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                   WHAT personal data do we collect?

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                   How do we collect personal data?

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                   Why AND ON WHAT BASIS do we process your personal data?

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                   For HOW LONG DO WE STORE YOUR PERSONAL DATA?

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                   TRANSFER AND DISCLOSURE OF PERSONAL DATA

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.

6                   Your rights

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.

6.1               The right to access

You have the right to demand and receive confirmation whether or not we process personal data which concerns you. If such personal data is being processed, you have the right to receive information regarding the processing and a copy, free of charge, of the personal data being processed. For any further copies requested by you, we may charge a reasonable fee based on administrative costs.

6.2               The right to rectification

You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

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.

6.4               The right to restriction of processing

You have the right to obtain restriction of the processing of personal data where one of the following applies:

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.

A restriction of the processing of personal data means that the personal data will continue to be stored, but Golfer will not process any personal data without your consent. Again, if we need to process the personal data in order to establish, exercise or defend against legal claims, the restriction on processing will not apply in relation to such processing. Lastly, if processing is necessary for the protection of the rights of another natural or legal person, the restrictions may not apply.

6.5               The right to data portability


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.

6.6               The right to object

You have the right to object, at any time, to processing of personal data which is based on a legitimate interest. Golfer shall no longer process the personal data unless Golfer demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Where personal data is processed for direct marketing purposes, you have the right to object at any time to such processing of personal data, and if you do so, we will no longer process your personal data for these purposes.

6.7               The right to withdraw consent

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.

6.8               The right to complain to the Swedish Authority for Privacy Protection

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                   Contact information

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/.