privacy policy
1. Purpose of this Charter
The purpose of this charter (hereinafter the "Charter") is to describe the policy of the ASBL Royal Waterloo Golf Club, whose registered office is located at Vieux Chemin de Wavre, 50, 1380 Lasne, registered with the ECB under no. 0407.692.879 (hereinafter the "Club") with regard to the processing of Personal Data of Internet Users, Members of the Club and Visitors.
This policy applies to all processing of Personal Data of Internet Users, Club Members and Visitors that is carried out under the responsibility of the Club, whether it is Personal Data collected via the https://www.rwgc.be/fr/ website published by the Club (hereinafter the "Site") or Personal Data collected by any other means in the context of the Club's operation and activities.
2. Definitions
The following terms shall have the following meanings in this Charter :
- The terms "Personal data" and "Data subjects" shall have the meaning given to them in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter "PGRD");
- The term "Internet User" refers to any person having access to and/or using the Website;
- The term "Member" refers to any person registered with the Club as a member and having paid the entry fee and the annual subscription;
- The term "Visitor" refers to any person participating in the Club's activities without being a Member.
3. Personal data processed by the Club
When you browse the Website as an Internet User, the Club automatically collects Personal Data about you. This data (the "Navigation Data") is as follows:
- your IP address;
- data collected by means of Cookies (see in this respect our Cookie Policy, available under the following link:
https://www.rwgc.be/images/PDF/2019/190607_Cookie_Policy_-_version_finale.pdf.
When you apply to join the Club, the Club collects Personal Data from you by means of an application form. This data (the "Membership Data") is as follows:
- personal identification data: surname(s), first name(s), photo ;
- contact data: private address, private telephone number, mobile phone number and e-mail address;
- personal details: age, date of birth, marital status, family composition, nationality, profession(s), company, position held;
- relationship, if any, to the Member(s) and sponsors supporting the application for membership; and
- sporting details: other club(s) of which you are a member, disability, federal card number, homeclub, other sports practised and clubs where these sports are practised, possible sporting responsibilities.
From the day your application for membership is accepted by the Club, your Membership Data is referred to as "Member Data". The identifiers assigned by the manager once membership is finalised will also be Member Data.
When you register on the Site as a Visitor in order to reserve a site with the Club, the Club collects from you, by means of a form, or from Mygreenfee.com, Personal Data about you. This data (the "Booking Data") is as follows:
- personal identification data: surname, first name, postcode, country ;
- electronic identification data: mobile phone, e-mail address; and
- personal details: date of birth, federal card number.
The bank details you provide when paying for your reservation are not collected by the Club. They are only collected by the operator of the CCV reservation service, in accordance with its privacy policy, which can be consulted here: https://www.ccv.eu/be-fr/a-propos-de-ccv/declaration-de-confidentialite/.
When you participate in competitions or activities organised by the Club or supervised by the Club, the Club processes Personal Data about you that has previously been collected by the Club. This data (the "Participation Data") is as follows:
- personal identification data: surname, first name, title, address (private and professional), telephone number (private, professional) ;
- electronic identification data: mobile phone number, e-mail address; and
- personal details: age, gender, date of birth, nationality.
4. Purposes of the treatment
The Personal Data about you collected by the Club is recorded in electronic form. They are processed for the following specific purposes:
Navigation Data is processed for the following purposes:
- The provision of content ;
- The optimisation of your experience on the Site;
- The statistical evaluation of the Site's traffic, with a view to improving its content and operation.
Membership Data is processed for the following purposes:
- Processing and management of the membership application and any subsequent requests.
Membership Data is processed for the following purposes:
- The exercise of the Club's activities and the services it offers;
- The promotion of the Club's activities and the services it offers;
- The processing and management of requests sent to the Club by Members;
- Communication between Members, in particular by providing contact data via the Members' Area of the Site.
The Reservation Data is processed for the management of reservations.
Participation Data is processed for the exercise, management and promotion of competitions and other activities organised by the Club or supervised by the Club.
5. Legal basis
Navigation Data is processed for the legitimate interests of the Club (article 6, 1., f), of the RGPD), namely to make the content of the Site available and to enable the proper functioning of the Site, its improvement and an optimal experience on it.
Member Data is processed for the legitimate interests of the Club (article 6, 1., f), of the RGPD), namely to enable the Club to carry out and promote its activities, to ensure its proper management, to offer and promote its services, and to process and manage requests addressed to it by Members. Certain Member Data is also processed to enable the Club to meet its legal obligations, in particular its obligation to keep a register of Members.
Membership Data are processed because they are necessary for the execution of pre-contractual measures (article 6, 1., b), of the RGPD), i.e. the obtaining of Membership by the person concerned.
Reservation Data is processed as it is necessary for the execution of the reservation contract with the Club (article 6, 1., b), of the RGPD).
Participation Data is processed in the legitimate interest of the Club (article 6, 1., f), of the RGPD), namely the exercise, management and promotion of competitions and other activities organised by the Club or supervised by it.
Wherever the legal basis of the processing is the legitimate interest of the Club, the Club shall ensure that the impact of the processing is as limited as possible and does not undermine the fundamental rights and freedoms of the data subject.
If the data subject refuses to provide certain Data essential to the processing, the Club may not be able to process the request submitted to it or to offer the services requested of it.
6. Length of retention of Personal Data
Navigation Data is stored in accordance with the Cookie Policy (https://www.rwgc.be/images/PDF/2019/190607_Cookie_Policy_-_version_finale.pdf).
Membership Data is kept for the duration of the membership process. If the membership application is not accepted, this data will be deleted after 10 years from the date of refusal. If the application for membership is accepted, the Membership Data becomes Member Data and is then retained for the duration of the Member's membership and then for 10 years, unless the Club has legitimate reasons for retaining it for longer, such as historical reasons if, for example, the Member has been President of the Club or has been a member of the Board of Directors, or has won competitions, is posted on the "hole in one" wall or has otherwise distinguished himself or herself in the life of the Club.
The Booking Data and the Participation Data will be kept for the time necessary to provide the service requested and then for 2 years.
Personal Data may be retained for longer if the Member, Visitor or User consents to this or if the legal periods required by any regulations to which the Club is subject so prescribe.
7. Communication of Personal Data
Personal Data is only transmitted to the Club staff in charge of processing requests or managing services. All Club employees with access to Personal Data are bound by a duty of confidentiality.
The Personal Data collected will only be used for the purposes described above and will therefore never be sold to other natural or legal persons, whether or not related to the Club, or otherwise used for profit-making purposes. Certain Member Data (in particular surnames, first names, e-mail addresses or telephone numbers) may be transmitted to Club Members in the context of the organisation of Club activities. Member Data may also be transmitted to third parties located in the European Economic Area who may be directly or indirectly involved in the exercise of the Club's sporting activity (the federation, the press, suppliers and subcontractors, etc.) and/or in the context of competitions, when this is necessary for processing the request of the Member, Visitor or Internet User or when this is necessary for the management or promotion of the services offered by the Club. The Club makes every effort to ensure that such transfers always take place in strict compliance with the RGPD. The Club does not transfer your Personal Data outside the European Economic Area.
The Club has implemented appropriate security measures to protect your Personal Data against loss, theft, misuse or alteration.
8. Your rights to your Personal Data
Any person concerned by a processing of Personal Data carried out by the Club has the rights listed in articles 15 to 22 of the RGPD and specified below. However, these rights are not absolute and the Club reserves the right to refuse to comply with a request to exercise a right outside the limits provided for by law.
These rights are as follows:
- Right of access to Personal Data by the person concerned, i.e. the right to obtain confirmation from the Club that his or her Personal Data is or is not being processed, as well as certain information regarding such processing, and the right to obtain access to such Data ;
- The right to rectify inaccurate Personal Data, including the right to obtain the completion of incomplete Data;
- Right to obtain the erasure of one's Personal Data when they are no longer necessary for the purposes for which they were collected or when the data subject withdraws his consent (and there is no other legal basis for the processing);
- Right to have one's Personal Data processed in a limited way;
- The right to portability of Personal Data, i.e. the right of the data subject to obtain the Personal Data concerning him or her that he or she has provided to the Club in a structured, commonly used and machine-readable format, and the right to transmit or have transmitted such Data to another controller without the Club being able to prevent this;
- The right to object to the processing of his or her Personal Data, allowing the data subject to request the Club to stop processing his or her Data under certain conditions.
Any request relating to the exercise of these rights may be sent to the Club by e-mail (infos@golfwaterloo.be) or by post (Vieux Chemin de Wavre, 50 - 1380 in Lasne). The reply will be given, via the same communication channel, as soon as possible and at the latest within one month of receipt of the request. No payment will be demanded by the Club, unless the requests are manifestly unfounded or excessive (if they are of a repetitive nature for example).
9. Requests for information and complaints
Any request you may have concerning the processing of your Personal Data by the Club may be sent by e-mail (infos@golfwaterloo.be) or by post (Vieux Chemin de Wavre, 50 - 1380 in Lasne). If the Club does not respond satisfactorily to a request that you send to it, you have the right to lodge a complaint with the Data Protection Authority (https://www.autoriteprotectiondonnees.be).
Charter established on 24 May 2019 in Lasne.