Privacy Policy &
Terms of Service

Section 1

Privacy Policy for Nchanga Golf Club

1. Introduction

This Privacy Policy outlines how Nchanga Golf Club ("the Club", "we", "us", or "our") collects, uses, maintains, and discloses information collected from users ("User", "you", or "your") of the Nchanga Golf Club Website ("Website"). This policy applies to the Website and all products and services offered by Nchanga Golf Club. We are committed to protecting your privacy and ensuring the security of your personal information in compliance with the Zambia Data Protection Act, 2021, General Data Protection Regulation (GDPR) principles, and UK GDPR best practices.

2. Definitions

Personal Data: Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Sensitive Personal Data: Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data Subject: The individual whose personal data is being processed.

Data Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Nchanga Golf Club is the Data Controller for the purposes of this policy.

Data Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Website: The official online presence of Nchanga Golf Club, accessible at https://nchangagolfclub.golf.

3. Scope

This Privacy Policy applies to all personal data collected and processed by Nchanga Golf Club through its Website, including data collected during event registrations, membership applications, newsletter subscriptions, tee time bookings, corporate golf day bookings, wedding and private event bookings, conference facility reservations, restaurant reservations, accommodation bookings, online payments, and any future features such as a secure member portal, online competition registration, handicap tracking, and merchandise store. It also covers data collected through direct interactions, third-party sources, and automatically collected technical information.

4. Information We Collect

4.1. Personal Information

Contact Information: Name, email address, postal address, phone number.

Identity Information: Date of birth, nationality, gender, identification document details (where required for specific services or legal compliance).

Payment Information: Credit/debit card details, bank account information (processed securely via third-party payment gateways, we do not store full payment card details).

Membership Information: Membership category, membership number, joining date, membership status, handicap data.

Event Registration Data: Details related to event participation, dietary requirements, guest information.

Booking Information: Details related to tee time bookings, corporate golf days, weddings, private events, conference facilities, restaurant reservations, and accommodation bookings.

4.2. Technical Information

Cookies: Information collected through cookies and similar tracking technologies (see Section 13).

Analytics: Data on how Users interact with our Website, including pages visited, time spent on pages, and click patterns.

Device Information: Type of device, operating system, unique device identifiers.

IP Addresses: Internet Protocol addresses.

Browser Data: Browser type and version, language settings.

Marketing Preferences: Your preferences in receiving marketing communications from us and our third parties.

Photographs and Media: Images and videos taken at Club events, tournaments, or on Club premises (with appropriate consent or legitimate interest).

CCTV: Where applicable, CCTV footage for security and safety purposes on Club premises.

4.3. Children's Privacy

Our Website is not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us.

4.4. Sensitive Information

We generally do not collect sensitive personal data unless it is necessary for a specific purpose (e.g., dietary requirements for events, health information for accessibility needs) and with your explicit consent. Where sensitive personal data is collected, it will be processed with extra care and in strict compliance with applicable data protection laws.

5. How Information Is Collected

We collect information in the following ways:

• Automatically Collected Data: When you visit our Website, certain information is automatically collected through cookies, web beacons, and other tracking technologies.
• Forms: Information you provide when filling out forms on our Website, such as membership applications, newsletter signups, contact forms, competition entries, booking forms (tee times, events, corporate days, restaurant, accommodation), and payment forms.
• Third-Party Sources: We may receive information about you from third-party service providers (e.g., payment gateways, event management platforms) when you interact with them in connection with our services.

6. Purpose of Data Collection

We collect and process your personal data for the following purposes:

• Marketing Communications: To send you newsletters, promotional offers, and updates about the Club's activities, events, and services, where you have opted in to receive such communications.
• Customer Support: To respond to your inquiries, provide assistance, and resolve issues.
• Website Improvements: To analyse Website usage, identify trends, and improve the functionality and user experience of our Website.
• Security: To maintain the security and integrity of our Website and services, and to prevent fraud.
• Fraud Prevention: To detect and prevent fraudulent activities.
• Event Administration: To manage your registration and participation in events, tournaments, and competitions.
• Membership Administration: To process membership applications, manage your membership, and provide member-only services.
• Analytics: To perform statistical analysis and generate insights into user behaviour and preferences.
• Legal Compliance: To comply with legal obligations, regulatory requirements, and lawful requests from public authorities.

7. Legal Basis for Processing

We will only process your personal data when we have a lawful basis to do so. The legal bases we rely on include:

• Consent: Where you have given explicit consent for the processing of your personal data for one or more specific purposes.
• Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.
• Vital Interests: Where processing is necessary to protect your vital interests or those of another natural person.
• Public Interest: Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
• Legitimate Interests: Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

8. Data Sharing

We may share your personal data with the following categories of recipients:

• Third-Party Service Providers: Payment gateways for secure processing of online payments, email services for sending newsletters and marketing communications, hosting providers for hosting our Website and storing data, event management platforms for managing event registrations, and analytics providers for Website usage analysis.
• Government Authorities: Where legally required, we may disclose your information to government authorities, regulators, or law enforcement agencies.
• Legal Advisors: Our legal counsel for legal advice and compliance.
• Auditors: External auditors for compliance and financial audits.

We ensure that all third parties with whom we share personal data are contractually obligated to protect your data and process it only for the purposes for which it was shared, and in accordance with applicable data protection laws.

9. Data Storage

Your personal data will be stored on secure servers located within Zambia. In accordance with the Zambia Data Protection Act, 2021, personal data must be processed and stored on a server or data centre located in the Republic of Zambia.

10. International Transfers

In limited circumstances, and only with your explicit consent, personal data other than sensitive personal data may be transferred outside the Republic of Zambia where: the transfer is made subject to standard contracts or intragroup schemes that have been approved by the Data Protection Commissioner; or the Minister has prescribed that transfers outside the Republic are permissible; or the Data Protection Commissioner approves a particular transfer or set of transfers as permissible due to a situation of necessity. Sensitive personal data will not be transferred outside Zambia.

11. Security Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include: encryption of data in transit and at rest where appropriate, Secure Sockets Layer (SSL) technology to encrypt data transmitted through our Website, access controls restricting access to authorised personnel only, strong password policies and multi-factor authentication where feasible, regular security audits, and internal data protection policies and procedures.

12. Data Retention

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

13. Cookie Policy

Our Website uses cookies to enhance User experience. Cookies are small text files placed on your device to collect standard Internet log information and visitor behaviour information.

13.1. Types of Cookies We Use

Essential Cookies: Necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

Analytics Cookies: Allow us to count visits and traffic sources so we can measure and improve the performance of our Website.

Marketing Cookies: May be set through our Website by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

Preference Cookies: Enable our Website to remember information that changes the way the Website behaves or looks, like your preferred language or region.

13.2. Cookie Management

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by adjusting your browser settings. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

14. User Rights

As a data subject, you have the following rights concerning your personal data, in accordance with the Zambia Data Protection Act, 2021, and GDPR principles:

• Right of Access: You have the right to request copies of your personal data.
• Right to Rectification: You have the right to request that we correct any information you believe is inaccurate.
• Right to Erasure (Right to be Forgotten): You have the right to request that we erase your personal data, under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.
• Data Portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

To exercise any of these rights, please contact us. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.

15. Complaints Process

If you have any concerns about our use of your personal data, you can make a complaint to us. You also have the right to lodge a complaint with the Data Protection Commissioner in Zambia if you believe your data protection rights have been violated.

16. Third-Party Links, Embedded Content, and Social Media

Our Website may contain links to third-party websites, embedded content from other sites (e.g., videos, images), and social media features. These third-party sites and services have their own privacy policies, and we do not accept any responsibility or liability for their practices. We encourage you to review the privacy policies of any third-party sites you visit.

17. Limitation of Liability

Nchanga Golf Club will not be liable for any damages arising from the use or inability to use the materials on its Website, even if Nchanga Golf Club or an authorised representative has been notified orally or in writing of the possibility of such damage. This limitation of liability applies to the fullest extent permitted by law.

18. Changes to Privacy Policy

Nchanga Golf Club has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.

19. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Zambia.

20. Contact Details

If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, please contact us:

Nchanga Golf Club, Fern Avenue, Chingola, Zambia
Email: info@nchangagolfclub.com
Phone: +260 760 601 207

21. Effective Date

This Privacy Policy is effective as of 23 July 2026.

22. Last Updated Date

This Privacy Policy was last updated on 23 July 2026.

References: [1] Zambia Data Protection Act, 2021 — [2] Electronic Communications and Transactions Act, 2021 — [3] UK GDPR best practices

Section 3

Supplementary Legal Documentation

1. Legal Compliance Checklist

The following checklist ensures that the Nchanga Golf Club website meets the necessary legal and regulatory requirements, particularly concerning data protection and electronic transactions in Zambia.

2. Recommendations for Legal Review

Before publishing the Privacy Policy and Terms of Service on the official website, it is strongly recommended that Nchanga Golf Club undertakes the following steps:

• Independent Legal Counsel Review: Have the drafted documents reviewed by a qualified legal professional practicing in Zambia.
• Data Protection Officer (DPO) Appointment: Consider appointing a Data Protection Officer as may be required under the Data Protection Act, 2021.
• Internal Policy Alignment: Ensure that the Club's internal data handling practices align with the statements made in the Privacy Policy.
• Cookie Banner Implementation: Implement a compliant cookie consent banner on the website.

3. Additional Policies to Consider

• Dedicated Cookie Policy: A separate, detailed Cookie Policy for transparency.
• Accessibility Statement: Commitment to making the website accessible to all users.
• Refund and Cancellation Policy: Clear, standalone policy for memberships, events, and bookings.
• Event Terms and Conditions: Specific terms governing participation in tournaments and events.
• Code of Conduct: Expected behaviour of members and guests.
• Safeguarding Policy: Particularly important for junior golf programmes.

References: [1] Zambia Data Protection Act, 2021 — [2] Electronic Communications and Transactions Act, 2021 — [3] Understanding Zambia's Data Protection Act (DPA)