PRIVACY POLICY

 

I.                   CONTROLLER

 

Contact details of the person in charge: GOLF MALCA, SL. , with registered office located in Santa Engracia, 14, 28010, Madrid (hereinafter ESTEPONA GOLF)

 

Contact details of the Data Protection Officer: you can contact him/her at the above-mentioned postal address and/or by e-mail: delegadopd@globalia.com.

 

II.                SCOPE OF THE POLICY

 

When you access and use this website or use any other means that involves the processing of personal data, you agree to accept this Privacy Policy, as well as the provisions contained in the Legal Notice and the Cookie Policy.

 

At ESTEPONA GOLF we provide you with information so that, prior to filling in your personal details, you can access the Privacy Policy and any other relevant information regarding Data Protection.

 

 

III. PURPOSES OF DATA PROCESSING

 

In what cases are personal data requested?

 

- To subscribe to the ESTEPONA GOLF newsletter.

 

- To request any of the services and/or products we offer.

 

 

What use will we give to the personal information we use?

 

- To manage queries, complaints/incidents, claims and requests made by the user/customer.

 

- To manage the sale of our services and any other described on our website, as well as to provide follow-up services.

 

- To manage connection and navigation data obtained through analysis tools (cookies).

 

- Single access intranet for partners.

 

How long will we keep your data?

 

The period of time for which personal data is kept will vary depending on the purpose for which it was collected, from contacting the user who requests it, to the actual contracting or not of our services.

 

Subsequently, we will keep your data blocked during the periods of prescription of the obligations that may have arisen from the processing and/or the applicable legal periods (maximum of 5 years), remaining at the disposal of the competent authorities, for the attention of the possible responsibilities arising from the processing.

 

 

IV. LEGITIMATION

 

- The unambiguous consent of the interested party himself, based on Article 6.1.a) of the RGPD.

 

- Obtained through the acceptance of cookies and other analysis tools.

 

- Obtained through the box prepared for this purpose when the user has registered for the ESTEPONA GOLF newsletter

 

- Management of pre-contractual and, where appropriate, contractual measures, based on Article 6.1.b) of the RGPD.

 

- Once the service requested has been contracted, maintain and review the compliance of the products and services contracted with ESTEPONA GOLF.

 

- By browsing the Web Site and accepting the Conditions of Use of the same.

 

- With respect to clients who can access the intranet, to be able to manage the connection to it.

 

- Compliance with legal obligations, based on article 6.1.c) of the RGPD.

 

- In cases in which the interested party exercises rights that will be indicated below.

 

- As a consequence of the legal actions that are promoted by or directed against ESTEPONA GOLF. are followed before the bodies of the Administration of Justice. Thus, as is informed in the Legal Notice and Conditions of Use, with regard to those users who make a bad faith, abusive, inadequate and/or illicit use of the Website, ESTEPONA GOLF will inform, where appropriate, the competent authority, including the State Security Forces.

 

- The legitimate interest based on article 6.1.f) of the RGPD.

 

- For the sending of electronic communications to the user who is a Client and who has not objected, provided that the services of ESTEPONA GOLF are related and without prejudice to the right to object to such sending at any time.

 

 

V. TARGETS

 

To whom do we give your data?

 

Competent public bodies, the Tax Agency, State Security Forces and Corps, Judges and Courts, when ESTEPONA GOLF is legally obliged to provide them.

 

In no case will your personal data be shared with third companies without your prior consent, unless the transfer of your data is necessary for the maintenance of the relationship with you, as well as in the cases provided for by the data protection regulations in force at any given time.

 

 

VI. DATA PROTECTION RIGHTS 

 

How can the rights be exercised? 

You can send a written communication to the registered office of ESTEPONA GOLF or to the e-mail address delegadopd@globalia.com, including in both cases a photocopy of your ID card or other similar identification document, to request the exercise of the following rights: 

- Right to request access to personal data: you may ask ESTEPONA GOLF if this company is processing your data. 

- Right to request rectification or deletion of data. 

- Right to oppose processing: ESTEPONA GOLF will stop processing the data in the manner you have indicated, unless the exercise or defence of any possible claims requires further processing. 

- Right to the portability of the data: in the event that you wish your data to be processed by another entity, ESTEPONA GOLF will provide the portability of your data to the new person in charge. 

- Right to request the limitation of their processing, in which case they will only be kept by ESTEPONA GOLF for the defence of any possible claims. 

- Possibility of withdrawing consent: in the event that consent has been given for a specific purpose, you are entitled to withdraw the consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal. 

 

In any case, we provide you with a form that will allow you to exercise the above-mentioned rights more easily and quickly by sending it to the contact address of the Data Protection Delegate. 

 

How can you complain to the Control Authority? 

If a user considers that there is a problem with the way in which ESTEPONA GOLF is handling his or her data, he or she can direct his or her complaints to the Data Protection Delegate or to the corresponding data protection control authority, the Spanish Data Protection Agency being the one indicated in the case of Spain. 

 

VII. SECURITY  

 

At ESTEPONA GOLF we maintain the highest levels of security required by law to protect your personal data against accidental loss and unauthorised access, processing or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which it is exposed. When we receive your data, we use rigorous procedures and security functions to prevent any unauthorised access. 

 

The actions described in this section and designed to ensure a level of security appropriate to the risk detected will include, if necessary, the following measures:

 

1. Pseudonymisation and encryption of personal data 

2. Measures capable of guaranteeing the permanent confidentiality, integrity, availability and resilience of the processing systems and services. 

3. Measures capable of restoring the availability of and access to personal data quickly in the event of a physical or technical incident. 

4. Existence of a process of regular verification, evaluation and assessment of the effectiveness of the technical and organisational measures to guarantee the security of the processing. 

5. Periodic assessment of the risk of accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data. 

6. Measures to ensure that any person acting under the authority of ESTEPONA GOLF and having access to personal data can only process such data following instructions from ESTEPONA GOLF. 

 

VIII. CONFIDENTIALITY 

The personal data that may be collected will be treated with absolute confidentiality, committing us to keeping them secret and guaranteeing the duty to safeguard them by adopting all necessary measures to avoid their alteration, loss and unauthorised processing or access, in accordance with the provisions of applicable legislation. 

 

IX. LIABILITY 

The user will be solely responsible for the completion of the forms with false, inaccurate, incomplete or outdated data. 

 

X. COOKIES 

Our website uses "cookies" to collect information on how the website is used. For more detailed information on how ESTEPONA GOLF uses cookies, please refer to the Cookie Policy. 

 

XI. UPDATING THE PRIVACY POLICY 

ESTEPONA GOLF may modify this privacy policy as a result of legislative changes, jurisprudential doctrine and opinions of the AEPD that are directly, indirectly or sectorally applicable. 

All the changes, modifications or amendments that we introduce in our Web Privacy Policy will be published in this page. 

 

Updated in October 2020