Privacy Policy

The Delhi Golf Club (DGC)

The Delhi Golf Club (DGC) hereby gives you the confidence that all the personally identifiable information (the “PII”) that you have provided to us are important and critical information that we commit to assure the protection and we shall only process that information at the best security information standard level in strict compliance with this Privacy Policy and the applicable laws and regulations.

Once you, as the DGC member, register your membership and/or use the DGC facilities and enjoy the DGC membership benefits, enters into this website or directly gives your PIIs to DGC in any other circumstance either online or offline, including giving consent to DGC under the terms and conditions of this Privacy Policy, DGC shall deem that you have agreed and accepted to be bound and comply with this Privacy Policy; provided that it is understood that this Privacy Policy is intended to supplement instead of superseding or replacing any consent that you may have given DGC in relation to the PIIs process prior to this Privacy Policy.

Please kindly study this Privacy Policy in details, together with the Membership charters or other membership documentation. If you do not agree to the PIIs process defined by the DGC hereunder, DGC would reserve the right to refuse to provide any service to you since the PIIs processing as defined hereunder are critical for the performance of the services to you.

This Privacy Policy shall be applicable to this website, the communication and/or services provided by DGC only and shall not be applicable to the application, services or other website of any third party that may connect to the DGC’s website or other process undertaken by any third party that DGC does not have any control over. In such circumstance, you should be studying the relevant privacy policy declared and announced by those third parties that are separate from this Privacy Policy.

DGC may adjust or amend this Privacy Policy at any time in order to assure the compliance with the relevant laws and regulations and to match with the services provided by DGC; provided that DGC shall notify you of all the amendment and modification made by announcing the amended Privacy Policy on the website and other communication channels.

PII to be processed by DGC in the Services Provision and the Communication

The PII being processed pursuant to this Privacy Policy is important and critical for the provisions of the services and other benefits to the member to be performed by DGC to you as the member, ranging from the qualification verification, notice and communication delivery, transaction effectuation, membership benefits communication, membership relationship management, the introduction of the new services and events; and the planning of new and future products or services. The PII that are required to be processed include the following information:

1. General information relating directly to you that you have provided in the membership application form, the application for the use of any particular services or other documentation that you have submitted to DGC in the form designated by DGC (i.e. the notice of absence, the e-statement request, notice of membership transfer, locker request, parking request and permission as well as other registration of your dependent), in particular the membership card number and your full name, the Membership Category and Signature etc;

2. Contact information, including residential address, contact address, telephone number, email that you have provided during the membership registration process and thereafter for any forms, including the complaint submission or lost-found request and form;

3. The service transaction records and logs information that includes the details of the transactions that you have executed with DGC, either online or offline, including the use of your log-in with the username and password, transaction history and other services that you have used and recorded in the membership system or the website and the payment information that you have transacted that may also include the details of your bank account and credit card information registered for the membership fees payment;

4. Other technical information that can identify or link to your identity, including IP address, setting and browser connection that the user uses to connect to the Platform and may include various types of cookies used in order to track your behaviour on the website;

5. Other information that you may give for the purpose of marketing and sales promotion; the participation in the event, survey, competition, lucky draw; or any other promotional events and activities hosted by DGC and other information relating to your preference and interest that DGC may process to personalize the DGC’s recommendation on services and/or products that would fit with your preference and interest, including also the photo and interview script that you have kindly permitted us to take;

6. Upon receipt of your explicit consent, your sensitive PII (as defined under the applicable laws);

7. Other PII that you may give to DGC during the correspondence and communication for the service performance or any other PII that you may give the consent to DGC to process.

DGC may collect your PII in the following circumstances:

1. When you contact DGC (i.e. when you contact for any enquiry undertaken in person, on the website, on phone or via email);

2. When you submit your PII for the membership registration, for the service and facilities used in various forms as provided and arranged by DGC, either via the email submission or online channel, including on the Platform;

3. When you participate in the survey, competition, lucky draw or other promotional events;

4. When you give your feedback and opinion on DGC’s services (i.e. survey gathering on the Platform); and/or

5. When you submit any PII to DGC for any other purposes.

In addition to the direct submission of the PII from you to DGC (as defined above), DGC may receive your PII from the third-party sources that you may contact with and you have given consent to them to disclose your PII to DGC, for instance, the submission of the referee or the dependent by other members. In such circumstance, DGC shall deem that you have acknowledged that by receiving those information, DGC believe and deem that you have given all the consent to the relevant person to disclose such PIIs to DGC.

Objectives of the PII Process

The PII that you have provided to DGC shall be collected and used for these particular purposes:

1. For the purpose of membership and user verification for granting access to the membership privileges and benefits pursuant to the defined terms and conditions in the Membership Charter or the terms of services of the website; validation and confirmation of any transactions undertaken by you with DGC (i.e. the facilities used) that may incur cost and expenses on you as defined under the terms and conditions of the Membership Charter; confirmation of the payment of any expenses or fees incurred for the use of any service or facilities; and for the purpose of contacting you with an aim to provide any supports or respond to any of your query relating to the member benefits and privileges;

2. For the dissemination of any membership benefits, privileges or any other membership events that may be of any interest to you via the communication channel that you have identified as the preferred communication channel;

3. For the creation and improvement of the business relationship between DGC and you that may include the case where DGC uses your PII for the employee training or supervisions to assure the service quality (in particular for the customer support staff provided through various channel); for analysis, investigation and complaints resolution;

4. For the management of the communication and correspondence that you may contact DGC (i.e. enquiry or complaint management or other feedback submission);

5. For the analysis of your preference where DGC may adjust the service provisions and channel which DGC intends to use the best effort in fulfilling your interest and request to the fullest extent and to create the good relationship between DGC and you;

6. For the purpose of preventing and inspecting any fraud or illegal use of DGC’s services; assessing and managing the commercial risk or any other associated risks in other aspects of DGC;

7. For the purpose of assessing in the participation in the competition, promotional events or other activities that you may have agreed to enter into under the relevant defined terms;

8. For the performance of any legal obligations that DGC may have and for the compliance with the instructions given by the relevant regulatory authorities, for instance, for the tax payment purpose or any other obligations under the Computer Crime Act or the electronic transaction regulations;

9.  Other purposes that the Company may consider related to the objectives already defined above. Other purposes that the Company may consider related to the objectives already defined above.

DGC is obliged to process and store your PII for the purpose defined above as long as you remain your membership status with DGC and throughout the period of time as defined under the applicable laws; provided that DGC reserves the right to retain your PII after the termination of the membership status for the period of 8 years thereafter for the purpose of facilitating you in case you would intend to resume the membership or for the legitimate interest protection in case of any dispute or complaint raised by you against us where DGC may retrain your PII for the period of time as necessary to appropriate to fulfil the defined objective. Also, for the PII process that is being undertaken on the consent basis, DGC will retain your PII for so long as until you have withdrawn your consent.

Disclosure of the PII

In general, your PII shall be kept in strict confidence by DGC; provided that in certain circumstances, DGC may have certain necessity to disclose the PII to these groups of people in order to fulfil DGC’s contractual or legal obligations:

1. To disclose to the outsourced service providers that have been engaged to provide direct services to DGC in the performance of any obligation to you, for instance the relevant professional counsel and other third party service providers engaged to provide performance assessment of the system and website; provided that always that the Company shall disclose your PII only for the specified objectives and solely on the need- to-know basis.

2. To disclose the operational information that may include your PII to the storage service providers on cloud (that may be located in India or abroad); provided that for the utilization of this particular services, DGC assure to set the high confidential configuration and setting to assure the security in your PII at the level that reflects the level of confidentiality and risk exposure;

3. To disclose your PII to third party in the legal proceedings to protect DGC’s legitimate rights or to detect and prevent any fraud on DGC’s system or the services that may also impact the third party’s rights; provided that such disclosure shall be done on the limited and specific purposes as explicitly defined.

4. In case DGC is obliged under the applicable laws, court judgment or administrative order to disclose any PII of any particular users, DGC would need to do so only on the necessary basis.

5. Other entity whom you may give consent to DGC explicitly to disclose your PII to.

Cookies that DGC use on website performance

Cookies are text files stored on your computer browser directory or program data subfolder in order to keep data log of the your internet usage and behaviour or interaction on the DGC website. For the performance of the website, DGC need to use 2 types of Cookies for various purposes as defined below:

1. Strictly Necessary Cookies are essential for you to browse the website and use its features, such as accessing secure areas of the website; and

2. Other Cookies that may include Functionality Cookies used to record information about choices that you have made in the website such as personal settings, languages, and fonts so this would allows DGC to tailor our website features that would match your preference setting; Performance Cookies used to assess the performance in any part of the website; and Advertising Cookies used to record the your on-site behaviour and history of the website visited and this would allow DGC to provide you the services and products that suit your preferences and to assess the success of each function of the website

For the use of Strictly Necessary Cookies, DGC needs to use this cookies for the performance of the website in full capacity and without this type of cookies, DGC shall not be able to provider the designated services to you. For other types of cookies, DGC will only use those cookies upon the receipt of your consent.

Even though the use of Cookies would enhance the performance in providing services in any features of the website to you, you shall be entitled to disable the Cookies setting on your browser at your own will; provided that you shall acknowledge that the Cookies-disabled setting may impact the efficiency and the performance of the website as defined in details for each type of Cookies above.

Representation on the Appropriate Information Security of the PII

DGC represents and guarantees that DGC shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of the PII in any form or in any circumstance by either internal or external persons and DGC commits to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws. Those measures may include the following measures:

1. DGC will use and store the PII in the anonymized form as much as possible by separating the PII from other information in order to reduce and mitigate the risk that any person receiving any piece of information may be able to use those information to identify the relevant individual;

2. DGC will encrypt most of the PII (if necessary) and shall limit the access control both physical and on the system and shall keep logs for all the PII access;

3. DGC shall adopt the inspection and monitoring scheme to monitor any threat, attack or any other unauthorized access to the PII. In this regards, DGC shall configure and review the measures set on a regular basis as appropriate and DGC shall establish a proper emergency response plan that include the process of reporting the incident to the relevant Systems Sub Committee and the relevant data subject pursuant to the timeline set under the applicable laws; and

4. In case of any PII exchange or disclosure to any third party outside DGC’s environment, DGC shall enter into the data processing agreement with the applicable receiving party in writing in order to set a clear scope of the rights and obligations of each party and shall establish a proper monitoring and management mechanism between the disclosing party and the receiving party; provided that such mechanism shall also include reporting obligations between the parties in case of incident or breach.

Data Subject Rights

DGC respect your rights as the data subject over their PII as defined under the applicable laws that include the following rights:

1. Right to access; to request for the copy of all the PII; and to rectify or update your PII;

2. Right to request for the PII that DGC has processed in the readable forms by the tools or automatic mechanics and to request for the data portability to other data controller;

3. Right to object to the PII process being undertaken;

4. Right to request for the erasure or de-identification of any PII that does not have any necessary basis to process, i.e. after the consent withdrawal;

5. Right to request for the PII process suspension in case that request for erasure is being exercised or when such PII is not necessary; and

6. Right to withdraw consent that has been given for the PII process for specific purpose.

You as the member can contact DGC in order to make the request to exercise any defined rights through the defined channel and DGC shall notify you of the DGC’s determination within 30 days after the receipt of the valid request.

Contact Us:

Sr. Manager IT :

Name:               Ravindra Kumar Pathak

Address:           Dr. Zakir Hussain Road, New Delhi, INDIA – 110003

Telephone:       011 24307100