be able to adjust your settings on your Android mobile
device to prevent our collection of location information be disabling the
location services feature on your device. For more detailed information on how
to choose with applications use your Android device’s location, please click here.
For any requests relating to this privacy policy, to
exercise any of your data protection rights, or if you have a complaint, you
are welcome to contact us, see section 8 below. You also always have the right
to file a complaint with the Swedish
Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten)
or the corresponding authority in your country of residence.
7.1
You are welcome to contact us by email at support@joinfade.com or the address
below.
7.2
The controller is Golfer Sweden AB, organisation number
559091-7745, Skeppsbron 44, 4tr, 111 31 Stockholm, https://golfersweden.com/.