CLAPPHOUSE PRIVACY POLICY

Access to the Clapphouse application (hereinafter, the “APP”), as well as its use, are subject to what is described in the document “Terms and Conditions of Use of Clapphouse” (hereinafter, the “T&C”).

This document describes the privacy policy of the APP and we inform you of the details related to the personal data that we collect and the different treatments that we carry out.

We advise you to read this privacy policy carefully. If you have any doubt or need any clarification, you can contact THE MULLIGAN FACTORY, S.L. (from now on, “TMF”) by email through hola@themulliganfactory.com or by writing to Carretera de Rubí 88, 08174 Sant Cugat del Vallès, Barcelona.

Non-acceptance of this privacy policy entails the loss of the right to use the APP, and therefore, the possibility of enjoying the services provided through it (hereinafter, “SERVICES”).

1. DEFINITIONS

“User” is any person who accesses the APP and makes use of it. By doing so, the person accepts and acknowledges the T&C, and becomes a User of the App (hereinafter, “USER”). Users are the owners of the personal data that is the object of treatment.

“Licensee” is any entity that has previously signed a software use license agreement with TMF that grants it a specific license for the use of the solution composed of the APP and the associated web manager through which it is possible to manage its presence in it and to provide the different SERVICES to USERS. Most of the licensees are entities that have the facilities and services necessary for the practice of golf (eg. golf clubs) and/or entities that are in charge of managing them.

“Account” refers to the virtual space dedicated to each licensee within the APP, and through which the licensee provides the SERVICES to USERS who have previously correctly validated their identity. In order to be a USER of a specific account of a licensee (eg. the usual golf club, another additional golf club that is often visited), it will be necessary to activate said account in advance. Each licensee provides the SERVICES within the scope of its account.

2. LEGAL FRAMEWORK OF REFERENCE

On the one hand, TMF declares to know and accept that by virtue of the provisions of the Directive on electronic privacy (directive 2002/58/CE modified by Directive 2009/136/CE), “the terminal equipment of users of network electronic communications, as well as all information stored in said equipment, are part of the private sphere of users that must be protected in accordance with the European Convention for the Protection of Human Rights and Fundamental Freedoms ”.

On the other hand, TMF declares to know and accept that the personal data of USERS must be protected as stipulated in the legislation in force at all times, and currently in accordance with the provisions of Regulation 2016/679 of Parliament European Council and of the Council of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (General Data Protection Regulation, and hereinafter, “RGPD”) and in the case of Spain in particular, with what is also established in Organic Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights.

TMF undertakes to comply at all times with said legal framework of reference, also committing itself to implement the security measures that are required by the applicable regulations and to adopt, as far as possible, any additional measures of a technical, administrative, informative or necessary to comply with the legal requirements on the protection of personal data and in particular, guarantee the security and integrity of such data and its protection against unauthorized alterations, losses, treatment or access.

TMF will not be responsible for the compliance by the licensees of the applicable legislation on data protection, being the responsibility of each licensee to comply with it at all times, and vice versa.

3. PURPOSE OF THE DATA PROCESSING

TMF, as the ultimate responsible for the processing of their personal data, informs USERS that their data will be processed by TMF and the licensees in order that they can enjoy the APP and the SERVICES provided, being precisely the acceptance of the T&C and the maintenance of the status of USER of the APP the legitimacy for the treatment of said data.

To the extent that the USER is enjoying the SERVICES in the context of the account of a particular licensee, TMF and the licensee in question will generally be joint controllers of the USER’s data.

Additionally, TMF may also act on certain occasions as the licensee’s processor. The user is also informed that the APP performs customer profiling activities, creating for each USER a specific profile that progressively expands over time as the USER uses the APP and the different SERVICES.

4. UNIVERSE OF PROCESSED PERSONAL DATA

TMF has a database with the information of all the USERS of the APP, which includes all the information captured from the USERS at all times and as set out in Annex 1 “Personal data processed” of this Privacy Policy. These personal data will be obtained or collected through the means described in Annex 1.

5. FUNCTIONS OF THE PARTIES

5.1. Functions of TMF

TMF will generally be the ultimate controller of the USER’s data, who may:

(i) Use the APP in the context of the specific account of one or more licensees (in which case TMF will be co-responsible for the treatment).

(ii) Use different SERVICES not linked to any particular licensee account and/or over which the licensees have no control.

TMF may also act in certain situations as the licensee’s processor (e.g. when publishing schedules, classifications and photographs for a tournament in the app; when providing technical support to the licensee for the resolution of an incident that is affecting one or more USERS).

5.2. Licensee functions

Regarding the scope of each licensee’s account in the APP, and always within the framework of the correct provision of the associated SERVICES:

(i) The licensee will also act as co-controller of the data processing of USERS who have activated its respective account.

(ii) The licensee will have access and may carry out different treatments on different information of the USER’s profile, preferences of the USER specific to the licensee’s account, and information related to the activity of the USER in relation to the licensee, and in particular on their reservations, participation in events, and payments.

Annex 2 “List of licensees” provides a list with identifying details for each of the licensees who currently have a license to use the APP.

5.3. Main treatments by the parties

Regarding the personal data to which TMF and the licensees will have access, the following main treatments may be carried out in general:

(a) Consult all the mentioned data.

(b) Modification of those data for which TMF has enabled the possibility of editing at any time.

(c) Extraction and conservation of the data in different formats and supports and information systems, including the generation of own independent databases.

(d) Deletion by manually deleting the USER’s profile.

(e) Publication of new data related to the activity of the USER.

6. SPECIAL PERMISSIONS

For the correct functioning of the APP and the correct provision of the different SERVICES, the APP needs to share certain personal data with the systems of the licensee and the licensee itself, and vice versa. In this sense, the USER declares to know, and accept that:

(a) During the process of activating a licensee’s account, the APP and the licensee’s management systems may exchange certain information of a personal nature, and as set out in Annex 1 of this privacy policy. Said data is only stored and subsequently processed by TMF and the licensee in the event that the USER completes the account activation process.

(b) The licensee can share with the APP personal information about the USER’s profile and its activity related to the licensee (and in particular in relation to reservations, participation in all types of events, payments made and consumption), and vice versa.

Additionally, and to the extent that each licensee has its own dedicated virtual space within the APP, thus facilitating each licensee to have its own “app”, the APP acts as one more digital channel through which the licensees capture personal data of their respective customers. In this sense, the USER declares to know, and accept that:

(a) The licensee will be empowered at any time to generate its own database with the personal data processed as part of the use that the USER makes of the APP, and/or to update any existing database with said data under its responsibility.

(b) The licensee will be empowered to process the USER’s personal data according to the permissions previously obtained from said USER through other channels, and additionally for (i) the correct management of the relationship with the USER as a client and provision of the different products and services offered and/or delivered at all times (e.g. to send the USER a confirmation about a registration made, to inform the USER of an incident that affects a contracted service) and (ii) the promotion of all kinds of initiatives, promotions and news related to the licensee’s activity (eg. to inform the USER of a special discount or the launch of a new service).

And this through the channels associated with the previously obtained permits and through the digital channels constituted by the APP and associated technologies (eg. push notifications), email marketing and SMS for the aforementioned additional permits.

7. ASSIGNMENT OF DATA AND TRANSFERS

7.1. Access to data

TMF and the licensees will only give access to the information of USERS to authorized third parties such as employees and suppliers, and as long as such access by third parties is necessary for the purpose of complying with the provision of SERVICES and other services according to the special permits detailed in the previous section.

7.2. International transfers

In certain circumstances, TMF and/or the licensees, may need to carry out international transfers of certain USER data with third parties (e.g. in the event that it is necessary, in the interest of the USER, for the conclusion or execution of a contract between TMF and the licensee; when using TMF and/or the licensee service providers located outside the European Union for the provision of certain auxiliary services to their activity such as hosting, provision of infrastructure, generation of remote backups, IT support or maintenance services, email management, email marketing, file transfer or provision of certain specific functionalities of the APP; or for the execution of pre-contractual measures taken at the request of the interested party).

These entities can be different and vary over time. In this sense, TMF and the licensees undertake to choose entities that belong to countries that have a level of protection equivalent to the European in terms of data protection, or that offer the appropriate guarantees to achieve that level, and otherwise, only to make an international transfer of data to a third party based on any of the exceptions provided for this purpose in the RGPD.

By accepting this Privacy Policy, in any case the USER gives her express consent to these transfers.

Beyond the cases that have just been indicated, if it is necessary to make a transfer to a third party in a country that does not have that level of protection comparable to that of Europe (for example, because it does not have an authority or data protection regulations that protects the rights of the interested parties) and that does not offer the adequate guarantees to achieve that level, the USER will be informed of this risk so that he or she explicitly authorizes said transfers, giving their consent to them.

In the event that TMF is forced to carry out an exceptional international transfer of data due to national or European Union law, TMF will guarantee compliance with any applicable legal requirements, unless applicable law prohibits it for important reasons of public interest.

7.3. Data processors

Annex 3 “TMF data processors” offers a list of the processors that TMF currently uses to provide the SERVICES, indicating in which cases there is an international transfer of data. In the case of wanting to know the list of data processors used by each licensee, the USER must refer to each licensee in question.

8. CONSERVATION OF DATA

8.1. USER profile data and data not shared with other USERS

In general, TMF will only keep personal data as long as the person maintains the status of USER. In the event that a USER deletes all its accounts activated in the APP, TMF will automatically delete all its personal data so that neither TMF nor the corresponding licensees can continue to process it and it is not accessible from then on by other USERS.

The deleted data will remain in the database associated with the APP for a period of 6 months to enable its recovery in the event that the USER so wishes. The data will not be definitively eliminated from the database in those cases in which it is strictly necessary or mandatory to maintain it due to a regulation or law that is applicable.

In the event that the USER deletes only one of its accounts in the APP, then TMF will only (i) proceed to restrict access to the USER’s profile data by the licensee associated with said account, and (ii) will eliminate the data related to the USER’s preferences specific to said licensee’s account. The rest of the licensees may continue to process the USER’s data as long as it maintains the associated accounts activated.

8.2. General activity data and shared with other USERS

In no case will TMF and/or the licensee have the obligation to delete the data of a USER that has been published in the APP as part of the general activity of the USER related to the particular account and SERVICES provided by said licensee, and in particular in relation to the USER’s participation in different tournaments, and as long as TMF and/or the licensee have complied in due time with their obligations regarding data protection.

Additionally, the USER declares to know and accept that the information that the USER has shared with other USERS or that other people have copied may continue to be seen after having permanently deleted its account or profile. These facts are not under the responsibility of TMF and/or the licensees, since it is beyond the control of the parties to verify and eliminate content that other member/s use thanks to the information that was shared at the time with them.

8.3. About the contract that binds TMF with each licensee

On the other hand, after the termination, rescission and/or resolution for any reason of the contract that binds TMF with any of the licensees, TMF shall not keep any copy of the personal data of USERS that are specific to the licensee’s account in matter and to which TMF might have had access during the provision of the SERVICES.

Notwithstanding the foregoing, in the event that TMF considers it necessary to keep certain data to prove the service provided or to comply with the legal obligations that concern it, it may do so after prior written communication to the licensee.

9. EXERCISE OF RIGHTS BY USERS

9.1. General considerations

In accordance with the rights conferred by current regulations on the protection of personal data, the USER may exercise the rights of access, rectification, limitation of treatment, deletion, portability and opposition:

(i) By directing its request to the postal address indicated at the beginning of the T&C or through the email hola@themulliganfactory.com

(ii) Through the different mechanisms enabled by TMF at all times through the APP (eg. through an option for this purpose enabled in the “Preferences” section) and/or in the different interactions with the USER (eg. through an “Unsubscribe from this type of communication” kind of link).

The USER may also contact the licensee in question who is treating its personal data, and/or the competent Control Authority to present the claim that its considers appropriate.

In the case of being necessary for the fulfillment of the exercise of the right in question, TMF will inform the affected licensees within 48 hours so that they can proceed accordingly.

9.2. Considerations about connecting with friends

One of the outstanding features of the APP is its “Friends” module, which allows USERS to connect with each other and become “friends” (hereinafter,
“FRIENDS”) on the APP and share information about their activity in the context of a particular licensee’s account.

USERS can disable and/or enable their participation in said social module in a simple way through the configuration of their preferences for the account of the licensee in question. Likewise, they can also control different aspects related to the privacy of their data through the different configuration options enabled at any time by TMF.

Regarding the current operation of said module, and the implications at the level of privacy, the USER declares to know and accept that:

(a) In the event that the module is enabled for the account of a particular licensee, the USER will appear in the search results for those USERS in the account associated with the licensee who are looking for other USERS to connect with. In order not to appear in the search results, it will be enough for the USER to disable the “Friends” module.

(b) For two USERS to be connected and become FRIENDS, both USERS must agree to connect.

(c) Once connected, the FRIENDS may be promptly informed of the other’s activity, among others, in relation to their next visits, reservations and participation in events, and according to the configuration that each FRIEND has made at any time on the controls of associated privacy.

(d) In relation to the personal data included in the profile of each USER, FRIENDS can only view at this time (i) the photograph of the USER’s profile,
(ii) its full name, (iii) its handicap.

9.3. Exercise of rights beyond the use of the APP

In the event that, for a particular licensee, the USER wishes to exercise its rights with a particular licensee and beyond the context of the SERVICES provided by the latter through the APP, the USER must go directly to said licensee according to the channels and instructions provided by the latter at all times.

10. OTHER ASPECTS OF INTEREST

10.1. Using device applications

The APP can use functions of the applications available on the device itself, and consequently access the stored data.

In any case, the APP will inform the USER about the use of said applications, and will request its consent, informing previously and clearly and completely, and offering the USER the possibility to express its willingness to accept or reject the use of specific data that the APP requires for its installation and operation.

It is recommended to refrain from installing the APP, if you do not want the APP to use other applications.

10.2. Geolocation

For the provision of certain SERVICES, the APP may require and make use of the device’s geolocation functionality. If it is necessary to have data on the user’s location, the APP will duly inform the USER of this.

In any case, TMF informs the USER that the APP does not require or make use of any location data that are not strictly linked and are strictly necessary for the different services enabled at any time and for which the USER expressly provides its consent through of the mechanisms enabled for this purpose.

10.3. Images

In accordance with the provisions of Law 1/1982, of May 5, on the right to honor, personal and family privacy and the image itself, TMF informs you that the characteristics of the APP allow the extraction of images published in the APP by TMF and/or the licensors (for example, in the context of sharing tournament photos) and that can be viewed by other USERS.

In this case, the images that are published, and which can identify the USER, are considered personal data, applying TMF and/or the licensees all the technical measures necessary to safeguard the privacy of the USER.

For its part, TMF reserves the right to delete or withdraw from the APP any image for breach of the provisions of the T&C and/or this Privacy Policy, as well as to delete, withdraw and/or suspend any image that incorporates information that is considered inappropriate (for example, with sexual content), without the need for prior notice or subsequent notification.

TMF reserves the right to consider an image “illegal”, the third party who published it being solely responsible for its publication.

In the event that the USER can publish any of the contents of the APP through social networks or other tools or channels external to the APP, the USER agrees to be subject to their T&C and this Privacy Policy as well as the terms and conditions provided by the aforementioned social networks, tools or external channels.

10.4. Minimum age and use by children

The APP is not directed at children. In order to use the APP, people who register as USERS must be at least 14 years old.

10.5. Code of conduct

In TMF we report the behaviors that we do not consider appropriate and we act accordingly to the following uses, actions, omissions or statements that both the USER and the licensees make, by virtue of the relationship that binds them to TMF and the rest of USERS:

(a) Acting dishonestly or unprofessionally.

(b) Post inappropriate or inaccurate content.

(d) Use or publish on the APP images, videos or any comment on the profile that may hurt the sensitivity of the USERS, as well as that may discriminate for any condition, race, ethnic group, nationality, religion, sex, sexual orientation, disability or disease , or that are illegal, injurious, abusive, obscene, discriminatory or for other causes considered reprehensible.

(e) Using someone else’s account or creating a false identity on the APP.

(f) Make false statements or that impersonate the identity of a third party.

(g) Include content that contains computer viruses or others that may eliminate, interrupt or hinder the correct navigation of the APP.

(h) Sell, sponsor or obtain economic benefit through the APP without the prior and express authorization of TMF.

(i) Share information of people who are not USERS without their express consent.

USERS must use the APP correctly and respect this code of conduct at all times.

10.6. Use of cookies

A cookie is a file that is downloaded to your device when you access certain web pages or use certain apps.
Cookies allow a web page or app, among other things, to store and retrieve information about the browsing habits of a user or their equipment and, depending on the information it contains and the way it is used, they can be used to recognize the user.

According to the provisions of article 22.2 of Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE), by which users must be informed about the use of data storage and retrieval devices in terminal equipment, TMF informs you that when accessing and using the APP cookies will be installed on your equipment. For more details, see Annex 1.

10.7. Confidentiality

TMF and the licensees have access to the personal data of USERS as described in Annex 1 of this Privacy Policy. Unless the USER indicates otherwise at some point and/or accepts that said information ceases to be, this information will be considered confidential, and the parties are obliged to implement the necessary and reasonable mechanisms so that it remains so.

The information that the USER provides about its preferences regarding a specific licensee will also be confidential information of said licensee. However, the rest of the information of the USER’s profile will not be, and that may be shared with other licensees present in the APP at the moment in which the USER also activates their respective accounts.

10.8. Security

As indicated in section 2 of this Privacy Policy, TMF undertakes to implement the security measures that are required by the applicable regulations and adopt, as far as possible, any additional technical, administrative, informative measures, or organizational that are necessary to comply with the legal requirements on protection of personal data and in particular, guarantee the security and integrity of such data and its protection against alterations, losses, treatments or unauthorized access.

As part of these measures, the USER is informed that in the APP the HTTPS protocol (standard protocol widely used on the Internet) is generally used to establish a secure communication channel between the USER’s device and the TMF server and between the TMF server and the management system of each licensee and/or other systems with which the TMF server needs to communicate for the provision of the SERVICES.

Providing the SERVICES through a secure communication channel means guaranteeing the confidentiality of the information exchanged between the USER’s device and third parties with whom information is exchanged, since an encrypted connection is established between the parties that practically makes it impossible by unauthorized third parties to access the information sent.

Additionally, for the provision of the most sensitive SERVICES (for example, for the automatic management of the USER’s login in the club’s member portal, and/or for the processing of data related to payment services provided in the APP), TMF has implemented additional measures for enhanced security such as the encryption of certain USER data and/or the functions of the APP, or the hiring of the services of specialized data processors (for example, for the provision of payment services and the treatment of credit card data).

11. MODIFICATIONS

TMF reserves the right to modify, revise or replace this Privacy Policy when it deems it necessary. The USER of the APP will be previously informed about any modification that affects it.

The modifications, revisions and substitutions will be effective immediately after their publication in the APP, and may be additionally informed through the website www.clapphouse.golf linked to this APP.

The continued use of the APP or the SERVICES after said notification constitutes your agreement to be limited by what is established in this modified, revised or replaced document, as well as your understanding and acceptance.

Non-acceptance of the modifications entails the loss of the right to use the APP, and therefore you must stop using the SERVICES provided through it.

ANNEX 1.- PERSONAL DATA TREATED

The different categories of personal data processed as part of the SERVICES provided through the APP are listed below:

(a) Information of the general profile of the USER.

Including, among others i) name and surname, ii) gender, iii) date of birth, iv) place of residence, v) playing license, vi) contact information (email and mobile number), vii) general preferences, viii) profile picture, and ix) personal statistics.

Part of this information is initially provided by the management systems of the first licensee whose account the USER has activated, and then edited in some cases by the USER, TMF and the licensees associated with the accounts that the user has activated at all times.

(b) User information specific to the activated licensee account. This information is part of the specific profile of the USER corresponding to each licensee and, among others, consists of:

Customer identifier.
Account activation date.
Date of last access to the account.
Preferred language and other interests on the licensee.
Preferences related to said licensee.
Connections with other USERS who have also activated the licensee’s account.
Information on the activity of the USER at the licensee’s facilities, and in particular in relation to their visits, reservations, participation in events and other consumption.
Photographs in which the USER appears and published by the licensee.

Some of this information (eg. USER reservations, tournament schedules) is provided promptly by the licensee and its management systems.

(c) Basic information on the configuration of the APP by the USER (such as the configuration of automatic alerts generated by the APP or the specific configuration of certain modules).

(d) USER information on payment methods, movements and balances. The APP enables the possibility of paying through it. In this case, TMF and the licensees may process, among others, the following additional data:

Data associated with the USER’s credit cards and provided by the USER, such as the holder name, the card number and security codes.
These data in particular are processed by TMF and PAYNOPAIN FINANCIAL SERVICES, S.L. (see Annex 3 for more details about this payment entity), so that neither TMF nor the licensees have access at any time to the card number and security codes provided through the APP, and which are duly tokenized by the aforementioned payment institution and always in compliance with current legislation on electronic payments.
Wallet card numbers provided to the USER by each licensee.
Details of the different transactions carried out by the USER.
Data related to different balances.
Configuration on the possibility of charging a data amount, and the associated credit, as provided to the USER by each licensee.

(e) Multiple statistics on the use of the APP by the USER.

Including, among others, i) the occurrence of different key events (eg. a reservation started or made, a new registration), ii) statistics on the use of specific functionalities of the app, iii) statistics on the specific content consulted and iv ) statistics on the number of sessions and average time per session.

To capture several of these statistics, TMF currently uses different Google solutions such as Firebase and Google Analytics.

The personal data of the USERS are obtained or collected mainly through the means described below:

Specific consultations to the licensees’ management systems.
Account activation forms for the different licensees.
USER profile in the APP and Preferences and Configuration sections.
Databases of official entities linked to the golf sector.
Registration forms for all types of events, and participation in them.
Information shared by the licensee’s management systems (eg. in relation to information on their reservations).
Schedules and classifications sent by the licensee’s management systems and/or published in the APP by the licensee
Own navigation through the APP and use of it.
Satisfaction surveys and other offline initiatives related to the activity of each licensee in which the USER can participate.

ANNEX 2.- LIST OF LICENSEES

Below is a list with the details of each licensee according to the name used in the APP for the identification by the USER:

Abra del Pas. The Sociedad Regional Cántabra de Promoción Turística, S.A. (CANTUR), of Spanish nationality, domiciled in Santander, Calle Albert Einstein, number 4, provided with C.I.F. number A39008073.

Bonalba Golf. The company BONALBA 2.000, of Spanish nationality, domiciled in Mutxamel, Calle Vespre nº 6 bis, provided with N.I.F. number A-03918349.

Cabanillas Golf. The company GREEN SIRE GOLF, S.L.V., of Spanish nationality, domiciled in Guadalajara, Avda. De Francia 12, Local 4, provided with N.I.F. B-19322957.

Campo de Golf de Logroño. The company FCC MEDIO AMBIENTE, S.A.U., of Spanish nationality, domiciled in Logroño, Avda. Club Deportivo nº 30 – 32 Bajo, provided with N.I.F. number A-28541639.

Club de Campo Sojuela. The company CLUB DE CAMPO SOJUELA, S.L., of Spanish nationality, domiciled in Logroño, Avenida Rey Juan Carlos I, no. 18 floor 7, provided with N.I.F. number B-26539254.

Club de Golf Escorpión. The sports association CLUB DE GOLF ESCORPIÓN, of Spanish nationality, domiciled in Bétera, Carretera de San Antonio de Benagéber a Bétera, km. 4, provided with N.I.F. number G-46/102471.

Club de Golf Gorraiz. The company GOLF GORRAIZ, S.A., of Spanish nationality, domiciled in Valle de Egüés (Navarra), Avda. De Egüés S / N, provided with N.I.F. number A31473770.

Club de Golf La Dehesa. The company INTERUVE, S.A., of Spanish nationality, domiciled in Villanueva de la Cañada (Madrid), Avda. De la Universidad, number 10, provided with N.I.F. number A78588274.

Club de Golf Llavaneras. The company CLUB DE GOLF LLAVANERAS, of Spanish nationality, domiciled in Sant Andreu de Llavaneres, calle Camí del Golf 49-51, provided with N.I.F. number G-08366902.

Club de Golf Retamares. The company RETAMARES GESTIÓN, S.L., of Spanish nationality, domiciled in Alalpardo, Ctra. Algete – Alalpardo KM. 2,300, provided with N.I.F. number B-81643025.

Club de Golf Terramar. The company CLUB DE GOLF TERRAMAR, of Spanish nationality, domiciled in Sitges, Camino carrerada s/n, provided with N.I.F. number G08328056.

Club de Golf Ulzama. The company CLUB DE GOLF ULZAMA, of Spanish nationality, domiciled in Guerendiain, Ctra. Lizaso km 6.9, provided with N.I.F. number G-31039191.

Costa Azahar. The company CLUB GOLF COSTA DE AZAHAR, of Spanish nationality, domiciled in Graó de Castellón, Avda. Del Golf, number 1, provided with N.I.F. number G-12039111.

El Paraíso Golf Club. The company EL PARAISO GOLF CLUB S.A.U., of Spanish nationality, domiciled in Estepona, Urbanización El Paraíso, Ctra. N340 KM. 167, provided with N.I.F. number A29110723.

El Vallès Golf. Entity REAL CLUB DE GOLF EL PRAT, of Spanish nationality, domiciled in Terrassa, Plans de Bonvilar 17, provided with N.I.F. number G-08403982.

Empordà Golf. The company EMPORDÀ GOLF CLUB, S.A., of Spanish nationality, domiciled in Gualta, Ctra. de Torroella a Palafrugell s/n, provided with N.I.F. number A-17233164.

Fontanals Golf Club. The company FONTANALS ESPORTIVA, S.A., of Spanish nationality, domiciled in Barcelona, Calle Casanova, number 211 Ent. 2nd, provided with N.I.F. number A-59985234.

Golf Barcelona. The company CLUB DE GOLF BARCELONA, of Spanish nationality, domiciled at Carretera de Martorell a Capellades, km. 19.5, provided with N.I.F. number G-59106807.

Golf Club Peralada. The company CLUB DE GOLF PERALADA, S.A., of Spanish nationality, domiciled in Barcelona, Calle Pere II de Montcada, number 1, provided with N.I.F. number A-17059924.

Golf Costa Brava. The company CLUB DE GOLF COSTA BRAVA, of Spanish nationality, domiciled in Santa Cristina d’Aro, Urbanización Costa Brava “La Masía”, provided with N.I.F. number G17028168.

Golf Costa Daurada. The company MAS MANEGUET, S.A., of Spanish nationality, domiciled in El Catllar (Tarragona), Calle Gregal 3 (Parc de Llevant), provided with N.I.F. number A-43052067.

Golf de Pals. The company GOLF DE PALS S.A., of Spanish nationality, domiciled in Pals, Carrer del Golf, 64, provided with N.I.F. number A-17012170.

Golf El Rompido. The company EL ROMPIDO GOLF CLUB, S.A., of Spanish nationality, domiciled in Cartaya – Huelva, Carretera Cartaya – El Rompido, km. 7, provided with N.I.F. number A95167847.

Golf La Roca. The company TEAM OPEN 2012, S.L., of Spanish nationality, domiciled in La Roca del Vallès, Carretera La Roca a Cardedeu (BV5105), Km. 4.5, provided with N.I.F. number B-65724841.

Golf Las Pinaillas. The company CLUB DE GOLF CASTILLA LA MANCHA, S.R.L., of Spanish nationality, domiciled in Albacete, Ctra. Prov. AB8820 from N322 to Motilleja, km 12, provided with N.I.F. number B-02277069.

Golf Los Lagos. The company GOLF LOS LAGOS, S.L., of Spanish nationality, domiciled in Pinseque, Zaragoza, Camino de Viñales, number s/n, provided with N.I.F. number B-50839554.

Golf Negralejo. The company NEGRALEJOGOLF S.L., of Spanish nationality, domiciled in Zamudio, P.I. Ugaldeguren, number 1 – PCL-1, provided with N.I.F. number B95841888.

Golf Sant Cugat. The sports entity CLUB DE GOLF SANT CUGAT, of Spanish nationality, domiciled in Sant Cugat del Vallés, Calle Villà, number 79, provided with N.I.F. number G-08408627.

Golf Sant Vicenç. The company DIVA GOLF SANT VICENÇ, S.L., of Spanish nationality, domiciled in Sant Vicenç de Montalt, Calle Balís 9, provided with C.I.F. number B65645293.

Golf Son Servera. The company CLUB DE GOLF SON SERVERA, of Spanish nationality, domiciled in Son Servera, Urbanización Costa de los Pinos s/n, provided with N.I.F. number G07049513.

Hato Verde. The company GUILLENA GOLF, S.L.U., of Spanish nationality, with address for the purposes of this contract in Madrid, Avda. Camino de Santiago, number 40, provided with N.I.F. number B-85469930.

Izki Golf Club. The company NATURGOLF, S.A., of Spanish nationality, domiciled in Urturi, Calle Arriba s/n, provided with N.I.F. number A-01147339.

La Llorea. PATRONATO DEPORTIVO MUNICIPAL DE GIJÓN, an entity of Spanish nationality, domiciled in Gijón, Plaza de la República s/n, provided with N.I.F. P8302404B.

Las Caldas. The company UTE LAS CALDAS GOLF, of Spanish nationality, domiciled in Oviedo, Plaza América 10, 5º, provided with N.I.F. number U-74407065.

Las Palmeras Golf. The company FEDERACIÓN CANARIA DE GOLF, of Spanish nationality, domiciled in Las Palmas de Gran Canaria, Calle Blasco Ibáñez 58D, provided with N.I.F. number G-35388602.

León Golf. The company PROSACYR OCIO, S.L.U., of Spanish nationality, domiciled in Madrid, Calle Condesa de Venadito, number 7, provided with N.I.F. number B-24352783.

Lerma – Saldaña. The company CLUB DE GOLF LERMA, S.A., of Spanish nationality, domiciled in Lerma (Burgos), Autovía Madrid-Burgos Km 195.5, provided with N.I.F. number A-09115668.

Lomas Bosque. The company CLUB DE GOLF LOMAS-BOSQUE, S.A., of Spanish nationality, domiciled in Villaviciosa de Odón (Madrid), calle Guadiana 102, Urb. El Bosque, provided with N.I.F. number A-78067840.

Meaztegi Golf. The Temporary Union of Companies UTE MEATZAGOLF, of Spanish nationality, domiciled in Ortuella-Bizkaia, Ctra. Triano a La Arboleda, s/n, provided with N.I.F. number U95955639.

Mediterráneo Golf. The company GOLF BORRIOL, S.L., of Spanish nationality, domiciled in Borriol, Urbanización La Coma s/n, provided with N.I.F. number B-86774346.

Oliva Nova. The company OLIVA GOLF, S.A., of Spanish nationality, domiciled in Oliva, Calle Picasso, 1 – C.C. Oliva Nova – Edif. CHG, provided with N.I.F. number A-53326567.

Raimat Golf Club. The sports entity RAIMAT GOLF CLUB, of Spanish nationality, domiciled in Raimat, Calle Afores s/n, provided with N.I.F. number G-25309881.

RCG de Tenerife. The REAL CLUB DE GOLF DE TENERIFE company, of Spanish nationality, domiciled in Tacoronte, c/ Campo de Golf, number 1, provided with N.I.F. number G-38015087.

RCG El Prat. Entity REAL CLUB DE GOLF EL PRAT, of Spanish nationality, domiciled in Terrassa, Plans de Bonvilar 17, provided with N.I.F. number G-08403982.

RCG La Coruña. The company REAL CLUB DE GOLF DE LA CORUÑA, of Spanish nationality, domiciled in A Coruña, Calle A Zapateira s/n, provided with N.I.F. number G15043839.

RCG La Peñaza. The company CLUB DE GOLF LA PEÑAZA, of Spanish nationality, domiciled in Zaragoza, Ctra. Madrid Km. 307, provided with N.I.F. number G-50027721.

RCG La Toja. The company REAL CLUB DE GOLF LA TOJA, of Spanish nationality, domiciled in O Grove, Isla de La Toja s/n, provided with N.I.F. number G-94126927.

RCG Las Brisas. The REAL CLUB DE GOLF LAS BRISAS company, of Spanish nationality, domiciled in Marbella, Calle Londres s/n, provided with N.I.F. number G-29129400.

RCG Las Palmas. The REAL CLUB DE GOLF DE LAS PALMAS company, of Spanish nationality, domiciled in Santa Brígida, in Lugar Campo de Golf, number 12, provided with N.I.F. number G-35031384.

Real Aeroclub de Vigo. The REAL CLUB DE GOLF DE LAS PALMAS company, of Spanish nationality, domiciled in Santa Brígida, in Lugar Campo de Golf, number 12, provided with N.I.F. number G-35031384.

Real Golf de Pedreña. The company REAL GOLF DE PEDREÑA, of Spanish nationality, domiciled in Pedreña, Ctra. General s/n, provided with N.I.F. number G-39030804.

Rioja Alta Golf Club. The RIOJA ALTA GOLF CLUB company, of Spanish nationality, domiciled in Cirueña, Avda. La Rioja 118, provided with N.I.F. number G-26523480.

RSG Neguri. The company REAL SOCIEDAD DE GOLF DE NEGURI, of Spanish nationality, domiciled in Getxo, Calle Juan Vallejo Real de Asua, number 26, provided with N.I.F. number G-48095277.

Salobre Golf Resort. The company CAMPO DE GOLF SALOBRE, of Spanish nationality, domiciled in Las Palmas, Calle Alcalde Díaz Saavedra Navarro, number 31, provided with N.I.F. number A-35364439.

Sotoverde Golf. AYUNTAMIENTO DE ARROYO DE LA ENCOMIENDA, of Spanish nationality, residing at Arroyo de la Encomienda, Plaza España 1, provided with N.I.F. P-4701100-B.

Talayuela Golf. The company ASOCIACIÓN DE GOLF TURISMO EXTREMADURA, of Spanish nationality, domiciled in Talayuela, Calle Camino General, number 8, provided with N.I.F. number G-10467694.

Torremirona Golf. The company GREEN MEETING POINT, S.L., of Spanish nationality, domiciled in Navata, Calle Avenida Josep Maria de Ventós s/n and provided with N.I.F. number B-17640541.

Valle del Este. The company VALLE DEL ESTE HOTEL GOLF SPA, S.L.U., of Spanish nationality, domiciled in Vera, Avda. Del Sol nº 2 (Urbanización Valle del Este), provided with N.I.F. number B-04722716.

Villanueva Golf. The company GESTORA COSTA ATLÁNTICA DE GOLF, S.L., of Spanish nationality, domiciled in Puerto Real (Cádiz), Avda. Vía Augusta 1, provided with N.I.F. number B-72287006.

ANNEX 3.- TMF DATA PROCESSORS

TMF uses different data processors to provide part of the SERVICES. Details on each of them are provided below:

Development and general maintenance of the APP. TMF uses the services of the Spanish company SOLUCIONES CUATROOCHENTA, S.L. with CIF B-12877445 and registered office at Espaitec, Universidad Jaume I, 12071 Castellón de la Plana.

Provision of infrastructure services. TMF uses the services of the company AMAZON WEB SERVICES EMEA SARL, with CIF B-18628438 and registered office in Luxembourg. Currently, the servers used by TMF are located in France.

Sending the SMS with the activation key. For this, TMF has integrated the APP with the solution of the Spanish company ASETEC GROUP INGENIERÍA DE SISTEMAS, S.L. with CIF B-82149139 and registered office at c/ Río Ulla 14, 28017 Madrid.

General telecommunications services. To do this, TMF has integrated the APP with the tools and services of the company TWILIO, INC., a company based in the United States that guarantees that all data transferred to its servers are treated with a level of protection in accordance with European regulations.

Generation and use of online forms. To do this, TMF uses the tool and services of JOTFORM INC, a US-based company that guarantees that all data transferred to its servers will be treated with a level of protection in accordance with European regulations. According to this company, the data processed on behalf of TMF are currently hosted on servers in Europe.

Technical support services. For this, TMF uses the solutions and services of ZENDESK INC, a company based in the USA. Zendesk uses the services of Amazon Web Services for the hosting and processing of data, and guarantees that all data transferred to its servers will be treated at all times with a level of protection in accordance with European regulations.

Email marketing. For this purposes, TMF uses the MailChimp tool and services. MailChimp is a solution from THE ROCKET SCIENCE GROUP, LLC, a US-based company that guarantees that all data transferred to its servers will be treated with a level of protection in accordance with European regulations.

Payment services. For this, TMF uses the services and solutions of the payment entity PAYNOPAIN FINANCIAL SERVICES, S.L., a Spanish company with CIF B-88513593 and registered office at Paseo de la Castellana 77, 28046 Madrid and registered in the Madrid Mercantile Registry in Volume 39824, Folio 88, Sheet M- 707501. La entidad de pago está supervisada e inscrita en el registro especial del Banco de España con código 6899. The payment institution is supervised and registered in the special registry of the Bank of Spain with code 6899. USERS can contact the entity directly through the email SAC@paynopain.com and find more information on the entity’s website at https://www.paynopain.com.

Obtaining data on the use of the APP. Anonymized and not anonymized. Specifically, the APP uses different Google services (Firebase and Google Analytics) that store, through cookies, information that allows the compilation of all kinds of statistics on the traffic and use of websites or applications. The storage devices of said Google services can be hosted on servers located outside of Spain. Google undertakes not to share the information captured with third parties, except in cases where it is necessary for the operation of the system or when the law requires it to do so. According to Google, the company does not save your IP address. Google Inc. guarantees that all transferred data will be treated with a level of protection in accordance with European regulations.

Likewise, the licensees may use additional processors for the provision of the SERVICES to their USERS. Among them, the following data controller stands out:

The Spanish company PORTAL GOLF GESTIÓN, S.A., with registered office in Madrid, c / Serrano 20, 2ª, and provided with CIF nº A-82662826D, and with whose management software the APP is integrated.

Last modified: December 8, 2020