Privacy and Cookie Policy
Last updated August 2021
Introduction
This privacy and cookies policy ("Privacy Policy") details data used on
www.acegolf.io (the "Website"), the Ace Golf Customer mobile application
software, the Ace Golf Pro App (golf professional calendar and
management tool) application software and website and the Ace Golf Admin
(golf school management app) application software and website which are
available for download from iTunes and Google Play (the "Apps") and the
web interfaces, also powered by Ace Golf, embedded on Partner Sites and
on our golf pro- course- or school partners (“Partners”)’ own website
and social media pages, through which customers can make bookings
directly with Partners at widget.acegolf.io (the “Widgets”) (together,
the “Platform”).
The data controller for your information is Ace Golf B.V (registered
address: Ruyschstraat 331, 1091 MR Amsterdam, Nederland) ("Ace Golf",
"we", "our" or "us"). You can write to us at: Ruyschstraat 331, 1091 MR
Amsterdam Amsterdam, the Netherlands or email us on:info@acegolf.io
Ace Golf B.V. shares your personal information with other entities in
its corporate group (“Group Companies”) for the purposes described in
this notice. The Group Companies also process your personal data as data
controllers as necessary for the purposes described in this notice. The
Group Companies are listed in the section of this Privacy Policy called
“Sharing personal information with third parties”, along with their
contact details.
We are committed to protecting the privacy of our users and customers.
This Privacy Policy is intended to inform you how we gather, define, and
use information that could identify you, such as your name, email
address, address, other contact details or online identifiers, other
information that you provide to us when using the Platform ("Personal
Information") and also what Cookies we use. Please take a moment to read
this Privacy Policy carefully.
What information do we collect?
When you visit and/or use our Platform or contact us, we may collect the
following information:
- Personal Information that you choose to share with us when you
register for an account, subscribe to emails, newsletters and alerts
and which you provide to us when using our services, including
information entered into our booking platform and included in your
comments, reviews or survey responses. In the course of making a
booking or submitting reviews, you might voluntarily provide us with
sensitive personal data if relevant to the service that you are
requesting or reviewing (relating to your health or ethnicity, for
example).
- Personal Information that you share with us as part of an application
for a job at Ace Golf, submitted either directly on the Websites or
indirectly, including but not limited to, via a recruitment agency,
unsolicited application or third-party recruitment platform. In the
course of making an application you may choose to voluntarily provide
us with sensitive personal data relating to whether reasonable
adjustments ought to be made for you in the application process or
subsequently if an employment relationship is established. However,
you must not share any sensitive personal data with us that would not
be necessary for us to make reasonable adjustments for you, e.g.
political opinions, religious beliefs or specific information on your
state of health.
- Where you are utilising our online payment facility, we may store (via
ourselves or our appointed payment processor) your credit and debit
card details on a secure encrypted basis.
- If you choose to communicate with us (for example, through the
Platform, email, telephone, SMS, or social media) we will record the
fact that you have contacted us and may retain the content of your
communication, together with your contact details and our responses.
- Information about your visits to and use of the Platform, such as
information about the device and browser you are using, your IP
address and location, your identifier for advertisers (IDFA), the date
and time that you visited, the duration of your visit, the referral
source and website navigation paths of your visit and your
interactions on the Platform including the salons and treatments you
are interested in. Please note that we may associate this information
with your Ace Golf account. Please see the cookies section of this
Privacy Policy for further information on the purposes for which we
collect and use this information.
It is important that all the Personal Information you give us when you
register as a user or otherwise when you use the Platform is correct and
accurate. This includes, by way of example only, ensuring that we have
your correct contact (including email) details at all times.
If you plan to submit someone else's Personal Information to us, for
instance when making a booking on their behalf, you should only provide
us with that third party's details with their consent and after they
have been given access to information about how we will use their
details, including the purposes set out in this Privacy Policy.
Protecting your personal information
The transmission of information via the internet is not completely
secure. So, whilst we will do our best to protect your Personal
Information, we cannot guarantee the security of your data transmitted
to our Platform. Any transmission is at your own risk. Once we have
received your Personal Information we will use strict procedures and
security features in relation to that data.
How do we use your personal information?
In general terms, we use Personal Information to provide you with the
services and products you request, process payment, provide customer
services, deliver our content which we think may be of interest to you,
for customer research, to send you marketing and promotional emails and
to notify you about important changes to our Platform.
We also use your Personal Information for the following purposes:
- To fulfil a contract, or take steps linked to a contract. This is
relevant where you request a service via Ace Golf. This includes:
- Sending you information about your requested services (such as
appointment reminders) by email, SMS and push notification;
- Facilitating your bookings and taking payments;
- Facilitating your bookings and taking payments; and
- Administering your account.
- As required by Ace Golf to conduct our business and pursue our
legitimate interests, in particular:
- To keep our Platform and systems secure and to prevent fraud,
security incidents and other crime;
- To verify compliance with our terms and conditions and for the
establishment, exercise or defence of legal claims;
- To notify you about new Ace Golf services and special offers we
think you will find valuable, for example via an email newsletter;
- To help us monitor, improve and protect our Platform, products and
services, and to personalise our Platform, products, services (and
those of our partners) for you, based on information you provide
and your use of our Platform, products and services and other
sites (please see the Cookies section of this Privacy Policy for
further information);
- To investigate and respond to any questions or complaints received
from you or from others, about our Platform or our products or
services;
- To conduct internal research and analysis so that we can see how
our Platform, products and services are being used and how our
business is performing;
- To conduct market research and consumer surveys;
- To collate and publish reviews of products or services offered by
our Partners; and
- To process applications for a position at Ace Golf, whether
submitted directly or indirectly, including to examine your
suitability for the role, curriculum vitae, and professional
skills, to schedule interviews and assessments, to contact
referees and, if successful, to offer you a job and establish an
employment relationship with you. Information which you provide
will be held for a period of 12 months and may be referred to in
the event you make future applications to work at Ace Golf, unless
you opt to delete this data which you may do so by following the
link in the confirmation of application email that we sent you.
- Where you give us consent:
- To notify you about new Ace Golf services and special offers we
think you will find valuable, for example via an email newsletter;
- To send you information about competitions and surveys and details
of promotional offers of our Partners by email and as push
notifications via the App;
- To pass your personal information to our Partners;
- To use customer communications for training, record-keeping and
quality control purposes. If you telephone our customer experience
team, and consent by not opting out, your call may be recorded.
You will be told if such a recording is being made and given the
opportunity to opt-out of being recorded if you wish to do so and
the means for doing so; and
- On other occasions where we ask you for consent, we will use the
data for the purpose which we explain at that time.
- For purposes which are required by law:
- To respond to requests by government or law enforcement
authorities conducting an investigation; and
- To meet legal, regulatory and compliance requirements.
Legitimate interest
We have carefully evaluated and weighed all the data processing we carry
out on the basis of our legitimate interests, which we have described
above.
Withdrawing consent or otherwise objecting to direct marketing
We have carefully evaluated and weighed all the data processing we carry
out on the basis of our legitimate interests, which we have described
above.Wherever we rely on your consent, you will always be able to
withdraw that consent, although we may have other legal grounds for
processing your data for other purposes, such as those set out above. In
some cases, we are able to send you direct marketing without your
consent, where we rely on our legitimate interests. You have an absolute
right to opt-out of direct marketing at any time. You can do this by
following the instructions in the communication where this is an
electronic message, or by contacting us using the details set out below.
- If you would like to unsubscribe from receiving communications which
Ace Golf sends you, you can do so by clicking the “unsubscribe” button
at the bottom of email communications which we send you or
alternatively by contacting us atsupport@acegolf.io. In the case of email marketing please allow 48 business hours for
your email address to be removed from our system.
- If you would like to unsubscribe from receiving communications which
are sent by Partners, please contact the Partner directly. In the case
of our Partners, if you need our assistance with this, we will be
happy to do what we can to help you.
- If you would like to no longer receive push notifications via the App,
you can do so by revoking push notification permission for the Apps in
your phone’s operating system settings.
Sharing personal information with third parties
We treat the security and method of processing your Personal Information
very seriously, and we will never sell your Personal Information under
any circumstances.
However, we may disclose your Personal Information to selected third
parties, including in the following situations:
- To any of our Group Companies for the purposes identified in this
Privacy Policy. A list of local Group Company entities and their
locations is as follows:
- Ace Technologies Holding B.V.: Ruyschstraat 331,
1091 MR, Amsterdam, the Netherlands, info@acetechnologies.io
- If you place an order or otherwise engage with Ace Golf through a
website or app powered on behalf of a third party, then your contact
details and details of your order will be passed on to the relevant
third party when you make a booking. If you give a third party the
relevant consents, they may also send you marketing communications.
- To third party service providers that perform functions on our behalf
in relation to the Platform or otherwise in connection with running
our business, recruiting candidates and for the provision of Ace
Golf's services (for example, processing credit card payments (please
see paragraphs on Stripe and PayPal below for more information on
this), website hosting, conducting surveys and market research,
providing social media analysis, providing marketing email services,
data analysis tools and to manage customer services communications
including telephone calls).
- To our Partners with whom you book services whether via our Website or
Apps, where we act as commercial booking agent, or directly with the
Partner via our Partner Platform or Widgets, where we act solely as a
technology provider. Your information is shared with Partners in order
that:
- bookings can be facilitated and, if necessary, contact made in
advance of your appointment;
- if you have opted in to receiving marketing emails from Partners
with which you book, these emails can be sent to you containing
news and special offers; and
- they can improve the services they offer to their customers and
business operations by providing statistical data regarding
customers, both on an aggregated basis and on an individual level.
- To third party brands with which we collaborate on products, services,
competitions and campaigns.
- To third party golf, sports or calendar software providers used by our
Partners to ensure that those third party software solutions and the
Platform each display real-time availability to customers
- To other third parties, for the purpose of facilitating our business
and improving our products, content, services or advertising
including, by way of example only, sending email communications or
publishing reviews of our or our Partners' products and services
- If we buy, sell or transfer any business or assets or if we go into
insolvency, bankruptcy or receivership. If this should happen, we may
need to disclose your Personal Information to the seller or buyer of
such business or assets, as appropriate
- If we are under a duty to disclose or share your Personal Data to
comply with any legal obligation or in order to enforce or apply our
terms and conditions and other agreements or protect the rights,
property, or safety of our customers, or others. This includes
exchanging information with other companies and organisations for
fraud protection and credit risk reduction
- To government authorities, and to other third parties as required or
permitted by law, including but not limited to in response to court
orders. We also may disclose user information when we have reason to
believe that someone is causing injury to or interference with our
rights or property, other users of our Platform, or anyone else that
could be harmed by such activities.
Please note: by posting any Personal Information in any publicly
accessible area of our Platform (such as review sections), such
information may be collected by third parties over which we have no
control. We are not responsible for the use of such information by such
third parties.
Please therefore exercise all due care and consideration before
disclosing any Personal Information that will be disclosed on public
areas. You should also avoid disclosing on public areas any Personal
Information that may be used to identify you (such as your name, age,
home or work address or name of your employer).
Stripe
We use a third party payment processor, Stripe, to process all payments
made by you on our Website & App. Ace Golf does not store credit card
details and instead relies on Stripe for this. We obtain limited
information from Stripe such as the last four digits, the country of
issuance and the expiration date. The processing of such data by Stripe
is covered by their privacy policy which may be viewed here: stripe.com/privacy.
Stripe’s services in Europe are provided by a Stripe affiliate, Stripe
Payments Europe Limited, an entity located in Ireland. In providing its
payment processing services, Stripe Payments Europe Limited transfers
personal data to Stripe, Inc. in the US. For further information about
the safeguards used when your information is transferred outside the
European Economic Area, see the section of Stripe’s privacy policy
entitled “International Data Transfers”
Your rights in relation to your personal information
In relation to the personal information we hold about you, you may be
entitled to ask us:
- For a copy of your personal information;
- To correct, erase or restrict the processing of your personal
information;
- To obtain personal data which you provide to us for a contract or with
your consent in a structured, machine readable format and to ask us to
transfer this information to another organisation;
- To object to the processing of your personal data in some
circumstances (in particular, where we don’t have to process the data
to meet a contractual or other legal requirement, or where we are
using the data for direct marketing).
In the first instance you may be able to view or change the information
you have provided us with by logging in to your online account.
Your rights in relation to your personal information are limited in some
situations. For example, if fulfilling your request would reveal
personal data about another person or if we have a legal requirement or
a compelling legitimate ground we may continue to process Personal
Information which you have asked us to delete.
You also may have the right to make a complaint if you feel your
personal information has been mishandled. We encourage you to come to us
in the first instance but, to the extent that this right applies to you,
you are entitled to complain directly to the relevant supervisory
authority.
If you wish to exercise any of the above rights, please contact us at support@acegolf.io. Please note, however, that no financial information will be provided
without verification.
What about other websites linked to our Platform?
We are not responsible for the practices employed by the website linked
to or from our Platform nor the information or content contained
therein. Often links to other websites are provided solely as pointers
to information on topics that may be useful to the users of our
Platform.
Please remember that when you use a link to go from our Platform to
another website, our Privacy Policy is no longer in effect. Your
browsing and interaction on any other website, including websites which
have a link on our Platform, is subject to that website's own rules and
policies. Always read over those rules and policies before proceeding.
Social Media and User Generated Content
Some of our Platforms allow users to submit their own content. Please
remember that any content submitted to one of our Platforms can be
viewed by the public, and you should be cautious about providing certain
personal information e.g. financial information or address details via
these Platforms. We are not responsible for any actions taken by other
individuals if you post personal information on one of our social media
platforms, e.g. Facebook or Instagram. Please also refer to the
respective privacy & cookie policies of the social media platforms you
are using.
Changes to our Privacy Policy
If we change our privacy policies and procedures, we will post those
changes on our Platform to keep you aware of what information we
collect, how we use it and under what circumstances we may disclose it.
Where we store your personal data
The data that we collect from you may be transferred to and stored at a
destination outside the European Economic Area (EEA), including in the
UK and US, including for the purposes of processing that data by
selected third parties, in order to facilitate Ace Golf's business.
Countries outside the EEA may not have laws which provide the same level
of protection to your personal data as laws within the EEA. Where this
is the case, personal data is adequately protected by EU Commission
approved standard contractual clauses, an appropriate Privacy Shield
certification, a vendor's Processor Binding Corporate Rules. A copy of
the relevant mechanism can be provided for your review on request to info@acegolf.io.
Retention
We retain your Personal Information for as long as is required to fulfil
the activities set out in this Privacy Policy, otherwise communicated to
you or for as long as is permitted by applicable law. For example:
- where you apply for a position at Ace Golf, whether directly or
indirectly, information which you provide will be held for a period of
12 months, unless you opt to delete this data which you may do so by
following the link in the confirmation of application email that we
sent you;
- where you contact us via the telephone and do not opt-out, we shall
retain call recordings for up to 90 days from the date of the call.
Our policy on Cookies
In common with other commercial website and apps, our Platform use
standard technologies including cookies and similar tools including web
server logs, web beacons, tokens, pixel tags, local storage, device
identifiers and tracking IDs (together referred to as “Cookies” in this
Privacy Policy) to enhance your user experience, to enhance your user
experience, improve our site and provide tailored offers on Ace Golf.
Please see the list below for a breakdown of the Cookies that are used
on our Platform.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be
switched off – our Platform cannot function properly without them. You
can set your browser to block or alert you about these cookies, but some
parts of the site will not then work. They may be required to enable you
to move around our Platform and use our features, for system
administration, to prevent fraudulent activity, to keep you logged in
from one page to another or so that we can remember what you have added
to your basket. These cookies do not store any personally identifiable
information.
Performance Cookies
These Cookies enable us to better understand how many users visit our
Platform, how users arrive at, browse or use our Platform and which
parts of our Platform are most popular. For example, they allow us to
count visits and traffic sources so we can measure and improve the
performance of our site. All information these cookies collect is
aggregated and therefore anonymous. If you do not allow these cookies we
will not know when you have visited our site, and will not be able to
monitor its performance.
Functional Cookies
These Cookies enable us to provide enhanced functionality and
personalisation and simplify your user experience. For example they may
remember choices you make such as the country you visit our Platform
from or your preferred language.. They may be set by us or by third
party providers whose services we have added to our pages. If you do not
allow these cookies then some or all of these services may not function
properly. They cannot track your browsing activity on other websites or
apps outside the Platform.