Privacy Policy

Privacy Policy for Badgemore Park in Henley-on-Thames.

For members, guests, customers, visitors, website users and event enquiries

Last updated: July 2026

  1. Introduction

Badgemore Park is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store and share personal data about members, guests, visitors, customers, event organisers, accommodation guests, gym members, golf members, website users and other individuals who interact with Badgemore Park.

This policy applies to personal data processed in connection with our golf, gym, hospitality, accommodation, events, meetings, office rental, marketing, website and general business operations.

This policy does not apply to employees, workers, contractors or job applicants. Separate privacy notices are available for staff and recruitment.

  1. Who we are

For the purposes of data protection law, the data controller is:

Premier Golf Developments Limited trading as Badgemore Park

Company number: 03353424

Trading address: Badgemore Park, Badgemore, Henley-on-Thames, Oxfordshire, RG9 4NR

Registered office: Ground Floor, Afon House, Worthing Road, Horsham, West Sussex, RH12 1TL

ICO registration number: ZA142960

Email: BusinessDirector@badgemorepark.com

In this policy, “Badgemore Park”, “we”, “us” and “our” refer to Premier Golf Developments Limited trading as Badgemore Park.

  1. Data protection laws

We process personal data in accordance with applicable UK data protection legislation, including:

  • the UK General Data Protection Regulation;
  • the Data Protection Act 2018;
  • the Privacy and Electronic Communications Regulations 2003;
  • the Data (Use and Access) Act 2025, where applicable; and
  • any other applicable data protection or privacy legislation.
  1. The personal data we collect

Depending on how you interact with us, we may collect and use the following types of personal data.

Contact details

This may include your name, address, email address, telephone number and emergency contact details.

Membership details

This may include your membership category, start date, renewal date, membership number, payment history, handicap information, class or activity participation, booking history, preferences and relevant correspondence.

Booking and reservation details

This may include golf bookings, tee times, gym bookings, class bookings, restaurant bookings, accommodation bookings, event enquiries, wedding enquiries, meeting bookings, room hire bookings and function details.

Payment and transaction information

This may include billing details, invoices, payment history, card transaction references and details required to process payments. We do not usually store full card details ourselves where payments are processed by a third-party payment provider.

Hospitality, event and guest information

This may include guest names, event attendance, menu choices, dietary requirements, allergies, access requirements, seating plans and event-specific arrangements.

Health, fitness and safety information

This may include information you voluntarily provide in connection with gym use, personal training, fitness activities, golf lessons, accidents, incidents, medical emergencies, accessibility requirements, health and safety records, or safeguarding matters.

Some of this information may be special category data under data protection law. Where we process special category data, we will only do so where we have a lawful basis and a special category condition, such as where processing is necessary for health and safety, legal claims, substantial public interest, vital interests or where you have provided explicit consent.

CCTV, images and video

We may collect CCTV images and, where applicable, photographs or video footage taken at events, golf days, club activities, promotional activity or on-site operations.

Website and technical data

This may include IP address, browser type, device information, operating system, time zone, pages visited, referral source, website usage information, cookie data and analytics information.

Further information is set out in our Cookie Policy.

Marketing preferences

This may include your preferences for receiving marketing from us, your communication choices, opt-ins, opt-outs and unsubscribe records.

Correspondence and communication records

This may include emails, letters, enquiry forms, complaints, feedback, survey responses, telephone notes and other records of contact with us.

  1. How we collect personal data

We may collect personal data directly from you when you:

  • become a golf member, gym member or customer;
  • make an enquiry;
  • book a tee time, class, event, room, table or accommodation;
  • visit our website;
  • complete a form;
  • contact us by email, phone, social media or in person;
  • enter a competition, promotion or survey;
  • attend an event;
  • use our facilities;
  • report an accident, incident or concern;
  • subscribe to marketing communications;
  • provide details on behalf of another person.

We may also receive personal data from third parties, including:

  • booking platforms;
  • payment providers;
  • membership management systems;
  • event organisers;
  • golf or sport governing bodies;
  • hospitality and accommodation platforms;
  • professional advisers;
  • insurers;
  • emergency services;
  • local authorities or regulators;
  • business partners, where appropriate.

If you provide personal data about another person, you should ensure you have authority to do so and, where appropriate, make them aware of this Privacy Policy.

  1. How and why we use personal data

We only use personal data where we have a lawful basis to do so.

Purpose Lawful basis
Responding to enquiries Legitimate interests / steps before entering into a contract
Managing golf, gym, hospitality, accommodation and event bookings Contract / legitimate interests
Managing memberships and member accounts Contract / legitimate interests
Taking payments and maintaining financial records Contract / legal obligation
Providing services you have requested Contract
Managing events, weddings, functions and private hire Contract / legitimate interests
Managing dietary, allergy and access requirements Legitimate interests / explicit consent or substantial public interest where special category data applies
Managing gym inductions, personal training and fitness services Contract / legitimate interests / explicit consent where required
Managing accidents, incidents, medical emergencies and health and safety Legal obligation / vital interests / legitimate interests
Safeguarding children or vulnerable individuals Legal obligation / substantial public interest / legitimate interests
Managing CCTV and site security Legitimate interests / legal obligation
Sending important service messages Contract / legitimate interests
Sending marketing communications Consent / soft opt-in under PECR / legitimate interests where lawful
Running surveys, feedback requests and customer research Legitimate interests / consent where appropriate
Website administration, security and analytics Legitimate interests / consent for non-essential cookies
Managing complaints and disputes Legal obligation / legitimate interests
Establishing, exercising or defending legal claims Legitimate interests / legal obligation
Complying with tax, accounting and legal obligations Legal obligation
Business sale, restructuring or professional advice Legitimate interests / legal obligation
  1. Marketing communications

We may send you marketing communications about Badgemore Park services, events, offers, golf, gym, hospitality, accommodation and related activities.

We will only send electronic marketing to individuals where we have consent or where the soft opt-in applies under PECR. The soft opt-in may apply where you have previously purchased or enquired about similar services from us, we gave you a clear opportunity to opt out, and you have not opted out.

You can unsubscribe from marketing at any time by using the unsubscribe link in our emails or by contacting us at BusinessDirector@badgemorepark.com.

We may retain limited information on a suppression list to ensure that we do not send marketing to people who have opted out.

We will not sell your personal data to third parties for their own marketing purposes.

  1. Service communications

We may send you non-marketing service communications where necessary. These may include booking confirmations, membership updates, changes to terms, safety notices, operational updates, payment reminders, event information or important information about facilities.

Service communications are not the same as marketing communications and may still be sent even if you have opted out of marketing.

  1. CCTV

CCTV may operate at Badgemore Park for security, safety, crime prevention, incident investigation and protection of our staff, customers, members, visitors and property.

CCTV footage is normally retained for a limited period unless it is required for an investigation, insurance matter, legal claim, police request, safeguarding issue or disciplinary matter.

CCTV footage may be shared with police, insurers, legal advisers, regulators or other relevant parties where lawful and necessary.

  1. Photography and video

We may take photographs or videos at events, golf days, promotional activities or general club activities.

Where images are used for marketing and individuals are clearly identifiable, we will take reasonable steps to make people aware. In some circumstances, we may ask for consent.

If you do not wish to be photographed or filmed for marketing purposes, please tell a member of the team at the relevant event or contact us using the details in this policy.

  1. Children’s data

We may process children’s personal data where necessary for junior golf, family events, coaching, safeguarding, accommodation, hospitality or other services involving children.

Where appropriate, we will collect information from a parent or guardian. We will take additional care when processing children’s personal data and will only collect information that is necessary for the relevant purpose.

Where we use images of children for marketing, we will normally seek appropriate consent from a parent or guardian.

  1. Who we share personal data with

We may share personal data with trusted third parties where necessary and lawful. These may include:

  • IT and website providers;
  • booking and membership software providers;
  • payment processors;
  • email marketing platforms;
  • customer relationship management providers;
  • gym and golf management systems;
  • accommodation booking platforms;
  • professional advisers, including lawyers, accountants and consultants;
  • insurers and insurance brokers;
  • event suppliers and contractors;
  • catering and hospitality partners;
  • golf and sport governing bodies where relevant;
  • HR, payroll, health and safety and compliance providers, where relevant;
  • regulators, HMRC, local authorities, police or emergency services;
  • prospective buyers, investors or advisers in connection with a business sale or restructuring.

Where we use third-party processors, we require them to process personal data only in accordance with our instructions and to protect it appropriately.

  1. International transfers

Some of our suppliers or service providers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will ensure that appropriate safeguards are in place. These may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

  1. How long we keep personal data

We will not keep personal data for longer than necessary.

The retention period depends on the type of data, the reason it was collected, legal requirements and whether the data may be needed in connection with a complaint, dispute, insurance matter or legal claim.

Type of data Typical retention period
General enquiries Up to 24 months after last meaningful contact
Membership records Duration of membership plus up to 6 years
Booking and reservation records Up to 6 years
Financial and accounting records Usually 6 years from the end of the relevant financial year
Event contracts and function records Contract period plus up to 6 years
Marketing records Until opt-out or withdrawal of consent, with suppression records retained where necessary
CCTV footage Usually up to 30 days unless required for investigation or legal reasons
Accident and incident records Usually at least 3 years; longer where children, serious incidents or legal claims are involved
Complaints and disputes Up to 6 years after resolution, or longer where necessary
Website analytics data As set out in our Cookie Policy
Children’s activity records As long as necessary for safeguarding, legal, insurance or operational purposes

These periods may be adjusted where required by law, insurance, safeguarding, legal claims or operational requirements.

  1. Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, secure systems, staff training, password controls, data minimisation, supplier checks, secure payment processing and physical security measures.

No method of transmission over the internet is completely secure. However, we take reasonable steps to protect personal data and to respond appropriately to any suspected data breach.

  1. Your data protection rights

Depending on the circumstances, you may have the following rights:

  • the right to be informed about how we use your personal data;
  • the right of access to your personal data;
  • the right to request correction of inaccurate data;
  • the right to request deletion of your data;
  • the right to request restriction of processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to withdraw consent where processing is based on consent;
  • rights relating to automated decision-making and profiling.

These rights are not absolute and may be subject to legal exemptions.

To exercise your rights, please contact:

BusinessDirector@badgemorepark.com

We may need to verify your identity before responding.

  1. Complaints

If you are concerned about how we use your personal data, please contact us first so that we can investigate and respond.

We will acknowledge data protection complaints within 30 days and respond without undue delay.

You also have the right to complain to the Information Commissioner’s Office.

Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113

  1. Third-party websites

Our website may include links to third-party websites, platforms or services. We are not responsible for the privacy practices of those third parties. You should read their privacy notices before providing personal data to them.

  1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will be published on our website. Where appropriate, we may also notify you by email or another suitable method.

  1. Contact

Questions, comments and requests regarding this Privacy Policy should be sent to:

BusinessDirector@badgemorepark.com