Privacy policy

Information on the processing of personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

1. Data controller

Controller: Golf Malca, S.L.
Tax ID: B10557874
Address: C/ Enrique Granados, 6 A, 28224 Pozuelo de Alarcón (Madrid, Spain)
Email: booking@esteponagolf.com

2. Data we process

We process the data the user provides through the Site's forms:

· Contact form: name, email, phone (optional) and message.
· Events form: in addition to the above, event type, estimated date and number of guests.

· Browsing data, only if you accept analytics cookies: pseudonymous Google Analytics identifier, pages visited, language, device type and approximate location. We do not collect your name or email this way.

· Cookie-free visit counter, always on: page visited, referring site, language, device type, browser, system, country and clicks on bookings, phone, email and WhatsApp. It stores nothing on your device and not your IP address: a visitor is counted with a fingerprint calculated on the server that changes every day, so you cannot be followed from one day to the next.

We do not process special categories of data. Nor do we request data from minors; if we detect that a user is under 14, their data would be deleted.

3. Purpose of processing

Data is processed in order to handle the query or request made and, where applicable, to manage the organisation of events or bookings. It will not be used for purposes other than those indicated without a new express consent.

If you accept analytics cookies, browsing data is used to measure in aggregate how the Site is used and to improve it.

The cookie-free visit counter is only used to know, in aggregate, how many people visit the Site and which pages they read.

4. Legal basis

The legal basis for processing is the consent of the data subject, given when submitting the form (article 6.1.a of the GDPR).

For analytics, the legal basis is your consent in the cookie banner (article 6.1.a of the GDPR), which you can withdraw at any time from "Cookie settings" in the footer.

For the cookie-free visit counter, the basis is the club's legitimate interest in knowing how its website is used (article 6.1.f of the GDPR), with minimal processing that identifies no one. You can object by writing to booking@esteponagolf.com.

5. Retention period

Data will be kept for as long as necessary to handle the request and, thereafter, for the periods legally required to address any potential liabilities. When no longer necessary, it will be deleted using appropriate technical measures.

Google Analytics data is kept for 14 months.

Cookie-free visit counter data is kept for 25 months.

6. Recipients

No data will be transferred to third parties except by legal obligation. Data may be processed by technology providers acting as data processors (for example, the hosting and database provider), subject to the guarantees required by the GDPR.

For analytics, Google Ireland Limited acts as data processor. There may be international transfers to the United States, covered by the EU-US Data Privacy Framework and standard contractual clauses.

The visit counter is provided by Polargate, the studio that maintains the website, as data processor.

7. Rights of the data subject

The user may exercise at any time their rights of access, rectification, erasure, objection, restriction of processing and portability, as well as withdraw the consent given, by writing to booking@esteponagolf.com and indicating the right they wish to exercise.

They also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if they consider that the processing does not comply with current regulations.