This website is managed by Albatross Digital Golf Ltd on behalf of the Hoburne and Burry and Knight Groups.
This Policy applies to any personal information you give to us. Please use the Glossary at the end of this privacy notice to understand the meaning of some of the terms used in this notice.
We may make changes to this Policy. If we make changes, we consider important, we may notify you by email. This Policy was last updated on 1st September 2022.
1. Important information and who we are
Hoburne Ltd, a limited company registered in England and Wales. Registered number 1102096. Our registered office is 10 Hoburne Lane, Highcliffe, Christchurch, Dorset, BH23 4HP, United Kingdom.
Burry and Knight Ltd is a limited company registered in England and Wales. Registered number 00552582. Our registered office is 10 Hoburne Lane, Highcliffe, Christchurch, Dorset, BH23 4HP, United Kingdom.
For the purpose of the Data Protection Act 2018 the data controllers are Hoburne Ltd and Burry and Knight Ltd. Hoburne Ltd is registered with the Information Commissioner’s Office, registered number Z5904273.
Burry and Knight Ltd is registered with the Information Commissioner’s Office, registered number Z5904165.
Purpose of this privacy notice
This privacy notice aims to give you information about how The Hoburne and Burry and Knight Groups collects and processes your personal data through either your use of our websites and/or services or your supply of goods and/or services to us (as appropriate).
Employees should also refer to the Hoburne Employee Privacy Notice which can be found on the intranet or requested from firstname.lastname@example.org and the Data Protection Policy.
How to contact us
For any questions or concerns about how we use your personal data send an email to email@example.com or write to our registered office, care of the IT department or use the contact us form on our websites.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Occasionally, we may amend this notice and the changes will come into effect from the date it is amended on this page. The notice was last updated on the 1st September 2022.
2. The data we collect about you
Personal information means any information relating to an identified or identifiable natural person; an identifiable 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, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. It does not include data where the identity has been removed (anonymous data).
We collect, use, disclose, transfer, and store personal information when needed to provide our products and services and for our operational and business purposes as described in this Policy. We want to be clear about our privacy practices so that you can make informed choices about the use of your information. We have grouped together the various data categories as follows:
• Identity Data includes first name, maiden name (if required), last name, marital status, title, date of birth and gender.
• Contact Data includes billing address (if required), delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details (as required).
• Transaction Data includes details about payments to and from you and other details of products and 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.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please see below in the privacy notice for the Special categories of personal data that we may collect in certain circumstances.
We do not target our products and services at children under the age of 17.
We will only collect limited personal information about children under the age of 17 such as their name, age, a postal address or telephone number.
Personal informal collected about children under the age of 17 is used solely by Hoburne or third parties which deliver technical services to Hoburne such improving our websites, fulfilling requests, or delivering a prize promotion.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. Your interactions with us may result in personal data being created. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our https://www.hoburnegolf.com/ for further information.
• Third parties or publicly available sources. We may combine information provided by you with information available from external, publicly available sources in order to get a better understanding of our customers and audiences and to improve our products, services and marketing methods. We will receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:
a) analytics providers;
b) advertising networks; and
c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services. This includes personal data obtained from a credit reference agency if you are purchasing goods or services from us using finance or from an affiliate if you are introduced to us by a third party.
4. How we will use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal obligation.
Please see the Glossary at the end of this privacy notice to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us and further details are available below.
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 in the table below.
Special categories of personal data
There are certain circumstances when we collect and process special categories of data which is limited to precise geographic location, information about your health, financial and bank account numbers or unique identifiers such as driver’s licence, and passport numbers. We may also ask you to provide us with information about your health, including any medication condition, health and sickness records. We will do this if:
(a) It is necessary for the performance of a contract with you;
(b) It is necessary to comply with a legal obligation; and/or
(c) It is necessary for our legitimate interests.
We will do this to keep you healthy and safe at the club, to comply with health and safety obligations, and for reasons of public health. We do not need your consent to use information about your health in this way.
In limited circumstances, we may approach you for your written consent to allow us to process certain special category data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
We will not use your data for any purpose other than for which it is sought. We have internal policies and controls in place to ensure that special categories of personal data is not misused, disclosed or accessed except by our employees in the proper performance of their duties.
We may use CCTV on our clubs for the purpose of safety and crime prevention.
Marketing and promotional offers from us
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
To opt out of email marketing you can use the unsubscribe link found in the email communication you receive from us. For other marketing you may email, write or call to let us know you do not wish to receive marketing communications. If you are a member you may manage this through the Subscription Centre online.
firstname.lastname@example.org , Crane Valley Golf Club, The Clubhouse, Verwood, Dorset, BH31 7LH
If you have previously told us that you do not wish to receive marketing communications from us and then subsequently purchase another product and service from us, such as making a booking online, we may recommence sending you marketing communications until you tell us you do not wish to receive them.
Our Chat Bot service allows users to make enquiries with us from a ‘bot’ (or automated service).
If you use the Chat Bot, the Chat Bot will share the data with us which will allow us to respond to your enquiry. It is necessary for you to share your personal data with the Chat Bot with us to use the service.
We retain the contents of the chats for one month to respond to you and for training and analysis. We also hold statistical information about the Chat Bot service, but this does not contain any personal data.
We use a third party, Albatross, to provide technical support for the Chat Bot.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above:
• External Third Parties as set out in the Glossary below.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Within the Hoburne Group
We may share and aggregate information about you from across companies within the Hoburne Group. Businesses operated by companies in the Hoburne Group include:
Personal information will be made available to our group companies if it necessary for the provision of products and services, account administration, sales and marketing, customer and technical support, and business and product development. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.
Any of our companies may send you marketing communications, but you may opt out of receiving marketing communications from one or all of our businesses at any time.
Our business partners
We occasionally partner with other organisations to deliver cobranded products or services. As part of these arrangements, you may be a customer of both Hoburne and our partners, and we and our partners may collect and share information about you. We will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information.
Where we store and process personal information
Your personal information may be stored and processed outside of the UK. We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located. Please see below.
6. International transfers
We collaborate with third parties such as cloud hosting providers located around the world so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For example, we use contractual clauses designed to ensure that the recipients of your personal information protect it. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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. Please see below:
• We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data.
• We have a business continuity and disaster recovery strategy that is designed to safeguard the continuity of our services and protect our people and assets.
• We place appropriate restrictions on access to personal information.
• We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely.
• We require privacy for our employees and contractors who have access to personal information.
• We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see the section Your legal rights below for further information.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us. You have the right to:
Access to personal information of your personal data
This is commonly known as a “data subject access request”. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We will only charge a fee for providing you with a copy of your data where the request will require an unusually large amount of work by us.
Correction and deletion of your personal data
You have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements. You can update your account information on our website.
Object to processing of your personal data.
This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process
your personal data
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
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. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• External Third Parties:
o Service providers acting as processors based around the world who provide IT, system administration, our Chat Bot, payment card processors and similar services.
o Services to fulfil our charitable objectives such as a printing services, marketing agencies, research firms and data disposal specialists.
o Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
o The Police, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.