This privacy policy applies to the processing of data at Golf Novo Sancti Petri. Please read it carefully because it contains important information about the processing of your personal data and the rights to which you are entitled in current data protection legislation. This policy is published on http://www.clubgolfrealnovosanctipetri.com/ and grupoiberostar.com/portal-privacidad and it can also be consulted in the Golf Club’s reception area where you can ask for a copy to keep. As a general rule, any fields on our forms that are marked compulsory must be completed for your corresponding request to be processed.

1. Who is the body responsible for processing your data?

The body responsible for processing data relating to members and users of Golf Novo Sancti Petri is Golf Novo Sancti Petri, S.A., with address at Urbanización Novo Sancti Petri, Casa Club, Chiclana de la Frontera, Cadiz (henceforth the GOLF CLUB). Iberostar Group’s Data Protection Delegate can be contacted at this e-mail address: privacy.dpd@grupoiberostar.com.

2. What personal data do we gather?

The processed data is gathered from: The forms that you fill in and requests you make, such as bookings, entries in competitions or requests for services. Supplied information for entry in competitions or to hire our services. Information generated as a result of your entry in competitions or the provision of the above services. All the said data is supplied either directly by yourself or by third parties dealing with requests on your behalf. The typical kinds of data that we process consist of: Identification and contact details, your ID card or passport number, and signature; Personal details, such as your sex, place and date of birth, nationality, family status and language; Data of a financial or transactional nature; Data relating to your handicap, place in the ranks or participation in competitions, courses and events; If, through previous contact with Iberostar Group, you authorized your data to be used for the creation of marketing profiles, we will be able to access your customer record to offer you customized service and attention.

3. For what purpose will your data be processed?

Our members’ data is processed for company management purposes, to fulfil the company’s corporate purpose and to meet our legal obligations. Data pertaining to the Golf Club’s users will be processed to manage bookings, to supply hired services, for the management of the Golf Club, golf course and competitions, and for compliance with the company’s legal obligations. Data pertaining to our members and users will also be processed for statistical and historical purposes, to improve the quality of our services and to keep members and users informed of news, events and special offers by the Golf Club, including by electronic and telephonic means. This data will also be processed by Iberostar Hoteles & Apartamentos, S.L. for Iberostar Group’s internal administration purposes and for statistical and quality assessment reasons. This includes analyses of consolidated online booking data managed through the website and the administration of opinion surveys, even though answering them is optional.

4. To whom can your data be disclosed?

Your data will only be disclosed to third parties when this is necessary for the provision of requested services or for your entry in competitions. It will only be disclosed to other companies from the group for administrative purposes in compliance with legal obligations or with your prior consent. Data pertaining to members may be disclosed to the tax authorities, other bodies from the public administration, and public registry offices and/or notaries. To ensure that tournaments are properly organized and publicized, data relating to your participation and place in the ranks shall be disclosed to the media when requested by the latter and published on websites, in newsletters or on the Golf Club’s notice boards. This information shall also be disclosed to the Spanish Royal Golfing Federation (Real Federación Española de Golf) for the control and administration of the handicaps of affiliated Federation members, the results and classifications of golfing competitions, and the federation members’ performance record sheet. Data needed to process the exams of students enrolled at the golf academy and their corresponding handicap shall also be disclosed to the Spanish Royal Golfing Federation. The disclosure of all the above information is essential for entry in competitions or to process exams or handicaps.

5. Lawful basis for processing the data

Your data shall be processed in order to enforce your contractual agreement with the Golf Club and in order to comply with its legal obligations, particularly in matters concerning the applicable accounting and tax legislation. The legal basis for any statistical activities or quality surveys that are conducted is to evaluate our services. Likewise, the legal ground for sending sales information is to promote the said services, with your consent to receive such e-mail messages. The lawful basis for analysing consolidated customer data and carrying out statistical and quality control activities at a group level is Iberostar Group’s legitimate interest in doing so for internal administration purposes and for evaluating its services.

6. How long will we keep your data?

Data relating to members and users of the Golf Club shall be kept as long as the relationship with the latter lasts and, in all circumstances, as per the retention periods established in the applicable legislation and as long as is necessary to meet any possible liabilities arising from the processing of the said data. We will delete your data when this information is no longer necessary or pertinent for the purposes for which it was originally gathered. Competition records shall be kept as part of Real Novo Sancti Petri Golf Club’s historical archives. Data processed for sales purposes shall be kept on record provided that its deletion is not requested.

7. What are your rights?

You have a right to be told whether your personal data is being processed and, in such an event, a right of access to it. Likewise, you are entitled to ask for your data to be rectified if it is not accurate, to request its completion if information is missing, and to ask for its deletion when, for instance, the data is no longer necessary for the purposes for which it was gathered. In certain circumstances, you may ask for restrictions to be imposed on the processing of your data. In such an event, we shall only process the data to establish, exercise or defend claims or to protect other persons’ rights. Under certain conditions and for reasons relating to your own specific circumstances, you may also object to the processing of your data. In this case, we shall stop processing it unless compelling legal reasons prevail over your interests or rights and freedoms or there is a need for the establishment, exercise or defence of claims. Notwithstanding the above, you may, at any time, withdraw the consent you gave for certain activities to be performed and object to your data being processed for direct marketing purposes, including the drawing up of marketing profiles. In such an event, we shall stop processing your personal data for such means. The withdrawal of your consent shall not affect the legality of data processed with your consent, prior to its withdrawal. Similarly, under certain conditions, you may request the portability of your data so that it is transferred to another body in charge of processing it. Likewise, you may file a claim with the Spanish Data Protection Agency or any other competent control body. To exercise your rights, you must send us a request accompanied by a copy of your national identity document, or another valid document that identifies you, by post or email to our data protection officer at C/ General Riera 154, 07010 Palma de Mallorca, Illes Baleares, Spain or to the email address given in the “Who is the body responsible for processing your data?” section. To withdraw your consent for us to send you communications, email us at: lopd.golf.novosanctipetri@iberostar.com. For further information about your rights and how to exercise them, see the pertinent web page of the Spanish Data Protection Agency at http://www.agpd.es.