Privacy Policy

1. Who are we?

The Royal Amicale Anderlecht Golf Club c/o G.Action (R.A.A.G.C. – hereinafter “the Club”) acts as controller when processing your personal data in the framework of its activities as golf club.

Our contact information is the following:

Rue Schollestraat 1
1070 Anderlecht, Brussels
Tel +32 2 521 16 87
E-mail : info@golf-anderlecht.com
Website : www.golf-anderlecht.com
Commercial Registration N°: 0433.210.413

2. Why a Privacy Policy ?

The Club is committed to protect your privacy and personal data. Since the introduction of the General Data Protection Regulation EU/2016/679 (‘GDPR’) on 25 May 2018 and the Law of 30 July 2018 regarding the protection and processing of personal data, the Club specifically undertakes to treat your personal data in a transparent, lawful and correct manner. This Privacy Policy is meant to inform you in the best way possible on the data we collect, the purposes we collect them for and the rights that you have in connection to this data processing.

3. What personal data is collected by the Club and how?

A) Data that you provide directly to us

The majority of the data that we possess, you have provided us directly. You provide us your personal data:

When you fill out a contact form on our website;
When you fill out the registration form “Become a member” on our website;
When you register for and take part in competitions;
Etc.

In particular, it concerns the following personal data:

Your identity information (name, first name, telephone number, postal address, e-mail address);
Your personal characteristics necessary for participating in competitions (gender, age, pictures and other images);
Your sporting information (ranking, handicap (previous and current), registration for activities, athletic history, homeclub, federation number, etc.);
Your banking and payment information (payment card number, IBAN and BIC/SWIFT-code) and invoicing information necessary for the processing of payments;
Our correspondence (for example, e-mails)

B) Automatically collected data

B.1. Comments

When you place a comment on our website, the information in the comment form, your IP-address and browser operator are collected by us so that we may detect and delete unwanted comments.

An anonymised code generated on the basis of your e-mail address (also known as a hash) may be sent to the Gravatar-service to verify whether you effectively use this e-mail address. The privacy policy of Gravatar is available on the following website: https://automattic.com/privacy/. After the approval of your comment, your profile picture will appear visible next to your comment.

B.2. Content of other websites

The articles on the website may comprise of embedded content (such as videos, pictures, articles, etc.). The embedded content of other websites operates in the same manner as when the visitor would interact with that content on the website of the owner.

The websites from which certain content is embedded could collect some of your personal information, use cookies or third-party tracking, or monitor your use of their content if you have an account on their website..

B.3. Media

If you are a registered user and upload pictures on our website, we recommend that you do not upload any images which contain EXIF data or GPS coordinates. Visitors on our websites might download and extract location data from such images.

B.4. Cookies

If you place a comment on our website, we will ask you to save your name, e-mail address and website-information as a cookie. We only do this for your convenience so that you do not have to re-enter this information when you want to place an additional comment on our website. Such a cookie expires after one year.

If you have an account and you log in on our website, a temporary cookie is created to assess whether your computer accepts cookies. These cookies do not contain any personal data and will automatically be deleted after you have closed your browser.

When you use our website, we make use of different cookies to collect certain information on your connection and screen preferences. The duration of such a connection cookie is two days, that of a screen preference cookie one year. If you click on “remember me”, your connection cookie will be retained for two weeks. When you log out, the connection cookie will be deleted.

By editing or publishing a comment or publication on our website, an extra cookie will be saved in your browser. This cookie does not contain personal data. The cookie only indicates the ID of the publication that you have just edited or published. This cookie expires after one day.

You can find more information on cookies on the website of the EU. You can refuse the installation of cookies in your browser preferences. At any given time, you can delete the cookies that are already installed on your computer or mobile device, in the following ways (external links) :

Internet Explorer
Edge
Google Chrome
Mozilla Firefox
Safari

4. For which purposes does the Club process personal data ?

We process and use your personal data only in so far it is necessary for:

Goal	Legal basis
The registration of members of the Club and the Golf federations (RBGF, Flandres, Wallonia)	Performance of the club-agreement
The daily management of the Club (administration; access to installations; handicap; ranking; activities related to the Club-house and the Pro-shop, etc.)	Performance of the club-agreement
The organisation of competitions	Performance of the club-agreement
The processing of payments (contribution, play duty, etc.)	Performance of the club-agreement
The sending of invitations or newsletters	Your consent and our legitimate interests
The processing of your complaints (in particular via the contact form)	Our legal obligations and our legitimate interests
The rendering of statistics and spectator numbers	Our legitimate interests and the performance of the club-agreement
The reporting on our website (including pictures)	Your consent and our legitimate interests
The compliance with our legal obligations	Our legal obligations
The protection of your safety (including the insurance of our members)	The protection of your vital interests and those of others and the performance of the club-agreement

5. The transfer and publication of your personal data / Transfer outside of the EU?

In irregular circumstances, we may transfer your personal data to third parties when necessary for the purposes provide above.

In the framework of general or specific competitions (ranking, handicap, insurance, etc.), we may transfer your personal data to the following entities:

The Royal Belgian Golf Federation (RBGF)
Golf Vlaanderen (Vlaamse Vereniging voor Golf)
AFGolf (Association Francophone Belge de Golf)
Other members of the Club or the respective Golf Federations
The managers of the Club-house or Pro-shop
Odoo (website)
The applicable insurer

The transfer of the necessary data related to the above purposes is necessary for the performance of the club-agreement and will generally not require your consent.

In the exceptional circumstance that we transfer personal data outside of the EU, we will guarantee that the receiving country retains an adequate level of protection of personal data as recognised by the EU Commission, in other words, that the country’s protection level is equivalent to that of the EU, or that that contractual clauses are used that adequately guarantee the protection of personal data.

We may be obligated to transfer certain of your personal data to public authorities when the prescribed by law, such as in the framework of a police investigation.

6. The use of visual material

During various events organised by the Club, pictures and videos are made of our members with their permission. This visual material may be published on our website, Facebook, or similar outlet. In such instances, the Club will first try to acquire your explicit consent. This consent will normally be obtained at the moment of your registration with the club or to the event. No consent is required in the case of spontaneous, generic pictures or videos which provide a general view on the event or setting, and which do not target specific persons.

7. Retention period of the personal data

In accordance with applicable law, we retain your personal data only for the period that is necessary for the purposes for which they are processed (see article 4). The retention periods are, for example, connected to official tournaments, membership, payment, etc. When you place a comment on our website, this comment and the related metadata will be retained for an indeterminate period. This allows subsequent comments to be recognised and approved automatically without the need for them to wait for approval by a moderator.

For users who potentially register on our website, we also retain the personal data connected to their profile. All users may consult, edit or delete the personal data connected to their account at any given time (except for their username). The website operators may also consult and edit this information.

8. What are your rights and how can you exercise them?

You have the right to obtain information in a clear and transparent manner on the way the Club processes your personal data and on the rights that you can exercise in this regard.

You have the right to request us to consult, correct, update or delete your personal data. You may also request (wholly or partially) that we restrict the processing of your personal data, or that we transfer your personal data to you in saveable and machine-readable format. We may require you to first identify yourself before we react to the abovementioned requests.

To exercise your rights, you may send a request:

By e-mail to: info@golf-anderlecht.com
by post to : Royal Amicale Anderlecht Golf Club, Rue Schollestraat 1, 1070 Anderlecht, Bruxelles

You may also always send a complaint to the competent authority for the protection of personal data, namely the Belgian Data Protection Authority (contact@apd-gba.be, Rue de la Presse 35, Bruxels).

9. Policy concerning minors

We only process the personal data of minors younger than 16 years old after we have obtained the previous consent of their parents or legal guardian. We also recommend that these responsible parties supervise their minors when surfing on our website, in order to minimise all risk on an unauthorised provision of personal data without valid consent.

10. Security, integrity and confidentiality

We apply proper technical and organisational measures in order to prevent the unauthorised access to your personal data, as well as the abuse, unwanted modification, or accidental loss of that data. For this, we retain your personal data in a secured cloud with data centres in the European Union. Access to your personal data is limited to a specific amount of staff members that require this information to provide or optimise our services.

All of our staff is informed of the importance that our Club attaches to the protection of your personal data.

11. Changes to this Privacy Policy

The Club can change or revise this Privacy Policy at any given time. In particular, in case of a revision of the applicable law. In such instance, we will notify you of this via our website. Nevertheless, we advise you to regularly consult this Privacy Policy. The latest version dates from March 1, 2019.