Privacy Policy

Club Systems International Limited ("Club Systems", "we" or "us") are committed to protecting and respecting your privacy.

This policy (together with our terms and conditions of use of the HowDidIDo website www.HowDidiDo.com (the “Website”) and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected and processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This privacy notice supplements any other notices in relation to how we handle your personal data and is not intended to override them.

The Website may be used by children. Where we rely upon consent as our lawful basis for processing Personal Data you must be aged 13 or over to lawfully provide such consent. For children under the age of 13 we require consent from whoever holds parental responsibility for the child.

Controller

Club Systems International Limited (Company number: 3550638) of 49 Peter Street, 2nd Floor, Manchester, M2 3NG ("Club Systems") is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this notice including requests to exercise your legal rights (detailed below) please contact the DPO using the contact details below.

Contact Details

Full name of legal entity: Club Systems International Limited
Name of DPO: Richard Peabody
Email address: Privacy@clubsystems.com
Postal address: 49 Peter Street, 2nd Floor, Manchester, M2 3NG
Telephone number: 03452229999

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.

Third-Party Links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.

Information we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect and process the following data about you:

  • Identity Data includes first name, last name, username, gender, CDH lifetime ID.
  • Contact Data includes email address, telephone numbers, address.
  • Technical Data includes internet protocol (IP) address, your encrypted 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 this website.
  • Usage Data includes information about how you use our website, products and services.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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.

How we collect your Personal Data

  • Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by Club Systems, and when you report a problem with the Website.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of postings on the Forum.
  • Details of transactions you carry out through the Website and of the fulfilment of your orders.
  • Details of your visits to our sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access
  • File names of any encrypted data.

Purposes for which we use 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.

Purpose/activity Type of data Lawful basis Retention period
To ensure that data is presented in the most effective manner for you and for your computer. Identity Data Legitimate Interest Until User opts to delete account
To provide you with information, products or services that you request from us or which we feel may interest you by email, SMS text messaging or both Identity Data

Contact Data

Usage Data

Profile Data

Marketing & Communications Data
Consent Until User opts to delete account
To carry out our obligations arising from any contracts entered into between you and us Identity Data

Contact Data

Usage Data

Profile Data

Marketing & Communications Data

Technical Data

Performance of contract

Legitimate interest

Until User opts to delete account
To allow you to participate in interactive features of our service. Identity Data

Contact Data

Marketing & Communications Data
Consent Until User opts to delete account
To notify you about changes to our service. Identity Data

Contact Data
Performance of contract

Legitimate interest
Until User opts to delete account
To notify you of your competition results by email, SMS text messaging or both Identity Data

Contact Data

Marketing & Communications Data
Consent Until User opts to delete account
To notify you of your handicap changes by email, SMS text messaging or both Identity Data

Contact Data

Marketing & Communications Data
Consent Until User opts to delete account
To notify you of national competitions and either weekly standings or finishing positions only Identity Data

Contact Data

Marketing & Communications Data
Consent Until User opts to delete account
To allow third parties to contact you about their products, services and offers or provide you with information on such products or services which may be of interest to you by email, SMS text messaging or both Entity Data

Contact Data

Usage Data

Profile Data

Marketing & Communications Data

Technical Data
Consent Until User opts to delete account

Retention Policy

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data at set out in the table above.

Notwithstanding the other provisions of this retention section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Lawful Basis for Processing

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.

Consent means yours express opt in consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can view and manage your settings and make certain decisions about your personal data use in your personal profile alert settings.

Promotional Offers from Us

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 or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside of the Club Systems International Limited group of companies for marketing purposes.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, golfers in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

IP Addresses and Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the website and to deliver a better and more personalised service. They enable us to estimate our audience size and usage pattern, to store information about your preferences, and so allow us to customise our sites according to your individual interests, to speed up your searches and to recognise you when you return to the Website.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Website.

Please note that our advertisers and other websites linked to our website may also use cookies and may not contain privacy policies. We have no control over such sites or their uses of cookies and the submission of information to them is at your own risk.

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"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA

Subject to any payment transactions, all information you provide to us is stored on our secure servers. Any payment transactions will be dealt with in accordance with World Pay’s terms and conditions and privacy policy from time to time and/or those of any other third party that provides payment facilities on the Website. You should read such terms and conditions and privacy policies carefully before making any payment.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Disclosure of your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the Companies Act 1985 as updated or amended from time to time.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Club Systems or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use terms and conditions other agreements; or to protect the rights, property, or safety of Club Systems, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

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 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 or where the processing is for the establishment, exercise or defence of legal claims.

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: (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.

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. You can withdraw consent by emailing HDIDSupport@clubsystems.com at any time.

If you wish to exercise any of the rights set out above, please contact us on the details provided in this notice.

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 may 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 may 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.

Changes to our Privacy Policy

This version of the privacy notice was last updated on 23rd May 2018.

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.