This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") in the context of the provision of our services and within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offering"). With regard to the terms used, such as "processing" or "person responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Responsible
Golfclub Hochschwarzwald eV
Oberaltenweg 7
D-79822 Titisee-Neustadt
Telephone (0 7651) 935 777
Email: info@gc-hsw.de
Internet: www.gc-hsw.de
president
Dr. Klaus Trescher
Types of data processed
- Inventory data (e.g., personal master data, names or addresses).
- Contact details (e.g., email, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we refer to the persons concerned collectively as “users”).
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.
‘Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
The “controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;
The legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
The legal basis for the processing required to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) (e) GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) (f) GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Article 6 (4) GDPR.
The processing of special categories of data (according to Art. 9 Para. 1 GDPR) is determined in accordance with the provisions of Art. 9 Para. 2 GDPR.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and response to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If, as part of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is necessary to fulfill the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose, transmit or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the statutory requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs as part of the use of third-party services or the disclosure or transmission of data to other persons or companies, this will only take place if it is necessary to fulfil our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have data processed in a third country if the legal requirements are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level equivalent to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations.
Rights of the data subjects
You have the right to request confirmation as to whether or not data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
In accordance with the statutory provisions, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
In accordance with the statutory provisions, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
You have the right to request that the data concerning you that you have made available to us be received in accordance with the statutory requirements and to request that it be transmitted to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of withdrawal
You have the right to revoke your consent with effect for the future.
Right of objection
You can object to the future processing of data concerning you at any time in accordance with the statutory provisions. The objection can be made in particular against processing for direct marketing purposes.
Cookies and right to object to direct advertising
“Cookies” are small files that are saved on users’ computers. Different information can be saved within cookies. A cookie is primarily used to save information about a user (or the device on which the cookie is saved) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. Cookies that remain saved even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the site several days later. Likewise, the interests of the user can be saved in such a cookie, which is used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online service.
A general objection to the use of cookies used for online marketing purposes can be made for a large number of services, especially in the case of tracking, via the US website
http://www.aboutads.info/choices/ or the EU side
http://www.youronlinechoices.com/ Furthermore, cookies can be blocked by deactivating them in the browser settings. Please note that in this case, not all functions of this website may be available.
The data we process will be deleted or restricted in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention periods that prevent deletion.
If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
Changes and updates to the privacy policy
In addition, we process
- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Provision of our statutory and business-related services
We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 Para. 1 lit. b. GDPR, provided that we offer them contractual services or act within the framework of an existing business relationship, e.g. with members, or are ourselves recipients of services and donations. In addition, we process the data of data subjects in accordance with Art. 6 Para. 1 lit. f. GDPR on the basis of our legitimate interests, e.g. when it comes to administrative tasks or public relations work.
The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. This generally includes inventory and master data of the persons (e.g. name, address, etc.), as well as contact details (e.g. email address, telephone, etc.), contract data (e.g. services used, content and information communicated, names of contact persons) and, if we offer paid services or products, payment data (e.g. bank details, payment history, etc.).
We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of commercial processing, we retain the data for as long as it may be relevant to the business transaction and with regard to any warranty or liability obligations. The necessity of retaining the data is reviewed every three years; otherwise, the statutory retention periods apply.
When you contact us (e.g. via contact form, email, telephone or via social media), the user's details will be processed to process the contact request and its handling in accordance with Art. 6 Paragraph 1 Letter b. (within the framework of contractual/pre-contractual relationships), Art. 6 Paragraph 1 Letter f. (other inquiries) GDPR. The user's details can be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We delete the requests if they are no longer required. We check the necessity every two years; statutory archiving obligations also apply.
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transferred to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with other services related to the use of this website and the Internet. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the user's IP address is shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the website and from processing this data by downloading and installing the browser plug-in available under the following link:http://tools.google.com/dlpage/gaoptout?hl=de.
For further information on data usage by Google, setting options and objection options, please see Google’s privacy policy (https://policies.google.com/privacy) and in the settings for the display of advertisements by Google
(https://adssettings.google.com/authenticated
).
Users’ personal data will be deleted or anonymized after 14 months.
Facebook Pixel, Custom Audiences and Facebook Conversion
Due to our legitimate interests in the analysis, optimization and economic operation of our online offering and for these purposes, the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used within our online offering.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
).
With the help of the Facebook pixel, Facebook is able to determine the visitors to our online offering as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to only display the Facebook ads placed by us to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined based on the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called "conversion").
The processing of data by Facebook takes place within the framework of Facebook's data usage policy. Accordingly, general information on the display of Facebook ads can be found in Facebook's data usage policy:
https://www.facebook.com/policy
. Specific information and details about the Facebook pixel and how it works can be found in the Facebook help section:
https://www.facebook.com/business/help/651294705016616
.
You can object to the collection by the Facebook pixel and the use of your data to display Facebook ads. To set which types of ads are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions there for the settings for usage-based advertising:
https://www.facebook.com/settings?tab=ads
The settings are platform-independent, meaning they are applied to all devices, such as desktop computers or mobile devices.
You can also object to the use of cookies for reach measurement and advertising purposes via the Network Advertising Initiative deactivation page (
http://optout.networkadvertising.org/
) and additionally the US website (
http://www.aboutads.info/choices
) or the European website (
http://www.youronlinechoices.com/uk/your-ad-choices/
) contradict.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users, as it could, for example, make it more difficult to enforce user rights. With regard to US providers who are certified under the Privacy Shield, we would like to point out that they are thereby obliged to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created from the user's usage behavior and resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the user (especially if the users are members of the respective platforms and are logged in to them).
The processing of users' personal data is based on our legitimate interests in effectively informing users and communicating with users in accordance with Art. 6 (1) (f) GDPR. If users are asked by the respective platform providers to consent to the data processing described above, the legal basis for processing is Art. 6 (1) (a) and Art. 7 GDPR.
For a detailed description of the respective processing and the objection options (opt-out), we refer to the information provided by the providers linked below.
In the case of requests for information and the assertion of user rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Facebook, -pages, -groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of a
Agreement on joint processing of personal data
- Privacy Policy:
https://www.facebook.com/about/privacy/
, especially for pages:
https://www.facebook.com/legal/terms/information_about_page_insights_data
, Opt Out:
https://www.facebook.com/settings?tab=ads
and
http://www.youronlinechoices.com
, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
.
- Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy:
https://policies.google.com/privacy
, Opt Out:
https://adssettings.google.com/authenticated
, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/Opt-Out:
http://instagram.com/about/legal/privacy/
.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy:
https://twitter.com/de/privacy
, Opt Out:
https://twitter.com/personalization
, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/Opt-Out:
https://about.pinterest.com/de/privacy-policy
.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy
https://www.linkedin.com/legal/privacy-policy
, Opt Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active
.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) - Privacy Policy/Opt-Out:
https://privacy.xing.com/de/datenschutzerklaerung
.
- Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) - Privacy Policy/Opt-Out:
https://wakelet.com/privacy.html
.
- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) - Privacy Policy/Opt-Out:
https://soundcloud.com/pages/privacy
.
Integration of third-party services and content
Within our online offering, we use content or service offerings from third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
We integrate the function for detecting bots, e.g. when entering data into online forms ("ReCaptcha") from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://www.google.com/policies/privacy/ , Opt Out: https://adssettings.google.com/authenticated .
We integrate the maps of the “Google Maps” service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually carried out as part of the settings on their mobile devices). The data may be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/ , Opt Out: https://adssettings.google.com/authenticated .
Use of Facebook social plugins
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
This may include content such as images, videos or texts and buttons that allow users to share content from this website within Facebook. The list and appearance of the Facebook social plugins can be viewed here:
https://developers.facebook.com/docs/plugins/
.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
).
If a user calls up a function of this website that contains such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user's device and integrated into the website by the user. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects using this plugin and therefore inform users according to our level of knowledge.
By integrating the plug-ins, Facebook receives the information that a user has accessed the corresponding page of the online offering. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plug-ins, for example by clicking the Like button or leaving a comment, the corresponding information is transmitted directly from their device to Facebook and stored there. If a user is not a member of Facebook, it is still possible that Facebook will find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of data collection and the further processing and use of the data by Facebook as well as the related rights and setting options for protecting the privacy of users can be found in Facebook's privacy policy:
https://www.facebook.com/about/privacy/
.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online service and link it to his or her member data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings:
https://www.facebook.com/settings?tab=ads
or via the US site
http://www.aboutads.info/choices/
or the EU side
http://www.youronlinechoices.com/
The settings are platform-independent, meaning they are applied to all devices, such as desktop computers or mobile devices.
Oberaltenweg 7
79822 Titisee-Neustadt
Telephone: 07651-93 57 77
Club manager Christoph Weiß: 0172 633 8620