La Grande Mare

1. Purpose Of This Privacy Statement

La Grande Mare takes the privacy of personal data seriously. Under the Data Protection (Bailiwick of Guernsey) Law, 2017 (as amended) (the "Data Protection Law") we must provide you with clear information about how we collect, use, store and share your personal data.

This policy explains who we are, how we collect your information, how and why we use it as well as information about where we might transfer your information to a third-party. 

We also tell you about how we keep your data secure, how long we will keep it and give you information about your rights in relation to our use of your personal data.

Please read this policy carefully to understand how and why we use your personal data.

This Privacy & Cookie Policy applies to any information you provide to us, including through this website, communications by email and through social media, by telephone and in person. It also covers any information we receive from third-parties. 

This policy explains how we use your personal data. Please read it carefully. If you have any questions about how we handle your information, please contact us using the details in Section 2.
This statement is reviewed and updated from time to time and supplements the other notices and is not intended to override them.

2. Who We Are And Contacting Us

We are La Grande Mare, a luxury golf and country club based in Guernsey, and we comply with The Data Protection (Bailiwick of Guernsey) Law, 2017 (the "Law") and are the data controller in relation to the processing activities outlined. 

Controller

La Grande Mare is the controller and responsible for your personal data (collectively referred to as "company", "we", "us" or "our" in this privacy notice).

If you have any questions about this policy or how we handle your data, please contact us at the address below. 

You have the right to make a complaint at any time to the Office of the Data Protection Authority (ODPA), the Guernsey supervisory authority for data protection issues (https://odpa.gg). We would, however, appreciate the chance to deal with your concerns before you approach the ODPA so please contact us in the first instance.

Our Contact Details:

• La Grande Mare, Rue de Gele, Guernsey, GY5 7LR
• Data Privacy Contact: info@lagrandemare.com
• Telephone: +44 (0)1481 234544
• Company Registration Number: 1178
• ODPA Registration Number: DPA5750 (attributed to Westward
• Investments Ltd – La Grande Mare)

3. Types Of Personal Data We Collect And Use

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity data: name, title, date of birth
• Contact data: postal address, email address, telephone numbers
• Financial and transaction data: payment card details (processed by third-party payment providers), billing address, booking history
• Technical data: IP address, device identifiers, browser type and version, operating system, cookie identifiers, server logs
• Location data: approximate location derived from IP address or device location where you have given permission
• Profile data: booking preferences, membership status, marketing preferences, feedback and survey responses
• Special category data: we only process limited health-related information where strictly necessary (for example, in relation to an on-site incident, safety requirements, or accessibility needs). 

Such data is processed in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 under one of the following conditions: 

o  it is necessary to protect your vital interests or those of another person;
o  it is necessary for reasons of substantial public interest, including health and safety obligations; or
o  you have provided explicit consent, where applicable

We limit the collection of such data to what is strictly necessary and apply enhanced safeguards.

We only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

4. How We Collect Your Personal Data

Where we collect personal data from third-parties we will identify the source in the relevant processing description.

Personal Information You Provide To Us

When you complete the contact form on our website or you contact or correspond with us by email, telephone, letter, SMS or WhatsApp, you will be providing personal information to us. 

La Grande Mare remains the controller of the personal data shared via these channels. The platform provider may act as an independent controller for its own processing activities (such as service delivery, security, and analytics), over which we have no control.

Please note that where you contact us via WhatsApp or SMS, those communications are also subject to the privacy policies of the relevant platform provider (Meta/WhatsApp or your telecommunications provider).

In some circumstances, La Grande Mare and the platform provider may act as joint controllers where we jointly determine the purposes and means of processing (for example, in relation to targeted advertising or audience matching). In such cases, processing is governed by the platform’s terms and privacy policies, and you should review those notices for further information.

From Third-Parties Acting On Your Behalf

We might receive information from persons duly authorised by you, such as your employer or staff at your firm or business, an advocate acting on your behalf or another third-party acting for you (such as your employer, spouse or family member).

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through: 

Direct Interactions - You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via booking mechanisms or otherwise. This includes personal data you provide when you:

• Apply for our products or services;
• Create an account on our website;
• Subscribe to our service or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion or survey; or
• Give us some feedback

Automated Technologies Or Interactions - As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

International transfers and safeguards - We use third-party service providers located both inside and outside the Bailiwick of Guernsey. 
Where personal data is transferred outside Guernsey (or to jurisdictions that do not have an ODPA adequacy decision), we ensure appropriate safeguards are in place, for example:

• Google (Analytics, AdSense) — transfers to the United States; processing is governed by Standard Contractual Clauses (SCCs) and Google’s Data Processing Terms
• Mailchimp (email communications) — transfers to the United States; processing is governed by SCCs incorporated into Mailchimp’s Data Processing Addendum
• Elavon (payment processing) — transfers within and outside of the EU; processing is governed by SCCs in our data processing agreement
• Adyen (payment processing) — based in the EU; transfers are within jurisdictions with appropriate safeguards

Where SCCs are relied on, a copy of the relevant SCCs and the data processing agreement is available on request from info@lagrandemare.com. 

Transfer safeguards: Where transfers are made to jurisdictions without an adequacy decision, we carry out a transfer risk assessment and implement appropriate safeguards (such as Standard Contractual Clauses and supplementary technical measures) in line with applicable data protection requirements.

5. Why We Use Your Personal Data

The law requires us to have a lawful basis for each type of processing we carry out. Set out below are our main processing activities, the lawful basis we rely on for each, and what that means in practice. 
Where we rely on legitimate interests as our lawful basis, you have the right to request further information about our legitimate interest assessments by contacting us, and the right to object to that processing (see Section 11):

 

Processing Activity	Lawful Basis	What this means in practice
Processing your golf tee-time, tuition or range booking	Performance of a contract	Necessary to fulfil your booking. You cannot opt-out of this without cancelling your booking.
Processing payments and maintaining financial records	Performance of a contract; Legal obligation	Required to take payment and comply with financial record-keeping obligations (7-year retention).
Sending you marketing by email or SMS — where you have actively opted in	Consent	You may withdraw consent at any time by unsubscribing or replying STOP.
Sending you marketing by email or SMS — where you are an existing customer (soft opt-in)	Legitimate interests	We rely on legitimate interests for soft opt-in marketing; you may object at any time. We may contact you about similar products and services (e.g. if you have booked a tee-time, we may email you about golf tuition or range sessions) unless you have opted out. You can opt-out at any time by clicking ‘unsubscribe’ in any email or replying STOP to any SMS.
Website analytics (Google Analytics)	Consent (via cookie banner)	Analytics cookies are only placed after you accept via our cookie consent banner; you may withdraw consent at any time.
Responding to enquiries and customer service	Legitimate interests	It is in our legitimate interests to manage communications and maintain our relationship with you.
Fraud prevention and site security	Legitimate interests; Legal obligation	It is in our legitimate interests to protect our business and users from fraud and security threats.
Complying with legal obligations (e.g. accident records, tax)	Legal obligation	We are required by law to retain certain records regardless of your preferences.
Verifying your identity when you return to our website or access your booking	Legitimate interests	We have a legitimate interest in keeping your account secure.
Personalising your experience and communications based on your preferences and booking history	Legitimate interests (or Consent where based on optional cookie tracking)	We have a legitimate interest in making your experience relevant to you.
Sending you service updates, booking confirmations and non-marketing communications	Performance of a contract; Legitimate interests	Required to deliver your booking and keep you informed.
Improving our website and services through statistical analysis and customer feedback	Legitimate interests	We have a legitimate interest in improving our services.
Blocking disruptive use and maintaining website and system security	Legitimate interests; Legal obligation	We have a legitimate interest in protecting our systems and users.
Complying with our legal obligations under Guernsey law and other applicable legislation	Legal obligation	Required by law.

 

Soft opt-in applies where La Grande Mare has collected your contact details in the course of a booking or enquiry and the marketing relates to similar products or services. You will always be given a clear opportunity to opt-out, both at the point of collection and in every subsequent communication.

• Legitimate Interests Tests
  
  For each processing activity where we rely on legitimate interests, we have carried out a balancing test. Below are short summaries for the main activities:
  
  Responding to enquiries and customer service
  
• Purpose: to manage communications and provide support
• Necessity: necessary to respond to enquiries and maintain
• service quality
• Balancing: impacts on privacy are low (we process contact and
• booking data only); we minimise risk by limiting access and
• retaining data for a short period

Opt-out: you may object at any time by emailing info@lagrandemare.com

·
Personalising experience and communications

• Purpose: to tailor offers and content
• Necessity: personalisation improves service relevance
• Balancing: we use pseudonymised profiles and allow opt-out of profiling; we do not share personal identifiers with advertisers without consent
• Opt-out: unsubscribe links in emails or contact info@lagrandemare.com.

Fraud prevention and site security:

• Purpose: to detect and prevent fraud
• Necessity: essential to protect customers and the business
• Balancing: processing is limited to technical and transactional
• data; retention is minimised; security controls are in place
• Opt-out: not available where processing is necessary for security

Website Improvements / Analytics:

• Purpose: to analyse website usage and improve performance,
• usability, and user experience
• Necessity: limited analytics data is required to understand how
• visitors use our website and identify areas for improvement
• Balancing: The impact on individuals is low; where possible, data
• is aggregated and does not identify individuals
• Opt out: you can withdraw consent at any time via the cookie consent tool or browser settings

6. Data Anonymisation For Statistical Purposes

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data is designed not to identify individuals and cannot reasonably be linked back to you. 
We may use this data for analytical, research or general management purposes. Aggregated or anonymised data is not personal data and may be retained indefinitely.

7. Using Your Information For Specific Products / Services

Registration
If you've registered on our website, you'll receive personalised recommendations, newsletters and marketing tailored to you based on your registration details, interactions with our emails, and information we receive from trusted service providers acting on our behalf, where those providers are contractually prohibited from using your data for their own purposes.
We will only use third-party data about you where those third-parties have a lawful basis to share it and we will identify the source on request.
Please see Section 12 (Your Choices – Cookies) of this policy for more details.

Competitions

If you enter a contest or promotion, we may ask for your name, address, e-mail address or telephone number. This is so we can run the contest effectively and tell you if you have won.

Tailored Advertising

We use advertising to improve the range of products and services that we are able to offer our patrons. We will not share your contact details with advertisers for linking to behavioural advertising unless you have given explicit consent.

Some advertising is “contextual” meaning it is shown due to the particular webpage you are presently viewing. Other advertising, known as “online behavioural advertising” is shown to you based upon your likely interests, which are inferred from your device's browsing history. This information is collected through the use of cookies and similar technologies. 

You may opt-out of online behavioural advertising at any time, please see our Cookies Policy for details.

Other times we will arrange for our patrons to be shown promotional information from selected suppliers and partners on our own or other websites. These advertisements are tailored to you with information we have obtained from your interactions with our website, services, and communications, and from service providers acting on our behalf, where such providers are contractually restricted from using your data for their own purposes.

Where we arrange for our customers to be shown such content, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioural advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.

If you have registered on our website, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.

When you are shown an advertisement, specific personal information is not displayed or shared with them, such as your name, email address or postal address.

Demographic information from your registration on our website (such as your age, gender and city) may be used to tailor the advertising we arrange to be shown. 

Where you have granted permission to access your device's location to us, our partners or specialist data companies, this location information may be used to tailor the messaging you receive, including showing you certain recommended promotions or messages when you are in the vicinity of a particular location.

Social Media Advertising

We may target promotional messaging on social media platforms such as Meta platforms (Facebook and Instagram) and X (formerly Twitter). These platforms may use their own tracking technologies and act as separate data controllers for certain processing activities. For example, customers who have subscribed to our newsletters may not see an advert for those newsletters.

8. How We May Share Your Information

La Grande Mare acts as a data controller for the processing described in this policy. We may engage third-party processors to perform services on our behalf (for example, payment processors, email service providers, analytics providers). 

We also use third-party booking platforms, including YourGolfBooking and Tee Track, to manage tee-time and golf-related bookings. These providers act as data processors on our behalf.

Where we share personal data with other organisations who determine the purposes and means of processing, those organisations will be separate controllers and will have their own privacy notices.

On occasion, we will bring you promotions from partners associated with La Grande Mare. On such occasions, your data will not be shared and La Grande Mare will remain as the data controller in line with the privacy policies we have already outlined within this document. 

However, if you decide to set up an account with them or purchase their products or services, this partner will be the data controllers of your information and will handle your information in accordance with their own privacy policies.

We may share information about you with suppliers that we engage to help us provide the services and/or functionality, e.g. online payment processing. 

We may also share personal information about you to third-parties, where you have given us permission or where the third-party can confirm that they have your permission for us to do this.

We may also provide third-parties with certain aggregate statistical data about our patrons' use of our website, which may include demographic data such as age range and/or geographic location of groups of our customers. This aggregate data does not include contact details (such as the customer's name, address or email address).
In the event of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business, personal data held by us may be transferred to the relevant third-party subject to appropriate data protection obligations. In such cases, we will notify you where required to do so by law.

We may also share your information as required by law, including under The Data Protection

(Bailiwick of Guernsey) Law, 2017.

 

9. Children & Young People

Our website and services are not aimed at children.
If you are a parent or guardian of a child under 16, please contact us by emailing info@lagrandemare.com if you are aware that your child has used our website or otherwise provided their information to us without your consent. 
In addition to “Your Choices” outlined in this Policy, we will delete or otherwise cease processing your child's personal information within a reasonable time.
If you are under 16, we request that you seek your parent or guardian’s permission before providing us with your information or using our website.

10. Storing, Retaining And Keeping Your Data Secure

Data Retention

We will only retain your personal data for as long as is necessary for the purposes it was collected and in accordance with legal requirements. Our standard retention periods are:

Processing Activity	Lawful Basis	Retention Rationale
Enquiry form data	2 years from last contact	Business records; legitimate interests (customer service)
Newsletter subscriber data	Until unsubscribe or withdrawal of consent	Consent
Website analytics (Google Analytics)	26 months (platform default)	Consent for analytics cookies
Financial and contractual records	7 years	Legal obligation (tax/accounting)
Golf bookings (tee-time, tuition, range)	3 years from booking	Contract performance; legitimate interests for service history
Fraud/security logs	12 months (or longer if required for investigation)	Legitimate interests; legal obligation where required
CCTV / incident reports (on‑site)	1 year (or as required by law)	Safety, legal obligation

Criteria For Retention

Where a fixed period is not specified above, we retain data only for as long as necessary to fulfil the purpose(s) for which it was collected, to comply with legal obligations, or to resolve disputes. When data is no longer required it will be securely deleted or irreversibly anonymised.
When one of the above situations arise, we will review the information which we hold concerning you and determine whether there are any legal reason why we need to continue holding that information. Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to retain your information, we will delete your information.
If you would like further information about our data retention and disposal policy, then please contact info@lagrandemare.com.

Keeping your data secure
While we use reasonable technical and organisational measures to protect your personal data, no internet transmission is completely secure. Please take care when transmitting personal data to us. 
Once we have received your personal information, we implement appropriate technical and organisational security measures, including (where appropriate) encryption, secure payment processing via PCI-compliant providers, access controls, and staff confidentiality obligations to ensure that it remains secure against accidental or unlawful destruction, loss, alteration or unauthorised access.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Office of the Data Protection Authority (ODPA) without undue delay and, where feasible, within 72 hours of becoming aware of the breach, as required by The Data Protection (Bailiwick of Guernsey) Law, 2017. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.

We comply with The Data Protection (Bailiwick of Guernsey) Law, 2017 and your related rights. Please visit the ODPA website https://odpa.gg/ for further information.

Our website may contain links to websites of other organisations. This policy does not apply to those other websites, so we encourage you to read their privacy statements. We are not responsible for the privacy practices of the other websites even if you access them through links we provide.

11. Your Rights

Under the Data Protection (Bailiwick of Guernsey) Law, 2017, you have the following rights in relation to your personal data: access, rectification, erasure, restriction, portability, objection, and the right to withdraw consent.

Identity Verification Checklist - we may ask for identification such as a copy of a government ID (passport or driving licence) and proof of address (utility bill or bank statement dated within 3 months). We will only use these documents to verify identity and will delete them once verification is complete:

• Right of access: to request a copy of the personal data we hold about you
• Right to rectification: to ask us to correct inaccurate or incomplete data
• Right to erasure: to request deletion of your data where there is no compelling reason for us to continue processing it
• Right to restriction: to ask us to restrict processing of your data in certain circumstances
• Right to data portability: where processing is based on consent or contract and carried out by automated means, to receive your data in a structured, commonly used, machine-readable format
• Right to object: to object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time
• Rights in relation to automated decision-making: we do not currently make decisions about you based solely on automated processing, including in relation to pricing or booking eligibility. This includes profiling for marketing purposes, which does not produce legal or similarly significant effects

We carry out limited profiling for marketing and personalisation purposes (for example, analysing booking history or preferences to tailor communications). This profiling does not produce any legal effects or similarly significant effects on you.

If we introduce any automated decision-making that produces legal or similarly significant effects, we will notify you in advance and explain the logic, significance and available safeguards.
To exercise any of these rights please contact us at info@lagrandemare.com or by post to Data Access, La Grande Mare, Rue de Gele, Guernsey, GY5 7LR. We will acknowledge your request within 5 working days and respond substantively within one month (or longer, where permitted by law).

Correcting and Updating (Rectifying) Your Personal Information

In most cases you are entitled to have your records amended if the personal data we hold about you is inaccurate or incomplete.
However, in some circumstances the right to rectification does not apply. For example, it does not include amending data which was accurate about you at one time even though the current position is different. Nor does it include changing records of information sent to us by others which you say is inaccurate because the information is an accurate record of what was sent to us.

Accessing Your Personal Information

You have the right to be provided with a copy of the personal information that we hold about you. However, there are exemptions which means you may not always receive a copy of all the information about you that we process. Where this is the case, we will let you know.

Withdrawing Your Consent

Where we rely on your consent as the lawful basis for processing — specifically, for sending you marketing emails or SMS messages, and for placing analytics cookies on your device — you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing carried out before you withdrew it, nor will it affect processing carried out on a different lawful basis.
To withdraw consent for marketing communications, use the ‘unsubscribe’ link in any email we send you, reply ‘STOP’ to any SMS, or contact us at info@lagrandemare.com. To withdraw consent for analytics cookies, update your preferences using our cookie consent tool or your browser settings.

Objecting To Our Use Of Personal Data

You have the right to object to us processing your information in certain circumstances — for example, where that processing is for direct marketing purposes (which you may object to at any time without giving any reason), on the grounds of public interest, or for historical or scientific purposes. In such cases we will stop processing unless we can demonstrate we are lawfully able to continue to do so.

Erasing Your Personal Data Or Restricting Processing

You can ask us to remove your personal data from our systems and, unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. 
An example of where we will not delete your personal data is where we need the information for the performance of our statutory functions, such as recording an accident / injury on-site.
You may also ask us to restrict processing your personal information where:
•  You dispute the accuracy of the information we hold about you; or
•  Where you do not wish your anonymised data to be included in an overall customer profiling exercise. Profiling means analysing your preferences and behaviour to tailor communications; or
•  You believe we are unlawfully using your data but you do not want that data erased; or
•  We no longer need your personal information but you need the information in connection with legal proceedings or obtaining legal advice.

Complaining To The Data Protection Authority

We hope that we can resolve any concerns you may have about how we use your personal information. You have the right to complain to the Data Protection Authority (as well as a right to appeal against any decision of the Data Protection Authority). 
The Data Protection Authority can be contacted at Block A, Lefebvre Court, Lefebvre Street, St Peter Port, Guernsey GY1 2JP or by telephoning +44(0)1481 742074 or by email at info@odpa.gg.

12. Your Choices - Cookies

We use a cookie consent banner that allows you to accept or reject non essential cookies. Strictly necessary cookies are always active. We do not place analytics or advertising cookies until you give consent. 
You can change your preferences at any time via the cookie preference tool or your browser settings. Our website uses Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website; these are only placed after you give consent.
Please note that our website may not work correctly (or at all) if you change your preferences. 

Email & SMS Marketing

If you object to marketing based on legitimate interests, we will stop processing for that purpose within 7 working days while retaining any data necessary for contract or legal obligations.
You can opt-out of marketing campaigns or newsletter subscription by clicking on the 'unsubscribe' link in each email.
You can opt-out of marketing text messages by replying 'STOP'.
In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.
Should you wish to resubscribe to La Grande Mare’s messaging, please contact info@lagrandemare.com to reinstate your opt-in.

13. Changes To This Statement

We review this Privacy & Cookies Policy at least annually and whenever there is a material change to our processing activities, the law, or guidance issued by the Office of the Data Protection Authority (ODPA). The date on which this policy was last updated is shown at the top of this document.

Minor Changes

Where we make minor changes — such as clarifications of existing wording, corrections, or updates to contact details — we will update the policy on our website without individual notification. The updated policy will take effect from the date shown at the top of the document.

Material Changes

Where we make material changes — meaning changes that affect how we collect, use, share or retain your personal data, or that affect your rights — we will notify you in advance by:
•    Email, where we hold a current email address for you; and/or
•    A prominent notice on our website at www.lagrandemare.com
We will give you reasonable notice before any material change takes effect, and where required by the Data Protection (Bailiwick of Guernsey) Law, 2017, we will seek your consent before implementing the change.