Clovelly Country Club Privacy Notice and Privacy Rights

 Introduction:

Clovelly Country Club collects information through our website, other interactive properties, as well as the day-to-day, in-person operations through which the services are delivered. We are committed to protecting the personal information we collect about you, and we take reasonable precautions to safeguard its confidentiality. This Privacy Notice describes the categories of information we collect, the purpose of such collection, the sources of information collection, and the categories of third parties we share information with.

Clovelly Country Club encourages our customers, visitors, business associates, and other interested parties to read this Privacy Notice, which applies to all users. By using our Service or submitting personal information to Clovelly Country Club by any other means, you acknowledge that you understand and agree to be bound by this Privacy Notice, and agree that Clovelly Country Club may collect, process, transfer, use, and disclose your personal information as described in this Notice. Further, by accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS OF OUR TERMS OF SERVICE (the “Terms of Service”). IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY NOTICE OR OUR TERMS OF SERVICE, PLEASE DO NOT USE ANY OF THE SERVICES.

Clovelly Country Club’s registered Information Officer ensures that the provisions of the POPI Act is complied with and implemented in the following way:

  1. Respecting the privacy rights of data subjects
  2. Complying with the conditions for lawful processing of personal information, and
  3. Ensuring reasonable measures are taken to secure personal information.

What personal information do we collect about you?

Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate.

The personal information that we collect directly from those registering for the Service, may include the following categories:

  • Name and contact information (e.g. address; phone number; email, fax, ID);
  • Billing Information (e.g. credit card, bank account, billing contact information)
  • Gender and age
  • Previous club affiliation
  • Geographic or location information
  • Information contained in posts you make on the public forums and interactive features of the Service.
  • Other information that may be exchanged in the course of engaging with the Service.  You will be aware of any subsequently collected information because it will come directly from you.
  • CCTV images of members, visitors and staff frequenting the Clovelly Country Club premises.

What are the sources of personal information collected by Clovelly Country Club?

When providing personal information to Clovelly Country Club as described in this Notice, that personal information is collected directly from you, and you will know the precise personal information being collected by us. Clovelly Country Club does not collect personal information from any other sources, except where it may automatically be collected as described in the section titled “Cookies, Device Data, and How it is Used”, if the information in that section is considered personal information.

Why does Clovelly Country collect your personal information?

Subject to the terms of this Privacy Notice, Clovelly Country Club uses the above-described categories of personal information in several ways. We collect and process your Personal Information mainly to provide you with access to our services and to interface with other Clubs, Golf RSA, Clubmaster, and Handicaps Network Africa. The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose. We collect information directly from you where you provide us with your personal details, for example when you join this Club, or enter a competition associated with this Club. We will only use this information to carry out the processes for the purpose for which you registered with us. We will protect your Personal Information in accordance with this Notice and POPIA. If you agree, we will use your information to send marketing information to you (it will always have an “opt-out” element). Clovelly Country Club will not share your Personal Information with external third parties, save for the Golf RSA appointed handicaps network operator and Clubmaster SA. CCTV images are kept secure and retained only as long as required.

How do we share your Personal Information with third parties?

We may provide any of the described categories of personal information to Clovelly Country Club employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Service to you. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Privacy Notice. Again, Personal Information is shared only when needed, and for the purpose of providing the Service which you require from us.

We will not share your personal information with other third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature which you will specifically be able to opt-out of.

In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce any provision of the Terms of Service , protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare; (iii) when disclosure is required to maintain the security and integrity of the Service, or to protect any user’s security or the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; or (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets.

Direct Marketing Communications

We may communicate with you using email, SMS, and other channels as part of our effort to market our products or services, administer or improve our products or services, or for other reasons stated in this Privacy Notice. You have an opportunity to withdraw consent to receive such direct marketing communications, as permitted by law.

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by submitting a request, or by using the UNSUBSCRIBE link in any email communication you may have received. Further, you may express your communication preferences by:

  • Noting your preferences at the time you join as a member of Clovelly Country Club
  • Contacting us using the contact information provided below

Please note that you may continue to receive non-marketing communications as may be required to maintain your relationship with Clovelly Country Club.

Retention of Data

Clovelly Country Club will retain your personal information only for as long as is necessary for the purposes set out in this Notice. We will retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Clovelly Country Club will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites and/or Portals, or we are legally obligated to retain this data for longer periods.

Cookies, Device Data, and How it is Used

When you use our Service, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Service, and your network location. Clovelly Country Club uses aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Service through cookies, web beacons, and other technologies:

  • domain name
  • browser type and operating system
  • web pages you view
  • links you click
  • IP address
  • the length of time you visit the Sites, Portals, and/or Services
  • the referring URL or the webpage that led you to the Sites

We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account to provide customer service. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on behalf of us).

In addition, we may use “cookies,” clear gifs, and log file information that help us determine the type of content and pages to which you link, the length of time you spend at any particular area of the Service, and the portion of the Service you choose to use. A cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser. A cookie contains limited information, usually a unique identifier and the name of the site. Your browser has options to accept, reject or provide you with notice when a cookie is sent. Our cookies can only be read by Clovelly Country Club; they do not execute any code or virus; and they do not contain any personal information. Cookies allow Clovelly Country Club to serve you better and more efficiently, and to personalize your experience with the Service. We may use cookies for many purposes, including (without limitation) to save your password so you don’t have to re-enter it each time you visit the Service, and to deliver content (which may include third party advertisements) specific to your interests.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on the Service. We may permit these service providers to use cookies and other technologies to perform these services for Clovelly Country Club. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect such personal information on our behalf. Our third-party service providers are required to comply fully with this Privacy Notice.

International Data Transfer

We may use third party service providers to help us deliver certain services, and it may result in the processing of personal information in data centers and locations outside of the Republic of South Africa. For example, these service providers may provide us with essential information technology or tools we use to run our business. We may permit these service providers to process our business information and/or your personal information. We do not permit these service providers to process any personal information outside of a contract, and these service providers may collect personal information on our behalf. Our third-party service providers are required to comply fully with this Privacy Notice as well as the laws of the Republic of South Africa as it pertains to your personal information.

For individuals located outside the Republic of South Africa, in particular in Switzerland, the United Kingdom and the European Economic Area (EEA), please note that Clovelly Country Club is a South African based business. Clovelly Country Club does not market to or solicit customers from outside the Republic of South Africa, therefore, users of the Services should not expect to avail themselves of the rights provided under the EU’s General Data Protection Regulation (“GDPR”). If you use the Services, all information, including personal information, will be transferred to Clovelly Country Club in the Republic of South Africa. By using the Services, you unambiguously consent to the transfer of your personal information and other information to the Republic of South Africa and elsewhere for the purposes and uses described in this Notice. Further, you acknowledge that Clovelly Country Club is not subject to the GDPR or similar international privacy laws, and, therefore, you will be unable to claim the privacy rights provided in those laws.

South African Privacy Rights

If you are a South African resident, South Africa law may provide you with certain rights with regard to your personal information under the Protection of Personal Information Act (“POPIA”) and Promotion of Access to Information Act (“PAIA”) as well the Consumer Protection Act. Throughout this Privacy Notice you will find information required by POPIA regarding the categories of personal information collected from you; the purposes for which we use personal information, and the categories of third parties your data may be shared with.  This information is current as of the date of the Notice and is applicable in the 12 months preceding the effective date of the Notice.

As a South African resident, the POPIA and PAIA provide you the ability to make inquiries regarding to your personal information. Specifically, the degree to which the information is not already provided in this Privacy Notice, you have the right to request disclosure or action your personal information, including:

  • If your personal information is collected by us.
  • The specific pieces of personal information collected about you.
  • The ability to correct or delete certain personal information collected about you.
  • The ability to delete all the personal information collected about you, subject to certain exceptions.
  • To opt-in or opt-out of direct marketing to you.
  • To object to processing of your personal information, or
  • Appeal any rejection of access to your personal information

You may submit a request regarding your rights under POPIA or PAIA by submitting a request by contacting us at: gm@clovelly.co.za

If we receive a POPIA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by Clovelly Country Club and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, and/or the contact information submitted to make the request).

Clovelly Country Club does not knowingly collect or process the special personal information such as your religious or philosophical beliefs, race or ethnic origins, trade union memberships, political persuasion, health or sex life, or your criminal behaviour or biometric information.

If you have a comment, question, or complaint about how we are processing your personal information, we hope that you contact us to allow us to resolve the matter. In addition, if you are located in the Republic of South Africa, you may submit a complaint regarding the processing of your personal information to the Information Regulator at the following link: https://www.justice.gov.za/inforeg/contact.html.

Information Storage and Security

We employ industry-standard and/or generally accepted security measures designed to secure the integrity and confidentiality of all information submitted through the Service. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. To protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach of security is suspected.

External Links

The Service may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and Clovelly Country Club is not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information.

You hereby acknowledge and agree that Clovelly Country Club is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release Clovelly Country Club from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.

Social Media

Clovelly Country Club will only publish images and personal information on social media if such images and data was published, submitted, or provided by the data subject, or alternatively, if explicit consent was obtained from the data subject before doing so.

Children’s Privacy

Clovelly Country Club may only process the Personal Information of a minor if the Club has the consent of the child’s parent or legal guardian.

Changes to this Privacy Notice 

Clovelly Country Club reserves the right to modify this Privacy Notice from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, Clovelly Country Club will post the revised Notice on our website. This Privacy Notice was last modified as of 1 July 2021.

Contact Us

If you have any questions or comments about this Privacy Notice or the Service provided by Clovelly Country Club, please contact us at: Clovelly Country Club, 177 Clovelly Road, Clovelly, Fish Hoek, Cape Town. Tel: +27 21 784 2111 or gm@clovelly.co.za.