Scope
This privacy policy applies to the processing of personal data of visitors to and users of the Nova Golf Club website and of people who contact the Nova Golf Club through it.
Who are we?
Nova Golf Club is a registered student club of Nova SBE Students’ Union, with tax number 501 662 219, located in Campus de Carcavelos, Rua da Holanda 1, 2775-405 Carcavelos.
Nova SBE Students’ Union is the controller of the personal data processed in connection with the Nova Golf Club activities, within the meaning given to that expression in data protection legislation.
What are the purposes of the processing?
We process personal data for the following purposes:
- Operating the website and keeping it secure, including delivering the website’s pages to your device through the automatic processing of technical data such as your IP address, browser and device information, as well as detecting and preventing misuse, attacks and technical faults;
- Responding to enquiries from companies and other organisations by processing the information you choose to send us, to reply to you and, where applicable, to discuss and conclude sponsorship or partnership arrangements;
- Presenting the Nova Golf Club committee by publishing names, roles, photographs and social media profile links;
- Sharing the Nova Golf Club activities and events, for example by publishing photographs taken at events;
- Selecting players for the club’s competitive squad during tryouts, where a panel of committee members assesses participants’ capability;
- Organising and managing events and tryouts.
Any further use of personal data for a different purpose will be assessed against the criteria set out in Article 6(4) of the GDPR.
You are not legally obliged to provide your personal data. However, where information is needed to achieve the purposes above, we will not be able to do so without it.
What is the legal basis for the processing?
The processing of personal data by Nova SBE Students’ Union is based on the following legal grounds:
- the legitimate interests pursued by the Nova SBE Students’ Union or by third parties, namely the interest in ensuring the operation and security of the website, selecting players for the club’s competitive squad and replying to the enquiries received, including, where applicable, to discuss and conclude sponsorship or partnership arrangements, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data;
- the performance of a contract to which the data subject is party, or steps taken at the data subject’s request before entering into a contract for the purposes of organising and managing events and tryouts;
- the consent of committee members to publish their photograph for the purposes of presenting the Nova Golf Club committee, and the consent of students to capture and publish their image for the purposes of sharing club activities and events.
Where none of the other legal grounds is suitable to support the processing, Nova SBE Students’ Union will only process personal data if it has obtained your consent to process personal data for specific, explicit and legitimate purposes.
You may request information about the criteria applied to determine our legitimate interests by contacting golf.club@novasbe.pt.
Who do we share personal data with?
In the course of its activities, Nova SBE Students’ Union shares personal data with processors, other controllers and joint controllers. These include the following:
- Website hosting provider;
- Tournament and cup organisers, including Bocconi & Friends Golf Cup, only in respect of players selected for an external tournament who choose to enter;
- Social media platforms;
- Online forms provider, used to receive registrations for events and tryouts;
- Event venues, transport providers and insurers;
- Public, judicial or administrative authorities, where there is a legal obligation to disclose your personal data.
Do we transfer personal data outside the EEA?
Some of our service providers are established, or process data, outside the European Economic Area (EEA). These transfers are carried out in accordance with the General Data Protection Regulation. Where the destination country does not provide a level of protection equivalent to that of the European Union, Nova SBE Students’ Union ensures that appropriate safeguards are in place, such as an adequacy decision by the European Commission or, in its absence, the Standard Contractual Clauses approved by the Commission.
You can obtain more information about these safeguards by contacting golf.club@novasbe.pt. The providers concerned are our website host, our online forms provider and the social media platforms we use.
How long do we keep personal data?
Nova SBE Students’ Union keeps personal data only for as long as necessary to fulfil the purposes for which it was collected.
The retention periods applicable to each purpose are:
- Website technical access data: for the period defined by the hosting service provider under its terms and internal privacy policies;
- Enquiries from companies and other organisations: until the end of the academic year in which the enquiry was received or, where a sponsorship or partnership arrangement is concluded, for the duration of that arrangement and any period required by law thereafter;
- Committee members’ information: for the duration of the member’s term and subsequently removed from the website within seven days after the member leaves the committee;
- Event photographs: for as long as the event is being promoted and reviewed at the end of each academic year, when photographs no longer needed are deleted. Photographs that are not selected for publication are deleted within seven days of the event.
- Event and tryout registration data: until the event or tryout to which the registration relates has taken place, after which the data is securely deleted within 7 (seven) days.
What are the rights of data subjects?
Data subjects may, at any time, exercise a set of rights under the terms and conditions provided for by law. These include the right to object, often exercised in relation to certain types of communication, as well as the rights of access, portability, erasure, restriction of processing and rectification. In addition, data subjects have the right to withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
These rights may be exercised by e-mail to golf.club@novasbe.pt, the contact point designated by Nova SBE Students’ Union, or to the Union at clubs.su@novasbe.pt, or by post to the Union at Campus de Carcavelos, Rua da Holanda 1, 2775-405 Carcavelos. We will reply within one month of receiving your request.
You also have the right to lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados, at https://www.cnpd.pt/.
Changes to this privacy policy
This privacy policy may be updated. Data subjects will be informed within a reasonable period whenever the changes represent a fundamental change in the nature of the processing, such as a change in the purposes of the processing, a change in the identity of the controller or an extension of the categories of recipients.