This Privacy Notice explains the types of personal data we collect about you when you deal with us. It also explains what we do with that data, how we keep it safe, and your rights in relation to our processing of it.
We are Golfsavers Co., Ltd (company number 007283), and if you have any questions regarding the way we process your personal data you can get in touch with our Data Protection Officer:
Data Protection Officer
Golfsavers Co., Ltd
55/1, Bandon-Cherngtalay Road,
Cherngtalay, Thalang,
Phuket 8311o
david@golfsavers.com
We are a golf tour operator, and we process your personal data in order to:
We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
The following definitions apply in the sections below:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting david@golfsavers.com.
Contract legal basis means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
How do we process your information when you enquire about our holidays?
We collect some information about you if you make contact with us in order to obtain information before you make a booking. This contact might be made by filling in a form on our website, or by telephone or email. In each case, we might ask you for your:
We will process your personal data so that we can give you the information that you requested, and we rely on the ‘contract’ lawful basis when we perform this processing.
If you provide us with contact details (e.g. an email address) when you request information prior to making a booking, we will also use those contact details in order to send you information about other, similar holidays sold by us in the future. We occasionally use these details to promote products sold by other companies in the Palatinate Group. At the point we collect your contact details (email address, telephone number or postal address) we will ask you if you would prefer not to receive marketing materials from us.
Even if you choose to receive these materials, you can tell us to stop sending them at any point in the future, either by clicking the ‘unsubscribe’ link in an email, by calling us, or by contacting david@golfsavers.com. When we process the personal data received in the course of a sale (or negotiations for a sale) in order to send marketing materials, we are doing so under the lawful basis called ‘legitimate interests’.
When you make a booking with us, we might ask for more personal data so that our suppliers can fulfil our (or their) obligations to you. For example, if you book a flight we will ask for your date of birth and passport number so that we can make the appropriate arrangements with the airline. We will only ask for details that are necessary in order to deliver the services you have booked with us, and we will only process them in order to deliver those services.
The arrangements we make for your holiday are fulfilled by our suppliers: hotels, golf courses, airlines etc. When we confirm your booking we make sure you are aware of all the companies involved in delivering the services you have requested, and we pass on to them only the details that they need so that they can deliver those services. For example, if you book a hotel stay with us we will make sure that they are aware of your name, the date you are arriving, and how long you will stay.
Both we and our suppliers of travel services act as data controllers when you book with us. We never give our suppliers contact details for you unless it is absolutely necessary to provide the services you have requested, and even in this case our contract with them does not allow those details to be used for marketing purposes. They may independently ask if you are happy for them to use you personal data in other ways; if you consent, this will be a direct arrangement between you and them. If you have any questions about how our suppliers process your information you can call us or email dpo@yourgolftravel.com.
Between the time you book with us and the time you travel we may need to contact you directly about your booking using the details you have given us. For example, we might email you in order to request that you pay your balance, or call you to tell you about a change of flight time.
When you book with us we will ask you to make sure that other members of your party are happy for us to process their details in the same way as your own.
We rely on the ‘contract’ legal basis for all of the processing we perform in order to provide the services you have booked with us.
Independently of this, we would like to ask you for a review both of our booking process and of your trip after you have travelled. For this processing we rely on our ‘legitimate interests’, but you can ask us at any time not to process your details for this reason.
When you call us our systems automatically record some details, for example the number you called us from, who you spoke to, and how long you spoke to us for. We also record the audio of all calls in and out of our call centres.
We process this information under our ‘legitimate interests’ in order to help us resolve complaints or disputes. These recordings and call details are kept for long enough that we still have access to them for a reasonable amount of time after each booking has travelled; at present, this time period is 12 months.
How do we process your information when you email us?
When you email us, we keep a record of the email to help us with the administration of your booking and to resolve any complaints or disputes that might arise. We rely on our ‘legitimate interests’ for this processing.
When you visit our websites we keep logs of your visit containing such information as the IP address from which you made each request, the type of browser you were using and the pages you viewed. Unless you explicitly give it to us, for example by making an online booking, we don’t store any information other than your IP address that might identify you to us, and we only keep these logs for long enough to ensure that we are able to fix any technical problems that might arise.
We use Google Analytics in order to analyse how our visitors use our websites, and to measure the effectiveness of our marketing on the Internet. This information is only ever processed in aggregate, and we never link it back to any personal identifier.
All the processing described in the preceding paragraphs of this section relies on the ‘legitimate interests’ lawful basis. Our partners sometimes collect data and use cookies for ad personalisation and measurement, so that ads you see on other sites can be tailored to you. We never allow them to do this without your express consent, which we gather via a ‘pop up’ message on our website.
The Personal Data Protection Act (PDPA) gives you rights regarding the way we process your information, and we aim to allow you to exercise these rights easily.
Right to be informed
We inform you about the ways in which we process your personal data both here and in specific messages you will see on our websites when we record your data. Our call centre staff are also trained to keep you informed about the way your data will be processed throughout the booking process. If you have any questions about the way your data is processed you can contact us by phone, or email david@golfsavers.com.
Right of access
We are always happy to give you a copy of the information we hold about you. We may sometimes ask you for some information to confirm your identity before we are able to send the information, and we may sometimes ask you to clarify your request. You can email any request for the information we hold about you to dpo@yourgolftravel.com.
Right to rectification
If you believe any information we hold about you is inaccurate or incomplete, please let us know by email to dpo@yourgolftravel.com.
Right to erasure
If we are processing any information about you purely for marketing purposes, we are always happy to erase it. If you have made a booking with us, we sometimes have to retain the information in order to comply with the law or, for example, with the obligations imposed upon us by our contract with our insurers. If you contact us to request erasure of the personal data we will comply with your request insofar as we are able, and if we are not able to we will explain why.
Right to restrict processing
If you believe that you have grounds to request that we restrict our processing of your information, please contact us.
Right to data portability
If you request it, we will do our best to provide the information we hold about you in machine-readable form using open formats. The type of information we hold is such that we are unlikely to be able to perform a controller-controller transfer, as there are no open standards relating to such transfers.
Right to object
You have an absolute right to object to processing your personal data for marketing purposes, and we are always happy to comply with requests to exercise these rights. We will do our best to comply with other requests to stop processing your data, but in some circumstances we will be unable to – if that is the case, we will always explain why.
Rights related to automated decision making including profiling
We do not perform any automated decision making or profiling using the personal data that we process.
We have agreements with third parties (data processors) who process personal data for us in accordance with our instructions. Below is a list of the data processors who may be processing your data on our behalf, and a brief summary of the type of processing they perform.
Google will process your personal data on our behalf as provider of our email services, as hosting provider for our websites and internal systems and as operator of Google Analytics and AdWords.
Amazon Web Services provides our transactional email services and process, for example, the emailed copy of your booking documents.
Freshdesk (Freshworks Inc.) hosts the system that we use to manage contact with our customer services department.
2c2P and Stripe provide our payment processing services.
Trustpilot hosts the software we use for recording and managing reviews of our booking process.
Mailchimp provides our email marketing service.
If you believe there is any problem relating to the way we are processing your personal data, you can always contact us by telephone or as david@golfsavers.comIf you are not satisfied with the way we have handled your query, you can contact the Personal Data Protection Committee.