iGaming Golf Club

WHO ARE WE

iGaming Golf Club Ltd ("iGaming Golf Club", "we", "us", "our") is the data controller responsible for your personal data. We organise and facilitate corporate golf events, membership programmes, brand partnerships, and the iGaming Golf Club application ("the App") for professionals in the iGaming, gambling, and gaming industry.

Data Controller:

iGaming Golf Club Ltd,

FDBC 3039

Compass Building

Al Shodada Road

Al Hamra Industrial Zone-FZ

Ras Al Khaimah, UAE

Contact:

support@igaminggolfclub.com

ICO Registration Number:

TBC

WHAT DATA WE COLLECT

We may collect and process the following categories of personal data about you:

2.1 IDENTITY AND CONTACT DATA

• Full name, job title, and company name
• Email address, telephone number, and postal address
• LinkedIn or other professional profile links (where provided)

2.2 MEMBERSHIP AND ACCOUNT DATA

• Membership tier and registration details (including Founding 100 membership)
• Username and password (stored in encrypted form)
• Membership preferences and communication preferences

2.3 EVENT AND ACTIVITY DATA

• Event registration and attendance records
• Golf scores, handicap information, and competition results
• Dietary requirements or accessibility needs (where provided for event logistics)

2.4 PAYMENT AND FINANCIAL DATA

• Payment card details and billing information (processed securely via third-party payment processors; we do not store raw card data)
• Transaction history and invoicing records

2.5 TECHNICAL AND USAGE DATA (APP AND WEBSITE)

• IP address, device type, browser type, and operating system
• App usage data, pages visited, features used, and session duration
• Cookies and tracking technologies (see Section 11)

2.6 MARKETING AND COMMUNICATIONS DATA

• Records of your marketing preferences and consent
• Records of communications sent to you and your responses

2.7 SPECIAL CATEGORY DATA

We do not intentionally collect special category data (e.g. health data, political opinions, ethnicity). Where you voluntarily provide dietary requirements or accessibility needs for event purposes, this is processed solely for event logistics and not retained beyond the event.

HOW WE COLLECT YOUR DATA

We collect personal data in the following ways:

• Directly from you when you register for membership, sign up for an event, contact us, or use the App
• Through our website and App via cookies and analytics tools

• From third parties such as event co-promoters, partner organisations, or publicly available professional sources (e.g. LinkedIn)

• From sponsors or partners with whom you have a relationship and who share your data with us in accordance with their own privacy policies

HOW WE USE YOUR DATA

We use your personal data for the following purposes and on the following legal bases under UK GDPR / EU GDPR:

4.1 MEMBERSHIP AND ACCOUNT MANAGEMENT

Legal basis: Performance of a contract

• Creating and managing your membership account
• Processing membership fees and renewals

• Communicating essential membership information

4.2 EVENT ORGANISATION AND DELIVERY

Legal basis: Performance of a contract / Legitimate interests

• Processing event registrations and managing attendee lists

• Administering golf tournaments, scoring, and leaderboards

• Communicating event logistics, schedules, and updates

• Ensuring health, safety, and access requirements are met

4.3 MARKETING AND PROMOTIONAL ACTIVITIES

Legal basis: Consent (for electronic marketing) / Legitimate interests (for postal marketing to existing contacts)

• Sending newsletters, event announcements, and promotional offers

• Sharing news about the iGaming Golf Club community and the App

• You can opt out of marketing communications at any time (see Section 9)

4.4 SPONSORSHIP AND PARTNER RELATIONSHIPS

Legal basis: Performance of a contract / Legitimate interests

• Managing commercial relationships with brand partners and sponsors

• Sharing agreed contact details with sponsors as part of partnership deliverables (only where expressly consented or where a legitimate interest applies)

4.5 APP FUNCTIONALITY AND IMPROVEMENT

Legal basis: Performance of a contract / Legitimate interests

• Providing App features including search, scoring, tournaments, and community functions

• Analysing usage patterns to improve the App experience

• Troubleshooting technical issues

DATA SHARING

We do not sell your personal data. We may share your data with:

5.1 SERVICE PROVIDERS

Third-party suppliers who process data on our behalf under data processing agreements, including: payment processors, email marketing platforms, CRM providers, App hosting and infrastructure providers, and event management tools.

5.2 SPONSORS AND PARTNERS

Where you have given explicit consent, or where it is within the reasonable expectations of an attendee at a sponsored event, we may share your name and professional contact details with relevant sponsors. We will always be transparent about this in our event communications.

5.3 GOLF CLUBS AND VENUES

We share necessary booking and attendance information with golf clubs and venues hosting our events, limited to what is operationally required.

5.4 LEGAL AND REGULATORY OBLIGATIONS

We may disclose data where required to do so by law, court order, or regulatory authority.

5.5 BUSINESS TRANSFERS

In the event of a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction, subject to the same privacy protections.

INTERNATIONAL DATA TRANSFERS

iGaming Golf Club primarily operates in the UK and EU. However, some of our service providers may be based outside the UK or EEA. Where we transfer personal data internationally, we ensure appropriate safeguards are in place.

DATA RETENTION

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our general retention guidelines are:

Membership records: Duration of membership plus 3 years

Event records: 3 years after the event date

Financial / payment records: 7 years (HMRC requirement)

Marketing consent records: Until consent is withdrawn, plus evidence of withdrawal

App usage and technical logs: 12 months rolling, unless required for ongoing investigation

After applicable retention periods expire, data is securely deleted or anonymised.

YOUR RIGHTS

Under UK GDPR (and EU GDPR where applicable), you have the following rights in relation to your personal data:

Right of Access: Request a copy of the personal data we hold about you (Subject Access Request).

Right to Rectification: Request correction of inaccurate or incomplete data.

Right to Erasure: Request deletion of your personal data in certain circumstances ("the right to be forgotten").

Right to Restrict Processing: Request that we limit how we use your data.

Right to Data Portability: Receive a copy of data you have provided to us in a structured, machine-readable format.

Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.

Rights Related to Automated Decision-Making: Not to be subject to purely automated decisions that produce significant effects, without human review.

To exercise any of these rights, please contact us at [contact@igaminggolfclub.com]. We will respond within one calendar month. We may need to verify your identity before processing your request.

If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk, or with your local supervisory authority if outside the UK.

MARKETING PREFERENCES AND OPT-OUT

We will only send you marketing communications if you have given your consent, or where we have a legitimate interest to do so as an existing contact.

You can opt out of marketing at any time by:

• Clicking the unsubscribe link in any marketing email

• Updating your preferences in your App account settings

• Emailing us directly at support@igaminggolfclub.com

Opting out of marketing does not affect transactional or operational communications related to your membership or events.

Legal basis: Performance of a contract / Legitimate interests

DATA SECURITY

We take the security of your personal data seriously. We have implemented appropriate technical and organisational measures to protect against unauthorised access, accidental loss, destruction, or alteration, including:

• Encryption of data in transit (TLS/HTTPS) and at rest where appropriate

• Access controls limiting data access to authorised personnel only

• Regular security reviews and staff data protection awareness

• Use of reputable, GDPR-compliant third-party service providers

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours and affected individuals without undue delay, as required by UK GDPR.

Our website and App use cookies and similar tracking technologies to enhance your experience and to understand how our services are used. The types of cookies we use include:

Strictly Necessary Cookies: Required for the website and App to function. These cannot be disabled.

Analytics Cookies: Help us understand how users interact with our services (e.g. Google Analytics or similar). Require your consent.

Functional Cookies: Remember your preferences and settings to improve your experience.

Marketing Cookies: Used to deliver relevant advertising. Require your consent.

On first visit, you will be presented with a cookie consent banner allowing you to manage your preferences. You can update your choices at any time via [Cookie Settings].

THIRD-PARTY LINKS

Our website and App may contain links to third-party websites, social media platforms, or partner pages. This Privacy Policy does not apply to those third parties. We recommend reviewing the privacy policies of any external sites you visit.

CHILDREN

Our services are intended for adults aged 18 and over, consistent with industry standards in the iGaming sector. We do not knowingly collect personal data from individuals under 18. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or services. We will notify you of material changes by email or via the App. The date at the top of this document indicates when it was last updated. Continued use of our services after changes take effect constitutes acceptance of the revised policy.