Privacy Policy

We, in Gryyny s.r.o., Identification No. 02057875 (hereinafter only as “We”) pay maximum attention to the issue of personal data protection. In this document you may find information about which personal data we process, namely about our customers and users of our website, whether we process data on the basis of a consent or on other legitimate grounds, for which purpose we use data, to whom we may transmit it and what rights you have in connection with processing your personal data.

A. Which personal data do we process?

When using our services, whether as players or as coaches, we collect all kinds of data, such as your user name and password, your contacts and other settings. We monitor the content you edit on our website and from which device or which of our offers sent by email captured your attention in order to be able to improve our website in the future. If you order any service from us or create an account, we also work with name and surname, your orders and data you may set in your account.

We process the following personal data:

• identification data which means namely name and surname, user name and password;
• contact data which means personal data thanks to which we may contact you, namely your email address, telephone number, location and your contacts in social networks;
• your settings which mean data in your account, namely your assessment of coaches;
• information about your orders which means namely data about ordered games with a coach, completed reservations, type of service, method of payments and information about complaints;
• data about your services which also include courses where you operate and a tariff of your services;
• data about your behaviour on the website, including when you edit it through our mobile application, namely which content of our website you edit, links on which you click, method of navigation through our website and moving a screen and also data about a device from which you edit our website, such as an IP address and location derived from it, device identification, its technical parameters, such as an operating system, its version, screen resolution, browser and its version and also data obtained from cookies and similar technologies for device identification;
• data about your behaviour when you read emails sent by us,  namely times of opening messages and also data about a device on which you read them, such as an IP address and location derived from it, device identification, its technical parameters, such as operating system and its version, screen resolution, browser and its version;

B. Why do we process personal data and what gives us an authorisation to do it?

We process your personal data in various situations and for various reasons. If you use our website where we use cookies, we use your data namely in order to monitor a visitor rate and to improve our services. If you register with us, we use your data for keeping your account and providing related functions. If you order a service through us, we use your data in order to attend your orders, protect your rights and fulfil our legal obligations. Using your contacts, we also send you our offers. If you are a golf coach, we may make your data accessible to players, even if you are not registered with us. With your consent we disclose your data to third parties for displaying offers on other websites. We are authorised to process personal data either on the basis of the process of preparation or performance of a contract with you, compliance with legal obligations, our legitimate interests or your consent.

Within our activities we process personal data for various reasons and in various extent, either:

• without your consent on the basis of performance of a contract, our legitimate interest, or on the grounds of compliance with a legal obligation, or
• on the basis of your consent.

What processing activities we may carry out without your consent depends on the purpose to which the relevant processing is aimed and in which position you are with respect to us – whether you are only a common visitor of our website, or you are registered with us as a player or as a coach. We are also authorised to process your data if you communicate with us, complete questionnaires or participate in contests.

B.1 If you visit our website or use our mobile application

B.1.1 Using cookies and other technologies, transferring data to advertising agencies and social networks

If you visit our website, we store in your device and subsequently read from it small files called cookies. A cookie is a small file of letters and numbers which we store in your internet browser or on the hard disk of your computer. Some cookies enable us to connect your activities when you are browsing our websites from the moment you open a window of a web browser until you close it. When you close the window of the web browser, the cookies are deleted. Other cookies remain in the device for the set period of time and they are activated whenever you edit the website which created the specific cookie file. We also use web beacons which are small pictures with a similar function as cookies. Unlike cookies that are stored on your computer's hard disk, web beacons are a fixed part of a website. For the sake of simplicity, in this document we will refer all these technologies as cookies. Not only that we store cookies in your device, but we also read cookies that are stored in your device by our website. For the sake of simplicity, we will refer this process only as storing.

Some cookies are stored in your device directly by our website. These cookies help us:

• identify you when you are browsing through our websites and when you visit them repeatedly so as we could remember your logging in from a specific device and so as not to ask you again for your email and password, or to store the version of our website we should display if the website is offering more alternatives at the given moment;
• record that you granted a consent according to this document, or whether you, for example, offered your participation in a survey;
• ensure safety, for example in order to examine whether your connection to our website has not been misused by someone acting instead of you;
• register, examine and remove failures and dysfunctional components of our website.

Such cookies and other files are necessary in order to make our website functional. If you block these cookies in your browsers, our website may not function correctly and we may not be able to provide you with our products and services.

We also store in your device:

• cookies from our website which enable us:
  • to monitor a visitor rate of our website and its individual sites, create statistics and reviews and measure effectiveness of advertisement;
  • to show you various alternatives of your website when we are testing new functionalities;
• we allow third parties to store cookies and they may use them:
  • for collection of data about your behaviour on our website and on other websites;
  • to display customized offers and targeted ads within advertising and social networks on websites other than our website;
  • to connect with social networks, such as Facebook, including automatic login, to activate functions such as “Like” button or to send notifications related to the completed order through the Messenger service and to show adjusted offers and targeted ads on such social networks and websites other than our website.

In order to show adjusted offers and targeted ads within advertising and social networks on websites other than our website, we also transmit data about your behaviour on the website to advertising and social networks. However, we do not transmit your identification data to such partners. See the list of social and advertising networks that we use in the section Who processess your personal data and to whom we transmit them?

B.1.2 The use of personal data of web visitors

If you visit Gryyny.com website or use our mobile application, we process data about your behaviour on the website on the basis of our legitimate interest (i.e. even without your consent) in order to:

• obtain information based on which we will be able to improve the website or the application in the future so that the process of choosing or offering lectures would be even better than it is; in this case our legitimate interest is improvement of our services for you;
• create statistics and reviews, namely to monitor a visitor rate of our website and its individual sites, the method of use of the mobile application and to measure effectiveness of advertisement; in this case our legitimate interest is the measurement of effectiveness of our website and expenses on advertisement;
• test new functions and applications before deployment in order to prevent problems with functionality or such news in real operation which could worsen your experience with using our services; in this case our legitimate interest is a smooth operability of our services for you;
• prevent attacks on our website and threats to its operability and safety of your data; in this case our legitimate interest is a smooth operability of our services for you and safety of your data.

We do not get data about your behaviour on the website only from cookies. We add to it also the following data:

• IP address of your device (address of your device through which you communicate with other devices in the Internet network);
• operating system of your device, its version and language settings;
• browser you use on your device, its version and language settings;
• website address (URL address) from which you come to our website.

We use your personal data for these purposes for the maximum period of 50 months and during this time we keep data only in a pseudonymized form. You have the right to object to processing.

B.2 If you are a golf coach

On our website we post the lists of golf coaches providing services in various locations which contain identification and contact data. We post such lists in order to make it possible for players to find a coach in the location of their interest and also to share information about coaches, such as their rating and experience.  

For this purpose we use data about coaches who created an account with us, but also data obtained from public sources, such as golf association websites. We process your data on the basis of legitimate interest of players to obtain information regarding quality and services of coaches (including their rating) who provide their services on a public basis.

If we have available your contact email, we will inform you about your registration in the list. If you do not wish to be registered in the list of coaches, you have the right to object to processing. If you, for example, finished your activities as a golf coach or you have serious reasons for your request, we will remove you from the list.

B.3 If you register with us

In order to get registered, you must visit our website or use our mobile application, and therefore processing activities described in this section - If you visit our website or use our mobile application concern you.  If you register, we also perform the following processing activities:

B.3.1 Processing on the basis of performance of a contract

If you create an account on gryyny.com website, we process your identification and contact data, your settings and data about your orders (if you reserve a game or accommodation through us), on the basis of performance of a contract with you (without your consent) so that we could keep your user account. A contract on which our processing is based arises upon creation of your account. For this purpose, we use personal data for the time of existence of your account which you may delete at any time.

If you create an account as a coach, we process for the same purpose also data about services offered by you. Please consider that if you are a coach, you can cancel your user account on Gryyny.com.

B.3.2 Processing on the basis of legitimate interest

If you create an account on gryyny.com website, we process your identification and contact data, your settings, data about your orders (if you order our services at any time later), and data about your behaviour when reading emails also on the basis of our legitimate interest (i.e. even without your consent), in order to:

• obtain information based on which we will be able to improve our services in the future so that the purchasing process on our website was even better than it is; in this case our legitimate interest is the improvement of our services for you; and
• provide offers that we may send you by email, SMS, through social networks, communicate them on telephone or by other electronic means; in this case our legitimate interest is an effective promotion of our products and services.

For this purpose, we use personal data for the time of existence of your account which you may delete at any time. You have the right to object to processing.

B.4 If you order a service through us

In order to order a service through us, you must visit our website, and therefore processing activities described in this section – “If you visit our website or use our mobile application” concern you. If you order a service with us, we also perform the following processing activities:

B.4.1 Processing from the processor's position

If you create an account with us, we will collect your identification and contact data and data about your orders as a processor for a resort from which you order the products. We will transmit your personal data to such resort so that they could attend your order immediately after you create your reservation.

B.4.2 Processing for the purpose of performance of a contract

If you order a service through us as a natural person, we will process your identification and contact data and data about your orders data for the purpose of preparation, conclusion and performance of a contract with you.If you have a user account, we may also use your settings for this purpose.

If you order a service through us as an agent of a legal person, we will process the same data for the same purpose on the basis of our legitimate interest consisting in conclusion and performance of a contract with a person you represent.

The fact that we will use this data for the purpose of preparation, conclusion and performance of a contract with you means that we will use it namely:

• to enable you to complete your order on the website, for example to prevent deletion of data from an order in progress;
• to communicate with you regarding your order, for example to send you an order confirmation or inform you of a change of its status;
• for the purpose of payment of an order; in this connection we may transmit your data also to our partners operating payment systems, as described in the section Who processes your personal data and to whom we transmit it?;
• in connection with your other requirements with which you may address us, e.g. by means of a call centre, as described in the section If you communicate with us through more channels;

For this purpose, we use personal data for a necessary period of time in order to attend your order, or to attend a contract requirement, such as a complaint.

B.4.3 Processing on the basis of legitimate interest

If you create an order with us, we process your identification and contact data, your settings (if you register with us), and data about your orders also on the basis of our legitimate interest (i.e. even without your consent), in order to:

• obtain information based on which we will be able to improve our services in the future, namely to check your satisfaction with our services; in this case our legitimate interest is improvement of our services for you;  
• provide offers that we may send to you by email, SMS, through social networks, communicate them on telephone or by other electronic means; we are authorised to send you our offers, if you do not reject this option when ordering a service; in this case our legitimate interest is an effective promotion of our products and services.

In order to protect legitimate rights and for the purpose of our internal records and audit, we process data for the time of a statute of limitation of 3 years and one year after the lapse of it with respect to the complaints lodged at the end of the statute of limitation. If any judicial, administrative or other proceedings are initiated, we process your personal data in a necessary scope for the whole duration of such proceedings and for the rest of the statute of limitation after such proceedings are closed. For other mentioned purposes we use personal data for the maximum period of 6 months, with the exception of email address for sending our offers which we will process until you reject them.

You have the right to object to such processing carried out on the basis of our legitimate interest.

B.4.4 Processing on the basis of compliance with legal obligations  

We also have to comply with certain legal obligations set by law. If we process your personal data exactly for this reason, we are not obliged to obtain your consent for such processing. We process your identification and contact data, data about your orders on the grounds of compliance namely with the following acts:

• Act No. 89/2012 Coll., the Civil Code;
• Act No. 634/1992 Coll., on the Consumer Protection;
• Act No. 235/2004 Coll., on the Value Added Tax;
• Act No. 563/1991 Coll., on Accountancy.

We use personal data for these purposes for the maximum period of 10 years from the issue of the last document to your order.

B.5 If you register to receive our newsletter

If you register to receive our newsletter, we will process your additional contact data on the basis of your consent for the purpose of sending our newsletter with news from Gryyny.com, including offers for our services. We use personal data for this purpose until you withdraw your consent to processing, i.e. until you deregister from receiving our newsletter. Withdrawal of your consent will not affect a lawfulness of processing before the withdrawal.

C. Who processes your personal data and to whom we transmit it?

In most cases we process your data for internal purposes as its controller. In such case we transmit your data to our partners for payment and other necessary issues regarding your order. We also transmit data to our partners who process it according to our instructions. With your consent we may transmit data also to advertising and social networks for displaying customized ads to other websites.

We process all the above mentioned personal data as a controller. It means that we set the above defined purposes for which we collect your personal data, and we determine the means of processing and are responsible for proper performance of such processing.

In certain cases, we also act as a processor for other controllers who are partner resorts, as described in the section If you order a service through us.

We may transmit your personal data also to other entities who are in the position of a controller, specifically:

• in connection with attending your order to our partners who participate in attending it, as mentioned in the section If you order a service through us, specifically  
• to partners operating payment systems for payment transfers, mainly in connection with bank card transactions, namely PayPal (Europe) S.à r.l. et Cie, S.C.A.. 22-24, boulevard Royal. L-2449 Luxembourg. Luxembourg (G-D);
• to a coach who was contacted by a registered player.
• on the basis of your consent to advertising and social networks as described in the section Using cookies and other technologies, transferring data to advertising and social networks, specifically to:
• Google Ireland Limited (registration code: 368047), with registered office Gordon House, Barrow Street, Dublin 4, Ireland; privacy protection terms of this company are available at:https://policies.google.com/technologies/ads
• Facebook Ireland Limited, with registered office 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland; privacy protection terms of this company are available at:https://cs-cz.facebook.com/about/privacy

D. From which sources do we obtain personal data?

In most cases we obtain personal data directly from you through our website or during communication with you. We may also obtain some other data from our partners, e.g. payment gates. If you are a golf coach, we can obtain your data also from public sources.

In most cases we process personal data that you provide when you order services, or when you create and use your account or when communicating with us.

If you order a service with us, we can obtain in connection with performance of the concluded contract additional data about your orders from banks or our partners operating payment systems, e.g. your bank account number or about successfully completed payment transaction

For this purpose, we use data about coaches who created an account with us, but also data obtained from public sources, such as golf association websites. See more information about this processing in the section If you are a golf coach.

E. What rights do you have in connection with personal data processing?

You have many rights in relation to your personal data. It is the right of access, correction, deletion, limitation of processing, transferability, right to object and lodge a complaint.

Similarly as we have rights and obligations in processing your personal data, you have certain rights related to processing your personal data. These rights include:

Right of access

Simply speaking, you have the right to know which data we process about you, for which purpose, for how long, where we obtain your personal data, to whom we transmit it, who process it apart from us and what are your other rights related to processing your personal data. You can learn it all in this document. However, if you are not sure which personal data we process about you, you can ask us for a confirmation whether or not personal data related to you is processed by us, and if so, you have the right of access to such personal data. Within the right of access, you can ask us for a copy of processed personal data and we will provide you with the first copy free of charge, while other copies will be charged.

Right to rectification

To make mistakes is human. If you find out that personal data we process about you is incorrect or incomplete, you have to right to ask us to correct it or supplement it without undue delay.

Right to erasure

In certain cases, you have the right to ask us to delete your personal data. We will delete your personal data without undue delay, if any of the following reasons is fulfilled:

• we no longer need your personal data for the purpose for which we processed it;
• you withdrew your consent to personal data processing, and the withdrawal concerns data which can be processed only with your consent and at the same time we have not any other reason to process such data;
• you exercised the right to object to processing (see below the section Right to object to processing) of personal data which we process on the basis of our legitimate interests and we conclude that such legitimate interests that would justify processing no longer exist or  
• if you suppose that processing of your personal data performed by us is no longer in compliance with generally binding legal regulations.

But please bear in mind that even if any of such reasons exists, it does not mean that all your personal data will be deleted immediately. This right will not apply if processing of your personal data continues to be necessary for the compliance of our legal obligation or determination, exercise or defence of our legal rights (see the section Why do we process personal data and what gives an authorisation to do it?).

Right to restriction of processing

In addition to your right to erasure, you have in certain cases the right to exercise the right to limited processing of your personal data. On the basis of this right you can in certain situations request that your personal data was marked and was not a subject of any further processing tasks – in this case, however, not for an indefinite period of time (such as in case of the right to erasure), but for a limited period of time. We are obliged to limit processing of personal data when:

• you object to the accuracy of personal data until we make an agreement on which data is correct;
• we process your personal data without a sufficient legal ground (e.g. outside the scope of what we have to process), but you prefer restriction over the erasure of such data (e.g. if you assume that you could provide us with such data in the future);
• we do not need your personal data any more for the aforesaid purposes of processing, but you request it for determination, exercise or defence of your legal rights, or  
• you object to processing. The right to object is described in details in the chapter Right to object to processing. During the time we examine whether or not your objection is legitimate, we are obliged to limit processing of your personal data.

Right to data portability

You have the right to obtain from us all your personal data that you have provided us and that we process on the basis of your consent (see the section If you grant us your consent) and on the basis of the performance of a contract (see the section Why do we process personal data and what gives an authorisation to do it?). We will provide you with your personal data in a structured, commonly used and machine readable form. In order to be able to easily transfer your data to your request, we may be able to transfer only data that we process in an automated way in our electronic databases.

Right to object to processing

You have the right to object to processing of your personal data which we perform on the basis of our legitimate interest (see the section Why do we process personal data and what gives an authorisation to do it?). In case of marketing activities, we will stop processing your personal data automatically; in other cases, we will do it only if we do not have serious and legitimate reasons to continue processing.

Right to lodge a complaint

Upon the exercise of your rights in the aforesaid manner, your right to lodge a complaint with the competent supervisory authority is not affected. You can exercise this right namely if you suppose that we process your personal data illegitimately or in conflict with generally binding legal regulations. You can lodge a complaint against processing of personal data performed by us with The Office for Personal Data Protection seated at the address Pplk. Sochora 27, 170 00 Prague 7.

F. How to exercise specific rights?

For any inquiries, complaints or requests in relation to processing of your personal data, please contact us using the form at https://www.gryyny.com/route-contact/.

In all matters related to processing of your personal data, whether you want to file a request, exercise right, lodge a complaint or ask any other question, you can use our contact form at https://www.gryyny.com/route-contact/

We will attend your request without undue delay, however, no later than within one month. Exceptionally, namely for the sake of complexity of your request, we are authorised to extend this time period by another two months. We will of course inform you of such extension and the reasons for it.