Our legal bases for processing
We collect and process information about you only where we have legal bases for doing so. This legal bases will depend on the individual services you use and how you use them. Additional information is provided below but in general terms we will only collect and use your information where:
- It is necessary for us to provide you with a service, including for support or to protect the safety and security of the website itself.
- It satisfies a legitimate interest which is not overridden by your data protection interests. Such as for research and development.
- You have given us consent to do so for a specific purpose.
- We need to process your data to comply with a legal obligation.
In cases where you have consented to our use of your personal information for a specific purpose you have the right to change your mind at any time. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use, but in some cases this may mean your are no longer able to access our service.
Third-party data processors
Like most businesses we rely on a number of third-party providers to support our day-to-day operations, for example in areas such as online file storage and email delivery. We may also hire third parties to operate, maintain or improve our website and other digital services. Some of these service providers will by necessity have access to or be directly involved in processing or storing a subset of the personal information you share with us. All our third-party data processors have been carefully chosen as service suppliers who also practice responsible data handling. We believe that each has in place appropriate protections to ensure the security of the data we store or process with them and have clear policies for how they treat that data. But if in doubt you should review their individual Privacy Policies.
Amazon Web Services (file storage):
Google (website analytics):
HeartInternet (hosting services):
Microsoft (email services):
PayPal (payment processing)
The Pixel Parlour (website development & support):
Before using or sharing your information with third parties in ways not described here or previously authorised by you, we will provide you with notice and an opportunity to control the further use or disclosure of your personal information.
Transfers outside of the European Economic Area
Under certain circumstances we will transfer your information outside of the European Economic Area. We will only do this with your informed consent, when it is necessary to perform a contract we have with you or where the receiving organisation has adequate safeguards in place – for example certification under the EU-US Privacy Shield framework.
Our website is hosted in the UK in a data centre managed by Heart Internet. When you visit our website or access one of the files stored on our web server information about this request will be automatically stored in our log files to provide usage statistics, enable security features and aid technical troubleshooting. This is on the legal basis of legitimate commercial interests. In these cases, your IP address at the time acts as a unique identifier and is stored along with information about your operating system, browser version and the pages/files you access. These logs are retained on the server for up to 30 days, after which they are automatically deleted. Heart Internet will also record a similar set of data for the purposes of data management and security. This data is retained by them for up to 3 months. Like most businesses, we use Google Analytics to help understand how our website is being discovered and interacted with and we use this information to help improve the experience for our visitors and make decisions about future development. Google Analytics presents us with aggregate information about the geographic location, device types and operating systems used by our website visitors, but not in a way that personally identifies you. Additionally, Google will record your computer’s IP address and set a number of temporary cookies in your browser to help distinguish you as an individual visitor as you move around our site. In the interest of limiting the amount of data Google collects via our site we are using Google’s standard Analytics implementation and have not enabled any additional advertising features, such as remarketing tags which would tie your usage of our site in with your broader browsing habits. Any user-level data that is associated with Analytics’ cookies are retained for up to 26 months from your last activity on our site, after which it is automatically deleted from Analytics’ servers. Our website and emails contain a number of links to third party sites. It is important to be aware that these external sites are governed by their own privacy policies and we do not accept any responsibility or liability for these policies. The inclusion of a link to an external source should not be understood to be an endorsement of that website, it’s owners or their products/services. Always check the individual privacy policies of these external sites before you submit any personal data through them.
Cookies are temporary files stored in your web browser by a website to help track usage and enable services that rely on a persistent identity. You can control which cookies you accept and remove them at any time by adjusting your browser settings or using the tools provided by this site, but it is important to be aware that some cookies are essential and our website may not function as expected without them.
Essential cookies: These cookies are strictly necessary to provide you with services available through our websites and to use some of its features. But you can still block or delete them by changing your browser preferences.
- PHPSESSID, JSESSIONID (Golf Buyer Europe). Used to give you a unique identifier during your time on the site for security purposes. Expire at the end of your session.
Functional cookies: These cookies are used to enhance the performance and functionality of our websites. They are non-essential but without them, certain functionality may become unavailable.
Analytics and customisation cookies: These cookies collect information to help us understand how our website is being used or customise it in order to enhance your experience.
- _ga (Google Analytics) – used to distinguish between users. Expires after 2 years.
- _gat (Google Analytics) – used to distinguish between users. Expires after 24 hours.
- _gid (Google Analytics) – used to throttle the request rate. Expires after 1 minute.
Advertising cookies: These cookies are used to make advertising messages more relevant to you and your interests.
Contacting us by email
When you send us an email, either to one of the addresses displayed on our website or an an individual member of staff, we will collect your email address and any other information you provide within your email.
Microsoft are our email service provider so any emails you send us will be stored on their servers. Therefore your email and any associated personal data may be transferred outside of the European Economic Area to servers located in the USA. Microsoft’s certification under the EU-US Privacy Shield Framework commits it to maintaining appropriate safeguards for international data transfers. You can learn more here: https://privacy.microsoft.com/en-GB/privacystatement
The information you provide will only be processed in relation to the purpose of your correspondence with us. We have no fixed retention period for email correspondence, but we are committed to only storing your data for no longer than is necessary to serve our legitimate interests of record keeping or to perform a contract we have entered into with you.
We use PayPal as an online payment processor, so when you book a paid-for advert through our website some of the information you submit is sent to them to allow your payment to processed. PayPal is committed to handling your personal data securely and will not reveal your financial information to any third party except with your express permission or if required to do so by a court order or other legal process. You can read the full in their privacy statement here: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. Please be aware that PayPal may transfer information relating to your transaction outside the European Economic Area, but in such cases they are committed to protecting it with adequate safeguards. All the information you submit at checkout is transmitted securely via an encrypted https connection and the information we receive from these transactions is just that needed to process or support your order. That includes your name, email address, billing address and contact phone number, but does not include any sensitive financial information such as credit card numbers or bank account details. We will retain this information, along with the details of your purchase, for 5 years as part of our financial records.
Posting an advert
When you post an advert to our website the information we collect is only that which we require to process your submission and create a listing that potential buyers will be able to respond to. Your name and email address are used to uniquely identify your submission and provide us with a point of contact for any follow-up communication such as sending you an electronic receipt. We also collect your IP address and physical address to facilitate payment processing and meet our obligations to maintain appropriate financial records. For example we need to know the country of origin of all transactions for calculating VAT. This order information is retained for up to 5 years after which is erased. Payment processing is handled by PayPal and only they have access to sensitive financial information shared during your purchase, such as your credit/debit card details. You can learn more in the Payment Processing section above.
When an advert expires it is removed from the public-facing side of the site, but the data itself is still held by us for up to 90 days. If an advert is not re-activated within this time it will then be permanently deleted.
Messaging a seller
When you contact a seller through our website using the contact form found on individual listings the information you submit is sent to the seller by email. This includes your name, email address and any other details you include within the body of your message. A copy is also stored by us for up to 90 days along with details of your IP address. For your own security you should avoid sharing any sensitive personal data through our platform and restrict information to the bare minimum needed to complete your transaction.
Your Golf Buyer Europe Account
When posting an advert to our website you have the option to create an account that allows you to log in to the website and manage your advert, including removing an item from sale or updating your contact information. You can close your account at any time, but please be aware that it may take up to 30 days for your account closure request to be processed and any associated data to be removed from our primary and backup systems. We also reserve the right to remove dormant accounts from our system (along with any associated data) if they are inactive for longer than 12 months.
To minimise data sharing we host our own email marketing solution rather than using a third-party service. So when you subscribe to our newsletter the email address and name you submit are held by us on servers within the UK.
To help ensure that only those who really consent to receiving our emails are signed-up we use a double opt-in process where a confirmation email will be sent to the email address supplied with a link to click. Only after clicking that link will you be opted-in to receive our emails. At this point we also collect your IP address, which along with a timestamp helps provide our evidence of consent should we need to produce this in future.
By default we will retain your data for as long as you choose to stay subscribed or such time as we consider your account to be in-active (ie. you are no longer opening or engaging with our emails). But you can update your details or opt-out of our emails at any time using the ‘Unsubscribe’ or ‘Email Preferences’ links found at the bottom of every marketing email we send. If you unsubscribe we will retain your email address for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.
In addition to the information you supply at sign-up we may also capture data about your interactions with our emails and website, such as which links you click within an email which pages you go on to visit on our website. We use this information to help improve our product and provide more personalised messaging.
We may also combine the information you provide us at sign-up with data from other sources to help us improve the relevance of the emails we send you. For example if you are also attending one of our events we will record that information in your subscriber profile to ensure that the content of our emails reflects that.
Children under 13
Our website and services are not for use by children under 13 years and we will not knowingly collect or use the personal data of children. If you are under the age of 13 please do not provide any personal data even if prompted to do so.
Personal data breaches
Questions & access requests
The Elite Luxury Events
Attn. Data Protection Officer
Palmers Barn, Station Road