Privacy Policy.

22 May 2018

1. Data privacy at a glance


GENERAL GUIDELINES
The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data are all data which can be used to identify you personally. Detailed information on the issue of data privacy can be found in the Data Privacy Policy below.
Data collected on our website
Who is the responsible controller for the data collected on this website?
The website operator processes data on this website. The website operator’s contact data can be found in the Imprint on this website.

HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect data that you communicate to us. These data could, e.g., be information which you enter in a contact form.
Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data (e.g. Internet browser, operating system or time at which a page is called up). These data are collected automatically as soon as you enter our website.

WHAT DO WE USE YOUR DATA FOR?
We collect some of your data to ensure that we can provide the website without any errors. Other data may be used to analyse the way you use the website.
What are your rights concerning your data?
You have the right to receive information, at any time and at no cost, about the source and recipients of your personal data as well as the purpose for which your personal data have been stored. You also have the right to obtain rectification or erasure of these data or to have them made unavailable. You may contact us at any time at the address provided under Imprint if you have any other questions about data privacy. You also have the right to lodge a complaint with the responsible supervisory authority.

ANALYSIS TOOLS AND THIRD-PARTY PROVIDER TOOLS
Your surfing behaviour on our website can be analysed statistically. This is primarily done using cookies and analysis programs. Your surfing behaviour is usually analysed anonymously; surfing behaviour cannot be traced back to you. You may object to this analysis or prevent it by not using certain tools. Detailed information is available in the following Data Privacy Policy.
You can withdraw your consent to such analysis. You are informed about your rights to object in this Data Privacy Policy.

2. General and mandatory information


DATA PRIVACY
The operators of these pages take the protection of your personal data very seriously. We treat your personal data with confidentiality and in compliance with legal data protection regulations as well as this Data Privacy Policy.
Various personal data are collected whenever you use this website. Personal data are all data which can be used to identify you personally. This Data Privacy Policy explains which data we collect and what we use them for. It also explains how and for what purpose this is done.
We draw your attention to the fact that security gaps may affect the transmission of data on the internet (e.g. when communicating by email). It is not possible to guarantee absolute protection of data against access by third parties.

INFORMATION ABOUT THE CONTROLLER
The controller responsible for data processing on this website is:
Roxburghe Golf
Heiton by Kelso
Roxburghshire, TD5 8JZ

Tel. +44 1573 450333
E-Mail: info@roxburghe-golf.com

The controller is the natural or legal person who alone or together with others decides on the purposes for and means by which personal data (e.g. names, e-mail addresses and similar) are processed.

WITHDRAWAL OF YOUR CONSENT TO DATA PROCESSING
Many data processing operations are only possible with your explicit consent. You may revoke any consent you have already given at any time. All you need to do is send an informal message to us by e-mail. Withdrawal of consent does not affect the lawfulness of any processing based on consent before its withdrawal.

RIGHT TO LODGE A COMPLAINT WITH THE RESPONSIBLE SUPERVISORY AUTHORITY
The data subject is entitled to lodge a complaint about violations of data protection law with the responsible supervisory authority. The responsible supervisory authority for data protection issues is the state data protection officer for the federal state in which our company is based. A list of data protection officers and their contact information is available at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

RIGHT TO DATA PORTABILITY
You have the right to have data which we automatically process, either on the basis of your consent or to perform contract, released either to you or to a third party in a structured, commonly used machine-readable format. Any request to have personal data transmitted directly from one controller to another will only be complied with where this is technically feasible.

SSL OR TLS ENCRYPTION
This website uses an SSL or TLS encryption procedure for security purposes and to protect the transmission of confidential contents, such as purchase orders or inquiries which you have sent to us (website operator). You will recognise an encrypted connection by the change in the address line of your browser from “http://” to “https://” and the lock symbol in your browser bar.
Data sent to us cannot be read by third parties if SSL or TLS encryption are enabled.

ENCRYPTED PAYMENT TRANSACTIONS ON THIS WEBSITE
If, after entering into a payment-related contract, you are required to provide us with your payment data (e.g. account number for collection authorisation direct debits), such data are required in order to process payments.

Payment transactions by means of commonly used means of payment (Visa/MasterCard, direct debit procedures) are performed exclusively via an encrypted SSL or TLS connection. You will recognise an encrypted connection by the change in the address line of your browser from “http://” to “https://” and the lock symbol in your browser bar.
Where communication is encrypted, the payment data you send to us cannot be read by third parties.

INFORMATION, LOCKING, ERASURE
You have the right to obtain information at any time and at no charge about the personal data we have stored on you as well about where the data have been obtained, by whom they have been received and the purpose for which they are processed; you also have the right to have these data rectified, erased or made unavailable at any time. You may contact us at any time at the address provided under Imprint if you have any other questions about personal data.

OBJECTION TO MARKETING E-MAILS
Objection is hereby made to the use of contact data published in accordance with legal requirements for the purpose of sending marketing and information material which has not been explicitly requested. The operators of this website explicitly retain the right to take legal action in the event that unsolicited marketing information, such as spam mail, is sent.

3. Data Protection Officer


Data protection officer required by law
We have appointed a data protection officer for our company.
Stefan Maier
12.18. Investment Management GmbH
Königsallee 2b
40212 Düsseldorf
Germany
Telephone: +49(0) 211 5808070
E-Mail: datenschutz@12–18.com

4. Data collected on our website

COOKIES
The internet web pages use “cookies” in several places. Cookies do not cause any damage to your computer and do not contain viruses. We use cookies to make our website more user friendly, more effective and more secure. Cookies are small text files which are placed on your computer and stored in your browser.
Most of the cookies we use are “session cookies” which are automatically deleted as soon as you leave the website. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to recognise your browser the next time you visit our website.
You can change the settings of your browser so that you are informed every time a cookie is set. This will allow you to permit cookies in specific cases, to exclude them completely, or to have them deleted automatically every time you close your browser. However, if you disable cookies, this may affect the functionality of this website.
Cookies which are needed for the performance of the electronic communication procedures or to provide certain functions (e.g. shopping cart function) requested by you are stored on the basis of Article 6(1) f) GDPR. The website operator has a legitimate interest in storing cookies in order to provide technically faultless and optimised services. Any other cookies (e.g. cookies used to analyse your surfing behaviour) which are stored are treated separately in this Data Privacy Policy.

SERVER LOG FILES
The website provider automatically collects and stores information in server log files which your browser then sends to us automatically. This information concerns:
• The browser type and version
• The operating system used
• Referrer URL
• The host name of the accessing computer
• The time of the server request
• IP address

These data are not combined with other data sources.
Data processing is lawful under Article 6 (1) f) GDPR, which permits the processing of data for the purpose of performing a contract or of taking steps prior to entering into a contract.

CONTACT FORM
If you send inquiries to us via a contact form, the information you provide in the inquiry form, including the contact data you provide in the form, is stored by us for the purpose of handling the inquiry and dealing with any subsequent questions. We do not disclose this data without your consent.
Data entered in the contact form are processed exclusively with your consent (Article 6 (1) a) GDPR). You may withdraw this consent at any time. All you need to do is send an informal message to us by e-mail. Withdrawal of consent does not affect the lawfulness of processing operations undertaken with your consent prior to the withdrawal of such consent.
The data entered in the contact form will be held by us until you ask us to erase them, you withdraw your consent to storage or the purpose for which data have been stored no longer applies (e.g., after finally processing your inquiry). Mandatory legal provisions – including but not limited to retention periods – remain unaffected.

PROCESSING OF DATA (CUSTOMER AND CONTRACT DATA)
We collect, process and use personal data only to the extent necessary for establishing, agreeing the content of or modifying the legal relationship (stock data). The processing of this data is lawful under Article 6 (1) b) GDPR, which permits the processing of data for the purpose of performing a contract or of taking steps prior to entering into a contract. We only collect, process and use personal data about the use made of our website (usage data) to the extent that this is necessary to enable the user to make use of the service or for settlement purposes.
Any customer data collected in this way are erased after the order has been completed or the business relationship has ended. Statutory retention periods remain unaffected.

Data transmission relating to contracts made for online shops, dealers and shipment of goods
We only transmit personal data to third parties if this is necessary for the purpose of performing the contract, such as to companies shipping our goods or banks handling our payment transactions. Data are not transmitted for any other purpose except if explicit consent has been given. Your data are not passed on to third parties, such as for marketing purposes, without your explicit consent.
Data processing is lawful under Article 6 (1) b) GDPR, which permits the processing of data for the purpose of performing a contract or of taking steps prior to entering into a contract.
Data transmission relating to contracts made for services and digital contents
We only transmit personal data to third parties if this is necessary for the purpose of performing the contract, such as to banks handling our payment transactions.
Data are not transmitted for any other purpose except if explicit consent has been given. Your data are not passed on to third parties, such as for marketing purposes, without your explicit consent.
Data processing is lawful under Article 6 (1) b) GDPR, which permits the processing of data for the purpose of performing a contract or of taking steps prior to entering into a contract.

5. Analysis tools and marketing


GOOGLE ANALYTICS
This website uses the functions provided by the web analysis service Google Analytics from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses “Cookies”. These are text files which are stored on your computer to analyse the way you use the website. The information about the way you use this website created by the cookie is usually sent to and stored on a Google server in the USA.
The storage of Google Analytics cookies is lawful under Article 6 (1) f) GDPR. The website operator has a legitimate interest in the analysis of user behaviour for the purpose of optimising its web services and its marketing.

IP anonymisation
We have enabled the IP anonymisation function on this website. This means that Google truncates your IP address in Member States of the European Union or in other state parties to the Agreement on the European Economic Area. Only in exceptional circumstances will the full IP address be sent to and truncated on a Google server in the USA. Google uses this information on behalf of the website operator to evaluate the way you use the website, to collate reports on website activities and to provide the website operator other services related to website and Internet use. The IP address sent by Google Analytics from your browser is not combined with other data held by Google.

Browser plug-in
You can change your browser settings to prevent cookies from being stored; however, we draw your attention to the fact that, in these circumstances, you may find that you are unable to make full use of functions on the website. You can also prevent the data (including your IP address) relating to your use of the website which are captured by the cookie being sent to or processed by Google by downloading and installing the browser plug-in from the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Objection to data collection
You can prevent your data being collected by Google Analytics by clicking the following link. An opt out cookie is then set which prevents your data being collected the next time you visit this website: Disable Google Analytics.
More information about the way Google Analytics handles user data can be found in Google’s data privacy statement: https://support.google.com/analytics/answer/6004245?hl=de.

Order data processing
We have entered a contract with Google for the processing of data; we implement the stringent requirements of the German data protection authorities in full when we use Google Analytics.

Demographics in Google Analytics
This website uses the Google Analytics “Demographics” function. This enables reports to be produced with information about the age, gender and interests of website users. These data originate from interest-related advertising from Google and traffic data from third-party providers. These data cannot be assigned to particular people. You can disable this function at any time by changing your display settings in your Google account or prohibit the collection of your data by Google Analytics entirely as explained under “Objection to data collection”.

GOOGLE ADWORDS AND GOOGLE CONVERSION TRACKING
This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
We use the Google AdWords Conversion Tracking function. If you click on an advertisement placed by Google, Google is set for Conversion Tracking. Cookies are small text files which are stored on your computer by the Internet browser. These cookies cease to be valid after 30 days and are not used to identify users personally. If the user visits certain pages on this website and the cookie has not yet expired, we and Google can recognise that the user has clicked the advertisement and has been redirected to this website.

All Google AdWords customers are given a different cookie. This means that cookies cannot be tracked via the websites of AdWords customers. The information obtained with the aid of the conversion cookie is used to produce conversion statistics for AdWords customers who have opted for Conversion Tracking. The customers obtain information about the total number of users who have clicked their advertisement and have been redirected to a website with a Conversion Tracking tag. However, they do not receive any information which could be used to identify users personally. If you do not wish to participate in tracking, you can easily object by disabling the cookie for Google Conversion Tracking in your Internet browser and user settings. You will then not be included in the Conversion Tracking statistics.
The storage of Google Analytics conversion cookies is lawful under Article 6 (1) f) GDPR. The website operator has a legitimate interest in the analysis of user behaviour for the purpose of optimising its web services and its marketing.
More information about Google AdWords and Google Conversion Tracking is available in Google’s data privacy policy: https://www.google.de/policies/privacy/.

You can change the settings of your browser so that you are informed every time a cookie is set. This will allow you to permit cookies in specific cases, to exclude them completely, or to have them deleted automatically every time you close your browser. However, if you disable cookies, this may affect the functionality of this website.

6. Newsletter


NEWSLETTER DATA
If you would like to receive the newsletter which is offered on the website, we will need an e-mail address as well as information which enables us to check that you are the authorised account holder of the e-mail address and have agreed to receive the newsletter. Any other data are provided on a voluntary basis only. We use these data exclusively for the purpose of sending the requested information and do not share such information with third parties.
Data entered in the newsletter subscription form are processed exclusively with your consent (Article 6 (1) a) GDPR). You may withdraw at any time the consent you have given to the storage of your data and the use of your data for the purpose of the sending the newsletter by, for example, clicking the “unsubscribe” link in the newsletter. Withdrawal of consent does not affect the lawfulness of previous processing.
We will store the data held by us for the purpose of receiving the newsletter until you are unsubscribed from the newsletter and will erase such data as soon as the newsletter order has been cancelled. Data which are stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected.

MAILEON
This website uses MailEon to send newsletters. This service is provided by XQueue GmbH, Christian-Pleß-Str. 11–13, 63069 Offenbach am Main, Germany.
The purpose of processing is to produce and send mass marketing e-mails using the online “Maileon E-Mail Marketing” solution. E-mails can be sent manually or automatically (API, Marketing Automation). Some activities, such as modifications or settings, may be undertaken as a service on our behalf; in this case our contractor’s employees inevitably have access to personal data in the relevant Maileon accounts. Usually the e-mail addresses of recipients are collected on a registration page or addresses are sent by the customer to Maileon. In addition to the e-mail address, additional data on the data subject (e.g. form of address, first name, etc.) may also be processed to make the design of the newsletter more relevant. Usage data on the newsletter recipients (e.g. e-mail openings) may be recorded and processed automatically (single user tracking). The double opt in procedure is used when a user subscribes to a newsletter via the Maileon system, and the subscriber data, including consent to receipt of marketing e-mails (permission) are processed in Maileon in the same way as cancellations (objection) by the contractor.

Contractor
12.18. Investment Management GmbH
Königsallee 2b
D-40212 Düsseldorf
Telefon: +49 (0) 211 5 80 80 70
Telefax: +49 (0) 211 5 80 80 711
E-Mail: info@12-18.com

Lawfulness
The processing of this data is lawful on the basis of your consent given (Article 6 (1) a) GDPR). You may withdraw this consent at any time. Withdrawal of consent does not affect the lawfulness of previous processing.

Storage period
We will store the data held by us for the purpose of sending the newsletter until you are unsubscribed from the newsletter and will erase such data from our servers and from MailEon servers as soon as the newsletter order has been cancelled. Data which are stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected.
More data privacy information is available from MailEon at: https://www.rapidmail.de/datensicherheit.

7. Plugins and tools


YOUTUBE
Our website uses plug-ins from the YouTube site which is operated by Google. The websites are operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
When you visit one of our webpages which contains a YouTube plug-in, a connection is established to YouTube servers. In this way information about which of our web pages you have visited is passed on to the YouTube server.
If you are logged into your YouTube account, you allow YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account in advance.
We use YouTube in the interest of providing an interesting online website presentation. This is a legitimate interest within the meaning of Article 6 (1) f) GDPR.
More information on what happens to user data can be found in the YouTube data privacy policy at: https://www.google.de/intl/de/policies/privacy.

VIMEO
Our website uses plug-ins from the Vimeo video-sharing website. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.
When you visit one of our webpages which contains a Vimeo plug-in, a connection is established to Vimeo servers. In this way information about which of our web pages you have visited is passed on to the Vimeo server. Vimeo also receives your IP address. This also happens even if you are not logged in to Vimeo or do not have a Vimeo account. The information collected by Vimeo is sent to Vimeo servers in the USA.
If you are logged into your Vimeo account, you allow Vimeo to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your Vimeo account in advance.
More information on what happens to user data can be found in the Vimeo data privacy policy at: https://vimeo.com/privacy.

GOOGLE WEB FONTS
This website uses Web Fonts provided by Google for the purposes of uniform presentation. Whenever you access a page, your browser loads the required web fonts in your browser cache in order to display texts and fonts correctly.
In order to do this, the browser you are using must make a connection to Google servers. In this way Google receives information that our website has been accessed from your IP address. We use Google Web Fonts in the interest of providing an interesting online website presentation. This is a legitimate interest within the meaning of Article 6 (1) f) GDPR.
If your browser does not support Web Fonts, your computer will use a standard font.
More information about Google Web Fonts is available at https://developers.google.com/fonts/faq and in the Google data privacy policy: https://www.google.com/policies/privacy/.

GOOGLE MAPS
This website uses an API, the map service of Google Maps from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Your IP address must be stored in order to use the Google Maps function. This information is usually sent to and stored on a Google server in the USA. The provider of this website has no influence on this data transmission.
Google Maps are used in order to present our online offers in an interesting way and to make it easier to find the locations given on our website. This is a legitimate interest within the meaning of Article 6 (1) f) GDPR.
More information on what happens to user data can be found in the Google data privacy policy at: https://www.google.de/intl/de/policies/privacy/.


End of the Data Privacy Policy

NOTE ON THIS DATA PRIVACY POLICY
The primary objective of the European General Data Protection Regulation is to inform data subjects – i.e. you – about the precise extent to which data is stored and processed and to give you easily understandable information about all the rights which you acquire as a result. This is why the above policy statement is so long and precise. However, if you do have any other questions about any of the matters addressed here, you may contact the data protection officer referred to above at any time.

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