Privacy Notice

PGA European Tour Privacy Notice

Introduction


The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. GDPR does not apply to information already in the public domain.

PGA European Tour (PGAET) takes your privacy seriously and we are committed to protecting your personal information.

This Privacy Notice applies to personal data (i.e. information concerning any living person (Data Subject)) held by members of the PGAET group of companies (PGAET Group) as data controllers that is not already in the public domain. It explains what personal information we collect, how we collect and use that personal information, with whom we will share it, why and in what circumstances.

The PGAET Group is pleased to provide the following Privacy Notice which covers the PGAET Group, its websites, mobile applications and mobile websites (Platforms) except where you are notified of another privacy notice or policy by the specific PGAET Group entity which collects your personal information.

The address for PGAET (a company incorporated in England and Wales under number 1867610) is PGA European Tour, Wentworth Drive, Virginia Water, Surrey GU25 4LX. If you would like to get in touch with us, you can also find contact details in the ‘How to Contact Us’ section below.

You might find external links to third party websites on our Platforms and those websites may have their own privacy notices which are different to this Privacy Notice. Our Privacy Notice does not apply to your use of a third party site and you should therefore make sure that you are comfortable with their privacy notices prior to using those sites.
 
Personal Data

The PGAET Group uses the information collected from you to provide such organisational services as you request from us. In using our services you consent to the PGAET Group maintaining a dialogue with you until you either opt out (which you can do at any stage) or we decide to desist from promoting our services.

The type of information that we may collect will differ depending on the type of service we are offering or the request you make of us. Such information may include your:

•    name
•    title
•    date of birth
•    address
•    contact details (including email address and/or telephone/mobile number)
•    gender
•    booking reference
•    payment card details



The PGAET Group will only collect the information necessary so that it can provide you with its organisational services.

In order to meet its  legal obligations, PGAET utilises the following third parties:

Organisation / Service Description
Eventbrite - Selling of tickets for PGAET tournaments
Fanatics - Selling of merchandise via in store, online or telesales methods on behalf of PGAET

PGAET will ensure that each such third party organisation is contractually obliged to be GDPR compliant.

Cookies

Our Platforms use cookies. A “cookie” is a small computer file that is downloaded to your device that enables a web server to collect information from your web browser. It collects information as to how you navigate our Platforms and helps us to identify you, to make your visit to our Platforms more enjoyable by personalising your visit by customising our web pages for you, and to build up a demographic profile. For more information on cookies and how to manage cookie settings, please go to our Cookie Policy.
 
Legal Basis for Processing Personal Data

We will only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis for doing so. This may be because:

•    we need to use your personal information to take steps to enter into a contract with you or to meet our contractual obligations to you
•    we need to use your personal information to respond to marketing or other enquiries from you
•    we need to use your personal information to pursue our legitimate interests as a commercial organisation
•    we have your consent to using your personal information for a particular activity (for example, where you have consented to us sharing with you marketing or promotional communications from members of the PGAET Group and/or its official partners, sponsors, suppliers or licensees which we think may be of interest). 

Consent

You may withdraw your consent to the processing of your personal information at any time by contacting our Data Privacy Officer (see the ‘How to Contact Us’ section below).

Disclosure


The PGAET Group may, on occasion, pass your personal data to third parties exclusively to process such data on our behalf. We require any such third parties to agree to process your personal information based on our instructions and requirements consistent with this Privacy Notice and the GDPR.

We do not broker or pass on information gained from your engagement with us without your specific consent to do so. Notwithstanding the foregoing, we may disclose your personal information to meet our legal obligations, to comply with applicable regulations or a valid governmental request, in order to enforce or apply the terms of use of any of the Platforms or other agreements, or to protect the rights, property or safety of the members of the PGAET Group, our partners, customers and/or others.

Retention Policy

Members of the PGAET Group will only retain your personal information for as long as is reasonably necessary for the purposes for which it was collected and in line with our data retention policy. For example, we will normally keep contractual information for a period of ten years after the expiry of any such contract so that, if we need to establish, exercise or defend our legal interests, we may deal with any dispute or concerns that may arise.

Data Storage

Your personal information will be held by the PGAET Group within the European Economic Area (EEA) only, be this on-premise or in cloud services.

Your Rights as a Data Subject

At any point whilst a member of the PGAET Group holds your personal information, you have a number of rights available to you, including the following:

•    Right of access – you have the right to access a copy of the information that we hold about you and to obtain information about how we process it
•    Right of rectification – you have a right to request that we correct data that we hold about you if it is inaccurate or incomplete
•    Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
•    Right to restriction of processing – where certain conditions apply you have a right to request that we restrict the processing of your information
•    Right of portability – you have the right to have the data we hold about you provided to you in an electronic format and/or to request that it is transferred to another organisation
•    Right to object – you have the right to object to certain types of processing such as direct marketing
•    Right to object to automated processing, including profiling – you also have the right not to be subject to a decision based solely on automated processing (including profiling) which adversely affects your legal rights

You can exercise these rights in the first instance by contacting our Data Privacy Officer (see ‘How to Contact Us’ section below). Should you wish to do so, we will require you to provide additional information to confirm your identity as follows:

•    One piece of photographic identification (e.g. passport, other national identity card or photocard driving licence) and
•    One proof of address (e.g. utility bill dated within the last 3 months)

We will advise you promptly if we require further information in order to fulfil your request.


Further to the rights set out above, you can request the following information from us:

•    The identity and the contact details of the person or organisation that has determined how and why to process your data
•    Contact details of our Data Privacy Officer, where applicable
•    The purpose of the processing as well as the legal basis for processing
•    If the processing is based on the legitimate interests of PGAET or a third party such as one of its clients, information about those interests
•    The categories of personal data collected, stored and processed
•    Recipient(s) or categories of recipients that your data is/will be disclosed/transferred to
•    How long your data will be stored for
•    Details of your rights to correct or erase your personal data and your rights to restrict or object to the processing of your data
•    Information about your right to withdraw consent at any time
•    How to lodge a complaint with the data protection regulator in the country where you live
•    The source of personal data if it was not collected directly from you
•    Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

Updates

We may amend this Privacy Notice from time to time to keep it up to date with legal requirements, best practice and/or the way we operate our business. If we decide to change our Privacy Notice we will place any updates on this webpage and the privacy sections of any relevant Platforms. Please therefore check this page and the privacy sections of any relevant Platforms periodically in order to view the latest version of our Privacy Notice.

How to Contact Us

The primary point of contact for all issues arising from this Privacy Notice is our Data Privacy Officer, who can be contacted by email at: dataprotection@europeantour.com

or by post at:

Data Privacy Officer
European Tour
Wentworth Drive
Virginia Water
Surrey
GU25 4LX

In the event that you have any questions, concerns or wish to make a compliant about how your personal data is being processed or regarding our compliance with this Privacy Notice, we would encourage you to contact our Data Privacy Officer in the first instance. We will investigate and attempt to resolve complaints and disputes as quickly as possible. If you do not get a response within 30 days you can complain to the Data Protection Regulator (the Information Commissioner’s Office).


May 2018

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