Privacy Policy
As part of its activity, the association of the Golf Club of Courchevel hereinafter called the Golf is required to process Personal Data. This Privacy Policy informs you about how the Golf collects and processes your personal data. We invite you to read it carefully.
The Policy applies to all persons whose personal data are collected by the Golf. These are principally visitors to the Golf, members of the Golf, and more generally any person who may come into contact with the Golf (hereinafter the “Holders”) on the manner and purposes for which the Golf collects, uses and communicates their personal data.
Personal data (the “Data”) means any information relating to an identified or identifiable natural or legal person. We mean Owners, any natural or legal person whose Data is collected.Giving particular importance to the protection of the Data that the Owners entrust to it, the Golf is committed to respect the privacy of the latter.
This Policy is designed to comply with the requirements of applicable privacy laws, in particular Law No. 78-17 of 6 January 1978 on Information Technology, Files and Freedoms as amended; the General Data Protection Regulation n°2016/679 which came into force on 25 May 2018, the French laws and decrees transposing the Regulation.The data controller mentioned in this document is the association of the Golf Club de Courchevel, whose seat is located at 540, rue du Jardin Alpin 73120 Courchevel and whose President-in-Office is the legal representative.
The Golf Data Protection Officer is the Club Director.
Article 1. Acceptance of the policy.
The Golf reserves the right to modify and supplement this Policy at any time, the version in force being that available on the website located at www.golfdecourchevel.com on the date of connection of the Holder to the site.
It is agreed that the nullity of a contractual clause does not result in the nullity of the entire Policy.
Article 2. Processing of Personal Data.
All Data provided by the Holder to the Golf are treated with the utmost confidentiality.
The Data collected are for internal use within the Golf and strictly limited to teams having to know about them. In all cases, we limit ourselves to collecting and processing relevant, adequate, not excessive and strictly necessary data for the fulfilment of the purposes set out below.
Beyond the retention periods mentioned below, the Data may be anonymized and retained for exclusively statistical purposes and will not give rise to any exploitation of any kind whatsoever.
The operations described above are not used to draw up profiles likely to reveal sensitive personal data such as racial or ethnic origins, philosophical, political, trade union, religious, sex or health.
2.1. Nature of the Data collected, purpose and retention period.
a) Data collected from Golf members :
• Last name, first name, title, date of birth, nationality
• Mailing address, email address, phone number
• French Golf Federation license number, index
b) Data collected for the registration of children at the golf school:
When registering for the golf school, the following Data are collected by the Golf:
• Surname, first name, landline and cell phone, email address of both parents.
These Data are necessary to enter into a relationship with the parents
The recipients of the Data are the Golf staff, the teachers and trainees responsible for teaching, the members of the Golf Sports Commission and the members in charge of the Golf School.
These Data are kept for three years.
c) Photographs of club members:
As part of the Golf activities (including sports competitions, awards, entertainment, club party and general assembly), photographs of the members are taken.
The purpose of these photographs is to illustrate the social and sporting life of the Golf, to preserve memories and to maintain sports and friendly relations between the members.
The recipients of this data are the members of the Club as well as the staff.
These photographs are kept without time limit, with the purpose of documenting the history of the Golf whose creation date is 1989.
d) Data collected from Golf Occasional Visitor Holders:
During the visit of a Visitor Holder, the Golf Club of Courchevel shall, as part of the performance of its service contract, collect the following Data:
• First and last name, license number, index and club membership, and date of birth.
In particular, this Data is necessary to identify and verify that the visitor holds a valid FFG license and that its level of play (index) complies with the minimum required to access our routes.
The recipients of the Data are the Golf staff and the President of the Golf.
These Data are deleted or anonymized within 5 years of the end of the calendar year in which they are collected.
e) Data collected spontaneously from Shareholders when sending an email or when applying spontaneously:
The Golf Club of Courchevel may be made recipient of a certain amount of personal data, without this being a solicitation on its part.
These data will not be further processed.
These Data are archived within 3 years of the end of the calendar year in which they are collected.
Archived Data will be accessible only to the President and the Director, excluding operational services.
f) Video surveillance data:
The Golf has placed its infrastructure under video surveillance to ensure the safety of its staff, members, visitors and property.
Images recorded in this device are not used for personnel monitoring or time control purposes.
Anyone present on the Golf is likely to be filmed by the device.
The images can be viewed, in case of incident, by the Director of the Golf as well as by the President and the police forces in accordance with the declaration made in the prefecture.
The images are kept for three weeks.
In the event of an incident related to the safety of persons and property, video surveillance images may nevertheless be extracted from the device. They are then kept on another medium during the settlement of the procedures related to this incident and accessible only to persons authorised in this context.
2.2. Minor.
Data relating to minors are provided by their legal representatives only, the information collected is as follows:
As part of their parent’s application:
• name, surname and license number,
As part of the minor candidate application:
• the same information as requested from a major candidate,
As part of the registration to the Golf School:
• surname, first name, title, date of birth, nationality;
• postal address, e-mail address, telephone number;
• license number, index, medical certificate indicating no contraindication to golf practice including competition.
2.3. Legal basis for processing.
Performance of the contract.
This is the legal basis claimed by the Golf when the data collected are necessary for the provision of its services and any assistance that users and members may need.
Legitimate interest.
The Golf is also likely to collect personal data for legitimate purposes such as improving its services and security. Holders may at any time object to the processing of their data on this basis.
Consent.
In certain circumstances, and in particular where the legal bases mentioned above are not applicable, the golf course must obtain the consent of the holder necessary for the processing of these data. In this case, the holder may withdraw his consent at any time.
2.4. Information shared with third parties.
The processing of the personal data collected is strictly confidential.
The Golf does not transmit any personal data to third parties who may use them for their own purposes, particularly for commercial or advertising purposes, without having required the prior consent of the Owners.
It is possible that the Golf transfers certain personal data to third party partners in a temporary and secure way to ensure the proper performance of the services it offers.
As such, the partners concerned may have access to the Holder’s personal data and process them on behalf of the Golf, in accordance with the instructions of the latter and in compliance with this Policy and with any appropriate security and confidentiality measures.
The Golf will set up procedures to ensure that the third parties it authorises to access personal data, including any subcontractors, respect and preserve the confidentiality and security of the Personal Data.
To this end, the Golf undertakes to make its subcontractor(s) responsible for the same obligations as those set out herein to ensure that the confidentiality, security and integrity of the data are respected, and that the said data may not be transferred or rented to a third party for free or not, or used for purposes other than those defined in this Policy.
When these partners are located outside the European Union or in a country that does not have adequate regulations to meet the requirements of the applicable privacy laws, in particular the General Data Protection Regulation and the French laws transposing it, the Golf frames its contractual relationship with this partner by adopting an appropriate contractual mechanism.
2.5. Data hosting.
The collected data are stored on secure servers located in France or in another member country of the European Union.
It is possible that the Golf will have to transfer the data collected through its servers or to those of its partners present in countries whose legislation ensures a level of data protection may be different from those of the European Union.
In this case, the Golf will take all necessary measures to maintain a level of security of the collected data at least equal to the level required by the European regulations on personal data.
Article 3. Rights of Holders.
3.1. Nature of Rights of Holders.
In accordance with the laws relating to the protection of personal data in force, in particular the General Data Protection Regulation and the French laws transposing it, each Holder has the following rights:
• The Owner may object to the processing of his personal data in case of legitimate reason.
• The Holder has a right of access to the data concerning him
– He may rectify, update and/or delete his data.
– They can request data portability.
– It may request a limitation of the processing of its data carried out by the Golf.
– He can communicate directives on the retention, erasure and communication of personal data after his death (post-mortem directive).
3.2. Exercise of Rights of Holders.
At any time, the Holder may exercise his rights by sending his request, which includes his surname, first name, postal and electronic address and copy front/back of his identity card, either:
• Email: info@golfdecourchevel.com
• By mail to:
Directeur du Golf
Golf Club de Courchevel
540 rue du Jardin Alpin
73120 Courchevel
A response will be provided within one month of receipt of the request.
The Holder may also at any time ask the Golf to stop receiving information by e-mail.
Finally, the holder may lodge a complaint with the competent authority, namely the CNIL for the French territory.
Article 4. Use of cookies.
The Owner is invited to refer to the conditions of use of the website.
Article 5. Applicable Law – Jurisdiction.
These general conditions of use are governed by French law.
In the event of a dispute concerning, in particular, the validity, interpretation and/or enforcement of these conditions, the French courts will have jurisdiction regardless of the location and nationality of the Holder.
