PRIVACY POLICY
INSTA CLUB Privacy Policy

Privacy Policy Overview This privacy policy sets out how INSTA CLUB LTD collects, uses and protects Personal Data, which you agree to when you give us this data.

We are committed to ensuring that your privacy is protected. Your Personal Data will only be used in accordance with this privacy policy. We will also advise you of your Personal Data rights and how to register a complaint to the relevant authorities, namely the Information Commissioner's Office (UK).

We may change this policy. You should check this page periodically to review any changes. This policy is effective as of now and complies with all appropriate and applicable Data Protection legislation and regulations including the General Data Protection Regulation and the Data Protection Act of 2018.

If you choose not to give us Personal Data, it may delay or prevent us from fulfilling our contract with you, or doing what we must do by law. If it means we cannot provide our services to you, we may cancel services you have with us.

Who are we and how to contact us References in this Privacy Policy to INSTA CLUB LTD, "we", "us" or "our" relate to Love Golf Memberships.

We control the ways that Personal Data is collected and the purposes for which your Personal Data is used by INSTA CLUB LTD, acting as a "data controller" in line with GDPR and the Data Protection Act 2018 where we are offering memberships directly to an individual.

Where we act on behalf of a client, we act as a "data processor" under their strict instruction and in line with applicable European data protection legislation and under the Data Protection Act 2018.

For any privacy policy related enquiries you can contact us by writing to us via:

Post:
INSTA CLUB LTD
1 Pankhurst Avenue,
London, England, E16 1UT

Email: info@instaclub.uk

Protecting your Personal Data Your Personal Data is protected by certain regulations and laws. These state that we can only process your Personal Data for one of the following genuine reason types:

  • To fulfil and provide services as per our contract;
  • Where we have a legal obligation;
  • Where you have consented to the processing (e.g. Marketing);
  • When it's in our legitimate interest;
  • When it's in the public interest;
  • When it's in your vital interests.
The law and other regulations treat some types of sensitive Personal Data as special (e.g. Religious, Health and Criminal Convictions). We do not collect these types of data and so some of the obligations written in Data Protection legislation and regulations do not apply to us. If we ever need to collect data such as health data however (for you a legitimate reason), we will only collect and process this data with your consent unless the law allows us to do so.

Legitimate Interests for using your Personal Data When we have a business or commercial reason to process your Personal Data this is referred to as a legitimate interest. Your Personal Data is still protected and we must not process it in a way that would be unfair to you or your interests.

Here are our reasons for using your data:

Providing you with a service as a member of INSTA CLUB LTD: Personal Data Use

  • To manage our relationship with you or your business
  • To develop and carry out marketing activities
  • To study how our customers use products and services from us and other organisations
  • To communicate with you about our products and services


Genuine Reason

  • Your consent
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty


Our Legitimate Interest

  • Keeping our records up to date, working out which of our products and services may interest you and telling you about them
  • Developing products and services, and what we charge for them
  • Defining types of customers for new products or services
  • Seeking your consent when we need it to contact you
  • Being efficient about how we fulfil our legal and contractual duties


To improve the INSTA CLUB LTD Business and our services and products to you: Personal Data Use

  • To test new products
  • To manage how we work with other companies that provide services to us and our customers
  • To develop new ways to meet our customers' needs and to grow our business


Genuine Reason

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty


Our Legitimate Interest

  • Developing products and services, and what we charge for them
  • Defining types of customers for new products or services
  • Being efficient about how we fulfil our legal and contractual duties


Managing our operations: Personal Data Use

  • To deliver of our products and services
  • To make and manage customer payments
  • To manage fees, charges and recover money owed to us


Genuine Reason

  • Fulfilling contracts
  • Our legitimate interests


Our Legitimate Interest

  • Being efficient about how we fulfil our legal and contractual duties
  • Complying with rules and guidance from regulators


Managing security, risk and crime prevention: Personal Data Use

  • To detect, investigate, report, and seek to prevent financial crime
  • To manage risk for our customers and us
  • To obey laws and regulations that apply to us
  • To respond to complaints and seek to resolve them


Genuine Reason

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty


Our Legitimate Interest

  • Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect
  • Complying with rules and guidance from regulators
  • Being efficient about how we fulfil our legal and contractual duties


Business management: Personal Data Use

  • To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit
  • To exercise our rights set out in agreements or contracts


Genuine Reason

  • Our legitimate interests
  • Our legal duty
  • Fulfilling contracts


Our Legitimate Interest

  • Complying with rules and guidance from regulators
  • Being efficient about how we fulfil our legal and contractual duties


Although not applicable at this time if we ever process special categories of Personal Data, it will be for:
  • Substantial public interest
    • Using criminal records data to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour
    • Using criminal and health information as needed to provide insurance products
  • Responding to regulatory requirements
    • Showing whether we have assessed your situation in the right way
    • Passing information to the regulator as needed to allow investigation into whether we have acted in the right way
  • Legal claims
    • Using any special categories of data as needed to establish, exercise or defend legal claims
  • Consent
    • Telling you that we need your consent to process special categories of Personal Data, when that is what we rely on for doing so

Groups of Personal Data This explains what all the different types of Personal Data that we use that are covered by data protection law.

  • Contact
    • Your name, where you live and details like how to contact you. Collected when you apply for membership
  • Behavioural
    • Details about how you use products and services from us and other organisations. This may be gathered if you take part in competitions or events with INSTA CLUB LTD or from your preferences when joining
  • Communications
    • What we learn about you from letters and emails you write to us and conversations between us
  • Social Relationships
    • Your family, friends and other relationships when you join as part of a family membership
  • Usage Data
    • Other data about how you use our products and services that may be gathered if you take part in competitions or events with INSTA CLUB LTD or from your preferences when joining
  • Consents
    • Any permissions, consents or preferences that you give us. This includes things like subscribing to newsletters and future marketing or how you want us to contact you
How we store and process your data Your Personal Data will be collected, processed and stored in the EU for the duration of our contract with you plus 12 months. All data is protected in line with GDPR guidelines and best industry practices.

Who we share your information with In order to provide updates and offers that may be of interest to you, we may use recognised third parties to manage and provide services that enable us to meet and provide the services we've outlined in this privacy policy. An example is the Golf organisations that are part of your membership with INSTA CLUB LTD. These businesses will operate within the EU.

Where services and processes are completed by our partners and 3rd parties, we ensure they operate to our strict guidelines in accordance with this privacy policy, applicable Data Protection laws and regulations and we take reasonable precautions to safeguard your Personal Data and ensure our partners do the same.

It is highly unlikely that INSTA CLUB LTD will ever require to share your data with a 3rd party however in the slim chance that we do (for example for legal reasons) the here is a list of the types or people we may do so with:

Authorities. This means official bodies and includes:

  • Central and local government
  • HM Revenue & Customs, regulators and other tax authorities
  • UK Financial Services Compensation Scheme and other deposit guarantee schemes
  • Law enforcement and fraud prevention agencies.


Security In an unlikely event of a data breach we will notify the appropriate authorities as per the applicable regulations and laws. If the incident has a material impact to you, we will contact you also.

Cookies Cookies are small files containing information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs such as remembering your preferences, tailoring web-site content and generally improving your online experience.

Cookie Purpose _ga, _gid, __utma, __utmb, __utmc, __utmt, __utmz These cookies are used to collect information about how visitors use our site. We use the information to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. XSRF-TOKEN This cookie is written to help with site security in preventing cross-site request forgery attacks. hasSeenCookieMessage This cookie records when you have seen and accepted the cookie warning message. laravel_session This cookie is used for the user account area once you have signed up to a membership. suggested-club-1 This cookies records which clubs you have viewed on the site to improve the user experience during the sign up process.
You can block cookies using your browser settings. How to guides can be found online on how to do this for most web browsers.

Contacting us, exercising your information rights and complaints Under certain circumstances, by law you have the right to:

  • Request Personal Data (known as a Data Subject Access Request) we hold about you, what that is and why we are holding/using it;
  • Request correction of any incomplete or inaccurate Personal Data that we hold about you;
  • Request erasure of your Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below);
  • Object to processing of your Personal Data 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. You also have the right to object unreservedly where we process Personal Data for direct marketing purposes;
  • Object to automated decision-making including profiling by us using your Personal Data or profiling of you;
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Request transfer of your Personal Data (commonly known as a right to "data portability") in an electronically useable format and for your data to be transferred to another party in an electronically useable format;
  • Withdraw consent where it was requested to enable the collection, processing and transfer of your Personal Data for a specific purpose. Once we have received notification and assessed your request, if valid, we will no longer process your Personal Data for that purpose (e.g. direct marketing);
  • Register a complaint to us in relation to our collection, usage and/or storage of your Personal Data or that of one of our suppliers or partners;
  • Lodge a complaint with the Information Commissioner's Office via their website.
    You will not have to pay a fee to exercise any of these rights however we may charge a reasonable fee if your request for Personal Data access is clearly unfounded or excessive or alternatively, we may refuse to comply with the request in such circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to invoke any of your Personal Data rights. This is another appropriate security measure to ensure that Personal Data is not disclosed incorrectly.

If you have any questions about this Privacy Policy, wish to exercise your information rights in connection with the Personal Data you have shared with us or wish to make a complaint, please contact us via our contact details listed earlier in this Privacy Policy.