Privacy Policy

1. Data Use Policy

LeClub Golf, the data controller, and Scal-e, the technical operator responsible for collecting and processing data on behalf of LeClub Golf, attach great importance to protecting and respecting your privacy.

This policy is intended to inform you about our practices regarding the collection, use and sharing of information that you may provide when subscribing to our newsletter and/or our loyalty programme. We invite you to read this document to learn about and understand our practices. Each time you register, you must confirm that you have read and accepted its terms in order to complete your registration.

2. Data Collected

2.1 Personal Data

The personal data collected may include the following: title, surname, first name, personal postal address, business postal address, email address, landline telephone number, mobile telephone number, fax number, language spoken, date of birth, marital status, occupation, social media identifier, photograph, and the surname, first name, gender and date of birth of children. Interpersonal relationships (e.g. family, professional, friendship, etc.).

2.2 Behavioural Data

The behavioural data collected may include the following (depending on your level of interaction and whether you subscribe to the newsletter or the programme):

• Visits to equipped customer areas
• Purchase amount, date and details
• Opening and clicking emails
• Receipt of text messages
• Use of promotional offers
• Responses to satisfaction surveys

Information is also collected about the type of device used to access the online services managed by our technical operator, Scal-e, and its IP address.

2.3 Locally Stored Data and Cookies

Cookies are placed when you browse your customer area and the service’s other websites in order to make navigation and login easier and to save your layout preferences.

Mobile devices may be geolocated with the user’s consent, for example to allow the user to search for a nearby store. This information is not stored on the servers.

User-preference cookies are also placed to save login details for faster access to online areas and to retain display preferences.

Cookies are also placed through services such as Google Analytics to count visits and page views and analyse our users’ journeys. This data collection helps optimise usability and improve the functionality of the services provided by our operator, Scal-e. No cookies related to advertising targeting are placed. Finally, when you use social-media sharing features as a user, cookies may also be transferred.

To object to the use of cookies, you can change your browser settings: more information here.

2.4 Purposes of Processing

The data collected about you is processed electronically for the following purposes:

• For newsletter subscriptions or receipt of special deals and offers: creation of a database intended for targeted promotional communications by email, post or SMS/MMS, in accordance with the consent you have given for each channel.
• For registration in the programme and/or the online customer area: creation of a customer database intended to operate a loyalty programme. As part of the programme, you will receive information about your account and the programme. These non-promotional communications form part of the programme you chose to join.

Data collected through votes or the submission of customer reviews may be used to contact users again. This data will also be used for statistical purposes:

As part of game interruption insurance, which is one of the benefits of the Classic or Gold card, your personal data (surname, first name and card number) is sent to our partner Gras Savoye so that the reimbursement can be processed correctly.

2.5 Communications Sent

Communications sent as part of the programme through our operator, Scal-e, include in particular:

• Programme welcome message
• Appointment confirmation
• Purchase confirmation
• Satisfaction surveys
• Password reset
• Notification that a benefit has been awarded
• Message marking a special occasion (e.g. a birthday)

Promotional communications outside the programme sent through our operator, Scal-e, always comply with opt-in consent requirements. Users may withdraw this consent at any time:

• For emails: a link at the bottom of every email to the unsubscribe page
• For SMS messages: STOP requests are processed and the number is added to a blocklist

Transactional emails relating to the loyalty programme, including point balances, expiry alerts, renewals, welcome messages, gift-shop reservations, gift cards and points earned from a purchase, cannot be unsubscribed from. If the cardholder no longer wishes to receive this type of communication, they must end their participation in the LeClub Golf loyalty programme by sending an email to contact@leclub-golf.com

2.6 Right of Access, Amendment and Erasure

Right of access and amendment. You can access the data concerning you, amend it or change your communication preferences:

• in your online customer area
• by writing to LeClub Golf Customer Service, 5 rue Archimède, 33706 Mérignac, or to the programme’s technical operator, Scal-e – Green Park I, 298 allée du lac, 31670 LABEGE, stating your surname, first name, address and email address so that your request can be processed more quickly.

Right of access: you also have the right to receive a copy of the personal data we hold about you.

Right to erasure: you may request the deletion of your personal data. Please note that we may retain certain information about you where required by law.

Right to object: an unsubscribe link is always accessible and available at the bottom of every communication sent by our operator, Scal-e. This unsubscribe page can be accessed here. You may also object to the processing of your data on legitimate grounds. To learn more, consult your rights on the CNIL website: https://www.cnil.fr/fr/le-droit-d’opposition.

In accordance with Article L. 223-2 of the French Consumer Code, customers are informed of their right to register on the telephone marketing opt-out list available on the website www.bloctel.gouv.fr.

For all such requests, you can contact LECLUB GOLF Customer Service at contact@leclub-golf.com / 5 rue Archimède, 33706 Mérignac.

2.7 Password Confidentiality

You are responsible for keeping confidential the password you chose to access your account in the online customer area. You agree to keep this password secret and not disclose it to anyone.

2.8 Data Retention and Security

Our operator, Scal-e, has implemented the following measures:

• Hashed and salted passwords.
• Data associated with no activity is anonymised after 3 years of inactivity and then permanently deleted after 5 years, unless a specific request is received before that date.
• Data is stored in secure data centres located in Europe, in accordance with applicable regulations.

2.9 Changes to the Data Use Policy

We may occasionally amend this Data Use Policy. Where necessary, we will inform you and/or seek your consent. We recommend that you check this page regularly for any amendments or updates.

2.10 Contact

For any question relating to this Data Use Policy or any request concerning your personal data, you can contact us by sending an email to LECLUB GOLF Customer Service at contact@leclub-golf.com.

LECLUB GOLF
contact@leclub-golf.com
www.leclub-golf.com
+33 5 57 21 19 90
5 rue Archimède, 33706 Mérignac

2.11 CNIL

If the request remains unanswered within the time limits set by the GDPR, or if the response is unsatisfactory, the data subject may lodge a complaint with the CNIL, either through its website or by post at the following address: CNIL – Complaints Department – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

3. Data Retention Period

Our data relating to the LeClub Golf loyalty programme is retained according to the following criteria:

Profile : Active member
Retention criterion: Valid LeClub Golf loyalty card and active status
Retention period: No deletion while the status remains active

Profile : Former member (expired card)
Retention criterion: LeClub Golf loyalty card has expired
Retention period: Deletion if: the LeClub Golf loyalty card has expired, no purchase has been made for more than 2 years and no communications have been accepted

Profile : Prospect
Retention criterion: No purchase made
Retention period: Deletion if: no purchase has been made for more than 2 years and no communications have been accepted

3.1 Cumulative Conditions for Deletion

For former members and prospects, data is deleted when all of the following conditions are met:

1. LeClub Golf loyalty card has expired (former member) or no purchase has been made for more than 2 years (prospect);
2. The person has not consented to receive our communications by email and/or SMS, or has withdrawn their consent.

Conversely, data is retained for as long as active-member status is maintained (valid LeClub Golf loyalty card and active programme) or the person has agreed to receive our communications.

3.2 Legal Exceptions

Certain data may be retained beyond the periods stated above where required by a legal or regulatory obligation (e.g. invoicing, tax limitation periods or the defence of legal rights), in accordance with Articles L. 123-22 of the French Commercial Code and 222-32 of the French General Tax Code.