Last updated: 14.02.2023

Data privacy instructions

We, METZLER : VATER travel GmbH (hereinafter “we” or “MVT”), are pleased that you are interested in the Porsche Circle trips (hereinafter “trips”). The Porsche Golf Circle is a worldwide, online and event-based community that connects Porsche fans and golf enthusiasts the world over. Porsche Golf Circle trips are intended exclusively for verified Porsche owners and their companions. MVT is the exclusive tour operator of Porsche Golf Circle trips. When you participate in Porsche Golf Circle trips, we take the protection of your personal data very seriously. We only process your personal data within the scope of the legal provisions of data protection law, in particular the General Data Protection Regulation (hereinafter “GDPR”). In this Privacy Policy, we inform you about how we process your personal data along with your rights as a data subject within the scope of the booking and the implementation of the trip. Please consult the respective privacy policy for information on how personal data is processed in other areas of the Porsche Golf Circle.

 
1. CONTROLLER AND PROTECTION OFFICER

The Porsche Golf Circle trips are provided by METZLER : VATER travel GmbH as the responsible tour operator. The following entity is responsible for processing data within the scope of travel bookings and their implementation, as defined by the laws on data protection:

METZLER : VATER travel GmbH
Balanstraße 69b
81541 München.

Please do not hesitate to contact us if you have questions or suggestions relating to data protection. You can contact our data protection officers at the following address:


Data Protection Officer

datenschutz süd GmbH
Wörthstraße 15
97082 Würzburg
Kontakt: office@datenschutz-sued.de


2. SUBJECT MATTER OF DATA PROTECTION

The subject matter of data protection is the protection of personal data. This is all the information that relates to an identified or identifiable natural person (known as the data subject). This includes information such as your name, postal address, email address or telephone number as well as other information that originates during booking and participation in the trips, or from use of this website (in particular, details about the start, end, and scope of use, and the communication of your IP address).


3. PURPOSE AND LEGAL BASES OF DATA PROCESSING

A summary of the purposes and legal bases of data processing within the scope of Porsche Golf Circle trips can be found below. We always process personal data in line with legal requirements, even if a different legal basis than the one set out below might be relevant in individual cases.

You may be required by law or contract to provide personal data or this may be needed in order to enter into a contract. We will inform you separately if you are required to provide personal data and what the possible consequences of not doing so would be (e.g. loss of claims or being notified by us that the requested service will not be rendered without providing certain information).

In addition, processing may be permitted on the basis of legitimate interests of MVT or third parties. You can also consent to individual processing operations on a voluntary basis.

Participation in Porsche Golf Circle trips is intended exclusively for verified Porsche customers, which is why you need to enter the VIN (vehicle identification number) of a vehicle that you own in order to register. This information will be verified together with Porsche. 


3.1.    Fulfilment of contractual and pre-contractual obligations

We process your personal data if this is necessary to perform a contract to which you are a party, or to perform pre-contractual measures that take place at your request. We process data on the basis of Art. 6 (1) (b) GDPR. The purposes of the processing include enabling the use of our specific products and services within the scope of Porsche Golf Circle trips. Here specifically, these comprise the following functions in particular:  


Travel bookings

This function allows you to register for a Porsche Golf Circle trip. The disclosure and processing of the data listed below is necessary for the implementation and fulfilment of the travel contract with MVT.  Your data will be deleted after the end of the event/trip and the expiry of the two-year retention period. 


For the travel booking, it is necessary to provide and process the personal data listed below as mandatory information (marked with an “*”):

  • Salutation,
  • Title,
  • First and last name,
  • Email address,
  • Your address,
  • Your mobile phone number,
  • Your date of birth,
  • Billing address
  • Confirmation of whether a travel companion will be taking part in the event.

If a travel companion takes part in the trip, the following categories of personal data are required as mandatory data from your companion for booking the trip:

  • Salutation,
  • Title,
  • First and last name,
  • Your companion’s address,
  • Your date of birth,

It is not possible to register for an event or book a trip for your companion without providing this mandatory data.

You also have the opportunity to provide further information on a voluntary basis, such as:

  • Additional details such as food intolerances, nutritional requirements or similar.
  • Your companion’s mobile phone number,
  • Your companion’s email address,
  • Your individual general comment on the event.
  • Your emergency contact and, if applicable, a different emergency contact for your companion, such as salutation, first name, last name, telephone number and mobile phone number.


Please note that this information is not immediately required for booking the trip. However, if you would like to make use of other services by providing voluntary information, we process this data in order to provide you with the services you require in this context, to carry out the associated contractual relationship with you and to enable event registration.


Verification of Porsche customers

Since a Porsche Golf Circle trip is an exclusive offer for Porsche customers, verification as a Porsche customer is mandatory for booking a trip. Verification is carried out by providing a copy of your Porsche vehicle registration document with visible information about your name or company name, vehicle type and vehicle identification number.

The copy will be requested as an upload during the booking process and/or sent to MVT by email.


Visa Support

This function enables you to send us the necessary data for support in obtaining a visa if required. This is an additional service which we are happy to offer you, but which does not necessarily have to be used. If you do not want to use this service, you must arrange to obtain any necessary visa yourself. 

If you click “yes” in the selection, you can enter the necessary data for yourself and, if necessary, your companion, in the following form fields, which are absolutely necessary in order to be able to create and send the letter of invitation you have requested. Visa support then becomes part of the travel service.

  • Passport number
  • Date and place of issue
  • Issuing authority
  • Expiry date
  • Full name as stated in passport

Please note that this information is only required to request a letter of invitation.


Golf-related information

Since this is a golf event, data on your handicap will be requested in this step in order for us to be able to organise the golf tournaments as an operator. This is also information that we need for the fulfilment of the travel contract and the organisation of the events covered by it. You will also be asked on which days you would like to play in tournaments. We also need this information to organise the tournament and to determine the number of players.

  • Handicap
  • Participation in other golf events
  • Game day
  • Results of the games
  • Home club
  • Companion's full golf-related information

Please note that this data will only be processed to carry out the specific trip or specific event and will only be transmitted to third parties if this is necessary for the organisation of the event, or if you have given us your consent to do so (see below). 


Data for further activity programmes

Since this is an activity programme, this step asks which activities you and your companion would like to take part in. Furthermore, information on the programmes offered are requested in order for us to be able to organise them as an operator.

  • Golf glove size
  • Driving license number, date of issue, issuing authority, validity
  • Weight and clothing size
  • Height
  • Shoe size
  • Helmet size

Please note that this data will only be processed to carry out the specific trip or specific event, and will only be transmitted to third parties if this is necessary for the organisation of the event. 


Travel dates

This function allows you to receive support for organising your travel to and from a booked event and during an event.

  • Hotel room selection
  • Arrival date
  • Departure date


Payment for the events

The possibility of paying for the event for which you have registered by credit card through the external service Payone. Payone is operated by Payone GmbH, Lyoner Straße 9, 90528 Frankfurt am Main, Germany. We do not receive any information about the personal data (payment data) provided by you on the Payone payment page. We only receive the information that the payment has been made. The privacy notice of Payone applies in this case.


3.2.    Fulfilment of legal obligations  

We process your personal data to comply with legal obligations to which we are subject. We process data on the basis of Art. 6 (1) (c) GDPR. The obligations may arise, for example, under commercial, tax, money laundering, financial or criminal law. The purposes of the processing depend on the respective legal obligation; as a rule, processing serves the purpose of fulfilling state monitoring and information obligations.


3.3.    Safeguarding of legitimate interests

We also process your personal data to protect our legitimate interests or those of third parties, unless your interests requiring the protection of your personal data override these interests. We process data on the basis of Art. 6 (1) (f) GDPR. Processing of data to protect legitimate interests is carried out for the following purposes or to protect the following interests:

  • The further development of products, services, and support offers of MVT as well as other measures to control business transactions and processes;
  • Handling non-contractual enquiries and matters;
  • Ensuring lawful conduct, the prevention of and protection against infringements (in particular criminal offences), the assertion of and defence against legal claims, internal and external compliance measures;
  • Ensuring the availability, operation and security of technical systems as well as technical data management;
  • Answering and evaluating contact requests and feedback.


On-site support

On site, you will be supervised by competent contact persons for trips and events. Depending on the trip and event, the on-site contacts organise, for example, arrival, check-in, distribution of give-aways, check-out, shuttle coordination, arrival and departure planning, supervision of daytime and evening events, implementation / coordination of golfing activities and the further supporting programme. These are usually employees of MVT or PAG. For optimal on-site support, we therefore transmit the following travel data to PAG, provided that they are responsible for on-site support of participants and are therefore involved in the fulfilment of the travel services (the list of data types refers to all travel participants):


  • Contact details: Salutation, title, first name, last name, email address (main participant only), mobile phone number, street, building number (main participant only), postal code (main participant only), city (main participant only), country
  • Date of birth (main participant only)
  • Golf-related information: Handicap, attendance at other golf events, game day, results of games, home club, golf glove size, 
  • Data for activity programme: Driving license number, date of issue, issuing authority, validity, weight and clothing size, height, shoe size, helmet size
  • Travel dates: Arrival date, departure date

The transmission is based on the legitimate interests of MVT and PAG to provide optimal customer care and for the organisation of the events on site.


3.4.    Consent

We also process your personal data on the basis of a respective consent. We process data on the basis of Art. 6 (1) (a) GDPR. If you give your consent, this is always for a specific purpose; in each case, the purposes of processing derive from the content of your declaration of consent. You may revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent before revocation.

Consent is obtained individually and specifically. A separate declaration on your part is always required. We process your data on the basis of individual consent for the following purposes:


Creating an account

The following mandatory information, marked with “*”, is requested when registering and creating your account:

  • First name, last name,*
  • Email address,*
  • Your personal password.

A personal account is not required to book the Porsche Golf Circle trips. The creation of an account enables you to view your future and past trips or to book new trips.

After entering the above details, you will receive an email with a link to confirm your registration. Please click on this link to complete your registration and create your user profile. We process the data collected in order to add your profile and to identify you each time you log in. Depending on the service and function for which you are registering, further data may be collected and subsequently linked to your profile data.


Creation, duplication and publication of photographs and video recordings

As a rule, photos and, in individual cases, video recordings are made on trips and events. For this purpose, we always obtain your voluntary consent in writing in advance of the respective events and trips and inform you of the purposes for which we or PAG would like to use the photo and video recording. 


Transmission of personal data to PAG for the purposes of the Porsche Golf Circle Community 

If you consent, we will transmit the data to PAG on the basis of this consent for the purpose of supporting and optimising the Porsche Golf Circle. Your data will only be used by PAG for the purposes of the Porsche Golf Circle Community, in particular for the following purposes:

  • Maintaining the community profile (e.g., distribution of community badges)
  • Recording the result lists / rankings
  • Documentation of event or travel participation
  • Marketing activities for the Porsche Golf Circle (information on the Community, news, events and trips)
  • Internal management reporting 
  • Evaluation of event participation

You will find more details in the declaration of consent.


3.5.    Change of purpose

Where we process your personal data for a purpose other than that for which the data was collected, going beyond the respective consent or a compelling legal basis, we will take into account, in accordance with Article 6 (4) of the GDPR, the compatibility of the original purpose and the purpose now pursued, the nature of the personal data, the possible consequences of further processing for you and the safeguards for the protection of the personal data.


3.6.    Profiling

We do not carry out automated decision-making or profiling in accordance with Art. 22 GDPR. Profiling is only done to protect our legitimate interests as described above.


4. DEVICE ACCESS PERMISSIONS

Some features of our Online Offer require authorisation to access your device (e.g. access to location data). Granting authorisation is voluntary. However, if you want to use these features, you must grant the corresponding authorisations; otherwise, you will not be able to use these features. The authorisations remain active until you reset them in your end device by deactivating the respective setting.


5. INTEGRATED THIRD-PARTY SERVICES

If we integrate other providers within the scope of our services in order to provide you with certain content or functions, and we process personal data in the process, this is done on the basis of Art. 6 (1b) and (f) GDPR. This is because data then needs to be processed in order to implement the functions you have selected or in order to safeguard our legitimate interest in having an optimum range of functions in the Online Offer. Where cookies may be used within the scope of these third-party services, the explanations under Section 5 apply. With regard to third-party services, please also inform yourself about the privacy policy of the respective provider.

Services of other providers, which we include or to which we refer, are provided by the respective third parties. Third-party services also generally include offers from other Porsche AG Group companies and from Porsche Centres. We generally have no influence over the content and function of third-party services and are not responsible for the processing of your personal data by their providers, unless the third-party services are designed entirely on our behalf and then integrated by us under our own responsibility. If the integration of a third-party service leads to us establishing joint processes with its provider, we will stipulate with this provider in an agreement on joint responsibility pursuant to Art. 26 GDPR how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. If cookies are also to be set on the basis of your consent, you will receive further information on the responsibility for setting these cookies or any associated third-party services in the corresponding consent management area.

Unless stated otherwise, profiles on social media are only included in our Online Offer as a link to the corresponding third-party services. After clicking on the embedded text/image link, you will be redirected to the offer of the respective social media provider. After being redirected, personal data may be collected directly by the third-party provider.  If you are logged into your user account of the respective social media provider during this time, the provider may be able to assign the collected information of the specific visit to your personal user account. If you interact via a “Share” button of the respective social media provider, this information may be stored in the personal user account and may also be published. If you would like to prevent the collected information from being directly assigned to your user account, you must log out before clicking on the integrated text/image link.


6. RECIPIENTS OF PERSONAL DATA

Within our company, the only people who have access to your personal data are those who need it for the purposes referred to above in each case. We will only pass on your personal data to external recipients if we are legally permitted to do so or if we have your consent. Please see below for an overview of the corresponding recipients:  

  • Data processor: Group companies or external service providers, for example in the areas of technical infrastructure and maintenance, which are carefully selected and reviewed. Processors may only use the data in accordance with our instructions.
  • Public bodies: Authorities and government institutions, such as tax authorities, public prosecutors or courts to which we (must) transfer personal data, for example for legal reasons or to safeguard legitimate interests.
  • Private bodies: Group companies as well as other companies that support us in particular in the context of travel and travel implementation (airlines / hotels, etc.). 

Zudem und wie oben bereits im Detail erläutert, werden die Events und Reisen in Kooperation mit der PAG und exklusiv im Rahmen des Porsche Golf Circle ausgeführt. Aus diesem Grund empfängt die PAG zu Zwecken der Betreuung der Porsche Golf Circle Mitglieder vor Ort, Daten von Reiseteilnehmer von MVT (vgl. hierzu oben die Ziffern 3.1 und 3.3 mit weiteren Details).

In addition, and as explained in detail above, the events and trips are carried out in cooperation with PAG and exclusively as part of the Porsche Golf Circle. For this reason, PAG receives the data of tour participants from MVT for the purpose of supervising Porsche Golf Circle members on site (cf. Sections 3.1 and 3.3 above with further details).

For other purposes, we only transmit your data to PAG if you have given us your consent voluntarily. 

In order to process the payment, the payment service provider Payone GmbH, Lyoner Straße 9, 90528 Frankfurt am Main, Germany, also receives the payment data required for billing (cf. Section 3.1). 


7. DATA PROCESSING IN THIRD COUNTRIES

If data is transferred to bodies whose registered office or place of data processing is not located in a member state of the European Union, another signatory to the Agreement on the European Economic Area or a state for which an adequate level of data protection has been established by means of a decision of the European Commission, we will ensure prior to the transfer that the transfer of data is either covered by an act of legal authorisation, guarantees exist for an adequate level of data protection with regard to the transfer of data (e.g. by means of agreeing contractual warranties, officially recognised regulations or binding internal data protection regulations at the recipient) or you have given your consent to the data transfer.

Where the transfer of data is based on Article 46, 47 or 49 (1), subparagraph 2, GDPR, you may obtain from us a copy of the warranties in place to ensure an adequate level of data protection in relation to the transfer of data or an indication of the availability of a copy of the warranties. To obtain these, please contact the address specified in Section 1.


8. DURATION OF STORAGE, DELETION

We store your personal data, if permitted by law, only as long as necessary for the achievement of the pursued purposes or as long as you have not revoked the consent. If you withdraw your consent to us processing your personal data, we will delete it unless relevant legal provisions stipulate that it can be processed further. We will also delete your personal data if we are obliged to do so for other legal reasons. In line with these general principles, we will usually delete your personal data immediately

  • after the legal grounds cease to apply and provided that no other legal grounds apply (e.g. commercial law and tax law retention periods). If the latter is the case, we will delete the data once the other legal grounds cease to apply;
  • if we no longer need your personal data for the purpose being pursued by us and no other legal grounds apply (e.g. commercial law and tax law retention periods). If the latter is the case, we will delete the data once the other legal grounds cease to apply.


9. RIGHTS OF DATA SUBJECTS

Right of access: You have the right to obtain information from us about the data that we have stored about you.

Right of rectification and erasure: You have the right to demand that we rectify incorrect data and – provided the legal requirements are met – that we delete your data.

Restriction of processing: You have the right – provided the legal requirements are met – to demand that we restrict the processing of your data.

Data transferability: If you have provided us with data on the basis of a contract or your consent, you have the right, in accordance with the legal requirements, to obtain the data you have provided in a structured, standard and machine-readable format or you can demand that we transfer this data to another controller.


Revocation: You have the right to object at any time, on grounds relating to your particular situation, to our processing of your data, provided this objection is based on protecting legitimate interests. If you exercise your right to object, we will stop processing unless we can demonstrate compelling legitimate grounds for further processing that override your rights and interests.

Objection to direct marketing: If we process your personal data for the purpose of direct marketing, you have the right to object to our processing your data for this purpose at any time. If you exercise your right to object, we will stop processing for this purpose.


Revocation of consent: If you have given us your consent to the processing of your personal data, you can revoke this consent at any time with effect for the future. The lawfulness of the processing of your data remains unaffected up until the time of the withdrawal of consent.


Right to lodge a complaint with a supervisory authority: You can also submit a complaint to the competent supervisory authority if you believe that processing your data is in breach of the legislation. To do so, you can turn to the supervisory authority that is responsible for your town/city or country or to the supervisory authority that is responsible for us.


Your contact with us and exercising your rights: You can also contact us free of charge if you have any questions regarding the processing of your personal data and your rights as a data subject. Please contact datenschutz süd GmbH, office@datenschutz-sued.de or contact us by post at the address specified above in Section 1. Please ensure that it is possible for us to identify you uniquely. When revoking consent, you may alternatively choose the contact method you used when giving consent.


10. STATUS OF UPDATES TO THIS PRIVACY POLICY

Due to the further development of our website and our offers as well as changed legal or official requirements, it may become necessary to adapt this Privacy Policy. You can access and print out the current Privacy Policy at any time on this website. If we announce changes to this Privacy Policy, we will update the “Last updated” date at the top of this Privacy Policy. We also encourage you to periodically review this Privacy Policy for any changes.


The latest version of this Privacy Policy applies. As of 14/02/2023