Our website
This website is an ecommerce platform which enables you to purchase products from the website. We work with various partners (sellers) to provide you with a wide range of products to fulfil your golfing needs.
This privacy policy sets out how Hole19 uses and protects any information that you give Hole19, when you use our platform. Hole19 is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our platform, it will only be used in accordance with this privacy statement and pursuant to the Data Protection Act 2018, UK GDPR and EU GDPR (“Data Protection Laws”).
Controller for personal data
A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. For the purpose of this website and where you have a direct relationship with us, we act as the controller of personal data.
Joint controllers
We also act as joint controllers with our partners (sellers) in circumstances such as where you as a buyer purchase products with our third-party affiliates on our platform and we share information with one another to carry out your order.
Scope
This privacy policy applies to the processing of personal data by us in connection with any:
- Individuals who purchase products on our platform.
- Partners (sellers) on our platform.
- Suppliers who provide products and services to us as service providers.
- Visitors who enter our website.
Links to other websites
Our website may contain links to other websites for example external links to third-party affiliates (such as the partner’s (seller’s) external website). Once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Types of personal data
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.
We may collect, use, store and transfer different kinds of personal data about you depending on your relationship with us which we have grouped together:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details for the provision of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
How we collect your personal data
Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.
From use of our website
We gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice for more information.
Indirectly: Third-party sources: We can receive Identity Data or Contact Data about you from third parties when:
- other parties send us your personal data to enable the provision of those service.
- you provide your personal data to a third party for the purpose of sharing it with us.
Providing personal data
Where we need to collect personal data by law or under the terms and conditions we have with you and you do not provide that information when requested we may not be able to perform the service we have or are trying to enter into with you for example to fulfil your order transaction on our platform. In this case we may have to cancel our service but we will notify you if this is the case at the time.
How we use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.
- Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
- Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at shop@hole19golf.com to withdraw consent. Please also see Marketing communications.
Purposes for which we will use your personal data
We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity:
To perform our services to you when you make purchases on our site.
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests so we can provide the technicalities to the partner (seller) to carry out your order.
Purpose/Activity:
To respond to any enquires
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests where you contact us directly.
Purpose/Activity:
To process and deliver our services to you including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us.
Type of data:
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interest so we can assist the partner (seller) to carry out your order.
(b) Necessary for our legitimate interests i.e., to recover debts due to us.
Purpose/Activity:
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or provide us with feedback.
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests i.e., to keep our records updated and to study how customers use our products/services.
Purpose/Activity:
To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Type of data:
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation.
Purpose/Activity:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests i.e., to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data:
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice
Purpose/Activity:
To make suggestions and recommendations to you about our services that may be of interest to you.
Type of data:
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests to develop our products/services and grow our business.
Marketing communications
We may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact Us.
Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.
How we share your personal data
We do not and will not sell any of your personal data to any third party, including your name, contact information or payment information. We may have to share your personal data with the parties set out below:
- Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.
- Partners (sellers): Where you purchase a product on the website, these products can come from our third-party partners. They will only contact you to process your order.
- Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
- Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
- Advertising networks and analytics service providers: This is to support and display ads on our website and other social media tools.
- Third parties in connection with sale: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy policy.
International transfers
We may transfer and process your personal data outside of the United Kingdom/European Union to countries where data protection laws are less stringent than those in the UK/EU When we transfer your personal data outside of the UK/ EU we only do so to entities that offer our users the same level of data protection as that afforded by the UK Data Protection Act 2018, UK GDPR and the EU GDPR.
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
- We will use specific contracts approved for use in the UK or EU which give personal information the same protection it has in the UK/EU. For example, the use of Article 46 UK and EU GDPR safeguard mechanisms to transfer personal data endorsed by the UK Government or European Commission.
To find out more about the transfer mechanism used please contact us at shop@hole19golf.com.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Company name cannot guarantee the security of your information transmitted and any transmission is at your own risk.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.
We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Data Subject Rights
Where we act as a controller you have rights under Data Protection Laws. Some of these rights are not absolute. You can:
Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.
Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in certain circumstances such as if you want us to establish the information's accuracy or where our use of the information is unlawful but you do not want us to erase it.
Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making.
Carrying out your data subject rights
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us at shop@hole19golf.com
Concerns and complaints
We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.
Changes to our privacy policy
This privacy policy may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy policy. We will obtain your consent to any material privacy policy changes if and where this is required by applicable Data Protection Laws.
Contact us
If you would like more information about the way we manage personal information that we hold about you please contact us at:
shop@hole19golf.com
This version was last updated on 15 December 2023.
COOKIES NOTICE
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device.
Use of Cookies
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Strictly necessary cookies do not require your consent (opt-in).
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences, for example, your choice of language or region.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Terminology to help you understand cookies
First and Third-party cookies
First-party cookies are cookies set by our website, i.e. the website displayed in your URL window.
Third-party cookies are cookies that are set by a domain other than our website. We may use third parties’ cookies and these third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. Please see our cookies table for more information.
Session and Persistent cookies
Session cookies are cookies which expire once you close your web browser. Persistent cookies are cookies which stay on your device for a set period of time or until you delete them. Please see our cookies table for more information.
Cookies control and disabling cookies
You can refuse the use of cookies by changing the settings on your browser or by clicking on the cookies consent mechanism. However, if you block certain cookies, such as strictly necessary cookies for the functioning of our website, you may not be able to access all or parts of our website.
You can use your browser to delete cookies that have already been stored. However, the steps and measures required vary depending on the browser you use. If you have any questions, please use the Help function or consult the documentation for your browser or contact its creator for support.
To find out more about cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
Contact
Thank you for reading our Cookie Notice. If you have any queries concerning our use of your personal information, please email shop@hole19golf.com.
Cookie: Google Analytics
Name: _ga _gat
First or Third Party: Third party
Purpose: These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website.
Type: Persistent
Expiry: 2 years
Privacy Notice: https://privacy.google.com/?hl=en#
Name: EP_CartId
First or Third Party: First Party
Purpose: Storage - Persist cart data when changing pages
Type: Local
Name: EP_bearerToken
First or Third Party: First Party
Purpose: Storage - Make connections to EP API
Type: Local
Name: EP_bearerTokenExpiration
First or Third Party: First Party
Purpose: Storage - Expiration for token. Request new token when expired
Type: Local
Name: productURLs
First or Third Party: First Party
Purpose: Storage - Cart redirecting correctly to product webpages on product name click
Type: Local
Name: unstack_sid
First or Third Party: First Party
Purpose: Storage - Used in django sessions
Type: Local
Name: kla_viewed
First or Third Party: Third Party
Purpose: Storage - Klaviyo
Type: Local
Privacy Notice: https://www.klaviyo.com/legal/privacy/privacy-notice
Name: acs_rvd
First or Third Party: Third Party
Purpose: Storage - Hole19 specific searching
Type: Local
Privacy Notice: https://advancedcommerce.io/privacy-policy/
Name: acs_uid
First or Third Party: Third Party
Purpose: Storage - Hole19 specific searching
Type: Local
Privacy Notice: https://advancedcommerce.io/privacy-policy/
Name: sessionid
First or Third Party: First Party
Purpose: Storage - Backend tooling for a user session
Type: Session
Name: acceptGDPRScripts
First or Third Party: First Party
Purpose: Storage - Popup mini-modal which disables GDPR/cookies for users who opt out
Type: Session
Name: csrfToken
First or Third Party: First Party
Purpose: Token - Security measure used to protect against CSRF attacks
Type: Temporary
