Privacy Policy

The Wisley respects your privacy and is committed to protecting your personal data. This notice describes how we collect, use, and share your information when you interact with us – whether you’re using our website, visiting one of our properties, or corresponding with us.

By visiting our website or engaging with our services, you are accepting and consenting to the practices described in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how The Wisley collects and processes your personal data.

1. Who we are and how you can contact us

This privacy notice is issued on behalf of The Wisley Golf Club plc and is responsible for processing and controlling your data. The Wisley Golf Club plc is responsible for The Wisley website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email these to richard.goodley@thewisley.com.

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.

The Wisley Golf Club plc in accordance with the UK Data Protection Act 1998, are registered with the United Kingdom’s Information Commissioner’s Office as a data controller to collection Information:

Data Controller: The Wisley Golf Club plc
Registered company number: 2169672
ICO Number: Z5745587 ICO
Richard Goodley – Data Privacy Manager
Email address: richard.goodley@thewisley.com
Postal address: The Wisley Golf Club plc, Mill Lane, Ripley, Surrey, GU23 6QU

2. The data we collect about you

All personal information that we collect about you will be recorded, used, and protected by us in accordance with applicable data protection legislation and this privacy policy. We may supplement the information that you provide with other information that we obtain from our dealings with you or which we receive from other organisations.

The type of data we collect about you includes

Identity data: includes first name and last name.
Contact data: includes email address.
Technical data: includes internet protocol (IP) address, 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, as well as your journey through our digital platform (such as the links you click on and searches you make), which videos you have watched and for how long, what content you like and share, which pop up or push messages you might have seen and responded to, and information collected in any forms you complete. We may also analyse which marketing activity led to your taking specific action on our digital platforms e.g. downloading the app.
Marketing and communication data: includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect and use Aggregated Data such as statistical 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.

Individuals under 16

The Wisley Golf Club plc does not intentionally or knowingly process information from individuals under the age of 16, with the following exceptions:

• Lessons for children in golf;
• Some of our leisure experiences.

When necessary, underage users will be told not to submit any personal details, and we will make every effort to delete any details of such users where a parent or guardian has informed us that these details or applicable data as defined by law have been collected.

3. We use different methods to collect data from and about you, including through

Direct interactions:

You may give us your data by filling in forms, using our website, using Wi-Fi, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for Membership
• Attend one of our events as a guest
• Enter a competition
• Surveys, or,
• Give us feedback

Automated technologies or interactions.

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies. We may also receive technical data about you if you visit our websites employing our cookies.

CCTV

Please note that for your safety and security, CCTV is in operation in the main Clubhouse and Greenkeeping compound.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources, such as:

• Technical data from analytics providers such as Google and search information based in or outside the EU;
• Contact data from providers or technical services based inside or outside the EU.

4. How we use your 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 reasons we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose of activity
To register you as a new Club Member

Type of data

1. Contact data
2. Technical data
3. Usage data
4. Marketing & communications data

Our reasons

1. Your consent
2. Fulfilling contracts
3. Our legitimate interests
4. Our legal duty

Lawful basis for processing including basis of legitimate interest

1. Developing products and services and what we charge for them

Purpose of activity
To process, maintain, fulfil and ensure the proper administration of your membership

Type of data

1. Identity
2. Contact
3. Financial
4. Transaction
5. Marketing and Communications

Our reasons

1. Manage payments, fees and charges
2. Collect and recover money owed to us

Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you (your membership agreement)
2. Necessary for our legitimate interests (to recover debts due to us)

Purpose of activity
To manage our relationship with you

Type of data

1. Identity
2. Contact
3. Profile
4. Marketing and Communications

Our reasons

1. Notifying you about changes to our terms of membership
2. Dealing with your requests, complaints and queries

Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you (your membership agreement)
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

Purpose of activity
To operate our club in compliance with applicable laws

Type of data

1. Identity
2. Contact

Our reasons

1. Ensuring compliance with age restrictions applicable to the sale of alcohol

Lawful basis for processing including basis of legitimate interest

1. Necessary to comply with a legal obligation

Purpose of activity
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

1. Identity
2. Contact
3. Technical

Lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
2. Necessary to comply with a legal obligation

Purpose of activity
To enable you to take part in events (social and golf)

Type of data

1. Identity
2. Contact
3. Profile
4. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you (your membership agreement)

Purpose of activity
To enable you to partake in a prize draw, competition or complete a survey

Type of data

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you (your membership agreement)
2. Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow our business)

Purpose of activity
To enable you to suspend your membership for medical reasons or give you access to specific equipment

Type of data

1. Health

Lawful basis for processing including basis of legitimate interest

1. Consent

Purpose of activity
To enable you to use our Club app

Type of data

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

1. Consent
2. Performance of a contract with you (your membership agreement)
3. Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow our business)

Purpose of activity
To include you in the Club’s private member directory

Type of data

1. Identity
2. Contact

Lawful basis for processing including basis of legitimate interest

1. Consent
2. Necessary for our legitimate interests (to enable directory listing services for individual member access and communication & booking purposes)

Purpose of activity
To deliver relevant website content and online promotions to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications
6. Technical

Lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose of activity
To use data analytics to improve our website, products/services, member relationships and experiences and to measure the effectiveness of our communications and marketing

Type of data

1. Technical
2. Usage

Lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (to define types of members for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose of activity
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

Type of data

1. Identity
2. Contact
3. Technical
4. Usage
5. Profile
6. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

1. Consent, having obtained your prior consent to receiving direct marketing communications

*Examples of our legitimate interests:

• complying with regulations that apply to us
• being efficient about how we fulfil our legal and contractual duties
• managing our facilities
• making decisions about continued memberships, arranging termination and exercising our rights set out in agreements or contracts and dealing with complaints
• efficient and proper estate and business management, planning, communications, keeping records up to date, benchmarking, accounting and auditing
• responding to communications sent to us, incl. social media posts; informing you of important changes to our business or policies; reviewing and improving the performance of our systems, processes & employees (including training)
• obtaining legal advice
• to monitor and protect people and property for security purposes
• effective resource management
• to decide whether you can provide goods or services to The Wisley and take part in hosted events, and to enable the same
• administering competition entries

5. Opting out

As a member you can ask us or third parties to stop sending you marketing messages at any times by logging in to the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any newsletter sent to you, or by contacting us at any time.

Where you opt out of receiving the newsletter, this will not apply to personal data provided to us as a result of membership of a club as we will still need to contact you regarding your membership

As a non-member, you can ask us or third parties to stop sending you marketing messages at any time by contacting richard.goodley@thewisley.com.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain why we require to do so. Please note that we may process your personal data without your knowledge or consent where this is required.

6. Disclosures of your personal data

Third Party Service Providers.

We employ other companies and individuals to perform functions on our behalf and fulfil our obligations. Examples of such activity include carrying out surveys, analysing data, providing marketing assistance, social network, hosting providers, data storage providers and other technical providers. They have access to personal information in accordance with this privacy notice and are permitted by applicable data protection laws. Our website may include links to our 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 our website, we encourage you to read the privacy policy of every website you visit.

7. International transfers

Some of our external third parties are based outside the European Economic Area (EAA), so their processing of your personal data will involve a transfer of data outside the EAA. Whenever we transfer your personal data out of the EAA 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 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 Europe and the US.

By downloading our Club app, you consent to your personal data being transferred outside the UK. Please refer to Pacesetter’s privacy policy presented to you when downloading the Club app for further information on how Pacesetter will process your personal data.

8. Data security

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

You have the right to ask The Wisley Golf Club plc to provide you with all the information it stores on you. You can make a Data Access request by contacting richard.goodley@thewisley.com.

You have the right to ask The Wisley Golf Club plc to rectify, block, complete and delete your personal data and to restrict its use. You also have the right to object to the processing of your data by The Wisley Golf Club plc in some circumstances and, where we have asked for consent to process your data, to withdraw this consent.

You may contact richard.goodley@thewisley.com if you would like assistance with any of the aforementioned rights.

There are exceptions to these rights, however, for example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if The Wisley Golf Club plc is legally prevented from disclosing such information. In addition, The Wisley Golf Club plc may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.

9. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under the Data Protection you have certain rights.

Request access – to your personal data (commonly known as ‘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, 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 for 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.

Request the transfer of your personal data to you or to a third party – we will provide it to you, or a third party you have chosen, in a 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.

If you wish to exercise any of the rights set out above please contact the Data Privacy Manager, richard.goodley@thewisley.com.

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.

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 will 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.