Privacy policy 1. Introduction In order to comply with the relevant legislation in place from time to time, including the General Data Protection Regulations (“GDPR”), this document sets out my Privacy Policy, which details how I will collect and use your personal information. 1.1 I am committed to safeguarding the privacy of my clients and visitors to my website. 1.2 This policy applies where I am acting as a data controller with respect to the personal data of my clients and visitors to my website (i.e. I determine how your data is used). 1.3 I will only retain such personal data as is necessary for the smooth operation of my business, and if you have concerns as to what data I hold in relation to you, I am happy to discuss this with you at any time, so please do not hesitate to get in touch with me. 1.4 In this policy, “I”, "we", "us" and "our" refer to Paul McKay Golf Coach, and any authorised employees of Paul McKay Golf Coach. For more information, please see Section 13 below. 2. Collection & Consent 2.1 Your personal data will be collected either directly from you, to me in person or through my web contact form or other electronic means, including via cookies on my website. More details on the sourcing of your personal data is available at Section 3 below. 2.2 By using my website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy, which are set out at Sections 9-12 below. 3. How we use your personal data 3.1 In this Section 3 we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing. 3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is *********** This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is pursuance of our legitimate interests, namely monitoring and improving our website and services. 3.3 We may process your information to build up your client profile ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details, together with notes monitoring your progress and attainments throughout your use of our services. The profile data may be processed for the purposes of enabling and monitoring your use of our website and our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 3.4 We may process information contained in any enquiry you submit to us regarding our goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, signified by the action of submitting your information electronically on our website. Our secondary legal basis is pursuing our legitimate business interests. 3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business. This processing may be carried out by a third party service provider as a Data Processor. They will only act in accordance with our specific instructions as Data Controller of your personal information, and in accordance with this Privacy Policy. All third party processors used by us will be GDPR compliant. 3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the pursuance of a legitimate business interest, namely the proper administration of our business and communication with you. 3.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 3.11 We may process data in relation to any health conditions that you disclose to us that may need to be taken into consideration when providing goods and services to you. (“health data”). This data may include details of health conditions, previous surgeries or injuries, pregnancy, allergies or any other health related matter. The source of this data will be you. This data may be processed to ensure that our services and goods are delivered to you in an appropriate manner. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and to ensure the proper administration of our business. 3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. 3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing 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. 3.15 Please do not supply any other person's personal data to us, unless we prompt you to do so. 4. Providing your personal data to others 4.1 We may disclose your personal data to such third party data processors who, from time to time, provide us with our payment and booking services but only in so far as is reasonably necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 4.3 We may disclose your personal data to such third party data processors, who, from time to time, provide us with our email marketing and communication platform for the purposes of maintaining our email and marketing service. 4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 5. International transfers of your personal data 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). 5.2 The hosting facilities for our website are situated in the UK. 5.3 From time to time we may use third party data processors for the purposes of maintaining our online booking and payment system and our direct email marketing and communication systems that may be located outside of the European Economic Area. We will ensure that, prior to the use of any such third party data processors, the European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries and the transfer of the data will be will be protected by such appropriate safeguards as are recommended from time to time. 5.4 You acknowledge that any personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. 6. Retaining and deleting personal data 6.1 This Section 6 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. 6.2 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. 6.3 We will retain your personal data for as long as you are a service user, or a subscriber to our mailing list, and for a further period for ten years after your death (where your death is made known to us) 6.4 Notwithstanding the other provisions of this Section 6, 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. 7. Amendments 7.1 We may update this policy from time to time by publishing a new version on our website. 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 7.3 We may notify you of changes to this policy by email or through the private messaging system on our website. 8. Your rights 8.1 Your principal rights under data protection law are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent. 8.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will , upon written request, supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 8.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. 8.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. 8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. 8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. 8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 8.10 To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. 8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 8.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8. 9. About cookies 9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 10. Cookies that we use 10.1 We use cookies for the following purposes: (a) [authentication - we use cookies [to identify you when you visit our website and as you navigate our website][ (cookies used for this purpose are: [identify cookies])]]; (b) [status - we use cookies [to help us to determine if you are logged into our website][ (cookies used for this purpose are: [identify cookies])]]; (c) [personalisation - we use cookies [to store information about your preferences and to personalise the website for you][ (cookies used for this purpose are: [identify cookies])]]; (d) [security - we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally][ (cookies used for this purpose are: [identify cookies])]]; (e) [advertising - we use cookies [to help us to display advertisements that will be relevant to you][ (cookies used for this purpose are: [identify cookies])]]; (f) [analysis - we use cookies [to help us to analyse the use and performance of our website and services][ (cookies used for this purpose are: [identify cookies])]]; and (g) [cookie consent - we use cookies [to store your preferences in relation to the use of cookies more generally][ (cookies used for this purpose are: [identify cookies])]]. [additional list items] 11. Cookies used by our service providers 11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: [identify cookies].] 11.3 [We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.] OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.[ The relevant cookies are: [identify cookies].] 11.4 We use [identify service provider] to [specify service]. This service uses cookies for [specify purpose(s)]. You can view the privacy policy of this service provider at [URL].[ The relevant cookies are: [identify cookies].] 12. Managing cookies 12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). [additional list items] 12.2 Blocking all cookies will have a negative impact upon the usability of many websites. 12.3 If you block cookies, you will not be able to use all the features on our website. 13. Our details 13.1 This website is owned and operated by [name]. 13.2 “Paul McKay Golf Coach” and “Paul McKay Golf” are the trading names of Paul McKay, a Sole Trader. 13.3 Our principal place of business is at Broadlees Golf, Chapelton, ML10 6RG. 13.4 You can contact us: (a) 32 Warwick, East Kilbride G74 3PZ (b) by using our website contact form; (c) by telephone, on 07734816223 or such other contact number as is published on our website from time to time; or (d) by email, to paul@paulmckaygolf.co.uk or such other email address as is published on our website from time to time 14. Data protection officer 14.1 Our data protection officer's contact details are: Paul McKay, 32 Warwick, East Kilbride G74 3PZ. Telephone 07734816223 email – paul@paulmckaygolf.co.uk.