Le Club Golf

Privacy Policy

version updated on May 4, 2021

Data Usage Policy

LeClub Golf, controller, and Adelya, the technical operator in charge of collection and processing on behalf of LeClub Golf attach great importance to the protection and respect of your privacy.

The purpose of this policy is to inform you of our practices regarding the collection, use and sharing of the information you provide us with when you subscribe to our newsletter and / or our loyalty program. We invite you to read this document to know and understand our practices. It is asked at each registration to have read and accepted its conditions to be able to register.

Data collected

Personal data

The personal data collected may be the following:

Civility, surname, first name, personal mailing address, professional mailing address, email address, landline number, mobile number, fax number, language spoken, date of birth, marital status, profession, social media ID, photography, surname, first name, sex and date of birth of the children. Interpersonal relationships (ex: family, professional, friendly, …)

Behavioral data

The behavioral data collected may be the following (depending on your level of contact, subscription to the newsletter or the program):

• Passage into the equipped customer areas

• Amount, date and detail of purchases

• Opening and clicking on emails

• Receiving sms

• Use of promotional offers

• Response to satisfaction surveys

Also captured are information on the type of device used for the consultation of online services managed by our technical operator Adelya and the IP address of this one.

Data stored locally and cookies

Cookies are deposited during your navigation on your customer area and the other sites of the service, in order to streamline your navigation and connection, to preserve your preferences of layout.

Mobile devices can be geolocated upon acceptance by the user, in order to allow the user to search for a nearby store, for example. This information is not stored on the servers.

For the retention of identifiers for faster access to online spaces and display preferences, user preference cookies are also stored.

Cookies are also deposited, through service such as Google Analytics, to record the number of visits, page views and the course of our users This data collection is useful to the optimization of ergonomics and functional improvement services of our operator Adelya. No cookie linked to advertising targeting is deposited. Finally, when as a user you use the sharing functions on social networks, cookies can also be transferred.

To oppose the use of cookies, you can change the settings of your browser: more info here.

Purpose of the treatment

The data collected about you are subject to data processing for the following purposes:

– To subscribe to the newsletter or receipt of good deals and offers: constitution of a file for targeted promotional communication by email, mail or sms / mms, respecting the agreements you have given for each media .

– For registration in the program and / or online customer area: creation of a client file for the purpose of running a loyalty program. As part of the program, you will receive information about your account and about the program, this non-promotional communication is part of the program you wish to subscribe to.

– The data collected during votes or customer reviews may be used to recontact users. This data will also be used for statistical purposes

– Aggregated reporting for analysis and statistics purposes

– Monitoring the use of the platform of our technical operator Adelya and for the optimization of ergonomics and functional improvement of services.

– Only in the context of a partner optin that you have explicitly given: Transmission of your email address and / or any information relating to the registration for purposes of commercial prospection by third partners.

– As part of the interruption insurance game which is one of the advantages of the Classic or Gold card, your personal data (surname, first name, card number) are transmitted to our partner Gras Savoye insurance for the smooth completion of the refund.

Communications addressed

The communications sent under the program via our operator Adelya include:

• Welcome message to the program

• Confirmation of appointment

• Purchase confirmation

• Satisfaction surveys

• Password regeneration

• Notification of a benefit award

• Message to wish a particular deadline (eg the birthday)

Non-program promotional communications sent via our Adelya operator always comply with the optin declaration management. This one is revocable at any time by the user:

– At the level of the emails: systematic link in the base of the email towards the page allowing an unsubscription

– At the level of SMS: management of the Stop with blacklisting

Right of access, modification and deletion

Right of access and modification. You may have access to your personal data, modify it or modify your communication agreements:

– on your online customer area

– by writing to LeClub Golf customer service, 5 rue Archimède, 33706 Mérignac or to the technical operator of this program Adelya – Green Park I, 298 Lake Lane, 31670 LABEGE, indicating your last name, first name, address and e- mail to speed up the consideration of the request.

Permission to access. You also have the right to receive a copy of your personal data in our possession.

Right of cancellation. You can request the deletion of your personal data. Please note that we may retain certain information about you when required by law.

Right of opposition. An unsubscribe link is always accessible and available at the bottom of any communication sent by our operator Adelya. This unsubscribe page is available here. You can also, for legitimate reasons, oppose the processing of data concerning you. To find out more, check your rights on the CNIL website: https://www.cnil.fr/en/the-right-of-theopposition.

For all these requests, you can contact LECLUB GOLF customer service at contact@leclub-golf.com / 5 rue Archimède, 33706 Mérignac or our technical operator Adelya – Green Park I, 298 Lake Lane, 31670 LABEGE or on privacy@adelya.com by indicating your last name, first name, address and e-mail in order to accelerate the taking into account of the request.

Privacy of your password

You are responsible for the confidentiality of the password you have chosen to access your account on the online customer area. You agree to keep this password secret and not to communicate it to anyone.

Preservation and security of data

Our operator Adelya has implemented the following measures:

– Chopped and salted passwords.

– The data without activity are anonymized after 3 years without activity, then completely deleted after 5 years, unless special request received before this date.

– Data is held in secure DataCenter located in Europe, in accordance with regulations

Modification of the data usage policy

We may occasionally modify this Data Use Policy. When necessary, we will notify you and / or seek your agreement. We advise you to regularly consult this page to be informed of any modifications or updates made.

Contact

If you have any questions regarding this Data Usage Policy or any request for your personal data, you can contact us by:

– sending an email to LECLUB GOLF customer service – contact@leclub-golf.com

– or, in the absence of a response, to our technical operator Adelya at support@adelya.com, or by mail to Adelya – Green Park I, 298 Lake Lane, 31670 LABEGE, indicating your last name, first name, address and e-mail to speed up the consideration of the request.

Version updated on May 15, 2018

LECLUB GOLF

contact@leclub-golf.com

www.leclub-golf.com

+33 5 56 00 72 63

5 rue Archimède, 33706 Mérignac

LEGAL NOTICES

Presentation of the site

By virtue of article 6 of law no. 2004-575 of 21 June 2004 on confidence in the digital economy, users of the https://leclub-golf.com website are informed of the identity of the various parties involved in its creation and monitoring:

Owner: LECLUB GOLF – 7/9 rue Nationale – 92100 Boulogne-Billancourt

LeClub Golf SARL with a capital of 10,000 euros, registered with the RCS of Nanterre under the number 809 416 076, having its head office at 7/9 rue Nationale, 92100 Boulogne Billancourt.

Host: Dutiko – 37 Rue des Mathurins, 75008 Paris

Contact: Frédéric Fedon – Director

General conditions of use of the site and the services offered

The use of the https://leclub-golf.com website implies full acceptance of the general conditions of use described below. These conditions of use may be modified or supplemented at any time, and users of the https://leclub-golf.com website are therefore invited to consult them regularly.

This site is normally accessible to users at all times. However, LECLUB GOLF may decide to interrupt the site for technical maintenance purposes. In such a case, LECLUB GOLF will make every effort to inform users of the dates and times of the intervention beforehand.

The https://leclub-golf.com website is regularly updated by LECLUB GOLF. Similarly, the legal notices may be modified at any time: they are nevertheless binding on the user, who is invited to refer to them as often as possible in order to read them.

Description of the services provided

The purpose of the https://leclub-golf.com website is to provide information concerning all the company’s activities.

LECLUB GOLF endeavours to provide information on the https://leclub-golf.com website that is as accurate as possible. However, it cannot be held responsible for omissions, inaccuracies and shortcomings in updating, whether these are its fault or the fault of third-party partners who provide this information.

All information on the https://leclub-golf.com website is given for information purposes only and is subject to change. Furthermore, the information on the https://leclub-golf.com website is not exhaustive. It is given subject to modifications having been made since it was put on line.

Contractual limitations on technical data

The website cannot be held responsible for material damage linked to the use of the site. Furthermore, the user of the site undertakes to access the site using recent, virus-free equipment and with a last-generation updated browser.

Intellectual property and counterfeiting

LECLUB GOLF is the owner of the intellectual property rights or holds the rights of use on all the elements accessible on the site, in particular the texts, images, graphics, logos, icons, sounds and software.

Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the site, whatever the means or process used, is prohibited, except with the prior written authorisation of LECLUB GOLF.

Any unauthorised use of the site or of any of the elements it contains will be considered as constituting an infringement and will be prosecuted in accordance with the provisions of articles L.335-2 et seq. of the Intellectual Property Code.

Limitations of liability

LECLUB GOLF may not be held liable for direct or indirect damage caused to the user’s equipment when accessing the https://leclub-golf.com website, resulting either from the use of equipment that does not meet the specifications indicated in point 4, or from the appearance of a bug or incompatibility.

LECLUB GOLF may not be held responsible for indirect damage (such as loss of market or loss of opportunity) resulting from the use of the https://leclub-golf.com website.

Interactive areas (possibility of asking questions in the contact area) are available to users. LECLUB GOLF reserves the right to delete, without prior notice, any content posted in this area that contravenes the legislation applicable in France, in particular the provisions relating to data protection. Where applicable, LECLUB GOLF also reserves the right to hold the user civilly and/or criminally liable, particularly in the event of messages of a racist, insulting, defamatory or pornographic nature, whatever the medium used (text, photographs, etc.).

Hypertext links and cookies

The https://leclub-golf.com website contains a certain number of hypertext links to other sites, set up with the authorisation of LECLUB GOLF. However, LECLUB GOLF does not have the possibility of checking the content of the sites visited in this way, and consequently cannot accept any responsibility for this.

Browsing the https://leclub-golf.com website may result in the installation of the Google Tag Manager cookie on the user’s computer.

A cookie is a small file which does not allow the user to be identified, but which records information relating to the navigation of a computer on a site. The data thus obtained is intended to facilitate subsequent navigation on the site, and is also intended to allow various measures of frequentation.

Refusing to install a cookie may make it impossible to access certain services. However, the user can configure his computer as follows to refuse the installation of cookies:

In Internet Explorer: tool tab (pictogram in the shape of a cog in the top right-hand corner) / internet options. Click on Confidentiality and choose Block all cookies. Validate with Ok.

Under Firefox: at the top of the browser window, click on the Firefox button, then go to the Options tab. Click on the Privacy tab. Set the Retention Rules to: use custom settings for history. Finally uncheck it to disable cookies.

In Safari: Click on the menu icon (symbolised by a cog) at the top right of the browser. Select Settings. Click on Show advanced settings. In the ‘Privacy’ section, click on ‘Content Settings’. In the ‘Cookies’ section, you can block cookies.

In Chrome: Click on the menu icon (symbolised by three horizontal lines) at the top right of the browser. Select Settings. Click on Show advanced settings. In the « Privacy » section, click on preferences. In the ‘Privacy’ tab, you can block cookies.

The main laws concerned

Law n° 78-17 of 6 January 1978, notably modified by law n° 2004-801 of 6 August 2004 relating to information technology, files and freedoms.

Law n° 2004-575 of 21 June 2004 for confidence in the digital economy.

Glossary

User: Internet user connecting to and using the above-mentioned site.

Personal information: « information that allows, in any form whatsoever, directly or not, the identification of the natural persons to whom it applies » (article 4 of law n° 78-17 of 6 January 1978)

Warning

This website is published for information purposes only and no legal consequences may be derived from it. The entities in which LECLUB GOLF directly or indirectly holds a stake are separate and independent legal entities. LECLUB GOLF shall not be held liable for the acts or omissions of the said companies. The terms « LECLUB GOLF » and « Group » used in this document are generic and are used for convenience only. Similarly, the terms « we », « us » and « our » may also be used to refer to subsidiaries or their employees.

This website may contain forward-looking information and statements that are based on economic data and assumptions made in a particular economic, competitive and regulatory environment. They may prove to be inaccurate in the future and are subject to risk factors. LECLUB GOLF does not undertake any obligation or responsibility to investors or any other stakeholder to update or revise, in particular as a result of new information or future events, any of the statements, forward-looking information, trends or objectives contained in this website.