Eagle Golf Holidays Ltd ("Eagle Golf Holidays", "we", "us") is the data controller for the personal information described in this policy. We follow the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
• Company: Eagle Golf Holidays Ltd, registered in England and Wales, company number 17429830
• Registered address: 9 Concra Park, Woburn Sands, Milton Keynes, MK17 8NS
• Data protection contact: Data Protection Officer – sales@eaglegolfholidays.com
• ICO registration number: ZC235597
• Website: www.eaglegolfholidays.com
This policy applies to customers, group organisers and travellers, website visitors, enquirers and anyone who contacts us. When a group organiser books on behalf of others, they must share this policy with each traveller and have their permission to give us their details.
We only collect what we need to arrange and manage your golf holiday.
We collect identity details such as your full name as shown on your passport, title, date of birth and gender, along with contact details including your email address and phone number. Where a supplier or destination requires it, we also collect travel document details such as your passport number, nationality and expiry date.
To arrange your trip we hold booking details, including destinations, travel dates, hotels, tee times, transfers, room-sharing arrangements and golf handicaps. We keep records of deposit and balance payments and bank transfer references. Card payments are processed by Stripe, and we do not store full card numbers.
If you tell us about special requirements, such as dietary needs, mobility or accessibility needs, or medical information relevant to your trip, we record these so we can pass them to the relevant suppliers. We also keep a record of our communications with you, including emails, calls, messages, feedback and complaints.
When you visit our website we collect technical information such as your IP address, browser and device type, the pages you visit and how you reached our site. We also record your marketing preferences, including whether you have opted in or out.
Medical, mobility and some dietary information is "special category" data. We only collect it when you give it to us so we can meet your needs, and we use it only for that purpose with your explicit consent.
• Directly from you when you enquire, request a quote, book, pay, call or email us.
• From a group organiser who books on behalf of other travellers.
• From our website through enquiry and booking forms.
• From suppliers such as hotels, golf courses and transfer companies, for example when they confirm a booking or report an issue.
• From advertising and analytics partners such as Google, when you reach us through an advert.
UK GDPR requires a lawful basis for each use of your data. Ours are explained below.
We use your data to quote for, book and manage your holiday with hotels, golf courses and transfer providers, and to take deposits and balance payments and issue refunds. Our lawful basis for this is the contract between us.
Where you share special requirements with us, we use them only to meet those needs, and we do so with your explicit consent.
We have a legal obligation to keep accounting and tax records and to meet package travel and consumer protection rules. We also use your data to protect customer money through our trust account, relying on both legal obligation and our legitimate interests.
We rely on our legitimate interests to handle complaints, claims and disputes, to improve our website, services and adverts, and to prevent fraud and keep our systems secure.
We send marketing emails and newsletters with your consent or, for past customers, under the "soft opt-in" rules, which rely on our legitimate interests.
We do not make decisions about you based solely on automated processing.
We never sell your personal data. We share it only where needed to deliver your holiday or run our business:
• Travel suppliers: hotels, golf courses, transfer and car hire companies, ground handlers and other providers in your itinerary.
• Customer money protection: our trustee, who oversees the trust account holding customer payments. For details of our trust account, email sales@eaglegolfholidays.com.
• Business service providers: email, website hosting, booking software, IT support, accountants and professional advisers, under contracts that require them to protect your data.
• Marketing and analytics providers: such as Google, for website analytics and advertising.
• Authorities and legal parties: HMRC, regulators, the police or courts where the law requires it, or to establish or defend legal claims.
• A buyer of our business, if Eagle Golf Holidays is ever sold or restructured.
Your holiday may take place in Europe, the USA or elsewhere, so we must send booking details to suppliers in those countries. Some of our service providers also store data outside the UK.
• Transfers to the EEA and other countries with UK "adequacy" status are permitted under UK law.
• Transfers to US organisations certified under the UK Extension to the EU–US Data Privacy Framework are covered by that framework.
• For other transfers we use safeguards such as the ICO's International Data Transfer Agreement or Addendum, or rely on the transfer being necessary to perform your booking contract.
Contact us for more detail on the safeguards used for a particular transfer.
We send offers and news about golf holidays only if you have opted in, or if you are a past customer and did not opt out when booking. Every marketing email includes an unsubscribe link, and you can also opt out at any time by emailing sales@eaglegolfholidays.com. Opting out does not affect messages about bookings you have made.
We keep booking, payment and accounting records for 6 years after your holiday ends, to meet tax requirements and deal with any legal claims. Records of complaints and claims are also kept for 6 years after the matter is closed.
Passport details and special requirements are deleted within 3 months of your return, unless we need them for a complaint or claim. Enquiries and quotes that do not lead to a booking are kept for 2 years from our last contact with you.
We keep your marketing preferences until you opt out, and then keep a record of the opt-out so we do not contact you again.
After these periods we securely delete or anonymise your data.
We protect your data with password-protected and multi-factor-secured systems, encrypted payment processing through Stripe, and access limited to people who need it. Our suppliers and service providers must keep your data secure and use it only on our instructions. If a data breach is likely to put you at risk, we will tell you and the ICO as the law requires.
Under UK data protection law you have the right to:
• Access a copy of the personal data we hold about you
• Rectification of inaccurate or incomplete data
• Erasure of your data in certain circumstances
• Restrict how we use your data
• Object to processing based on legitimate interests, and to direct marketing at any time
• Data portability – receive your data in a machine-readable format
• Withdraw consent at any time, where we rely on it
To use any of these rights, email our Data Protection Officer at sales@eaglegolfholidays.com. It is free, and we will respond within one month. We may ask for proof of identity first.
If you are unhappy with how we handle your data, please contact us first. You can also complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.
We may update this policy as our business grows. The latest version will always be on our website, and we will tell you about significant changes.
Contact us: Eagle Golf Holidays Ltd, 9 Concra Park, Woburn Sands, Milton Keynes, MK17 8NS · sales@eaglegolfholidays.com · 0333 577 8020
