At GolfToday, we are strongly committed to your right to privacy and to providing a safe, enjoyable and productive customer experience both off-line and on-line. Our Privacy Policy has been created as to ensure compliance from 25 May 2018 in line with the General Data Protection Regulations (EU) 2016/679, as well as the Data Protection Act 1998 (and any amendment of or replacement for that Act) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (and any amendment of or replacement for those Regulations), as well as any other data protection laws that apply from time to time (together the “Data Protection Laws”).
In this Privacy Policy, references to GolfToday, ‘we’, or ‘us’ or ‘our’ mean Mediadrive Ltd, a company registered in England and Wales, with company number 6753171, with its registered office address at Turnbull House 226 Mulgrave Road, Cheam, Sutton, Surrey, England, SM2 6JT. Golf Today is a data controller in that we determine the purposes and means of the processing of the personal data that we collect and are responsible for your data. We are registered with the Information Commissioner’s Office.
Any questions concerning personal data should be addressed to the Data Protection Officer by email to info@mediadrive.co.uk or by post to 19 Catherine Place, London, SW1E 6DX.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We reserve the right to modify or amend this Policy at any time and will display the effective date at the end of this Policy. Previous versions can be obtained by contacting us.
It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
GolfToday will not give or sell any personal data to any third party companies, organisations or individuals without your prior consent.
This Policy is organised into sections:
- What personal data we collect
- How we use your personal data
- Security and storage
- Your rights
- Sharing your personal data
- Cookies and other tracking technologies
- Third party websites
- Children and young people
- Cookie Policy
1. What personal data we collect
As an online publisher and software service provider, we need to collect certain personal data from you to ensure that we can fulfil the services we provide to you. We will ask for your consent or rely on another legal basis for processing before we process your personal data, in accordance with the Data Protection Laws.
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may collect personal data in the following manners:
Automated technologies: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. Technical data may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions we collect from the devices you use to access our website. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy LINK for further details.
Aggregated Data: We also collect, use and share aggregated data, such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your information about how you use our website, products and services to calculate the percentage of users accessing a specific website feature and to improve our website service using this information. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
2. How we use your Personal Data
When you use GolfToday, we will use any consented personal data to deliver the most relevant advertising experience we can to you. Opting out of targeted and personalising advertising will not mean that adverts will be gone, but you will see less relevant adverts.
If GolfToday expands our service at any point in the future, we will notify all users and require them to re-consent to allowing for additional sharing of information.
Application analytics:
If you use our mobile web version of GolfToday, we may collect additional data to provide the service to you and for us to analyse how to improve the service. Use of Google Analytics may be used to help collate statistical information (further information on our data subprocessors below), which may include device id & location, you can decline this request.
For other lawful purposes:
We will use your personal data for such other lawful purposes as are permitted under the Data Protection Laws and we will always obtain consent where required.
3. Security and storage
We take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. This includes, as appropriate: the pseudonymisation and encryption of personal data; the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
The information that you provide to us will be held securely in our systems of an appointed third party hosting company. We will only allow access to your personal data by third parties who act for us for the purposes described in this privacy policy for the delivery and service of the site, or for other purposes approved by you.
We will only retain your personal data for as long as is appropriate and necessary to the fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, taking into account the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, and whether we can achieve those purposes through other means. We will limit the period for which personal data is stored to a minimum. We will set time limits for erasure or periodic review. You may request details of our retention policy and in addition, you have a right to have your personal data restricted or erased – see more details under “Your Rights” below.
4. Your rights
Your rights under the Data Protection Laws in relation to your personal data include (but are not limited to) the following:
You have the legal right to ask us to supply you with a copy of the personal data that we hold about you at any time free of charge. Further copies may incur a reasonable fee and also if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances).
Where you have given your consent to our processing your data, you have the right to withdraw your consent at any time. If you withdraw your consent and there is no other legal ground for us to process your data, you can ask us to erase your personal data. You can also require us to erase your data if we have processed your data unlawfully or if the law requires us to erase your data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You may also restrict the processing of your data: This enables you to ask us to suspend the processing of your personal data if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
5. Sharing your Personal Data
We will share your personal data with suppliers or other third parties only on the legal basis indicated in this Privacy Policy to provide services and functionality as outlined in this Privacy Policy. Our “third party data processors” (such as our fulfilment partners, hosting providers, digital agencies, data storage providers and advertising partners) help us administer and delivery the services to this website, and may have access to your data which is submitted for processing as indicated in this Privacy Policy through legitimate and consented interests as well as legal basis.
Transfers outside of the EEA: Where we need to transfer your data to a third party supplier or service provider based in a country located outside of the EEA, for the purposes of the third party providing us with a service, we will ensure that either the country to which the data is to be transferred has an adequate level of protection for data (as determined by the European Commission) or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe or where a supplier or service provider is based in the US, we may transfer data to them if they have certified to the Privacy Shield Framework Principles which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will share your personal data with any member of our group of companies (which means our subsidiaries, our holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) for internal administrative purposes including processing of personal data on the basis of being in our legitimate and consented interests to do so. We ensure that our group companies follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
If the shares in GolfToday or substantially all of our assets are sold to a third party, your personal data may be disclosed to the prospective buyer during the sale negotiations and on conclusion of the sale will be transferred as a company asset to the third party. This is necessary for our legitimate interests to be able to sell the company or its assets in the future, provided that we take all appropriate steps to keep your personal data confidential and secure at all times in accordance with this Policy and the Data Protection Laws, including requiring the third party to sign a confidentiality and non-disclosure agreement.
Other than as previously stated, we will only disclose or share your personal data if necessary to comply with any legal obligation or in order to enforce or apply our Terms of Use and other agreements with you, or to protect the rights, property or safety of GolfToday, our customers or others.
6. Cookies and other tracking technologies
We use cookies and other tracking technologies on our site. These allow you to use our site effectively, as well as give us information about your use of our site which we use to develop and improve our site. The cookies and tracking technologies in operation are for our legitimate interest to provide our site services, content and relevant advertising to you to allow us to run the site effectively, securely and to enhance and improve. A list of all the cookies that we use and what we use them for are set out in our Cookies Policy Link. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
7. Third party websites
Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Mediadrive Ltd is a controller of personal information. If you have any queries in relation to data protection, please email us at info@mediadrive.co.uk
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
8. Children and young people
When considering targeting marketing at children, we abide by the ICO rerecommendations, as outlined on the ico.org.uk, and we take into account their reduced ability to recognise and critically assess the purposes behind the processing and the potential consequences of providing their personal data. We take into account sector specific guidance on marketing, such as that issued by the Advertising Standards Authority, to make sure that children’s personal data is not used in a way that might lead to their exploitation. We stop processing a child’s personal data for the purposes of direct marketing if they ask us to. We comply with the direct marketing requirements of the Privacy and Electronic Communications Regulations (PECR).
Children under the age of 13 are not eligible to use our services and we do not knowingly collect personal information from those under 13.
Parents and guardians of under 13s are advised to contact us, info@golftoday.co.uk, if they believe we have collected any information illegitimately.
9. Cookie Policy
What Are Cookies?
Cookies are small pieces of data stored within your browser or device that assist us in providing a more customised web site experience, specific functions and some personalisation.
Cookies are stored by the browser or device and allow data to be stored and sent between a web server to a web browser. This allows a web server to identify and track the web browser for any individual user and are required for some uses such as logging into a website and storing user settings in relation to a web service or application.
You can choose to refuse or delete cookies by altering your browser preferences. If you choose to do so, then most of the site’s pages should still work fully in your browser.
GolfToday Cookie Use
GolfToday.co.uk use both session based cookies and persistent cookies. Session cookies are used to analyse browsing behaviour and end when the browser is closed or the website left.. Persistent cookies are used by us and third parties to monitor and track some activity GolfToday site options and digital advertising and will remain stored on your computer until deleted or once expired.
Why We Collect Data
Collecting data allows us to understand what your needs are when visiting the site and allows us to provide personalised content and match the most relevant adverts and services for you. It also allows us to provide targeted offers and services you may be interested to hear about.
Cookies & Tagging
By accessing GolfToday.co.uk we may send you a cookie to enhance your experience on the site directly from us or a 3rd party service.
What Types of Cookies are Used?
- Strictly Required Essential Cookies
Essential cookies are required to use GolfToday.co.uk. Some strictly essential cookies maybe used to save your preferences when visiting the site. - Functionality Cookies
Functional cookies are required when using GolfToday.co.uk in order for us to enhance and protect our services to you, the end user. - Performance & Analytical Cookies
Analytical cookies are used to monitor our websites performance and how it is used and provide us with information that helps us provide better products to users of the site and identify any areas that may need maintenance. Performance based cookies in use are provided by Google Analytics. - Behavioural Online Advertising Cookies/Third Party Cookies
These cookies include cookies from ourselves, advertisers/sponsors and provide tailored advertising to you which we believe are relevant to you.
We also include third party plugins which utilise cookies to enhance your experience including use of Facebook, Twitter and Google cookies. These allow you to interact with third party services through the GolfToday.co.uk website.
What are tagging technologies?
Tagging works in a similar way to cookies using a tag known as a pixel, sometimes called beacons. A pixel is an image that will be embedded on our site or within an email and allows us to determine customer interest in relation to our website. This then allows us to optimise the experience for you providing more relevant content, promotions or advertising.
Cookies and similar technology used by us are listed below.
Company/Cookie Purpose
GolfToday Web service delivery
- Google Analytics Analytics, monitoring and ad delivery Privacy Policy
- Facebook Analytics of social interaction and website use Privacy Policy
- Twitter Analytics of social interaction and website use Privacy Policy
- Linkedin Analytics of social interaction and website use Privacy Policy
- Adtech Advertising and targetting Cookie Policy
Can I Control Which Cookies Are Used?
Yes, you can control which cookies you allow or decline through your browser settings. GolfToday will also provide an online preference tool for this specific to our website.
If you do choose to alter your browser settings to control the cookies that you receive then some parts of our site may not function as intended. You can control your cookie settings through the browser tools, the following link may provide useful information:
- Firefox Cookie settings
- Safari Cookie settings
- Safari iOS Cookie settings
- Android Cookie settings
- Internet Explorer Cookie settings
- Chrome Cookie settings
- Microsoft Edge Cookie settings
By using GolfToday.co.uk you agree to the use and collection of information as outlined above and to our Terms and Conditions Link. Changes to this policy may occur in the future and will be posted here so that you are aware of any amendments.