Revised May 30, 2018
We, Poppy Hills, part of the NCGA with offices at 3200 Lopez Road, Pebble Beach California, USA as the data controller (“Poppy Hills,” “we,” or “us”), explain in this Policy how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the “Website”) that link to this Policy, as amended from time to time. This Policy describes how Poppy Hills collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.
This Policy applies only to information we collect, process and use through the Website. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.
Information We Collect
We collect information about you to provide and tailor our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.
Information You Give Us
When you fill out registration forms, or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:
- Signing up for email alerts;
- Signing up for blog posts;
- Signing up for online-based golf challenges;
- Completing a form related to one of our products or services;
- Signing up for a membership;
- Making a golf reservation
Depending on how you interact with our Website, the personal information we collect from you may vary. For example, to sign up for blog posts, we may ask only for an email address and a name. In other circumstances, such as when you complete a form related to a particular service offering, we may ask you to provide other information, which may include your name, phone number, and/or zip code. We also collect and store certain information associated with actions you take. For example, when you sign up for a more information about a group package, we store your location and number of people that you’ll be golfing with. We also store information about the website pages that you read, the time and duration of your activity on our Website, and other information about your behavior on our Website.
If you connect to the Website using Facebook, Google+, or another social networking site (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include your golf handicap, current city and email address. When we receive this information, it becomes Poppy Hills account information for purposes of your use of the Website. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Poppy Hills account by adapting the privacy settings in your Social Networking Site account. If you come to the Website through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.
If you enter credit card information on the Website in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
Information We Collect Automatically
When you use the Website, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Website. That information may include the URLs of the web pages that you visited on the Website, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Website.
Automated means of data collection include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access the Website. For example, when you access the Poppy Hills website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Website, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
How We Use Information
We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:
- to provide you with personalized content, services offered by Poppy Hills as well as promotional content and services (for example, Poppy Hills uses your previous search and browsing history (e.g. the blog posts you click on), or your location, to provide you with recommended service offerings or reach out to you about seasonal or promotional offers you may be interested in; we also use your IP address and mobile device for these purposes);
- to customize and improve the features, performance, and support of the site;
- to provide relevant advertising, including interest-based advertising;
- for internal operations, including troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Website);
- to analyze use of the Website and improve the Website;
- for other purposes that you separately authorize as you interact with Poppy Hills.
When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.
How We Share and Disclose Information
We may share and disclose information:
- With third party service providers that we retain to perform functions on our behalf, such as web hosting, data analyses and promotion services providers, communication services providers, reservations and property management providers, and technology and data service providers, that have access to Personal Information needed to perform their functions;
- To enforce our agreements with other users or third parties, including in connection with claims of copyright infringement;
- To protect the safety and security of users;
- To comply with a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.
What types of Cookies do we use?
We use two types of Cookies on the Website: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings).
What are Cookies used for?
Cookies transmit information about you and your use of the Website, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use.
Preferences and Features
Analytics and Performance
Ad Choices and Managing Cookies
Poppy Hills works with several third parties to provide you with personalized, interest-based advertising. We may target ads to you, and measure their performance, on and off the Website using:
- Member-provided profile information (e.g., job title, occupation, location, authorized information shared from your Social Networking Site)
- Your use of the Website (e.g., search history, job clicks, companies you follow);
- Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket).
- IP address or mobile device location information (to the extent you have enabled location tracking on your device);
- Cookies (both on and off the Website) which may include information from the Ad Partners we use to help deliver relevant ads to you.
Opting Out of Cookies
Other Important Privacy Information
EEA Resident Rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at the end of this document.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at the end of this document.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. Registered users can manage their account settings and email marketing preferences as described in the “Choices Regarding Your Personal Information” section below. If you are an unregistered user, or to opt-out of other forms of marketing (such as postal marketing or telemarketing), you may contact us using the contact details provided at the end of this document.
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Choices Regarding Your Personal Information
We will send you notifications and if, and to the extent, you have opted-in to promotional communications, or other messages using the contact information (e.g., your email address, your mobile device identifier) you provided to us when you registered or when you requested information from us. You may opt-out of continuing to receive optional messages by following the instructions included in each message.
How Long We Keep Your Personal Information
We keep your personal information only so long as we need it to provide the Website to you and fulfill the purposes described in this Policy. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
The information about you that we collect, process and/or use through the Website is controlled by Poppy Hills of Pebble Beach, California. Poppy Hills and the services it provides are hosted and provided outside of the European Economic Area (EEA), including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.
We may revise this Policy from time to time by posting an updated version on the Website. This version of the Policy will be effective for you as described at the beginning of the Policy. Further revisions of this Policy will become effective as follows: The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately.
However they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Website is subject to the most current effective version of this Policy.
If you have any questions or suggestions regarding this Policy, please contact us here:
3200 Lopez Rd.
Pebble Beach, CA 93953