The Ryder Cup is a biennial golf competition between teams from Europe and the United States and is jointly operated by Ryder Cup Europe and the PGA of America. The venue location for the Ryder Cup alternates between courses in Europe and the United States and determines the ‘Home’ or ‘Away’ teams. For example, the 2018 Ryder Cup was held in France, making Ryder Cup Europe the Home team. Personal information relating to hospitality, volunteering, and ticketing activities on the Ryder Cup website and mobile app will be collected by the relevant Home entity beginning January 1st the year before the Ryder Cup through December 31st the year of the event. Any other personal information will be collected by your preferred team, or as otherwise indicated at the point of data collection.
Last updated: November 12, 2019
Overview - Categories and Sources of Information
- We collect personally identifiable information from Users of our Service when it is voluntarily provided by you, such as your name and email address (see Information We Collect below). We use such information to contact you directly and other purposes described in How We Use the Information and Information Sharing and Disclosure below
- We automatically collect browsing information and other non-personally identifiable information from Users of our Service and from third parties with whom we work, such as our broadcast partner NBCUniversal. This information includes information about your browsing activities and information about the device you use to access the Service (see Information We Collect below). We use such information to customize the Service for you and other purposes described in How We Use the Information and Information Sharing and Disclosure below.
- This information is collected to provide, manage, analyze and improve the features and functions available on or through this Service and other services, for marketing purposes and for the PGA’s and its affiliates’ internal business purposes.
- You can know, access, delete and control certain uses of your information, including opting out of any sales of your personal information (see User Rights - Data Access and Opt-Out below).
I. Information We Collect.
1. Information You Provide To Us.
At some Services, you can register, order products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters or alerts, participate in golfing activities, connect with other people or services or participate in one of our online forums or communities. In the course of these various offerings, we often seek to collect from you various forms of information, such as: name, address, e-mail address, telephone number and other personally identifiable information.
If payment details are required, such as credit card information when making a purchase through the Services, such information will be collected directly by our service provider and not by the PGA. Such service provider is required by the PGA to only use the payment details for purposes of that transaction with you.
2. Information That is Passively or Automatically Collected.
We, and our "Partners" who include third party service providers, broadcast partners (such as NBCUniversal), other golf organizations, advertisers, advertising networks and platforms, agencies, and distribution or other partners may use automated means to collect various types of Information about you, your device used to access, or in connection with, our Services. A representative, non-exhaustive list of the types of automatically collected information may include: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, device attributes, browser settings, the web pages of the Services you have visited, Services visited before and after you visit a Service, the type of handheld or mobile device used to view the Service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on. Please see our Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.
3. Geo-location Information.
If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on other Services, when we work with a Partner such as a third party mobile ad platform. You may also choose to provide your location, such as when searching for a golf course or services in a particular area or customizing the Service. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.
4. Information Collected By and From Social Media Services and Other Third Party Platforms.
II. How We Use the Information.
We, along with our Partners, may use the Information to:
- provide and communicate with you about the Services or your account with us,
- fulfill your requests regarding the Services, including without limitation requests for newsletters and notifications,
- respond to your inquiries,
- communicate with you about other products, programs or services that we believe may be of interest to you,
- enforce the legal terms (including without limitation our policies and terms of service) that govern your use of our Services, and/or for the purposes for which you provided the Information,
- provide technical support for the Services,
- prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services,
- protect the safety of our Users,
- customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them, or
- perform analysis regarding how you use the Services or any part thereof.
III. Information Sharing and Disclosure.
We may disclose the Information as follows:
IV. Cookies and Other User and Ad-Targeting Technologies.
2. Syncing Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partners' uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match Users to their likely product interests, or better synchronize, cap, or optimize advertising.
We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your device and/or to collect and record information about your web surfing activity, including those integrated with our Services. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising or to opt-out of this type of advertising by those third parties that are members of DAA's opt-out program, please go to //www.aboutads.info.
4. Web Beacons. We and our Partners may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
6. Mobile Device Identifiers. In connection with any mobile app that we offer as part of the Services, we may collect Information such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and Information connected to how mobile devices interact with our Services and those using our Services. We may use this technology to deliver or help our Partners deliver certain advertising through mobile applications and browsers based on information associated with your mobile device. If you'd like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the "Your Ad Choices" section below.
By visiting the Service, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Service through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.
Our unaffiliated Partners and third parties may themselves set and access their own tracking technologies when you visit our Services and they may have access to information about you and your online activities over time and across different websites or applications when you use the Service. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.
V. Your Ad Choices.
Advertising enables us to provide the rich content for which the Services are known, and to provide much of this content free of cost to our Users. Thus, we strive to provide you with ads that are relevant to you and for products you may want.
However, we also offer you choices with regard to interest-based ads. To learn more about interest-based ads and the choices available to you, please visit the Digital Advertising Alliance (the "DAA") at the DAA consumer choice Service. To the extent data is collected on this Service for interest-based advertising, we will adhere to the DAA's principles applicable to interest-based ads.
The tools provided on the DAA opt-out page are provided by third parties, not us. We do not control or operate these tools or the choices that advertisers and others provide through these tools. When using a mobile application you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device's advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.
At this time the Services do not recognize automated browser signals regarding tracking mechanisms, which may include "do not track" instructions.
VI. User Rights - Data Access and Opt-Out.
1. User Rights.
We provide you with choices regarding the Information you provide to us.
- Personal Information -
- Right to Delete - If you would like to delete the personal information we possess about you, you may contact us at email@example.com.
- Right to Know Categories & Information - If you would like to receive the categories of personal information collected about you, the categories of sources from which the personal information is collected, the purpose for collecting and selling the personal information, the categories of third parties which whom we share the personal information and the specific pieces of personal information collected about you, then you may contact us at firstname.lastname@example.org.
- Do Not Sell My Personal Information - If you would like us to simply not sell your personal information to a third party, then you may opt out of such disclosures by sending an email to us at email@example.com.
- Emails - If you have signed up to receive our marketing e-mails and prefer not to receive marketing information from this Service, follow the "unsubscribe" instructions provided on any marketing e-mail you receive from this Service.
- Cookies – You may delete or block cookies and other technologies by following the instructions above.
We will maintain procedures to verify that you are authorized to make the requests set forth above. You may designate an authorized agent to make these requests by informing us, though we will need to verify that such agent has the authority to act on your behalf.
We do not discriminate against you for exercising any of your rights above, though we are not able to provide some Services to you without receiving such information.
· EU Data Subject Rights. If you are a situated in the EU, under the General Data Protection Regulation (“GDPR”), as a data subject, you have the following rights:
o Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
o Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
o Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
o Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
o Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
o Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
To exercise your rights under the GDPR, please contact us at firstname.lastname@example.org. If you are situation in the EU and have any complaints regarding our privacy practices, you have the right to complain to the relevant data protection authorities.
2. Verify Requests.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your Information. This is a security measure to ensure that Information is not disclosed to any person who has no right to receive it.
3. International Transfer.
4. Data Security.
We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access to or use of the Information we collect through the Service. These safeguards vary based on the sensitivity of the Information that we collect and store.
5. How to Contact Us.
The Professional Golfers’ Association of American100 Avenue of the Champions, Palm Beach Gardens, FL 33418, 561-624-8400 email@example.com
VII. Third Party Sites.
Some of the Services contain links to other services such as Facebook, Twitter, LinkedIn, and other media services and platforms whose information practices may be different than ours. Users should consult these other services' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
VIII. Updates & Effective Date.
Ryder Cup Europe Privacy Notice
The Ryder Cup is a bi-annual competition between teams from Europe and America. You have been directed to this page as you have given, or are considering giving, personal data which is to be processed by Ryder Cup Europe (as defined below).
The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. GDPR does not apply to information already in the public domain.
Both Ryder Cup Europe Limited and Ryder Cup Europe LLP (the two entities through whom the European Ryder Cup team is organised and run) (together, Ryder Cup Europe and each such reference in this policy it a reference to both entities) take your privacy seriously and we are committed to protecting your personal information. The address for:
(a) Ryder Cup Limited (a company incorporated in England and Wales under number 02662321) is Centenary House, The Belfry, Sutton Coldfield, West Midlands, B76 9PT; and
(b) for Ryder Cup Europe LLP (a partnership registered in England and Wales under number OC307452) is Wentworth Drive, Virginia Water, Surrey GU25 4LX.
If you would like to get in touch with Ryder Cup Europe, you can find contact details in the ‘How to Contact Us’ section below.
This Privacy Notice applies to personal data (i.e. information concerning any living person (Data Subject)) held by Ryder Cup Europe as data controllers that is not already in the public domain. It explains what personal information we collect, how we collect and use that personal information, with whom we will share it, why and in what circumstances.
Ryder Cup Europe is pleased to provide the following Privacy Notice which covers all Ryder Cup Europe websites, mobile applications and mobile websites (Platforms) except where you are notified of another privacy notice which collects your personal information. For the avoidance of doubt, if you: (i) are buying merchandise, tickets, hospitality or tickets for a Ryder Cup being held in America; (ii) are volunteering for a Ryder Cup held in America; or (iii) you have registered an interest in receiving more information from the PGA of America, the personal data you provide in connection the above will be held and processed by the PGA of America in in accordance with is privacy notice, not this one.
You might find external links to third party websites on our Platforms and those websites may have their own privacy notices which are different to this Privacy Notice. Our Privacy Notice does not apply to your use of a third party site and you should therefore make sure that you are comfortable with their privacy notices prior to using those sites.
Ryder Cup Europe uses the information collected from you to provide such organisational services as you request from us. In using our services you consent to Ryder Cup Europe maintaining a dialogue with you until you either opt out (which you can do at any stage) or we decide to desist from promoting our services.
The type of information that we may collect will differ depending on the type of service we are offering or the request you make of us. Such information may include your:
· date of birth
· contact details (including email address and/or telephone/mobile number)
· booking reference
· payment card details
Ryder Cup Europe will only collect such of your customer information as is necessary to provide you with and keep you informed about its services.
Use and Disclosure of your Information
We may use your personal information: to communicate with you, either in response to a direct request from you or, where you have so consented, to update you on our products and/or offers and those of our partners; to fulfil any contract that we may enter into with you; to provide you with the products and/or services that you request from us; to create an individual profile for you so that we can understand and respect your preferences; for record keeping purposes; to track your activity on the Platforms; in connection with targeting and/or advertising activities; in such way as you may otherwise expressly consent to; and to comply with legal and regulatory requirements.
Ryder Cup Europe utilises the services of third parties in the processing your personal information as set out above. Ryder Cup Europe ensures that each such organisation, and any third party who processes your personal data on our behalf, is contractually committed to GDPR compliance and adequate data security standards. Third party contractors who process data on our behalf do so strictly under our instructions and are not permitted to make other uses of your personal data.
Legal Basis for Processing Personal Data
We will only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis for doing so. This may be because:
· we need to use your personal information to take steps to enter into a contract with you or to meet our contractual obligations to you;
· we need to use your personal information to respond to enquiries from you;
· we need to use your personal information to pursue our legitimate interests as a commercial organisation; or
· we have your consent to using your personal information for a particular activity (for example, where you have consented to us sharing with you marketing or promotional communications from Ryder Cup Europe and/or its official partners, sponsors, suppliers or licensees which we think may be of interest).
Our legitimate interests as a commercial organisation include the administration and promotion of the Ryder Cup and the sport of golf, and the fulfilling of services to its fans and our customers.
You may withdraw your consent to the processing of your personal information at any time by contacting the Chief Privacy Officer (see the ‘How to Contact Us’ section below).
Ryder Cup Europe will only retain your personal information for as long as is reasonably necessary for the purposes for which it was collected and in line with our data retention policy. For example, we will normally keep contractual information for a period of ten years after the expiry of any such contract so that, if we need to establish, exercise or defend our legal interests, we may deal with any dispute or concerns that may arise.
Your personal information will either be held by us, on-premise or in cloud services, or our service providers. If your personal information is transferred outside of the European Economic Area, we ensure that it is afforded the protections required under GDPR.
Your Rights as a Data Subject
At any point whilst Ryder Cup Europe holds your personal information, you have a number of rights available to you, including the following:
· Right of access – you have the right to access a copy of the information that we hold about you and to obtain information about how we process it;
· Right of rectification – you have a right to request that we correct data that we hold about you if it is inaccurate or incomplete;
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records;
· Right to restriction of processing – where certain conditions apply you have a right to request that we restrict the processing of your information;
· Right of portability – you have the right to have the data we hold about you provided to you in an electronic format and/or to request that it is transferred to another organisation;
· Right to object – you have the right to object to certain types of processing such as direct marketing;
· Right to object to automated processing, including profiling – you also have the right not to be subject to a decision based solely on automated processing (including profiling) which adversely affects your legal rights.
You can exercise these rights in the first instance by contacting the Chief Privacy Officer (see ‘How to Contact Us’ section below). Should you wish to do so, we will require you to provide additional information to confirm your identity as follows:
· One piece of photographic identification (e.g. passport, other national identity card or photocard driving licence); and
· One proof of address (e.g. utility bill dated within the last 3 months).
We will advise you promptly if we require further information in order to fulfil your request. Please be aware that these rights are, in the most part, not absolute and are subject to exceptions; for example if we have a necessary and lawful basis on which to continue processing your personal information, we may refuse any request you make to delete it.
Further to the rights set out above, you can request the following information from us:
· The identity and the contact details of the person or organisation that has determined how and why to process your data;
· Contact details of the Chief Privacy Officer, where applicable;
· The purpose of our processing of your personal information as well as the legal basis for processing;
· If the processing is based on the legitimate interests of Ryder Cup Europe or a third party, such as one of its clients, information about those interests;
· The categories of your personal data we have collected, stored and processed;
· Recipient(s) or categories of recipients that your personal data is/will be disclosed/transferred to;
· How long your data will be stored for;
· Details of your rights to correct or erase your personal data and your rights to restrict or object to the processing of your data;
· Information about your right to withdraw consent at any time;
· How to lodge a complaint with the data protection regulator in the country where you live;
· The source of your personal data if it was not collected directly from you;
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
We may amend this Privacy Notice from time to time to keep it up to date with legal requirements, best practice and/or the way we operate our business. If we decide to change our Privacy Notice we will place any updates on this webpage and the privacy sections of any relevant Platforms. Please therefore check this page and the privacy sections of any relevant Platforms.
Please therefore check this page and the privacy sections of any relevant Platforms periodically in order to view the latest version of our Privacy Notice. Please note, however, that any substantial changes affecting your personal data will be notified to you.
How to Contact Us
The primary point of contact for all issues arising from this Privacy Notice is our Chief Privacy Officer, who can be contacted by email at: firstname.lastname@example.org
or by post at:
Chief Privacy Officer
Ryder Cup Europe
In the event that you have any questions, concerns or wish to make a compliant about how your personal data is being processed or regarding our compliance with this Privacy Notice, we would encourage you to contact our Chief Privacy Officer in the first instance. We will investigate and attempt to resolve complaints and disputes as quickly as possible. If you do not get a response within 30 days you can complain to the Data Protection Regulator (the Information Commissioner’s Office or ICO). You can refer matters to the ICO at any time, but the ICO recommends that individuals always seek to resolve matters through the data controller’s usual processes in the first instance.
Date of issue: October 2019.