PRIVACY POLICY
GOLFY APP, S.L. (hereinafter referred to as "GOLFYAPP") aims to respect the privacy of its users and protect the personal data that they may provide to GOLFYAPP.
In compliance with Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter referred to as "LOPDGDD") and the General Data Protection Regulation of the European Union (hereinafter referred to as "GDPR"), this data collection process will be governed by the terms described below:
Information about the data controller, collection, purpose, legitimacy, and retention period of personal data.
This privacy policy contains all the information about the processing of personal data that GOLFYAPP carries out regarding user data. As a commitment to data protection regulations, GOLFYAPP makes available to the user, permanently, the information regarding our privacy policy.
GOLFY APP, S.L. (hereinafter referred as, GOLFYAPP)
NIF: B-44.828.671
Calle Peña Santa, 18
Madrid (28034 - Madrid)
Golfyapp.com
Depending on the user's use of GOLFYAPP, GOLFY APP, S.L. will need to process personal data, which, in general, will include the following:
Identifying information (e.g., name, surname, language, contact information, etc.).
Economic and transactional information (e.g., payment or card data, information about purchases, orders, returns, etc.).
Connection, location, and browsing data (in case of interaction with us from mobile, for example).
Commercial information (e.g., if the user subscribes to our newsletter).
GOLFYAPP reminds that some of the personal data requested to access certain functionalities or services of GOLFYAPP will be mandatory, as they are essential to provide the service, grant access to the functionality in question, or manage the reason for their contact and process it at the administrative level.
Depending on how the user interacts with GOLFYAPP, personal data will be processed for the following purposes:
| INFORMATION |
|---|---|
MANAGE REGISTRATION IN GOLFYAPP | If the user decides to register, their data will be processed for unequivocal identification on the platform and to grant access to various functionalities, private area, contracted products and services, invoices, promotions, and to manage contact and billing information. The user can cancel their account by contacting GOLFYAPP via email at privacidad@golfyapp.com. The user is informed that being of legal age (eighteen years old) is a mandatory condition for registering as a user. |
DEVELOPMENT, COMPLIANCE, AND EXECUTION OF THE CONTRACTUAL RELATIONSHIP BETWEEN THE USER AND GOLFYAPP | This purpose includes the processing of data for:
|
| Handle the strictly necessary personal data to manage or resolve the inquiry, request, or petition made by the user. |
MARKETING | Personal data will be processed to:
|
QUALITY SURVEYS | Sending quality surveys about the products or services provided. |
The user will be responsible, in any case, for the accuracy of the data provided. Otherwise, GOLFYAPP may exclude the user from the services in which false data has been provided, without prejudice to any other legal actions that may be taken.
The legal basis for processing the personal data provided by the user will be governed by the following table:
| PURPOSE | LEGAL BASIS |
|---|---|
| MANAGE REGISTRATION IN GOLFYAPP | The legal basis for the processing of personal data for user registration on GOLFYAPP is the execution of the terms and conditions governing the use of this platform. In order for the user to register on GOLFYAPP, it is necessary to process personal data. Otherwise, this service cannot be provided. In the event that the data provided by the user are contact details of individual entrepreneurs and liberal professionals, the legal basis for the processing is the execution of the terms and conditions governing the use of this platform, and subsidiarily, legitimate interest, as stipulated in Article 19 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in relation to Article 6(1)(f) of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016 |
| DEVELOPMENT, COMPLIANCE, AND EXECUTION OF THE CONTRACTUAL RELATIONSHIP BETWEEN THE USER AND GOLFYAPP | The processing of personal data is necessary for the execution of the contract governing the provision of services or products by GOLFYAPP. In the event that the data provided by the user are contact details of individual entrepreneurs and liberal professionals, the legal basis for the processing is the execution of the terms and conditions governing the use of this platform, and subsidiarily, legitimate interest, as stipulated in Article 19 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in relation to Article 6.1( f) of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016. GOLFYAPP has a legitimate interest in carrying out as many checks as it deems appropriate to detect and prevent potential fraud during the execution of the contract. This processing is necessary to monitor the payment of a service or product in order to protect against fraud attempts. Principio del formulario |
| CUSTOMER SERVICE | When the user contacts GOLFYAPP through any form enabled on the platform or through any other contact method advertised on GOLFYAPP, the legal basis for the processing is the user's consent. Additionally, GOLFYAPP has a legitimate interest in addressing requests, inquiries, or doubts raised by the user, whether through GOLFYAPP or through any other contact method available with the company, including social media platforms where GOLFYAPP is present. If the user's contact with GOLFYAPP is made in accordance with the exercise of rights protected by any legal provision, including complaints or inquiries related to GOLFYAPP's services or products, the legal basis for such processing is the fulfillment of legal obligations. In the event that the data provided by the user are contact details of individual entrepreneurs and liberal professionals, the legal basis for the processing is legitimate interest, as stipulated in Article 19 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in relation to Article 6.1 (f) of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016. |
| MARKETING | The legal basis for the processing of personal data for the purposes described in the marketing purpose is the user's consent. In the event of a pre-existing contractual relationship with the user, provided that GOLFYAPP has lawfully obtained the contact details of the recipient and uses them to send commercial communications regarding products or services of its own company that are similar to those initially contracted with the customer, the legal basis for the processing shall be based on legitimate interest, with specific reference to the provisions of the second paragraph of Article 21 of Law 34/2002, of July 11, on information society services and electronic commerce. In the case that the data provided by the user are contact details of individual entrepreneurs and liberal professionals, the legal basis for the processing is legitimate interest, as stipulated in Article 19 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in relation to Article 6.1 (f) of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016. |
| QUALITY SURVEYS | GOLFYAPP has a legitimate interest in conducting quality surveys with users to analyze user satisfaction with GOLFYAPP, the quality of customer service, or the products and/or services contracted. |
The retention period of personal data will depend on the purposes for which they have been collected:
| PURPOSE | DATA RETENTION PERIOD |
|---|---|
| MANAGE REGISTRATION IN GOLFYAPP | The personal data processed will be retained for as long as the user maintains their status as a registered user, that is, until the user informs us of their decision to unsubscribe |
| DEVELOPMENT, COMPLIANCE, AND EXECUTION OF THE CONTRACTUAL RELATIONSHIP BETWEEN THE USER AND GOLFYAPP | The personal data processed for this purpose will be retained for the time necessary to manage the contractual relationship, including any returns, complaints, or claims associated with the purchase of the product and/or service. |
| CUSTOMER SERVICE | The personal data processed for this purpose will be retained for as long as necessary to address the inquiry, request, or petition made by the user. |
| MARKETING | The personal data processed for this purpose will be retained until the user decides to withdraw consent. In the case of newsletters, the user may unsubscribe from the service at any time by clicking the link at the bottom of the update message received in their email. |
| QUALITY SURVEYS | The personal data processed for this purpose will be retained for as long as necessary to carry out the appropriate actions to improve our service, our products, or the usability of GOLFYAPP, depending on the purpose of the survey, or until GOLFYAPP anonymizes the collected data. |
The user is informed that GOLFYAPP will process personal data for the period during which civil, commercial, administrative, criminal, or tax liabilities may arise, in compliance with current regulations at all times. Once these periods have elapsed, the personal data will be deleted.
GOLFYAPP informs that to fulfill the purposes described above, it is necessary to transfer or communicate the personal data provided by the user to companies linked to GOLFYAPP, as well as to companies that support us in the services we offer, such as:
Financial institutions and payment gateways
Fraud detection and prevention entities
Technological service providers
Customer service-related service providers
GOLFYAPP administration-related service providers
Marketing and advertising-related service providers and collaborators
Public administrations when required by current regulations
It is informed that GOLFYAPP contracts the management of some of the functions necessary for the provision of the service with data processors located outside the EU and that, in any case, ensure an adequate level of protection of personal data. For more information, you can send a written communication to the email address privacidad@golfyapp.com.
The users who have provided personal data for GOLFYAPP to process have the following rights:
| RIGHT OF ACCESS | The user has the right to obtain confirmation from GOLFYAPP as to whether or not personal data concerning them is being processed, as well as to access the personal data held by GOLFYAPP. |
|---|---|
| RIGHT OF RECTIFICATION | The user has the right to request that GOLFYAPP rectify any inaccurate data concerning them. They also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. |
| DERECHO DE SUPRESIÓN/DERECHO AL OLVIDO | The right to erasure, also known as the right to be forgotten, allows the user to request the deletion of their personal data when it is no longer necessary for the purposes for which it was collected, among other reasons |
| RIGHT OF RESTRICTION | The user will have the right to request GOLFYAPP to limit the processing of personal data, always considering the requirements established in the current legislation. |
| RIGHT OF PORTABILITY | The user shall have the right to receive from GOLFYAPP the personal data concerning him or her in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller where the processing is based on consent or on a contract, and is carried out by automated means. |
| RIGHT TO OBJECT | The user has the right to object to GOLFYAPP processing their personal data when such processing is based on public interest or legitimate interest. In such cases, GOLFYAPP will cease processing the data, unless there are compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the user, or for the establishment, exercise, or defense of legal claims. |
| RIGHT TO LODGE A COMPLAINT | The user has the right to lodge a complaint with the Spanish Data Protection Agency if they believe that the rights outlined in this privacy policy are being violated or if they believe that the processing of their personal data infringes Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights. |
The user may exercise the rights described above by sending a written communication to the email address privacidad@golfyapp.com including a photocopy of their ID card or other similar identification document and subject "DATA PROTECTION - GOLFYAPP".
Security applied to personal data
In order to guarantee the security and integrity of the provided personal data, GOLFYAPP has adopted the necessary technical and organizational measures to prevent the loss of data, as well as unauthorized processing or access by third parties, as stipulated by current legislation in this matter and taking into account the state of technology and the nature of the stored data**.**
Changes in the privacy policy
This Privacy Policy may be updated at any time based on the needs of GOLFYAPP and future legislative changes regarding privacy, reserving GOLFYAPP this right exclusively. In the event of such modification, GOLFYAPP will inform the user of the changes in question if they are significant to your privacy, so that the introduced changes can be reviewed, in order to assess opposition to the processing of personal data or to unsubscribe from any service or functionality. In any case, if consent is required for the processing of personal data for purposes other than those provided for in this privacy policy, the consent of the user will be requested in accordance with the provisions of the current data protection legislation at all times.
Contact with GOLFYAPP
Calle Peña Santa, 18
Madrid (28034 - Madrid)
Tlf. 691 226 747
Legal text developed by:
Área Digital Abogados, S.L.P.