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PRIVACY POLICY

Privacy Policy

SUMMARY

____________________________________________________________

CLAUSE

1. Important information and who we are 

2. The data we collect about you

3. How is your personal data collected?

4. How do we use your personal data?

5. Communication of your personal data

6. International transfers

7. Data Security

8. Data retention

9. Your legal rights

10. Glossary


Introduction

Welcome to Bee Leader's Privacy Policy.

Respecting your privacy and protecting your personal data are very important to Bee Leader. This Privacy Policy aims to explain to you how we process your personal data when you visit our website (regardless of where you are) and to inform you of your rights relating to your data and legal provisions that protect you.

This Privacy Policy is structured by section so as to facilitate consultation and to be able to click directly on the subject that interests you. A Glossary is provided to help you understand some of the terms used in this information notice.

1. [IMPORTANT INFORMATION AND WHO WE ARE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED?]

4. [HOW DO WE USE YOUR PERSONAL DATA?]

5. [COMMUNICATION OF YOUR PERSONAL DATA]

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]

10. [GLOSSARY]

  1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to inform you of the way in which Bee Leader collects and processes your personal data obtained through your use of this website, including the data that you are likely to provide when you subscribe to our subscription, you sign up for our newsletter, buy a product or service or when you participate in a contest.

As this website is not intended for children, we do not intentionally collect any data concerning children.

It is important to carefully read this Privacy Policy and any other privacy or fair data processing policies that we may from time to time publish when we collect or process personal data about you. , so that you are fully informed of how we use them and for what purposes. This Privacy Policy supplements the other policies we apply, without replacing them.

Data controller

Bee Leader SAS. (“Bee Leader”) encompasses several legal entities, affiliates, partners, licensors, subsidiaries and related companies and websites, including www.Bee Leader.fr and www.MyGolfCad.com. As this Privacy Policy is established on behalf of Bee Leader, any mention of the name Bee Leader or the pronouns "we" or "our" in this policy refers to the entity of the Bee Leader group responsible for the processing. of your data. Bee Leader is the data controller as well as the manager of this website.

We have appointed a Data Protection Officer (DPO) to oversee matters relating to this Privacy Policy. If you have any questions about this Privacy Policy, including requests to exercise [your legal rights], please contact the DPO at the contact details set out below.

Contact details

Full name of the legal entity: Bee Leader SAS

Name and title of the DPO of Bee Leader: Claude CEARD

Email address: contact@mygolfcad.com

You have the right to lodge a complaint at any time with the competent data protection supervisory authority in your jurisdiction. However, we cordially invite you to submit your questions to us before any recourse to the supervisory authority, so do not hesitate to contact us as a first resort.    

Changes to the Privacy Policy and your duty to notify us of any changes

The latest version of this policy dates from January 01, 2021, its previous versions are available on request.

It is important that the personal data we hold about you is accurate and up to date. Also, we kindly ask you to inform us of any changes to your personal data that may occur during our relationship.

We reserve the right to update and modify this Privacy Policy at any time without notice. We invite you to regularly consult this page to keep yourself informed of any changes.

Links to Third-Party Sites

This website may include links to third party websites, plug-ins and applications. By clicking on these links or allowing the connection to these modules or applications, third parties may collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements. When you leave our website, we recommend that you carefully read the privacy policy of the other websites you visit.

  1. The data we collect about you

Personal data, or personal information, refers to information about an individual that allows that person to be identified. The definition of this term does not include data in which the identity has been removed (anonymized data).

We may collect, use, store and transfer different types of personal data about you which we have classified into the following categories:

  • Identity Data including name, maiden name, first name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact data including billing addresses, correspondence addresses, e-mail addresses and telephone numbers.

  • Financial Data including bank account details and payment card information.

  • Transaction data including information about payments made or received by you and other information about the products and services you have purchased from us.

  • Technical Data including your IP address, login data, browser type and version used, location and time zone settings, browser plug-in types and versions, operating system, platform and other technologies on the devices you use to view this website.

  • Profile data including your username and password, purchases and orders you have made, your interests, preferences, comments and responses to satisfaction surveys.

  • Usage data including information about your use of our website and our products and services.

  • Marketing and Communications Data including your preferences for receiving marketing communications that we, or third parties, send to you and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data, to serve any purpose. Aggregated Data may derive from your personal data, but it is not considered personal data within the meaning of the law, as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to determine the percentage of users who use a given function of a website, the data entered during the use of Bee Leader sites, the most visited pages, the type of browser used, the links on which a user clicks, the IP address and other similar information. However, if we associate or link Aggregated Data with your personal data in such a way that it directly or indirectly identifies you, then we will treat the data so combined as personal data, the use of which will be in accordance with the this Privacy Policy.

We do not collect any Special Category Personal Data (including personal data that reveals your racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, as your genetic and biometric data and data concerning your health). We also do not collect personal data relating to criminal convictions and offences.

Failure to communicate your personal data

If we have to collect your personal data under the law or under a contract with you and you do not provide the required data, it is possible that we cannot ensure the proper performance of the contract concluded or contract with you (for example, provide you with goods or services). In this case, we may have to cancel our products or services that you use, of which we will notify you, if necessary.

  1. How are your personal data collected?

We use different means to collect data from and about you, including:

  • Direct interactions. You may give us your Identity, Contact and Financial Data when you fill in forms or when you communicate with us by post, telephone, email or otherwise. These interactions involve the communication of personal data when you:

  • request our products or services;

  • create an account on our website;

  • subscribe to our service or publications;

  • ask to receive commercial documentation;

  • enter a contest, promotion or survey; Or

  • you send us your comments.

  • Automated interactions or technologies. In your interactions with our website, we may automatically collect Technical Data about your computer hardware, browsing actions and behavior. We collect this personal data by means of cookies, server log files and other similar technologies. We may also receive Technical Data about you when you visit other websites using our cookies.

    • Cookies. When you visit a Bee Leader site, we may save one or more cookies on your computer in order to facilitate access to the Bee Leader site in question and to personalize your experience on this site. A cookie is a small text file, which does not contain any Personally Identifiable Information, that we place on the browser of the user's computer. Cookies also allow us to automatically collect information about your online activity on a Bee Leader site, such as the web pages you visit or the links you click on. Most browsers automatically accept cookies, but you can modify your browser settings to refuse cookies. If you decide to refuse cookies, you may not be able to log in or use some of the interactive features offered by the Bee Leader sites.

    • Other technologies. To track your use of the Bee Leader sites, we may use standard Internet technologies such as web beacons and other similar technologies. A web beacon is a small image file embedded in a web page that is used to track activity on the site, similar to cookie files. We may use web beacons in our email messages and newsletters to track whether messages have been opened and acted upon. The information we obtain in this way helps us to better personalize our services to visitors to the Bee Leader sites, to target our advertisements and to measure the general effectiveness of our advertisements, content, programming and other online activities.

  • Third-party or public sources. We may receive personal data about you from third-party or public sources such as:

  • Technical data from the following parties:

  1. analytics solution providers, such as Google, based outside the EU;

  2. advertising networks based in OR outside the EU; Or

  3. information search service providers based inside or outside the EU.

  • Contact, Financial and Transaction Data from technical, payment and delivery service providers based inside or outside the EU.

  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU.

  • Identity and Contact Data from public sources based inside or outside the EU.

  1. How do we use your personal data?

We use your personal data in strict compliance with the law. In general, we use your personal data in the following circumstances:

  • Where we need to perform the contract we have or will enter into with you.

  • We collect your information where it is necessary to serve our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests.

  • We also do so for the purposes of complying with a legal or regulatory obligation.

  • By creating an account with us, you agree that we may contact you, for commercial prospecting purposes, by phone, email, mail or text message, even if your number is on a black list or if it is a wireless phone number.

  • For the purpose of processing transactions.

Generally, other than sending third party direct marketing communications by email or text message, we do not rely on consent as a legal basis for processing your personal data. You have the possibility to withdraw your consent to receive commercial communications at any time by contacting us.

Purposes for which we use your personal data

The table below sets out the different ways in which we intend to use your personal data, as well as the legal bases on which we rely to do so. We also specify (where applicable) our legitimate interests.

It should be noted that our processing of your personal data may be based on several legal grounds, depending on the purpose for which we are using your data. In cases where more than one basis is indicated in the table above, please contact us to find out more about the legal basis justifying our processing of your personal data.
Marketing

We strive to provide you with choices about certain uses of your personal data, including those for marketing and advertising purposes.

Our promotional offers

We may use your Identity, Contact, Technical, Usage and Profile Data to advise us on your possible needs or wishes, or on what may be of interest to you. This use allows us to select the products, services and offers that best meet your expectations (in other words, to carry out marketing activities).

Following a request for information from you, a purchase of products or services, your registration for a contest or promotion and, in each case, if you have requested not to receive commercial communications , we will ask for your explicit consent before sending any marketing communications.

Third Party Marketing Communications

We will ask for your explicit consent before communicating your personal data for marketing purposes to any company outside the Bee Leader group.

Unsubscribe (opt-out)

You have the possibility to ask us, as well as any third party, and at any time, to stop sending you commercial communications by logging on to the website and then checking or unchecking the corresponding boxes in your communication preferences or by clicking on the unsubscribe link included in the commercial communication you have received or by  contacting usat any time.

Your choice to no longer receive marketing communications does not apply to personal data that you provide to us as a result of a product or service purchase, warranty registration, product or service experience. or any other transaction.

Cookies

You can set your web browser to refuse all or some cookies, or to alert you when a website uses cookies. If you deactivate or refuse cookies, it is possible that you will no longer be able to access certain parts of this website or that its operation may be impaired.

Modification of the purpose of the processing

We only use your personal data for the purposes for which it was collected, unless we reasonably believe that we need it for other purposes and those purposes are compatible with the original purpose. If you would like to know how the processing for the new purpose is compatible with the initial purpose, please contact us.

If we need to use your personal data for any other purpose, we will notify you and explain the legal framework that allows us to do so.

It should be noted that we may process your personal data without notifying you or obtaining your consent, in compliance with the aforementioned rules, when required or authorized by law.

Communication of your personal data

We may share your personal data with the parties mentioned below for the purposes defined in the table presented in paragraph 4 above.

  • Internal third parties, as defined in the [Glossary].

  • External third parties, as defined in the [Glossary].

  • Third parties with whom we may enter into assignment, transfer or merger agreements on part of our business or our assets. Conversely, we may seek to carry out acquisitions or business mergers. In the event of a change in our activity, the new owner will be entitled to use your personal data under the same conditions as those defined herein.

We require all third parties to maintain the security of your personal data and to process it in accordance with applicable law. We do not allow any of our third party service providers to use your personal data for their own purposes and allow them to process it only for the purposes specified and in accordance with our instructions.

International transfers

We share your personal data within the Bee Leader group. We store the information we collect, including your personal data, in the United States. Consequently, when you connect to a Bee Leader site from another country, your information is transferred from or to the United States or outside the European Economic Area (EEA).

We guarantee the protection of your personal data by requiring all companies in the Bee Leader group to comply with the same rules when processing your personal data. These rules correspond to the “binding corporate rules”. For more information, see the European Commission's Binding Corporate Rules. In addition, the exchange of sensitive and private data between a Bee Leader site and you takes place via secure SSL communication channels and is encrypted and protected by digital signatures.

However, while we want you to feel confident when using the Bee Leader sites, no system can be 100% secure. Also, although we take all necessary measures to secure your information, we cannot promise you, and you cannot require from us, a guarantee of 100% security of your personal information, research and other communications. It is also up to users to take their precautions when they manage and transmit their personal information, in particular by refraining from communicating it by unsecured transmissions. For more information on how to protect yourself against identity theft, visit the Federal Trade Commission website at: https://www.ftc.gov/bcp/menus/consumer/data.shtm.

Many of our external third parties are located outside the European Economic Area (EEA), so their processing of your personal data may involve a transfer of data outside the EEA.

When we are required to transfer your personal data, we ensure an adequate level of protection by ensuring that at least one of the following safeguards is implemented:

  • Where we engage certain service providers, we may apply specific contracts approved by the European Commission which provide for a level of data protection equivalent to that applicable within Europe. For more information, refer to the standard contracts of the European Commission for the transfer of personal data to third countries.

  • Where we engage service providers located in the United States, we may transfer data to them where they adhere to the Privacy Shield Principles which require them to provide adequate protection for personal data exchanged between Europe and the United States. For more information, see the European Commission's EU-US Privacy Shield.

To learn more about the mechanism we use to transfer your personal data within and outside the EU, please contact us.

Data security

We have put in place the appropriate security measures to safeguard your personal data against accidental or unlawful loss, use, access, alteration or disclosure. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties whose activity requires knowledge of them. They only process your personal data on our instructions and are subject to an obligation of confidentiality.

We have management procedures in place in the event of a personal data breach. We will notify you and the applicable supervisory authority of any breach where required to do so by law.

Data retention

Retention period of your personal data

We will keep your personal data for as long as necessary to fulfill the purpose for which it was collected, in particular for the purposes of legal, accounting and reporting obligations.

To determine the appropriate retention period for personal data, we consider the volume, nature and sensitivity of that data, the potential risk of harm from unauthorized use or disclosure of your data, purposes for which we process your data and the possibility of achieving these purposes by other means, as well as the applicable legal requirements.

The retention periods applicable to your personal data are presented in the table in paragraph 4 above.

We are required by law to retain certain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for tax purposes for seven years after they leave our customer file.

You have the possibility, in certain cases, to request the deletion of your data. To do so, please contact us at (866) 608-1798 during regular office hours. If we delete your account, your user profile will no longer be visible and all information associated with that account will be permanently deleted. In some cases, we may need to anonymise your personal data (so that it can no longer be associated with you) for research or statistical analysis purposes, in which case we will use it at our discretion without obligation to notify you. However, you may continue to receive promotional communications from us about new Bee Leader Products or Services.

Your legal rights

In some cases, data protection laws give you certain rights over your personal data. To learn more, please click on the following links:

  • [Request access to your personal data]

  • [Request rectification of your personal data]

  • [Request erasure of your personal data]

  • [Object to the processing of your personal data]

  • [Request restriction of processing of your personal data]

  • [Request the portability of your personal data]

  • [Right to withdraw your consent].

To exercise any of the above rights, please contact us.

No fees normally charged

Access to your personal data (or the exercise of any other right acquired by you) does not entail any costs for you. However, we may charge you a reasonable fee for repeated, unfounded or excessive requests. We may also refuse to comply with such requests.

Further information

We may need certain specific information about you to help us confirm your identity and ensure your right of access to your personal data (or your legitimacy to exercise any of your other rights ). This security measure ensures that no one can receive personal data without being entitled to it. We may also contact you to ask you for additional information relating to your request in order to speed up its processing.

Response time

We strive to respond to all legitimate requests within one month. This time may be longer if your request is particularly complex or if you have submitted several requests at the same time. In this case, we will notify you and keep you informed of the progress of the processing of your request.

California residents

Section 1798.83 of the California Civil Code authorizes users of the Bee Leader sites who are residents of the State of California to request certain information relating to our practice of communicating personal information to third parties for direct marketing purposes. .

Advertisements Disclaimer

Bee Leader has no form of affiliation with any political party or the views of any political party. Bee Leader advertisements visible on political websites are reminder advertisements (remarketing) and in no way the result of any affiliation or membership or partnership.

Remarketing allows Bee Leader to display advertisements targeting people who have already visited Bee Leader sites. When a person leaves a Bee Leader site without buying anything, remarketing allows us to contact them again through relevant advertisements displayed on their various devices and the various websites they may visit. Ads simply follow the user to the different sites they visit.

Glossary

LEGAL BASIS

Legitimate interest means the interest of our business to conduct and manage our business so that we can provide you with the best product/service and the best customer experience in a secure manner. We take care to consider the potential consequences (positive and negative) for you and your rights before processing your personal data to pursue our legitimate interests. We do not use any personal data where our interests do not outweigh the consequences for you of the processing (unless we have obtained your consent or are permitted or required by law to do so). You can contact us to find out more about how we assess our legitimate interests in relation to the potential consequences for you in relation to particular activities.

Contract performance refers to the processing of your data necessary for the proper performance of a contract to which you are a party or necessary to take steps at your request prior to entering into a contract.

Fulfill a legal or regulatory obligation refers to the processing of your data necessary for the proper performance of a legal or regulatory obligation to which we are subject.

THIRD

Internal third parties

Other companies in the Bee Leader group acting as joint controllers or processors who provide system administration and IT services and report information at a high level.

External third parties

  • Service providers acting as processors based in OR outside the EU who provide system administration and IT services.

  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in OR outside the EU who provide consultancy, banking, legal, insurance and accounting.

  • Supervisory authorities and other authorities acting as processors or joint controllers based in OR outside the EU that require disclosure of processing activities in certain circumstances.

  • Any other entity where required by law, for example, pursuant to a court order or subpoena. We may also disclose this information at the request of law enforcement or any public authority if we believe that doing so could prevent the commission of a crime or misdemeanour.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (more commonly known as a “data subject access request”). This right allows you to obtain a copy of your personal data that we hold and to check whether our processing of it is lawful.

Request rectification of the personal data we hold about you. This right allows you to have any incomplete or inaccurate data that we hold about you rectified. On the other hand, we are likely to verify the accuracy of the new data that you provide to us.

Request erasure of your personal data. This right allows you to ask us to delete any personal data about you where there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete your personal data under the terms of the exercise of your right to object to the processing of your data (see below) when it is possible that we are processing your data. unlawfully or that we are required to erase your data under local law. Please note, however, that we may not be able to comply with your request for erasure for specific legal reasons, in which case we will notify you at the time of your request.

Object to processing of your personal data based on our (or a third party's) legitimate interest. You can exercise this right for reasons relating to your particular situation which lead you to object to the processing, when you believe that this may affect your fundamental rights and freedoms. You also have the possibility to exercise your right of opposition when we process your personal data for direct marketing purposes. We may, in certain cases, demonstrate our compelling legitimate interests in processing your personal data which prevail over your rights and freedoms.

Request the restriction of the processing of your personal data. This right allows you to ask us to suspend the processing of your personal data in the following cases: (a) you want us to establish the accuracy of the data; (b) our processing of the data is unlawful, but you oppose its erasure; (c) we no longer need the personal data for the purposes of the processing but you still need them for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your data, but we need to verify whether our legitimate grounds override yours.

Request the portability of your personal data. You, or a third party, have the right to receive the personal data about you that you have provided to us, in a structured, commonly used and machine-readable format. It should be noted that this right only applies to information subject to automated processing for which you initially agreed that we use it or information that we use for the proper performance of a contract concluded with you.

Withdraw your consent at any time where our processing of your personal data is based on that consent. However, this withdrawal cannot affect the lawfulness of any processing carried out before the withdrawal of your consent. If you withdraw your consent, we may no longer be able to provide certain products or services to you. We will notify you, if applicable, when you withdraw your consent.

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