Anova.Golf

Privacy Policy and Cookie Policy

2019-08-02

Background:

Anova.Golf understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site; additionally, You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:  

2. Information About Us

1. Our Site, www.Anova.Golf, is owned and operated by Anova.Golf, a sole proprietorship registered in Sweden, whose registered address is Skidbacksvägen 2, 13336 Saltsjöbaden, Sweden. [Our VAT number is 840407035401.]
2. Our data protection officer is Thomas Petersson who can be contacted at [email protected]

3. Scope – What Does This Policy Cover?

1. This Privacy Policy applies only to your use of Our Site and related apps. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them

4. What Data Do We Collect?

1. Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies and Our Cookie Policy), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

1. Name;
2. date of birth;
3. gender;
4. business/company name
5. job title;
6. Place of employment or course affiliation;
7. contact information such as email addresses and telephone numbers;
8. demographic information such as postcode, preferences and interests;
9. financial information such as credit / debit card numbers;
10. IP address (automatically collected);
11. web browser type and version (automatically collected);
12. operating system (automatically collected);
13. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
14. Golf related information from rounds of golf that you enter into our Service

5. How Do We Use Your Data?

1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
2. We use your data to provide the best possible products and services to you. This includes:

1. Providing and managing your Account;
2. Providing and managing your access to Our Site;
3. Personalising and tailoring your experience on Our Site;
4. Supplying Our products and services to you;
5. Personalising and tailoring Our products and services for you;
6. Responding to communications from you;
7. Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking on the unsubscribe button or by emailing us directly;
8. Market research;
9. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.
4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post with information, news and offers on Our products and  services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5. Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
6. Personal Data does not include any Golf Related Data collected by the Service.
7. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following basis applies:

1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are  subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. Golf Related Information Collection

1. We are the sole owners of all golf data collected through this site and related apps.
2. We reserve the right to use your golf related information in an anonymous way to create benchmarks and data points that will be used in the service.
3. Certain functions of the service will enable the sharing of certain identifiable golf related information with other members of a bigger group. In these cases, the Coach user agrees to this, and can choose to remove players from those sharing functions.

7. How and Where Do We Store Your Data?

1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies can be viewed in our ‘Data Retention Policy’ which can be provided upon request.
2. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
4. Steps We take to secure and protect your data include:

1. Protecting all IT Systems against unauthorised access.
2. Making sure all IT Systems are to be used only in compliance with relevant Company Policies.
3. Making sure all data stored on IT Systems are to be managed securely in compliance with all relevant parts of the GDPR and all other laws governing data protection whether now or in the future in force.
4. Making sure that all employees of the Company and any and all third parties authorised to use the IT Systems including, but not limited to, contractors and subcontractors (collectively, “Users”), must ensure that they are familiar with this Policy and must adhere to and comply with it at all times.
5. Making sure that all Users must report any and all security concerns relating to the IT Systems or to the data stored thereon immediately to the IT Department.
6. All software in use on the IT Systems (including, but not limited to, operating systems and individual software applications) will be kept up-to-date and any and all relevant software updates, patches, fixes and other intermediate releases will be applied at the sole discretion of the IT Department.  This provision does not extend to upgrading software to new ‘major releases’ (e.g. from version 1.0 to version 2.0), only to updates within a particular major release (e.g. from version 1.0 to version 1.0.1 etc.).  Unless a software update is available free of charge, it will be classed as a major release and thus falls within the remit of new software procurement and outside the scope of this provision.
7. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

8. Do We Share Your Data? 

1. We may share your data with other companies in Our group. This includes Our subsidiaries AND/OR Our holding company and its subsidiaries.
2. We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
3. Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
4. Mixpanel. Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
5. Google AdWords. Google AdWords remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
6. Twitter. Twitter remarketing service is provided by Twitter Inc.You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
7. Intercom. Intercom is a system for communicating with customers. Please visit their terms page here: https://www.intercom.com/terms-and-policies#terms
8. Facebook. Facebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

5. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:

1. Apple Store In-App Payments. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
2. Google Play In-App Payments. Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
3. Stripe. Their Privacy Policy can be viewed at https://stripe.com/us/privacy
4. PayPal or Braintree. Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

6. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9. What Happens If Our Business Changes Hands?

1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account).
2. You may also wish to sign up to one or more of the preference services operating in the Your Country: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”) (or the equivalent organizations in your country. These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
2. You may restrict your internet browser’s use of Cookies. For more information, see section 12 and Our Cookie Policy.
3. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

12. How Can You Access Your Data?

1. You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected], or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.

13. What Cookies Do We Use and What For?

1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
2. Cookies are small text files placed on an individual’s computer by sites that the individual has visited. They are used to make websites work more efficiently and effectively and help us improve our Site, our marketing activities and your experience. Cookies may also provide information to the owner of a website about its users. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Specifically, we use cookies to see which areas and features are popular and to count visits to our Site. Most web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site and could remove cookies used to opt-out of tracking for the Services.
3. Anova.Golf uses cookies and similar technologies for several purposes, including:

1. Sign-In and Authentication. When you sign into the Site using your username and password we may store an encrypted cookie on your device. This cookie allows you to move from page to page within the Site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
2. Performance. Anova may use cookies for load balancing to help ensure that websites remain up and running.
3. Social Media. Portions of our Site may include social media cookies or widgets, including those that enable users who are logged in to the social media service to share content via that service.
4. Storing Information for Purchases on the Site. When you seek to purchase one of our Services plans, we may store the data in a cookie to remember the products and information you have added for purchase.
5. Opt-Out Cookie. When you opt-out of tracking on the Site, Anova.Golf may store a cookie that will block other cookies from being stored.
6. Some of the cookies we may commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the main reasons we typically set cookies. If you visit one of our sites, the site may set some or all of the following cookies:
7. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for the following (but not limited to): Facebook advertising, Google Adwords, Heap Analytics, Convertfox, Customer Labs, Hotjar, Google Analytics, Intercom. For more details, please refer to section 5, above, and to section 12.9 below.
8. All Cookies used by and on Our Site are used in accordance with current Swedish and EU Cookie Law.
9. Before any Cookies are placed on your computer or device , subject to section 12.5 AND/OR section 12.8, you will be shown a Insert description of prompt e.g. pop-up, message bar etc. requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
10. Certain features of Our Site depend on Cookies to function. Sweden and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
11. The following first party Cookies may be placed on your computer or device:

12. Our Site uses analytics services provided by (but not limited to) [Heap Analytics, Google Analytics, Hotjar and Convertfox. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.12.
14. Third Party Cookies. In addition to the cookies listed above, third parties may also set cookies when you visit the Site. In some cases, that is because we have hired the third party to provide services on our behalf, such as payment processing for credit card billing. In other cases, it is because our web pages contain content or ads from third parties, such as videos, news content or ads delivered by other ad networks. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services. To control cookies from those third parties, visit their sites.
15. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
16. You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
17. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Summary of Your Rights under GDPR

1. Under the GDPR, you have:

1. the right to request access to, deletion or correction of, your personal data held by Us;
2. the right to complain to a supervisory authority;
3. be informed of what data processing is taking place;
4. the right to restrict processing;
5. the right to data portability;
6. object to the processing of your personal data;
7. rights with respect to automated decision-making and profiling (see section 14 below)
8. To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

15. Automated Decision-Making and Profiling

1. In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
2. The right described in section 14.1 does not apply in the following circumstances:
3. The decision is necessary for the entry into, or performance of, a contract between You and Us; 
4. The decision is authorised by law; or
5. You have given you explicit consent.
6. Where We use your personal data for profiling purposes, the following shall apply:
7. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
8. Appropriate mathematical or statistical procedures will be used;
9. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
10. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

16. Contacting Us

1. If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected], by telephone on +46855922242, or by post at Skidbacksvagen 2, 13336 Saltsjobaden, Sweden. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

17. Changes to Our Privacy Policy

1. We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.