Our Privacy Policy valid from May 25th, 2018
When you the site visitor write a review on VIP Business Golf
network Limited or otherwise use our Website, we collect and process personal
data about you. This document helps you understand what personal information we
collect about you, how we collect it, what we use it for, and what rights you
have regarding your personal data.
When we talk about “VIP Business Golf network Limited,” “we,”
“us” or “our,” we mean VIP Business Golf network Limited and our affiliates. We
also use “Policy” to refer to this Privacy Policy and “Website” to refer to our
applications and all of VIP Business Golf network Limited’s websites to be
stated at any future appropriate time or at the time of updating of privacy
policy.
VIP Business Golf network Limited is
the entity responsible for processing your personal data.
1.1 Master data
When you create a profile or write
your first review on the Website, we will automatically generate a personal
account for you on VIP Business Golf network Limited (“Account”) and collect
the following personal data about you (the “Master Data”):
·
Your
username (this will be public)
·
Your
securely encrypted password, and
·
Your
email address.
This information is mandatory,
which means that it will not be possible to write a review on the Website
without it.
You can choose to add further
personal data to your profile. The additional data you can add is your name, a
profile description, photo, gender, city, country, and language. This
additional information will be part of your public profile and will also be
part of the Master Data.
VIP Business Golf network Limited
is an open review platform and when we display your review we will connect it
to your profile so that people can see who wrote the review. Therefore, please
be aware that depending on the information you add to your profile and the
username you choose, you may or may not be anonymous.
1.2 Information in reviews and
ratings
When you write a review about a
company and post it on our Website, we collect the information you put in your
review. This includes:
·
Which
company you review
·
The type
of buying or service experience your review concerns (see the definition of “Service
Experience” in our User Guidelines)
·
The
headline and content of your review
·
Your
rating of your Service Experience with the company (1-5 stars)
·
The date
of your review and, if you update your review, the date on which it is edited
·
A
reference number or order ID (if you or the company provides one)
·
If we ask
you to provide information or documentation verifying your Service Experience
and you send us such documentation, we will collect and process the
documentation for the purpose(s) stated in the request.
Please don’t share any sensitive
personal documents or information with us, either concerning yourself or
others.
1.3 Information about views,
likes and how useful your review is for others
When you write a review of a
company on our Website, people can show that they find your review useful, for
example by “liking it”, and we collect this information. We also collect information
about how many people read your review. We don’t track the identities of people
who aren’t logged in and read the reviews, but we do collect data on the number
of consumers who read your review. If you “like” another person’s review we
will also collect that information.
1.4 Notifications
If you notify us about a review
that you believe violates our User Guidelines, then we collect the information
you provide in your notification to us. This can include which review you
notified us about, the reason for your notification, the date of your
notification, etc.
1.5 Information from other
services, including social networks like Facebook
You can connect your VIP Business
Golf network Limited profile with your profile on social networks, e.g.
Facebook, and Google+ (“Social Network(s)”). When you use this option we
automatically collect selected information about you from your Social Networks.
The information we collect depends on what information you have made available
on those Social Networks and your privacy settings for sharing such information
on the Social Networks. Depending on your settings and selection, we will
collect the following information:
·
Name
and/or username
·
Email
address
·
Profile
photo
·
Who your
social connections are
When you make a request to connect
your VIP Business Golf network Limited profile with a Social Network profile,
you will be informed about which information we will collect from the Social
Network in question. You will receive this information before your request is
carried out.
You can choose to disconnect your
Social Network profile from your VIP Business Golf network Limited profile via
your Account. At this point, VIP Business Golf network Limited will remove your
Social Network unique ID, and disconnect/revoke VIP Business Golf network
Limited from your Social Network. Your profile picture from your Social Network
profile will remain on your VIP Business Golf network Limited profile.
1.6 Cookies
Our Website uses cookies. Cookies
identify your computer or device rather than you as an individual user, and are
used for different purposes.
Read more about which cookies the
Website uses and for which purposes below (in 8).
1.7 Your IP address, browser
settings and location
When you visit the Website, we
register your computer’s IP address and browser settings. The IP address is the
numerical address of the computer used to visit the Website. Browser settings
can include the type of browser you use, browser language, and time zone. We
collect this information so that we can trace the computer used in cases of
misuse or unlawful actions in connection with visits to or use of the Website.
We also use the IP address to approximate your location (at city level) and so
that we know which sets of our Terms & Conditions apply to your use of our
Website.
1.8 Newsletters and digest
emails
We collect the information you
provide us with when you subscribe to receive our newsletters, digest emails or
similar (we collect your name, email address and newsletter preferences). If
you no longer wish to receive our newsletters, digest emails or similar, you
can unsubscribe by logging into your Account and changing your settings.
1.9 For what purposes do we
use your personal information?
We will use the information you
provide to us to:
·
Provide
our services to you, including displaying your reviews, and providing you with
access to your profile and our Website
·
Identify
you as a registered user when you log in to the Website and re-visit the
Website
·
Verify
the legitimacy of your reviews
·
Improve
the Website and our services
·
Invite
you to leave more reviews
·
Respond
to your questions and provide related customer service
·
Pass on a
message from the company you reviewed via the Website
·
Contact
you if your review is flagged by other users or companies and, if necessary,
ask you to provide documentation to verify your review or experience
·
Send you
our newsletters
·
Inform
you when other users find your review helpful or otherwise provide feedback
concerning your review
·
Facilitate
the social sharing function, including giving you the option to connect with
members of your network who are both users of VIP Business Golf network Limited
and users of one or more Social Networks
·
Display
which members of your Social Networks are users of VIP Business Golf network
Limited in order to increase confidence in reviews and to create a better user
experience on our Website
·
Engage in
various internal business purposes, i.e data analysis, audits, fraud monitoring
and prevention, developing new products and services, improving or modifying
the Website, or our services including our TrustBoxes, identifying usage
trends, determining the effectiveness of our promotional campaigns and
operating and expanding our business activities
·
Comply
with legal requirements and legal process, requests from public and
governmental authorities, relevant industry standards and our internal policies
·
Enforce
our Terms & Conditions
·
Protect
our operations or those of any of our affiliates
·
Protect
our rights, privacy, safety or property and/or that of our affiliates, you or
others
·
Allow us
to pursue available remedies or limit any damages that we sustain
We will also use the information in
other ways for which we provide specific notice at the time of collection.
1.10 On what legal basis do
we process your personal data?
We need to process your personal
information in order to:
·
Perform
our contract with you (see Article 6.1.b of the GDPR)
·
Comply
with our legal obligations (see Article 6.1.c of the GDPR) and operate an
online review platform in compliance with, for example, the Unfair Commercial
Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The
Consumer Protection from Unfair Trading Regulations 2008, The Competition and
Markets Authority’s guidance on online reviews and endorsements, the Danish
Consumer Ombudsman’s Guidelines on publication of user reviews, the Danish
Marketing Practices Act etc.
·
Pursue
legitimate business interests of our own related to operating the Website and
providing our services to you, or to pursue the legitimate interests of third
parties as long as your interests and fundamental rights do not override those
interests (see Article 6.1.f of the GDPR).
·
For the
establishment, exercise or defence of legal claims, where necessary (see
Article 9.2.f of the GDPR)
Some of these grounds for
processing your personal data overlap, so there may be several reasons which
justify us processing your personal information.
In those limited circumstances
where you have expressly given your consent to us to process your personal data
(see Article 6.1.a of the GDPR), for example, when subscribing to our
newsletters, you are free to revoke your consent at any time. However, please
be aware that we may have the right to continue to process your information if
it can be justified on one of the other legal bases mentioned above.
You have the right to object to how
we process your personal information, or ask us to restrict the processing.
Please see below, at 13, for more details.
If you would like more information
about our legal basis for processing your personal information, please contact
our Data Protection Officer (DPO) - see 14, below.
2.1 Disclosure of personal
information on the Website
We are an open review platform and
we share your review on our Website so that others can read about your
experience with a specific company. When you write a review, we will disclose
your review, your username and other information you have chosen to connect
with your public profile. Remember that if you have selected to use your name
as your username, this can reveal your identity in full or in part - unless you
use a pseudonym.
We recommend that you exercise care
in deciding which information to make available for disclosing on the Website,
and be aware that depending on the level of information provided, you may or
may not be anonymous.
Master Data and other information
When you write a review on our
Website and create an Account, your username, review, photo, location and the
number of reviews you have written will be visible on the Website. The
companies you review can also receive information about your review.
Geo-location
When you write a review on the
Website, we use your computer’s IP address (see 1.7 of this Policy, above) to
approximate your location to the nearest city. This information is made
available to other users of the Website.
Reviews you found useful
When you find other reviews useful
(by “liking” them), other users of our Website can see the review(s) you
“liked”.
Social Networks
If you connect to a Social Network,
information such as your profile photo, your name, birth year and approximate
location will be collected from your Social Network profile and used to
identify you on the Website. Subject to your privacy settings and the level of
information available from the Social Network, users of the Website can use
this information to identify which reviews you have written.
If you have chosen to preserve
anonymity by using a pseudonym for your VIP Business Golf network Limited
username, be aware that information from Social Network(s) can reveal your
identity in part or in full and make it possible to identify which reviews you
have written.
If your contacts or friends
(referred to as “Connections”) on the Social Network have also connected with VIP
Business Golf network Limited, we display on the Website how you are connected
to these Connections through the Social Network. This is only visible to you.
Other people on VIP Business Golf network Limited cannot see your Connections
from Social Networks.
2.2 Disclosure on services to
which you connect your profile
If you choose to connect your VIP
Business Golf network Limited profile with your profile on a Social Network,
information and reviews provided by you on the Website or data compiled by us
about your use of the service on the Website (e.g. the number of reviews you
have written) will be shared with and displayed in connection with your profile
on the Social Network and will be subject to the privacy policy of the Social
Network.
2.3 Disclosure to other
services, websites and companies
One of VIP Business Golf network
Limited's main goals is to increase the exposure and availability of reviews on
the Website. We therefore permit other services to show reviews created on the
Website. This increases the potential audience for your reviews.
The categories of third party
services and companies who can show your review(s) together with your public
user profile are:
·
Search
engines, including Google and Bing
·
Companies
reviewed on VIP Business Golf network Limited
·
Consumer
portals and business portals, including price comparison websites, shopping
guides, etc.
·
Application
partners and platforms, such as to be stated as and when added to portfolio.
·
Other
similar websites where, in VIP Business Golf network Limited’s assessment, it
will be relevant for users to search for reviews.
·
Facebook
“If your review has been shared on the Social Network”
Once you submit your review, it is
published on the Website. This means that the following information is
disclosed:
·
Your
review(s), (see 1.2, above)
·
Your
username and the additional data you choose to add to your profile, such as
your name, a profile description, photo, gender, city, country, and language.
If you write a review on VIP
Business Golf network Limited in response to an invitation sent by a company
via our review invitation services, the company who sent you the invite will be
able to link your review with the invitation.
If we need to verify your review,
we will contact you and ask for documentation that shows that you have had a
Service Experience with the company that you have reviewed. We therefore
recommend that you keep such documentation for 12 months from the date of your
review. We explain the type of documentation you should send us here: support@VIPBusinessGolfnetwork.com
We do not share the documentation
you send to us with the reviewed company. However, if you have a reference
number or order ID, we may pass that on to the company, unless you ask us not
to.
2.4 Other disclosures
In addition to the above, we
disclose your personal information to the following parties and in the
following circumstances:
·
To allow
third party vendors, consultants and other service providers to perform
services on our behalf
·
To VIP
Business Golf network Limited subsidiaries and other companies within the VIP
Business Golf network Limited group of companies
·
To comply
with laws or to respond to claims, legal process (including but not limited to
subpoenas and court orders) and requests from public and government authorities
·
To
cooperate with regulatory bodies and government authorities, including but not
limited to Trading Standards, The Competition and Markets Authority, and the
Government of India if any Ombudsman, in connection with investigations or case
referrals
·
To third
parties in connection with enforcement of our Terms & Conditions and Guidelines
·
To third
parties in order for us to protect our operations or those of our affiliates
·
To third
parties in order for us to pursue available remedies, or limit damages that we
may sustain
·
To third
parties in order for us to investigate, prevent or take action regarding
suspected or actual prohibited activities, including but not limited to fraud
and misuse of our Website
·
To a
third party in the event of any reorganization, merger, acquisition, sale,
joint venture, assignment, transfer or other disposition of all or any portion
of our business or assets (including in connection with any bankruptcy or
similar proceedings).
3.1 Information for which we
are the data controller
We are the data controller of the
Master Data you enter to create and maintain your profile, which includes but
is not limited to your name, password and email address, as well as the
registration of your IP address.
We are also the data controller of
the information which is disclosed to other services (see 2.3). India’s data
protection laws govern our collection of your data.
3.2 Information for which you
are the data controller
You are the data controller for the
content you choose to disclose on the Website, and for the personal data
disclosed when you connect your Social Network profile(s) with your profile on
the Website.
Our Website contains links to other
websites. Our inclusion of such links does not imply that we endorse those
websites. We do not control the content of those third party websites, and
assume no responsibility for the third party or their policies or practices.
We encourage you to review the
privacy policies for these third party websites because their procedures for
collecting, handling and processing personal data will be different from ours.
We at our discretion may use
external companies to maintain the technical operation of the Website and our
services. These companies are data processors for the personal data for which
we are the data controller. By accepting this Policy, you agree that we may
also allow the data for which you are the data controller to be processed by
these data processors.
We in most cases have data
processing agreements in place with the data processors and it follows from
these agreements that they must act solely in accordance with our instructions.
By accepting this Policy, you authorize us to instruct the data processors to
process data in accordance with the Policy and for the purposes of using the
Website.
The data processors have taken
reasonable technical and organizational measures to protect against the
information being accidentally or illegally destroyed, becoming lost or
deteriorating, and to protect against the information being disclosed to
unauthorized persons, being misused, or in other ways being processed in
violation of data protection laws.
On your request – and possibly in
return for remuneration at the data processors' applicable hourly rates at any
time for such work – the data processors must supply you with sufficient
information to demonstrate that the above-mentioned technical and
organizational safety measures have been taken.
Some of these data processors and
third party services are located outside of India and the European Union, such
as in the US. You consent to us using data processors in unsecure third
countries provided that there is a legal framework governing the transfer of
your personal data and ensuring adequate protection of it, for example if the
data processor is part of the EU-US Privacy Shield framework.
We keep the Master Data and other
personal data you provide, including your reviews, for as long as you have an
Account or as needed to provide you with our services. If you choose to delete
your Account please note that all your reviews will also be deleted. We will
delete this information upon your request and we will only save a log with the
following information: your name, email address and the date of the deletion of
your Account. We will keep the log for 3 years. All other information will be
deleted.
If you only use our Website for
searching for reviewed companies, we will retain your information and keep your
Account open until you decide to close your Account. In some cases, even if you
close your account, we then choose to retain certain information (e.g. visits
to our Website) in an anonymized or aggregated form.
We use reasonable organizational,
technical and administrative measures to protect your personal information
within our organization and we regularly audit our system for vulnerabilities.
However, since the internet is not a 100% secure environment, we cannot ensure
or warrant the security of the information you transmit to us. Emails sent via
the Website may not be encrypted, and we therefore advise you not to include
any confidential information in your emails to us.
To learn more about our current
practices and policies regarding security and other information, please contact
us for our security practices support@VIPBusinessGolfnetwork.com.
We are always working to improve our security practices and we will update this
information as these practices evolve over time.
The Website uses cookies and
similar technologies (“Cookies”). By using our Website, you accept that we use
Cookies as described below.
8.1 What types of Cookies do
we use?
Cookies are small pieces of
information that the Website places on your computer's hard disk, on your
tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a
similar nature to Cookies, and that we therefore consider that as a Cookie in
the following.
Cookies contain information that
the Website uses to make the communication between you and your web browser
more efficient. Cookies identify your computer or device rather than you as an
individual user.
We use session cookies, persistent
cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5
sessionStorage objects are temporary in nature and are deleted when you exit
your web browser. Persistent cookies are permanent in nature and are stored and
remain on your computer until they are deleted. Persistent cookies expire or
auto delete after a certain period of time, which is set per cookie, but are
renewed each time you visit the Website. HTML5 localStorage objects are
permanent in nature and remain on your computer until they are deleted.
8.2 What do we use Cookies
for?
We use Cookies for:
Generating statistics
Measuring Website traffic such as
the number of visits to the Website, which domains the visitors come from,
which pages they visit on the Website and in which overall geographical areas
the visitors are located.
Monitoring Website performance and
your use of our Website
Monitoring the performance of the
Website, our applications and TrustBoxes and how you use our Website, applications
and TrustBoxes.
Authentication and improving the
functionality of our Website
Optimizing your experience with the
Website, which includes remembering your username and password when you return
to the Website, and remembering information about your browser and preferences
(e.g. which language you prefer).
Connecting you to Social Networks
We give you the option of
connecting with Social Networks, such as Facebook.
Quality assurance
Ensuring the quality of reviews and
to prevent misuse or irregularities in connection with writing reviews and
using the Website.
Targeted advertisements
Displaying relevant advertisements
on the Website, including interest-based advertisements, which we believe are
of interest to you. We use third parties to provide these advertisements when
you visit the Website and other websites. These third parties may use Cookies
alone or in conjunction with web beacons or other tracking technologies to
collect information about your use of our Website and other websites.
8.3 Third party Cookies
Third party Cookies are set by
third party websites – not our Website. When you visit our Website, the
following third party Cookies may be set:
·
Facebook
cookies, set when you log in to our Website with Facebook
·
Google
cookies, set when you log in to our Website with Google
·
Google
AdSense cookies, set when displaying relevant targeted advertisements on our
Website. Some cookies may be set as DoubleClick, which is part of Google
·
New Relic
cookies, set when monitoring and analyzing the performance of our applications
and metrics from user sessions. Read more here
·
Hotjar
localStorage, set for managing how and when surveys are displayed. Read more here.
8.4 Deletion of cookies
You can delete the cookies already
on your device. You can typically delete cookies from the Privacy or History
area, available from the Settings or Options menu in the browser. In most
browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard
shortcut or Command+Shift+Del if you're on a Mac.
If you do not accept Cookies from
our Website, you may experience inconvenience in your use of the Website, and
you may be prevented from accessing some of its features.
If you have an Account on VIP
Business Golf network Limited, you can log in to your Account and see what
information we have about you, including your reviews, and why we have that
information. You can read more about how to here (LINK).
If you don’t have an Account, you
can email privacy@VIPBusinessGolfnetwork.com and
request information about your personal data. Upon receiving your request, we
will let you know what personal information we have about you, how we collect
the information, the purpose for which we process your personal data, and who
we share your personal information with.
If you have a user profile on VIP
Business Golf network Limited, you can download the personal data that you have
provided to us, including your reviews. You can read more about how to download
your personal data here (LINK).
If any of the Master Data or other
personal information that we have about you in our capacity as a data
controller is incorrect or misleading, you can correct most of the information
yourself via your Account. We recommend that you make any the correction(s)
yourself. Otherwise, you are welcome to ask us to assist with correcting your
information.
You may at any time correct or
delete any content and personal information on the Website for which you are
the data controller (see 3.2). If your personal information changes, or if you
no longer wish to appear on the Website, you can update or delete the
information by logging in to your Account.
If your Account is deleted, all the
data associated with your Account will be deleted, including your Master Data
and reviews on the Website.
We reserve the right to block
access to your Account and/or delete it if the Account or the content
associated with your Account or your review(s) on the Website is, in our
assessment, discriminating, racist, sexually oriented, unethical, threatening,
offensive, harassing or otherwise violates applicable laws, third party rights
or our User Guidelines, or is inconsistent with the purpose of the Website. If
we block access to or delete your Account, we will inform you of the reason for
blocking or deleting your Account by sending an email to the address you
provided when you created your Account.
In addition to the rights set out
above concerning your personal data, you also have the following rights:
·
You also
have the right to object to the processing of your personal data and have the
processing of your personal data restricted.
·
In
particular, you have an unconditional right to object to the processing of your
personal data for direct marketing purposes.
·
If our
processing of your personal information is based on your consent, you have the
right to withdraw your consent at any time. Your withdrawal will not affect the
lawfulness of the processing of data carried out before you withdrew your
consent. You may withdraw your consent by emailing us at privacy@VIPBusinessGolfnetwork.com
In some circumstances, these rights
may be limited or conditional. For example, whether or not you have the right
to data portability in a particular case depends on the specific circumstances
of the processing activity.
Our Website is not intended for
children. If you become aware that a child under the age of 13 has provided us
with their personal information, please contact us.
We have a Data Protection Officer
(DPO). If you have any questions about the data processing activities performed
by us, you are welcome to contact our DPO by email at: privacy@VIPBusiness Golfnetwork.com
We reserve the right to make
changes to this Policy. The date shown at the start of this Policy indicates
when it was last revised. If we make material changes to it, we will provide
notice through our Website, or by other means, to give you the opportunity to
review the changes before they come into effect. If you object to our changes,
you can close your account. Your continued use of our Website after we
publish or send a notice about the changes to the Policy will mean that you
accept and agree to the updated Policy.
If you have questions or concerns
about our Policy, how we process your personal information, or would like us to
correct your personal information, feel free to contact us at: privacy@VIPBusiness
Golfnetwork.com you can also reach us by post.
If contacting us does not resolve
your complaint, you have further options, for example you may always lodge a
complaint with a data protection supervisory authority of your choice.
Our contact details are:
VIP Business Golf network Limited,
Address as stated on our Website www.VIPBusinessGolfnetwork.com .