In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e.
legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or
fulfil
our contractual obligations, to protect your rights, or to
fulfil
our legitimate business interests.
In legal terms, we are generally the
'data controller'
under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a
'data processor'
on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the
'data controller'
responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.
In Short:
We may share information in specific situations described in this section and/or with the following
categories of
third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (
'third parties'
) who perform services for us or on our behalf and require access to such information to do that work.
We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any
organisation
apart from us. They also commit to pr
otect the data they hold on our behalf and to retain it for the period we instruct.
The
categories of
third parties we may share personal information with are as follows:
We
also
may need to share your personal information in the following situations:
-
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to
honour
this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
-
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
-
Other Users. When you share personal information
(for example, by posting comments, contributions, or other content to the Services)
or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity.
If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
-
Offer Wall. Our application(s) may display a third-party hosted
'offer wall'.
Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services
, including our offer wall,
may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services
and your account
, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a
'sale'/'sharing'
(which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section
'
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
'
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice
:
__________
.
Google Analytics
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:
We keep your information for as long as necessary to
fulfil
the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this notice will require us keeping your personal information for longer than
three (3)
months past the termination of the user's account
.
When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymise
such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:
We aim to protect your personal information through a system of
organisational
and technical security measures.
We have implemented appropriate and reasonable technical and
organisational
security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised
third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short:
We do not knowingly collect data from or market to
children under 18 years of age
.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at
jshapiro@scottishgolfnoticeboard.com
.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
Depending on your state of residence in the US or in
some regions, such as
the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada
, you have rights that allow you greater access to and control over your personal information.
You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like
the EEA, UK, Switzerland, and Canada
), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below.
We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below
or updating your preferences
.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
when applicable law allows,
will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in the emails that we send,
replying
'STOP' or 'UNSUBSCRIBE'
to the SMS messages that we send,
or by contacting us using the details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
You may also opt out of interest-based advertising by advertisers on our Services.
For further information, please see our Cookie Notice:
__________
.
If you have questions or comments about your privacy rights, you may email us at
privacy@scottishgolfnoticeboard.com
.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (
'DNT'
) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for
recognising
and implementing DNT signals has been
finalised
. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for
recognising
or
honouring
DNT signals, we do not respond to them at this time.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:
If you are a resident of
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia
, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
| Category |
Examples |
Collected |
|
A. Identifiers
|
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
|
YES
|
|
B. Personal information as defined in the California Customer Records statute
|
Name, contact information, education, employment, employment history, and financial information
|
YES
|
|
C
. Protected classification characteristics under state or federal law
|
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
|
NO
|
|
D
. Commercial information
|
Transaction information, purchase history, financial details, and payment information
|
NO
|
|
E
. Biometric information
|
Fingerprints and voiceprints
|
NO
|
|
F
. Internet or other similar network activity
|
Browsing history, search history, online
behaviour
, interest data, and interactions with our and other websites, applications, systems, and advertisements
|
YES
|
|
G
. Geolocation data
|
Device location
|
NO
|
|
H
. Audio, electronic, sensory, or similar information
|
Images and audio, video or call recordings created in connection with our business activities
|
NO
|
|
I
. Professional or employment-related information
|
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
|
NO
|
|
J
. Education Information
|
Student records and directory information
|
NO
|
|
K
. Inferences drawn from collected personal information
|
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
|
NO
|
|
L
. Sensitive personal Information
|
|
NO
|
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
-
Receiving help through our customer support channels;
-
Participation in customer surveys or contests; and
-
Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
-
Category A -
As long as the user has an account with us
-
Category B -
As long as the user has an account with us
-
Category
F
-
As long as the user has an account with us
Sources of Personal Information
How We Use and Share Personal Information
We collect and share your personal information through:
-
Targeting cookies/Marketing cookies
-
Click redirects:
__________
.
-
Social media plugins:
__________
. We use social media features, such as a
'Like'
button, and widgets, such as a
'Share'
button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.
Will your information be shared with anyone else?
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be
'selling'
of your personal information.
We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:
The categories of third parties to whom we sold personal information are:
-
Affiliate Marketing Programs
The categories of third parties to whom we shared personal information with are:
-
Affiliate Marketing Programs
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
-
Right to know whether or not we are processing your personal data
-
Right to access your personal data
-
Right to correct inaccuracies in your personal data
-
Right to request the deletion of your personal data
-
Right to obtain a copy of the personal data you previously shared with us
-
Right to non-discrimination for exercising your rights
-
Right to opt out of the processing of your personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law)
, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (
'profiling'
)
Depending upon the state where you live, you may also have the following rights:
-
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including
California's and Delaware's
privacy law)
-
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
-
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
-
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us
by submitting a
data subject access request
,
by emailing us at
info@scottishgolfnoticeboard.com
,
or by referring to the contact details at the bottom of this document.
You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.
Under certain US state data protection laws, you can designate an
authorised
agent to make a request on your behalf. We may deny a request from an
authorised
agent that does not submit proof that they have been validly
authorised
to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an
authorised
agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at
privacy@scottishgolfnoticeboard.com
. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California
'Shine The Light'
Law
California Civil Code Section 1798.83, also known as the
'Shine The Light'
law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
'Revised'
date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
contact our Data Protection Officer (DPO) by email at
jshapiro@scottishgolfnoticeboard.com
,
by phone at
+441651277000
,
or
contact us by post at:
S G Noticeboard Ltd
Data Protection Officer
North Auchtylair Stuartfield, Peterhead
Stuartfield
,
Scotland
AB42 5EA
United Kingdom
If you are a resident in the United Kingdom, we are the
'data controller'
of your personal information. We have appointed
Jonathan Shapiro
to be our representative in the UK. You can contact them directly regarding our processing of your information
,
by email at
jshapiro@scottishgolfnoticeboard.com
,
by visiting
scottishgolfnoticeboard.com
,
by phone at
+441651277000
,
or by post to:
North Auchtylair
Stuartfield
Peterhead
AB42 5EA
Scotland
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country
or state of residence in the US
, you may
have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please
fill out and submit a
data subject access request
.