Cumberwell Park Golf Club in Bradford-on-Avon
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GDPR and Privacy Policy

Cumberwell Park is committed to protecting your personal data and handling it responsibly.

This policy covers the personal data that Cumberwell Park collects whenever you interact with us, including when you use our websites, when you stay in our accommodation, become a member or green fee affiliate, and when you correspond with us (such as by email or over the phone). It also covers personal data that we may receive from third parties such as Facebook, Mailchimp and other media platforms.

The policy will cover the bullet points below in order:

•    the types of personal data we collect from you
•    the types of personal data we receive from third parties
•    why we process your personal data
•    who we share your personal data with
•    how long we retain your personal data
•    your rights to withdraw your consent and to object (including to direct marketing)
•    your other personal data rights
•    how to contact us and exercise your rights

If you would like to know how we collect information about your use of our websites, apps and social media sites, you can read our Cookies Policy below.


Personal data Cumberwell Park collects from you

We collect personal data from your interactions with us, such as when you engage with our websites, stay in our accommodation, become a green fee affiliate or when you email or phone us.
The personal data we collect from you includes:
•    the name and contact details that you provide when you register as a member with us
•    your payment and address details
•    your marketing preferences, including any consents you have given us
•    your browser or device information
•    information about your use of our websites
•    your communications with us
•    information about your bookings at Cumberwell Park , such as tee times, events, dates visited, bar spend and conferences held at Cumberwell Park . Photos and video footage of you may be taken at these events


Personal data Cumberwell Park receives from third parties

Sometimes we receive personal data from third parties, in particular:
•    online personalisation providers tell us how you engage with our websites and social media accounts
•    data specialists provide us with insights about our customers, based on their own aggregated data sets
•    if you respond through using your social media account, the social media platform provides us with information that you have consented to share with us

Why Cumberwell Park processes your personal data

This section explains the reasons why we process your personal data and our legal bases for doing so.

If you’ve opted-in to receive information and offers relating to the Club (for example by ticking a box on one of our websites), then we’ll provide this information to you by email, text, or phone.
We also rely on your consent to process information about your use of our websites, apps and social media sites, so that we can improve your browsing experience and deliver online advertising that is relevant to you (for more information, read below to see our Cookies Policy).
Wherever we rely on your consent to process personal data, you have a right to withdraw that consent. See Section on how to exercise your rights below.

Legitimate interests
We process your personal data when necessary to pursue our legitimate interests in the following:
•    tailoring our websites and communications for you. We collect information about your engagement with us online (such as pages that you have visited on our websites) and combine that with aggregated insights we have about our customer base, to build a fuller understanding of your individual preferences •    monitoring, improving and protecting our products, content and services
•    checking the credit or debit card details you provide (to process your payments and prevent fraudulent transactions)
•    sending you some types of direct marketing, including by email and post
•    responding to your comments or complaints
•    undertaking, or inviting you to take part in, market research
•    querying whether you have had an issue completing an online form
•    using incident reports and CCTV footage to: protect the security of our customers and staff; and to help detect and prevent unlawful activity
•    managing legal claims, compliance, regulatory and investigative matters
•    processing job applications received through third party organisations
You have a right to object to any processing that we undertake for our legitimate interests. See Section on how to exercise your rights below.


We process your personal data when necessary for contractual reasons, such as to administer your membership registration and competition entries and to provide products and services that you have requested.

Legal obligation
We are legally required to process your personal data in cases where we need to:
•    obtain parental consent to provide services directly to children
•    respond to certain requests by government or law enforcement authorities


Who Cumberwell Park shares personal data with

We will share your personal data with the following recipients:
•    Facebook, so that we can display relevant advertising to you on their platform (your data is converted into a unique ID before it is shared with Facebook)
•    Mailchimp, an email platform that provides us with the ability to send emails to our past, current and potential customers
•    third party suppliers involved in: data insights; website hosting; online personalisation; and advertising.
•    government authorities or law enforcement officials, to assist with their official requests and comply with our legal obligations
•    Wiltshire Golf Ltd and English Golf Ltd, when they ask for information about Golf Participation.
•    our advisers, any prospective purchaser’s advisers, and any new owners of the business (in the event our business is sold or integrated with another business)
See Facebook’s Privacy Policy
See Mailchimp’s Privacy Policy


How long Cumberwell Park retains personal data

We retain personal data about your membership for as long as your account remains active, and for a limited period of time afterwards (in case you decide to reactivate your membership or have queries about it).
We retain personal data relating to your purchases for several years from the date of the relevant transaction. This is to understand your purchasing preferences and to meet our legal and contractual obligations.
Where you have asked us not to send you direct marketing, we keep a record of that fact to ensure we respect your request in future.
We also retain information with the potential to give rise to legal disputes for 7 years.


Your rights to withdraw consent and to object (including to direct marketing)

Wherever we rely on your consent to process personal data, you always have a right to withdraw that consent. See where we rely on your content in the section above
You also have the right to object to any use of your personal data for direct marketing purposes, as well as to processing that we undertake based on our legitimate interests (including profiling). See the above section for situations where we process data for our legitimate interests.


Your other personal data rights

In addition to your rights to withdraw your consent and to object, you have the right to ask us:
•    for access to information about your personal data or for a copy of your personal data
•    to correct or delete your personal data
•    to restrict (i.e. stop any active) processing of your personal data
•    to provide you with certain personal data in a structured, machine readable format and to transmit that data to another organisation
These rights may not always apply, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case then we’ll let you know when we respond to your request.

How to contact us and exercise your rights

The easiest way to stop receiving information from us is by opting out of emails by using the unsubscribe link at the bottom of each email. You can also call us on 01225 863322 or visit us in person to discuss your concerns.
We will do our best to assist with any queries you have about your personal data. You can contact our Data Protection Officer at any time using the contact details below. When you do so, please provide your full name, your preferred contact information, and a summary of your query.
If you have unresolved concerns, you also have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner’s Office in the UK.

Copyright 2018 Cumberwell Park. Permission to use quotations from this article is granted
Sources used in the creation and accuracy of this Policy –

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01225 863322


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