Five Iron Golf - Privacy Note

1. Who We Are

This website (the “Site”) is operated by Lucell Holding UK Ltd (company number 16119382), with registered office at 37 Leman Street, 907 Cashmere House, London E1 8PU (“we”, “us”, “our”). You can contact us using the details provided in the Contact section of our website. The data controller responsible for your personal data is the entity with which you contract as a customer, member, or membership applicant. If you use the Five Iron App, Five Iron App LLC is the data controller and can be contacted at [email protected].

2. What Is This Privacy Policy For?

This Privacy Policy explains how we collect, use, and process personal data when you use this Site or apply for, hold, or inquire about a membership or services with us. It describes what personal data we collect, why we collect it, how it is used, the lawful bases on which it is processed, and your rights under applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”). “Personal data” means any information that relates to an identified or identifiable individual. By using our Site or submitting your personal data, you are deemed to accept this Privacy Policy. Please read it carefully.

3. Personal Data We Collect

We may collect the following categories of personal data:

Membership Applications

When you submit a membership application (online or in person) or register through the Site, we collect personal details such as your name, address, email address, business contact details, gender, date of birth, country, photograph, employment information, and any other information you choose to provide. We also collect debit or credit card and bank account information provided to our payment service providers.

Reservation Information

We collect guest information in connection with reservations, including bay bookings, such as names, email addresses, and billing and payment details. Reservation-related personal data is processed in accordance with the privacy policy presented at the time of booking.

Site and Digital Channels

We collect information regarding your use of the Site and third-party digital channels, including how you interact with content, videos, the Five Iron App, and Five Iron websites. We may infer preferences to personalize content and communications.

Location Information

With your consent, we may use GPS technology or similar tools to determine your location. Location services can be enabled or disabled through your device settings.

Capacity Planning and Compliance

We collect visit and attendance information for capacity planning and compliance with governmental guidelines, regulations, and mandates.

Other Information

We collect personal data you choose to provide when communicating with us, participating in surveys, interacting with this Site or related websites, or visiting our clubs or premises, and may combine this with third-party reservation data.

4. Automatically Collected Personal Data

When you visit the Site, log data such as your IP address, browser type and settings, and date and time of access are automatically collected. We use cookies and similar technologies to enhance site usability and functionality. Further information is available in our Cookie Policy.

5. How We Use Your Personal Data

We use personal data to process and administer memberships, manage bookings and payments, provide customer service, personalize content and communications, conduct analytics, comply with legal obligations, and protect our operations and rights. Where processing is based on legitimate interests, we balance those interests against your rights and freedoms. You may object to such processing at any time.

6. Disclosure of Your Information

We may share personal data with service providers acting on our instructions, third parties involved in corporate transactions, and authorities where required by law or necessary to protect rights and safety.

7. Payment Information

Payments are processed by third-party providers using industry-standard security measures. Payment data may be retained in accordance with applicable law unless you opt out.

8. Personal Data Transfers

Personal data may be transferred to and stored in countries outside the UK or EEA, including the United States. Appropriate safeguards, such as standard contractual clauses, are used where required.

9. Security

You are responsible for safeguarding your login details. Although we implement reasonable security measures, no electronic transmission is completely secure.

10. Personal Data Retention

Personal data is retained only for as long as necessary for the purposes described or as required by law. Membership records are generally retained for six years after termination.

11. Your Data Protection Rights

Subject to applicable law, you have rights to access, correct, delete, restrict, port, and object to processing of your personal data, and to withdraw consent. You also have the right to lodge a complaint with the UK Information Commissioner’s Office or another competent data protection authority.