Privacy Policy

Florio Golf Ltd. (“Florio”, “we”, “us”, “our”) operates floriogolf.org. This policy explains what personal data we collect through the website, how we use it, who we share it with, and the rights you have.

For the purposes of UK data protection law, Florio Golf Ltd. is the data controller for the personal data covered by this policy.

Registered office: 24 Cherry Orchard, Chestfield, Whitstable, England, CT5 3NH
Company number: 16546881
Data protection contact: danny@floriogolf.org

1. What data we collect

When you contact us

• Your name
• Your email address
• The subject of your enquiry
• The content of your message

When you apply to join the Florio Collective

• Your first name and last name
• Your email address
• Your location, if you choose to provide it
• Your connection to golf
• Social links or website links, if you choose to provide them
• Your answers about why you want to join and how you think you could help
• Anything else you choose to include in the application

When you enquire about the Club Partnership Programme

• Your name
• Your email address
• Your club name
• Your role at the club, where relevant
• Your phone number, if you choose to provide it
• Your question, notes, or club suggestion

When you sign up for emails or updates

• Your email address
• Your name, where the form asks for it and you choose to provide it

Automatically when you visit our website

• IP address and basic request information, such as date, time, browser, and device type
• Pages visited, referral information, and broad usage patterns when analytics cookies are accepted
• Your cookie choice, stored in your browser so we can remember whether you accepted or rejected analytics cookies
• Form security information, including IP address and email address, used to limit spam and abuse

Special category data

Florio works in mental health, so there is a chance someone may choose to include sensitive information in a free-text message or application. We do not ask you to send health information, and you should avoid including anything sensitive unless it is needed for your enquiry. If you do send sensitive information, we will use it only where needed to handle your enquiry, application, or any safeguarding concern. We do not use it to make automated decisions or to profile you.

Access to sensitive information is limited to relevant Florio staff and, where necessary, responsible safeguarding staff.

2. How and why we use your data

To respond to enquiries

Legal basis: legitimate interests. We use your contact details and message so we can reply, keep a sensible record of the conversation, and follow up where needed.

To review Collective applications

Legal basis: legitimate interests. We use your application information to understand who you are, consider whether the Collective is the right fit, and contact you about the outcome.

To manage club enquiries and sign-ups

Legal basis: legitimate interests. We use club enquiry details to answer questions, arrange follow-up conversations, review club suggestions, and help clubs get started with Florio.

To send newsletters and updates

Legal basis: consent. Where you sign up for Florio emails, we use your email address to send the updates you asked for. You can unsubscribe at any time using the unsubscribe link in the email, or by emailing us at danny@floriogolf.org. We use Brevo to manage newsletter sign-ups, send email updates, and record unsubscribes.

We rely on explicit opt-in consent for newsletters and marketing-style updates. We do not rely on the PECR soft opt-in for fundraising, campaigning, or general Florio updates.

Website analytics

Legal basis: consent. We use Google Analytics to understand how visitors use the website, including which pages are popular, how people move through the site, and where we can improve. We only load Google Analytics after you accept analytics cookies. You can manage your cookie choice at any time through our Cookie Policy.

Security, spam prevention, and legal compliance

Legal basis: legitimate interests and legal obligation. We use basic technical information to protect the site, prevent spam, enforce rate limits, and respond to lawful requests from regulators or public authorities.

3. How we collect data

We collect data directly from you when you fill in a form, send us a message, or sign up for updates. We collect limited technical data automatically when your browser connects to the site. We collect analytics data only after you accept analytics cookies.

Some content and services are provided through third-party tools, such as website hosting, email delivery, analytics, content management, and media hosting. Those services may receive limited technical information when they help us deliver the site.

4. Who we share your data with

We do not sell your personal data. We do not share it with third parties for their own marketing. We use a small number of service providers to run the website and handle enquiries:

• Vercel: to host and serve the website
• Resend: to deliver contact, Collective, and club enquiry emails to the Florio inbox
• Google: to receive and store enquiry emails in the Florio inbox
• Google Analytics and Google Tag Manager: to measure website use after analytics consent
• Sanity: to provide content management and media delivery where the CMS is enabled
• Brevo: to manage email sign-ups, newsletters, and unsubscribe records

Where service providers process personal data for us, they do so under their applicable data processing terms or another appropriate contract.

We may also disclose your data to legal or regulatory authorities if required by law, court order, or another lawful request.

5. International data transfers

Some service providers may process personal data outside the UK or European Economic Area (EEA), including in the United States. Where a restricted transfer takes place, Florio should rely on safeguards recognised under UK data protection law, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU-US Data Privacy Framework where it applies.

You can ask us for more information about international transfer safeguards by emailing danny@floriogolf.org.

6. How long we keep your data

We keep personal data only for as long as we need it for the purpose we collected it, unless we need to keep it longer for legal, accounting, security, or dispute-resolution reasons. Our current retention schedule is:

• Contact enquiries: up to 2 years
• Collective applications: up to 2 years
• Club enquiries and sign-ups: up to 2 years
• Newsletter subscribers: until you unsubscribe, then retained only as needed to record and respect your unsubscribe request
• Analytics data: 14 months
• Security and rate-limit records:the website's own rate-limit records are temporary and held in server memory. Vercel runtime logs are retained for up to 1 hour on Vercel's free personal plan.

7. Your rights

Under UK data protection law, you have the following rights in relation to your personal data:

• Right to access: request a copy of the personal data we hold about you
• Right to rectification: ask us to correct inaccurate or incomplete data
• Right to erasure: ask us to delete your data in certain circumstances (“right to be forgotten”)
• Right to restrict processing: ask us to limit how we use your data while a dispute is resolved
• Right to data portability: request your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interests or to direct marketing
• Right to withdraw consent: where processing is based on consent, you can withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.

These rights are not absolute and may depend on the circumstances. To exercise any of them, email us at danny@floriogolf.org. We will respond without undue delay and, in any event, within one month. We may need to verify your identity before processing your request.

If you are not satisfied with how we handle your data or respond to a request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

8. Cookies and local storage

We use cookies and similar technologies on the website. Google Analytics only loads after you accept analytics cookies. We also store your cookie choice in your browser so we do not have to ask on every visit.

For more details of analytics cookies and how to manage your choice, see our Cookie Policy.

9. Children's privacy

The website is not specifically directed at children, but junior golfers may visit it. We do not run child-specific accounts, advertising profiles, or behavioural advertising on the website. We do not knowingly collect personal data from children under 13 without consent from a parent or guardian. If you believe a child has provided personal data to us, please contact danny@floriogolf.org and we will deal with it promptly.

Because junior golfers may access the site, we keep website data collection limited, avoid behavioural advertising, and consider children's privacy when adding new forms, features, or tracking tools.

10. Security

We take appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, and unlawful disclosure. The website uses HTTPS encryption, trusted-origin checks, body-size limits, honeypot fields, and rate limits on connected forms.

No system is completely secure. If you have concerns about the security of your data, please contact us at danny@floriogolf.org.

11. External links and embedded content

Our website links to external sites, including crisis support organisations such as Samaritans, CALM, and Shout. It also embeds some images or content served by third parties. Those third parties may process information such as your IP address when your browser loads their content or when you click through to their site. Their privacy policies apply to their services.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will update the “last updated” date at the top of the page. If a change materially affects how we use your personal data, we will take reasonable steps to draw it to your attention and, where required, ask for fresh consent.

13. Contact us

If you have any questions about this Privacy Policy or how we handle your data:

Florio Golf Ltd.
24 Cherry Orchard, Chestfield, Whitstable, England, CT5 3NH
danny@floriogolf.org