Privacy Policy

At GRANADA CLUB DE GOLF LOS COSARIOS SL, we care about privacy and transparency. Furthermore, we are committed to processing your data in compliance with the current Data Protection regulations:

• EU Regulation 2016/679, of 27 April 2016 of the European Parliament and of the Council, relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
• Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).

Below, we provide detailed information about the personal data processing we carry out, as well as all relevant information relating thereto.

1 Who is responsible for processing your data?

GRANADA CLUB DE GOLF LOS COSARIOS SL Tax ID: B18592881 AVDA. DE LOS COSARIOS, S/N – 18110 – LAS GABIAS – GRANADA Phone: 663833923 Email: administracion@granadaclubdegolf.com

1.1 Contact details of the Data Protection Officer (DPO):

GRUPO ALTABIR (FORMACONT SL), with CIF B18955195 C/ Luis Amador 26, Business Centre Chamber of Commerce of Granada, P.0 – Of.B Email: dpo@altabir.es

2 For what purpose do we process your personal data?

At GRANADA CLUB DE GOLF LOS COSARIOS SL, we process the information provided by data subjects for various purposes. Below is a description of each purpose according to the type of data processing carried out:

• Processing of job applicants’ data: We process the information provided by candidates to manage received CVs and conduct recruitment processes, interviews, and other procedures necessary to find the best candidate for a given job position.
• Processing of clients’ data: We process clients’ information to manage administrative, accounting, and tax obligations related to requested services, as well as to send promotional communications about our products and services.
• Processing of potential clients and contacts: We process information provided by individuals interested in our products and/or services for management of potential clients and commercial contacts, including the sending of promotional communications, also via electronic means.
• Processing of suppliers’ data: We process supplier information to manage fiscal, accounting, and administrative tasks, as well as professional contact details.
• Processing of employees’ data: We process employees’ data for personnel management; training; occupational risk prevention and health surveillance; payroll preparation, social security and contributions; work hour records; workplace accidents, if applicable.
• Processing of event attendees’ data: We process information to organise and manage event attendees and to send invitations to future events, including electronically.
• Processing of data for the exercise of data subjects’ rights: We process data to manage and respond to requests made by data subjects exercising their rights under data protection law.
• Processing of data collected through the website contact form: We process information provided via the contact form to respond to inquiries.
• Processing of video surveillance data (security): We process video footage to ensure the safety of people, property, and facilities through surveillance systems.

No automated decisions will be made based on the data provided. If you do not provide your personal data, we will be unable to fulfil the purposes described.

3 How long will we keep your data?

Each data processing activity has a specific retention period. The retention times for the different processing activities carried out by GRANADA CLUB DE GOLF LOS COSARIOS SL are:

• Job applicants: Two years from the last interaction.
• Clients: Data retained until the data subject requests deletion and, if applicable, for the years necessary to comply with legal obligations.
• Potential clients and contacts: Data retained until deletion is requested by the data subject.
• Suppliers: Data retained until deletion is requested and, if applicable, for the years necessary to comply with legal obligations.
• Employees: Data retained while the employment relationship exists and for the years required to comply with legal obligations.
• Event attendees: Data retained until deletion is requested by the data subject.
• Exercise of rights: Data retained as long as necessary to resolve requests and at least three years to handle possible claims.
• Website contact form: Data retained until deletion is requested by the data subject.
• Video surveillance: Data retained for a maximum of 30 days, except where shared with Law Enforcement or Courts.

4 What is the legal basis for processing your data?

The legal grounds for processing vary depending on the type of data processed. The legal bases for the data processing by GRANADA CLUB DE GOLF LOS COSARIOS SL are:

• Job applicants: Execution of a contract or pre-contractual measures: Managing CVs to conduct recruitment for the best candidate for a position (GDPR Art. 6.1.b).
• Clients: Execution of a contract or pre-contractual measures: Fiscal, accounting, and administrative management (GDPR Art. 6.1.b). Legitimate interest of the controller: Sending promotional communications, including electronically (GDPR Recital 47, LSSICE Art. 21.2).
• Potential clients and contacts: Execution of a contract or pre-contractual measures: Managing potential clients (GDPR Art. 6.1.b). Consent of the data subject: Sending promotional communications, including electronically (GDPR Art. 6.1.a, LSSICE Art. 21). Legitimate interest of the controller: Managing professional contact data (LOPDGDD Art. 19, GDPR Art. 6.1.f).
• Suppliers: Execution of a contract or pre-contractual measures: Managing services contracted (GDPR Art. 6.1.b). Legitimate interest of the controller: Managing professional contact data (LOPDGDD Art. 19, GDPR Art. 6.1.f).
• Employees: Execution of a contract or pre-contractual measures: Personnel management and training (GDPR Art. 6.1.b). Compliance with legal obligations: Occupational risk prevention and health surveillance; payroll, social security and contributions; work hour records; accident management, where applicable (Law 31/1995, Royal Decrees 2/2015, 8/2015, 8/2019; GDPR Arts. 6.1.c and 9.2.b). Royal Decree 902/2020 on equal pay.
• Event attendees: Consent of the data subject: Organisation and management of events and sending invitations, including electronically.
• Exercise of rights: Compliance with legal obligations: Managing and responding to requests (GDPR Art. 6.1.c).
• Website contact form: Execution of a contract or pre-contractual measures: Responding to inquiries (GDPR Art. 6.1.b).
• Video surveillance (security): Public interest mission: Processing necessary for public interest tasks or exercise of official authority (GDPR Art. 6.1.e), as per the Spanish Data Protection Agency’s guide on the use of video cameras.

5 To which recipients will your data be disclosed?

Depending on the processing, data may be disclosed to third parties as follows:

• Job applicants: No data disclosed to third parties, except by legal obligation.
• Clients: Tax Authorities, to comply with legal obligations. Financial institutions, for payment collection.
• Potential clients and contacts: No data disclosed to third parties, except by legal obligation.
• Suppliers: Tax Authorities, to comply with legal obligations. Financial institutions, for payment processing.
• Employees: Tax Authorities, Social Security and Mutual insurance, for tax and social security obligations. Banks and financial institutions, for salary payments. State Foundation for Employee Training (Fundae), for managing training bonuses.
• Event attendees: No data disclosed to third parties, except by legal obligation.
• Exercise of rights: Supervisory authorities, public administration bodies, and the Ombudsman for managing requests and claims.
• Website contact form: No data disclosed to third parties, except by legal obligation.
• Video surveillance: Where applicable, law enforcement and courts for crime investigation.

6 Data transfers to third countries

No transfers of personal data to third countries are foreseen for any of the processing activities carried out by GRANADA CLUB DE GOLF LOS COSARIOS SL.

7 What are your rights when you provide us with your data?

Any individual has the right to obtain confirmation on whether GRANADA CLUB DE GOLF LOS COSARIOS SL is processing their personal data. Data subjects have the right to access their data, rectify inaccurate data, or request deletion if the data is no longer necessary. They also have the right to data portability.

Under certain circumstances, data subjects may request the restriction of processing, in which case data will only be kept for exercising or defending claims. They may also object to processing for reasons related to their particular situation; if so, processing will cease unless there are overriding legitimate grounds.

Rights can be exercised by contacting dpo@altabir.es or writing to C/ Luis Amador 26, Business Centre Chamber of Commerce of Granada, P.0 – Of.B.

If commercial communications are sent based on legitimate interest, data subjects may object to such processing. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

If you consider your data protection rights have been violated and you have not obtained satisfaction, you may file a complaint with the competent Data Protection Authority via their website: www.aepd.es.

8 How have we obtained your data?

The personal data processed by GRANADA CLUB DE GOLF LOS COSARIOS SL come directly from the data subject.