PRIVACY POLICY

1. IDENTIFICATION OF THE PROCESSING RESPONSIBLE :

The controller is: the company GOLFY CLUB RÉSEAU, SAS with capital of €229,588.22, registered in the Montpellier Trade and Companies Register under number B 415 008 150, whose registered office is located Domaine de Massane, 34670 BAILLARGUES, below “GRIPRÉSA”.

GRIPRÉSA can be contacted at the following coordinates:

- By mail to: GRIPRÉSA- GOLFY CLUB RÉSEAU, Domaine de Massane, 34670 Baillargues.
- By e-mail: contact@golfy.fr - By telephone: 04 67 91 25 35 (price of a local communication from France, from a fixed post, excluding any additional cost of the operator) from Monday to Friday, 9 am to 12 pm / 2 pm to 5 pm.


2. PURPOSE OF THE PRIVACY POLICY :

The purpose of this Privacy Policy, hereinafter the "Privacy Policy", is to specify the conditions under which GRIPRÉSA, as controller, collects and uses personal data from users (hereinafter the “Users”) in connection with the use of the website (the “Site”) that it publishes and the reservation service it offers.

In connection with the use of GRIPRÉSA services, its navigation on the Site, and generally its exchanges with GRIPRÉSA, the User is required to communicate personal data about him or about third parties. This is particularly the case when a User (i) creates a customer account, (ii) makes a reservation for himself or for a third party, (iii) agrees to receive notifications and (iv) exchanges with FLU by phone, mail or e-mail.

In accordance with the provisions of European Regulation No. 2016/679 of 27 April 2016, known as the “General Data Protection Regulation” or “GDPR”, and the amended French Data Protection Act, GRIPRÉSA ensures the collection and processing of personal data under the conditions described below.


3. CHANGES TO THE PRIVACY POLICY :

GRIPRÉSA may be required to modify this Privacy Policy, in particular to comply with any regulatory, case law, editorial or technical changes. If applicable, the date of the header update hereto will be modified.

When necessary, Users will be informed or asked for their consent. It is advisable to consult this Privacy Policy page regularly to be informed of any changes or updates that may be made.


4. CATEGORIES OF PERSONAL DATA CONCERNED :

The categories of personal data that GRIPRÉSA may collect and process are:

• Identification data: first name, last name, country;
• Login data: username, password;
• Contact information: email address, mailing address; telephone number (see bloctel);
• Loyalty data: Hold a Golfy card, card type and number, as well as its activation and expiry dates;
• Sport-related data: FFG license number and ranking;
• Bank data: Payment made or not, provided that GRIPRÉSA does not have access to the bank transaction data and the means of payment used, as long as the payment is made via a dedicated payment platform (STRIPE) which ensures payment directly to the golf beneficiary of the reservation;
• Transaction data: bookings made (date, nature, golf concerned), bookings executed, modified, cancelled or refunded;
• Navigation Data: Customer account connections; Internet URL of links through which the User accessed the GRIPRÉSA
• Technical data: terminal used, User’s internet browser, OS, IP address, MAC number.

When collecting data through forms, the mandatory or optional character of certain data fields is indicated by the presence of an asterisk. Personal data identified by an asterisk are mandatory. If the field is not populated, the query cannot be processed.

The User acknowledges that, by voluntarily communicating the required data, he accepts that these data are processed under the conditions and for all the purposes indicated below.


5. CATEGORIES OF PERSONAL DATA CONCERNED :

GRIPRÉSA collects personal data directly from Users, in particular at their own initiative, in particular through the creation of a customer account or the reservation that may be made by a User, on its own behalf or on behalf of a third party.


6. CATEGORIES OF PERSONAL DATA CONCERNED :

The data shall be collected and processed for the following purposes and on the basis of the following legal bases:

• Online booking management, tracking and transmission to partner golf courses; processing is contract based.
• Customer account management; processing is contract based.
• Customer or player relationship management (if different from customer); processing is based on the legitimate interest of GRIPRÉSA to monitor customer relations, measure User satisfaction and improve its services.
• Management and operation of the Site and access to the different spaces of the Site; processing is based on the legitimate interest of GRIPRÉSA to ensure the safety and proper functioning of the Site and the legitimate interest of Users to benefit from the free features offered on the Site.
• Respond to requests from Users and in particular to any request for information or contact regarding the services offered by grip-resa.com; processing is based on the legitimate interest of GRIPRÉSA to respond to Users' requests and the legitimate interest of Users in obtaining a response.
• Contact the Users for commercial or marketing purposes; the processing is based on consent, it being specified that the Users can withdraw it at any time by sending a simple mail or e-mail to the contact details at the top of this document.
• Accounting management, anti-fraud and money laundering; processing is based on compliance with a legal obligation.

No personal information is collected or published without the User's knowledge, exchanged, transferred, assigned or sold on any medium whatsoever, to third parties without the User's consent. Only the assumption of the purchase of GRIPRÉSAand its rights would allow the transmission of said information to the prospective purchaser who would in turn be held the same obligation to store and modify data vis-à-vis the user of the site www.grip-resa.com .

Moreover, GRIPRESA is authorized to carry out studies and statistical analyzes on the use and topology of users of the Site GRIPRESA, subject to confirming their anonymity.
Finally, the data is not subject to automated decision-making (including profiling). It is nevertheless specified that non-member Users Golfy or former members Golfy for more than 3 years who make a reservation on the site GRIPRESA will automatically receive an email offering them the free Golfy card. This sending does not generate any legal effect on the User and does not limit his rights in any way. If the User wishes to benefit from the card, he will simply be invited to complete and return the form attached to the e-mail.
The User is in any case free to refuse the benefit of this card and to oppose new proposals for the provision of the Golfy card by grip-resa.com. It is recalled in this respect that the Site grip-resa.com is administered by the same legal structure as that which administers Golfy loyalty cards.


7. DATA RECIPIENTS :

The recipients of the data are, within the limits of their respective powers: (I) the members of GRIPRÉSA in charge of the relationship with Users, especially the marketing and sales department, the department in charge of the loyalty program via the Golfy card, the digital / Web department as well as (II) the providers of GRIPRÉSA likely to intervene within the framework of the aforementioned purposes, especially its IT service providers and hosts and (III) the Golf Partners responsible for performing the service reserved online.

The data is stored and processed within the European Union.


8. DATA STORAGE DURATION :

The data retention period is:

• For booking management:
- For the entire duration of their execution.
- Beyond:
      • for data relating to the contract: for five years as evidence of the contract under the Civil Code; and,
      • for accounting data: for ten years under the accounting obligations under the Commercial Code.

• For sales or marketing: for three years from the last online reservation or the last request from the User to
GRIPRESA or the User's last response to a request from GRIPRESA (retain the deadline longest of the three), unless the User has withdrawn his consent before this deadline.

• For a period of 12 months from their deposit on the User's terminal with regard to connection data and for the periods indicated below for data collected through cookies.


9. DATA SECURITY AND PRIVACY :


10. PERSONAL RIGHTS :

With respect to personal data concerning him, the User has a right of access and a right of rectification for all data concerning him and, if applicable, a right of deletion, a right to oppose the processing of this data, a right to erasure and limitation of processing as well as a right to data portability. He also has the right to formulate specific and general directives concerning the storage, erasure and communication of his post-mortem data. He can exercise these rights, at any time, electronically or by post, by sending you a letter or an e-mail to the contact details appearing at the top of this document.

Furthermore, pursuant to Article L.223-2 of the Consumer Code, the User is reminded that, if he does not wish to be the subject of commercial prospecting by telephone, he has the possibility of register free of charge on the list of opposition to cold calling via the website
Bloctel. This list is binding on all professionals with whom the User does not have a contractual relationship in progress.

In the event of a dispute relating to the processing of his personal data, the User lodge a complaint with the supervisory authority, in this case the CNIL.


11. COOKIES :

For optimal use of the Site, GRIPRESA uses files called "cookies", which may be saved on the User's terminal. A cookie is a text file stored by the browser, which allows it to retain information between web pages and browsing sessions.
The user can refer to the site of the CNIL to obtain additional information on cookies: https://www.cnil.fr/fr/cookies-et-traceurs- what-says-the-law.

These cookies record information relating to navigation and store information that the User has entered during his use of the Site.
The Site uses cookies necessary for the operation of the Site, but also cookies relating to the production of statistics (anonymous).

These cookies are:

COOKIE NAME COOKIE UTILITY RETENTION PERIOD
reservation_api_session Allows you to manage the connection and the shopping cart. 31 Days
__stripe_mid Used by the company Stripe (online payment) to prevent possible fraud. 1 Year


Optional Cookies
localize.page.confidentials.article_11_table2_colLabel_1 localize.page.confidentials.article_11_table2_colLabel_2 localize.page.confidentials.article_11_table2_colLabel_3
localize.page.confidentials.article_11_table2_lineLabel_1 localize.page.confidentials.article_11_table2_lineDuration_1
localize.page.confidentials.article_11_table2_lineLabel_2 localize.page.confidentials.article_11_table2_lineDuration_2


If the User does not want such cookies to be installed on his terminal, he can modify his browser preferences to refuse them in whole or in part. Such a refusal may, however, affect the use of the Site and the reservation services offered.
To delete and manage cookies, the user is invited to refer to the dedicated help pages of his browser.
The access links for the main browsers are as follows:

  • Google Chrome
  • Safari
  • Firefox
  • Opera


The User can also configure his browser so that it indicates to the sites consulted his wish not to be tracked ("Do Not Track").
The User can also block tracking from social network buttons on the reference pages of the networks concerned. The User is invited to read the management policy for these social network cookies on the sites concerned. Button blocking can also be achieved using the free software extension Privacy badger