Version Dated 18 March 2022
The team at Donnington Grove understand how important it is to protect your personal information. As individuals, we use companies and websites to provide us with goods, services and information. We care about how everyone’s personal data is used, including our own. We ensure the use of your personal data is in accordance with applicable data protection laws. Please see below for more information on why and how we obtain and use your personal data.
1) About Sandtrend Limited T/A Donnington Grove Country Club
Donnington Grove Country Club is a company registered in England and Wales.
Company Number: 04460633
Registered Office: 68 Grafton Way 68 Grafton Way, London, England, W1T 5DS
Registered with the Information Commissioner’s Office, reference number ZA227945
Sandtrend Limited T/A Donnington Grove Country Club is a Data Controller and a Data Processor as defined in the General Data Protection Regulations 2018 (‘GDPR’).
2) How to Contact Us
You can contact us via telephone, email or post.
Data Protection Officer, Donnington Grove, Grove Road, Newbury, West Berks RG14 2LA.
01635 581 000
3) Data Collection and Our Legal Obligations
What information do we collect from you?
We collect information from you that is necessary and proportionate to allow us to provide our goods, services and information to you
Identity Data • includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, your spoken language, gender, job title and company details.
Contact Data • includes billing address, delivery address, email address and telephone numbers.
Financial Data • includes bank account, billing information and payment card details.
Transaction Data • includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data • includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data • includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (via telephone, email, social media or post).
Usage Data • includes information about how you use our website (including redacted chat transcripts), products, technology systems and services.
Marketing and Communication Data • includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Certain personal data we collect is treated as a special category to which additional protections apply under data protection laws. Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws.
We must have a lawful basis under UK GDPR in order to process your personal data, we therefore rely on the following in order to ensure legal compliance:
a) Art.6(1)(a) - we use consent as the lawful basis where we are sending you marketing information that you have agreed to receive.
b) Art.6(1)(b) - for the performance of the contract with you (where we are providing you with goods and services).
5) How We Use the Information
The information is collected and processed to provide you with our contracted services.
Where we collect and process sensitive personal data, care is taken to ensure the data is stored securely and accessed only for the purpose necessary to provide you with the services listed below:
Event hosting (such as weddings)
We may also collect your data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
6) Third Party Data Processors and Data Transfers
Sandtrend Limited T/A Donnington Grove Country Club contracts with third party Data Processors inside of the European Economic Area (EEA) for the purpose of providing our services or marketing information to you.
We have taken steps to ensure these Data Processors high have standards of data protection and comply with the GDPR regulations. Your data will be processed in accordance with our instructions for the purposes of providing services to you or for our business operational requirements. We have ensured the necessary agreements and protections are in place to protect your data.
We may share your data from time to time (unless you decide to opt out) with the following:
• any company within our group for the performance of any contract with you
• suppliers and sub-contractors for the performance of any contract with you
• suppliers and sub-contractors for the purposes of maintaining our systems and security
We never sell or provide your data to third parties for any other purposes. We dislike spam as much as you do.
In any event, we do not transfer your data outside of the UK.
7) Where We Store Your Data
All data you provide is stored on our own systems or those of our contracted Data Processors. We use industry standard encryption when storing and transferring your data. Any payment information you provide is stored securely with a third-party payment processor that complies with current industry regulations.
8) Security of Our Systems
Where we have provided you with usernames and passwords to access our services such as golf membership systems, you are responsible for keeping this information safe. You agree to keep this information confidential and not to share it with anyone else.
Information sent over the internet is never completely secure. We and our contracted third parties use current technologies to protect your data as much as possible. We have processes in place to identify and remedy security breaches or other incidents. You agree that by using our services, you will provide us with any information regarding any security breach or other risk as soon as you become aware of it.
9) Data Retention Policy
For the purposes of providing services, we will keep your data for the duration of the contract and thereafter for as long as the law permits or requires. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
For marketing purposes, where you have given consent, we will keep your data for 36 months in order to provide you with information about relevant promotions. You can unsubscribe at any time by clicking the unsubscribe link in the email we send you.
The UK GDPR gives you as an individual (a Data Subject) certain rights as to how your data is processed and controlled.
You can ask us to stop processing your data. We will retain a copy of this data until you ask us to delete it or the data reaches the limits of our retention policy.
We do not carry out any automated decision making or profiling.
You may withdraw your consent previously given, for example where we send you email marketing you can easily unsubscribe.
The full list of right are:
• The right of access: You can request access to your personal data (known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• The right to rectification: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• The right to erasure: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• The right to restrict processing You can request that we restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• The right to data portability: You have the right to ask that we transfer data collected by us from one organisation to another, or to give the data to you. This right only applies where we are processing data based on your consent or the data we process is by automated means.
• The right to object: You can object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Rights in relation to automated decision making and profiling.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
For more information about your rights, please refer to the following website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Alternatively, contact us for more information and how to exercise your rights.