Privacy

1. Your Privacy

Scotland Where Golf Began (SWGB) is committed to protecting and respecting your privacy.

This document (the “Privacy Policy”) explains our policy regarding any information you might supply to us when you visit our website at scotlandwheregolfbegan.com (the “Website”) or that you provide to SWGB via another route. Our goal is to protect your information.

This Website contains links to other websites, which are provided for your convenience. We are only responsible for the privacy practices and security of this Website. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit.

The ‘Data Controller’ (for the purposes of the EU General Data Protection Regulation 2018 (GDPR) (the “Act”)) of any personal information that you provide to us through the Website will be SWGB.

Where you provide personal information via another route to SWGB, the Data Controller of such information will be the company to whom you provide it.

This Privacy Policy uses some words with special meanings.  These words identified are in bold. If you want to know what any words with special meanings mean, simply scroll back till you find the word in bold, where you will also find the relevant explanation.

2. What Information Do We Collect?

This website collects and uses personal information for the following reasons:

2.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 3 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

In addition to Google Analytics, this website may collect information (already held in the public domain) attributed to the IP address of the computer or device that is being used to access it. 

2.2 Email links

Should you choose to contact us using our email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 3. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by SSL meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.

2.3 Email newsletter

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 3 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the MailChimp database, you will receive periodic (approximately one per quarter) newsletter-style emails from us.

3. Our Third Party Date Processors

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. Both of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

4. Consent

By using the Website you indicate your consent to us collecting and using your Information (that you provide to us when interacting SWGB) in accordance with the terms of this Privacy Policy, unless you expressly state that such consent is not given. When you submit Information to us you understand and agree that we and our associated companies (as defined in bold above) may record, transfer, store, and process your Information in any of the countries in which we and our subsidiaries or affiliates maintain offices, including without limitation, the United Kingdom.  See also Use of your Information outside the European Union (Section 6 below).

If you do not agree to these terms, please do not use the Website, register or purchase goods and services on the Website, enter competitions, or provide your Information to SWGB via any other route.

5. Security 

We take the security of your Information seriously.

We have a committed security policy.  We implement a number of security measures to ensure the safety of any Information in our possession or control. The Information is contained on a secure server, which is accessible only by a limited number of employees who have limited access rights to such information.

We have security procedures in place to protect our customer database from loss and misuse, and only allow access to it when absolutely necessary, and then under strict guidelines as to what use may be made of the Information contained within it.

6. Use of your Information outside the European Union

Some of the organisations (including, without limitation, our associated companies and partners) to which we may disclose your Information are situated outside of the European Union. In order to provide you with the products and services you require, we may need to transfer your Information to these countries some of which do not have laws that protect privacy rights as extensively as in the United Kingdom. If we do transfer your Information to other territories, we will endeavour to ensure that your Information is properly protected.

7. Policy for Children

We realise and understand that many children will visit the Website, or interact with SWGB via another route, but encourage all persons under 13 to consult with their parents or legal guardian before submitting any content or information to SWGB. Parents or legal guardians should, in particular, supervise children when online and recommend that parental control tools be put in place. Although anyone known to be under the age of 13 may participate in competitions and promotions, notification of a win or prize will be sent directly to the parent or legal guardian identified in the initial registration process. Any publication of a competition winner’s personal details for visitors known to be under 18 will require parental or legal guardian consent during registration.

8. Changes to this Privacy Policy 

This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

9. Updating and Correcting Information

You may correct the Information we hold about you by changing your profile preferences online or by contacting the Data Protection Officer. Please include your name, address, and/or email address when you contact us. We encourage you to update your Personal Information promptly if it changes.

10. Your Rights to Access Your Information

You have the right to see details of the information that we hold about you.  We may charge a small fee towards the cost of administering any request you make.

You may ask us to make any necessary changes to your Personal Information to ensure it is accurate and up-to-date.

11. Relevant Legislation

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer for clarification.

12. Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

13. How to Contact Us

If you would like any further information or have any comments about our use of your Information, our Privacy Policy or any aspect of the Website or our service, please contact our Data Protection Officer by email to info@scotlandwheregolfbegan.com.