Terms of Business - Appendix 1
1. Parties and Roles
-
- Data Controller: The Golf Club (customer) that owns and controls the personal data provided through the GLFR member import feature.
- Data Processor: Ingenium Golf ApS (DK VAT no. 34 46 64 91)(GLFR), processing this data solely on behalf of the club and according to its instructions.
2. Purpose and Scope
The club authorizes GLFR to process personal data (e.g. name, email address, member ID) solely for the purpose of sending an initial onboarding email to each member. Processing includes data import, temporary storage, and dispatch of this email.
3. Processing Activities and Data Types
- Importing a member list from the club’s system.
- Temporarily storing the data within the GLFR platform.
- Sending one single email to each contact, inviting them to access the GLFR platform.
- Deleting or anonymizing data for non-activated users no later than 90 days after import.
4. Duration
The processing continues until the onboarding email is sent and the data for non-registered users has been deleted—no later than 90 days after the import.
5. Security and Confidentiality
GLFR ensures appropriate technical and organizational measures in accordance with GDPR, including encryption, access controls, and staff confidentiality obligations.
6. Sub-Processors
GLFR may use sub-processors (e.g. hosting providers) under separate data processing agreements that ensure equivalent data protection in line with this agreement.
7. Personal Data Breaches
GLFR will notify the club without undue delay—and no later than 24 hours—if a personal data breach occurs, and will assist in any required notification to authorities.
8. Audits and Documentation
The club has the right to request audits or inspections of GLFR’s data processing practices with reasonable notice, to verify compliance with this agreement.
9. Data Deletion and Return
Once processing is complete—or after 90 days for unregistered users—GLFR will delete or anonymize all relevant data. The club may request a copy of the data before deletion.
10. Effective Date and Acceptance
This Data Processing Agreement enters into force automatically when the club uses the member import feature and is binding as long as the feature is in use.