PRIVACY POLICY

 
1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

Please find below brief information about:

  • what data we collect about you,
  • the purposes for which your data are used,
  • the rights and guarantees that the GDPR provides you as a personal data subject.
2. Who we are

Company Frontbyte AS is the controller of your personal data.

Company Frontbyte AS is a legal entity created in accordance with the legislation of the Norway.

Contacts: Vestre strandgate, 23, 4th and 6th floors, Kristiansand, Norway.

Frontbyte LLC is the processor of your personal data.

Frontbyte LLC is a legal entity created in accordance with the legislation of the Republic of Belarus.

Contacts: Dombrovskaya Str., 9-10.2.2, 220140, Minsk, the Republic of Belarus.

3. Collection of personal data

"Personal data" means any information relating to an identified or identifiable natural person (‘data subject’).

We may collect data, including personal data, about you as you use BirdieEyes App and interact with us, and it may include:

  • e-mail
  • password
  • name
  • surname
  • club where you play
  • phone number
  • book date and time
  • Club Membership ID
  • location
  • gender
  • date of birth

We also collect the content, communications and other information you provide when you use BirdieEyes App, including when you create or share content, and message or communicate with others.

If we link other data with your personal information, we will treat that linked data as personal data.

Golf clubs in which you play can send us information about your activities off BirdieEyes App. Golf clubs receive your data when you visit or use their services. We require each of these Golf clubs to have lawful rights to collect, use and share your data before providing any data to us.

People who can see your activity on BirdieEyes App can choose to share it with others on and off our BirdieEyes App.  For example, people can share a photo of you in a Gmail, Telegram, Instagram or Facebook, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on BirdieEyes App, you can contact our Data Protection Officer.

If you use the data of others received on BirdieEyes App for personal or other purposes, please make sure that this person's consent.

We may use your personal data for the purposes of operating our business, delivering, improving, and customizing BirdieEyes App, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law.

Some of the ways we may use personal data include:

  • provision of our services to you;
  • creating your account;
  • managing and coordinating our relationship with you;
  • personalizing your experience;
  • replying to your questions or requests;
  • requiring your feedback on our offers, and other information or communication;
  • analyzing, supporting, and improving BirdieEyes App and your online experience;
  • for any other legitimate business purposes.

Please note that your e-mail box can be used to send the information messages.

We can also use your e-mail box for commercial mailing. If you do not want this, please contact us using the contacts listed in paragraph 6.

We use automatic data collection tools, such as cookies.

So, we can automatically collect information about you and your devices when you use the BirdieEyes App. Such information may include:

  • Your Internet Protocol (IP) address. This is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device.
  • Clickstream behavior. This includes, for example, the pages you view and the links you click while using the BirdieEyes App. These tools help make your using the BirdieEyes App easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.

By using the BirdieEyes App, you accept the use of cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the BirdieEyes App.

A children's personal data merits particular protection under the GDPR. We encourage parents and guardians to take an active role in their children's online activities.

Accepting the terms of this Data Protection Policy, you confirm that you have reached the age of 16 years.

We may transfer your personal data to third parties and business partners which are located in various countries around the world. By using the BirdieEyes App or providing any personal data to us, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

We will retain your personal data as needed to fulfill the purposes for which it was collected. Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. 

Your personal data may also be accessible to competent state and other public authorities only on the basis of lawful requests.

4. Your rights as a data subject

As a data subject whose personal data we hold, you have certain rights.

We provide a number of options to exercise the following rights provided to you by the GDPR:

• The right to be informed

We are obliged to provide clear and transparent information about our data processing activities. This is provided by this Data Protection Policy and any related communications we may send you.

• The right of access

You may request a copy of the personal data we hold about you free of charge, as well as the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients to whom the personal data has been disclosed;
  • the retention period or envisioned retention period for that personal data;
  • when personal data has been collected from a third party, the source of the personal data.

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them.

If requests are frivolous or vexatious, we reserve the right to refuse them.

If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

• The right to rectification

When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

• The right to erasure (the ‘right to be forgotten’)

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

• The right to restrict processing

You may ask us to stop processing your personal data («Delete profile»). We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

  • the accuracy of the personal data is contested;
  • processing of the personal data is unlawful;
  • we no longer need the personal data for processing but the personal data is required for part of a legal process;
  • the right to object has been exercised and processing is restricted pending a decision on the status of the processing.

• The right to data portability

You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format.

• The right to object

You have the right to object to our processing of your data where:

  • processing is based on legitimate interest;
  • processing is for the purpose of direct marketing;
  • processing is for the purposes of scientific or historic research; or
  • processing involves automated decision-making and profiling.

We promise to respond to your request without undue delay and within one month from the receipt of.

We keep the data and information provided by you confidential, in particular in accordance with the laws of EU, this Data Protection Policy, and contractual arrangements with data processor. We do not trade the data we have about you, and we do not make it commercially available to any other third party.

5. Security measures

We intend to protect the personal data entrusted to us and treat it securely in accordance with this Data Protection Policy.

We have implemented organizational, administrative, technical and physical measures to protect your data from unauthorized access, use, or disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.

If you are of the opinion that your rights related to the protection of your personal data were breached, you may submit a complaint to the relevant authority for the protection of personal data in your respective country (the country of your residence).

6. Contact us

If you need additional assistance, or help with accessing, correcting, suppressing, or deleting your personal information, or if you have any questions to our Data Protection Policy please do not hesitate to contact us.  

You can contact our Data Protection Officer (DPO) by sending an e-mail to privacy@birdieeyes.com.

Also you may contact the Norwegian Data Protection Authority: www.datatilsynet.no.

We may update this Data Protection Policy from time to time. You agree to visit these pages periodically to be aware of and review any such revisions.