Privacy Policy
(Last updated: February 21, 2025)

PREAMBLE

This Privacy Policy informs you about how Phileas Golf uses and protects the information you may transmit to us when you use the website accessible at the following URL:
www.thefrenchgolfcoach.net (hereinafter referred to as the “Site”).

Please note that this Privacy Policy may be modified or supplemented at any time by Phileas Golf, particularly to comply with legal or technological developments. In such a case, the date of the update will be clearly identified at the top of this policy. These changes are binding on the User as soon as they are posted online. Therefore, the User is advised to regularly consult this Privacy Policy to stay informed of any changes.

PARTIES

This Privacy Policy applies between the publisher of the Site, namely Phileas Golf (hereinafter “Phileas Golf”), and any person connecting to the Site (hereinafter “the User”).

DEFINITIONS

• “Site Content”: all elements published on the Site, whether or not protected by intellectual property rights, such as texts, images, designs, layouts, videos, diagrams, structures, databases, or software.

• “User”: any person connecting to the Site.

• “Site”: the website accessible at www.thefrenchgolfcoach.net as well as any sub-sites, mirror sites, portals, and URL variations related to it.

SCOPE OF APPLICATION

This Privacy Policy applies to any User. Your simple browsing of the Site constitutes full and complete acceptance of it.

The User acknowledges the evidential value of Phileas Golf’s automatic recording systems and, unless they provide proof to the contrary, waives the right to dispute them in case of a dispute.

Acceptance of this Privacy Policy implies that Users have the necessary legal capacity or are at least 16 years old, or have obtained the authorization of a guardian or custodian if they are incapable, or from their legal representative if under 16, or hold a mandate if acting on behalf of a legal entity.

PERSONAL DATA

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016, and applicable national legislation, Phileas Golf provides you with the following information:

Identity of the Data Controller

The controller of data collection and processing is Phileas Golf, SASU, SIREN: 820072379, headquarters: 16 rue du Palais, 86200 Loudun, France,
Phone: +33 6 18 65 67 22,
Email: reno@thefrenchgolfcoach.net

Data Collected by Phileas Golf

Data collected while browsing the site

By browsing the Site, you consent to Phileas Golf collecting information relating to:

• the usage of the Site;

• the content viewed;

• your connection data (time, pages viewed, IP address, etc.).

Data collected via the contact form

When using the contact form, Phileas Golf collects:

• First name;

• Phone number;

• Email address.

Data collected when ordering videos

When a User orders videos, Phileas Golf collects:

• Last name;

• First name;

• Phone number;

• Mailing address;

• Email address.

Data collected when signing up to receive free videos

When signing up to receive free videos, Phileas Golf collects:

• First name;

• Email address.

Data collected when registering for courses (stages)

When signing up for courses, Phileas Golf collects:

• Last name;

• First name;

• Phone number;

• Mailing address;

• Email address.

Data collected when subscribing to the newsletter

When signing up for the newsletter, Phileas Golf collects:

• Last name;

• First name;

• Email address.

Purpose of Data Collection

The data collected during browsing is processed automatically for the purpose of:

• Developing, operating, improving, providing, and managing the Site;

• Sharing Site content with others or letting others know about your views or visits;

• Enhancing User experience;

• Targeting advertising content;

• Enforcing the Site’s terms of use.

The data collected via the contact form is processed automatically to:

• Verify the User’s identity;

• Provide tailored responses to the User;

• Send information and contact the User, including via email, phone, and push notification;

• Target advertising content.

The data collected during video orders is processed automatically to:

• Verify the User’s identity;

• Respond to the User;

• Deliver videos;

• Execute the contract;

• Target advertising content.

The data collected when signing up for free videos is processed to:

• Verify the User’s identity;

• Send videos;

• Target advertising content.

The data collected when signing up for courses is processed to:

• Verify the User’s identity;

• Register the User for a course;

• Communicate with the User;

• Target advertising content.

The data collected when subscribing to the newsletter is processed to:

• Send newsletters.

Legal Basis for Processing

• Browsing data is processed on the basis of Phileas Golf’s legitimate interest in analyzing user behavior and ensuring the security and optimal operation of the Site. For cookie-related data, please refer to Phileas Golf’s cookie policy.

• Data from the contact form is processed based on the User’s consent.

• Data from video orders is processed as part of a contractual relationship.

• Data from signing up for free videos is processed based on consent.

• Data from signing up for courses is processed as part of a contractual relationship.

• Data from the newsletter form is processed based on consent.

Internal Recipients of the Data

The collected data is only accessible by Phileas Golf’s management and staff responsible for the Site and user relations. It is never made visible to third parties.

Data Retention Period

• Browsing data: kept for a reasonable time necessary for site management, up to 36 months, or until consent is withdrawn.

• Contact form data: kept for up to 12 months.

• Video order data: kept for up to 12 months.

• Free video signup data: kept for up to 12 months.

• Course registration data: kept for the duration of the contractual relationship.

• Newsletter data: kept until unsubscribed.

After these periods, Phileas Golf will archive the data for the period during which it may be held liable. Once this period expires, the data will be permanently deleted.

Security and Confidentiality

Personal data is stored securely, using current technical means, in accordance with the GDPR and applicable national legislation.

Data Minimization

Phileas Golf may also collect any data voluntarily provided by Users, especially through email sent to reno@thefrenchgolfcoach.net.

Phileas Golf encourages Users not to submit unnecessary or excessive personal data.

Phileas Golf is committed to only keeping and processing data strictly necessary for its operations and will promptly delete any irrelevant data received.

Respect for Rights

You have the following rights regarding your personal data, which you may exercise by writing to us at our postal address or by sending an email to the following address: reno@thefrenchgolfcoach.net

Right to Information, Access, and Communication of Data

You have the ability to access personal data concerning you.

Due to the obligation of security and confidentiality in the processing of personal data incumbent on The French Golf Coach, your request will only be processed if you provide proof of your identity, in particular by submitting a scan of your valid ID (for email requests) or a signed photocopy of your valid ID (for written requests), both accompanied by the statement: “I hereby certify on my honor that this copy of my ID is a true copy of the original. Made in … on …,” followed by your signature.

To assist you in this process, you will find a sample letter drafted by the CNIL [French Data Protection Authority].

Right to Rectification, Erasure, and the Right to be Forgotten

You may request the correction, update, locking, or erasure of your personal data if it is found to be inaccurate, erroneous, incomplete, or obsolete.

You may also define general and specific directives regarding the fate of your personal data after your death. If applicable, the heirs of a deceased person may request consideration of their relative’s death and/or request the necessary updates.

To assist you in this process, you will find a sample letter drafted by the CNIL.

Right to Object to Data Processing

You may object to the processing of your personal data.

To do this, please send an email to the following address: reno@thefrenchgolfcoach.net
In this email, please specify the data you wish to have deleted as well as the reasons justifying this request, except in the case of commercial prospecting.

Right to Data Portability

You have the right to receive the personal data you have provided to us in a portable, open, and readable format.

Right to Restriction of Processing

You have the right to request that the processing of your personal data by The French Golf Coach be restricted. As such, your data may only be stored and not used by The French Golf Coach.

Withdrawal of Consent

Your consent is necessary for The French Golf Coach to process your data. However, you may withdraw this consent at any time. This withdrawal will result in the deletion of your personal data.

However, services requiring the processing of your data by The French Golf Coach will no longer be accessible.

Response Time

The French Golf Coach undertakes to respond to your request for access, rectification, opposition, or any other additional information within a reasonable time, which shall not exceed one month from the receipt of your request.

Complaint to the Competent Authority

If you believe that The French Golf Coach is not complying with its obligations regarding your personal data, you may file a complaint or request with the competent authority. In France, this authority is the CNIL, to which you can submit a request here.

Transfer of Collected Data

Transfer to Partners

The French Golf Coach informs you that we use authorized service providers to facilitate the collection and processing of the data you provide. These providers may be located outside the European Union and have access to the data collected on the Website.

The French Golf Coach has ensured in advance that its service providers have implemented appropriate safeguards and comply with strict conditions regarding confidentiality, use, and data protection.

The user consents to the collected data being transmitted by The French Golf Coach to its partners and being processed by these partners as part of third-party services, namely:

Transfer on Request or Judicial Decision

The user also consents to The French Golf Coach disclosing the data collected to any person, upon the request of a government authority or pursuant to a court decision.

Transfer in the Context of a Merger or Acquisition

If The French Golf Coach is involved in a merger, asset sale, financing, liquidation, bankruptcy, or acquisition of all or part of its business by another company, the user consents to the data collected being transferred to that company and for that company to process the personal data in accordance with this privacy policy, in place of The French Golf Coach.

INTELLECTUAL PROPERTY

Legal Protection of Site Content

The content of the Website may be protected by copyright and database rights. Any unauthorized representation, reproduction, translation, adaptation, or transformation, in whole or in part, without the consent of The French Golf Coach or its assignees, constitutes an infringement of Books I and III of the Intellectual Property Code and may result in legal action for counterfeiting.

Contractual Protection of Site Content

The user agrees contractually with The French Golf Coach not to use, reproduce, or represent, in any way whatsoever, the content of the Site—whether or not protected by intellectual property rights—for any purpose other than viewing via a browser or robot. This restriction does not apply to indexing robots whose sole purpose is to scan site content for indexing.

FINAL PROVISIONS

Modifications

This Privacy Policy may be modified at any time by The French Golf Coach. The terms applicable to the user are those in force at the time of their connection to the Site. Any new connection to the Site implies acceptance of the new terms.

Entirety

The nullity of any clause in this contract shall not invalidate the other clauses of the contract or the contract as a whole, which shall retain their full force and effect. In such a case, the parties shall, to the extent possible, replace the nullified provision with a valid provision corresponding to the spirit and purpose of this policy.

No Waiver

The failure of The French Golf Coach to exercise the rights granted to it under this policy shall not be interpreted as a waiver of those rights.

Languages

These terms are provided in French.

Unfair Terms

The provisions of these terms are subject to compliance with the mandatory provisions of the French Consumer Code concerning unfair terms in contracts concluded between a professional and a consumer.

DISPUTES

Applicable Law

This Privacy Policy is governed by French law and European regulations, particularly the European Data Protection Regulation (GDPR).

Disputes

Pursuant to Ordinance No. 2015-1033 of August 20, 2015, any disputes that may arise in the execution of these general terms and that cannot be resolved amicably must be submitted to an accredited mediator.

Arbitration

Any dispute relating to or connected with this contract shall be settled by arbitration in accordance with the FastArbitre regulations of the Digital Institute of Arbitration and Mediation.

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