Privacy Policy
Scarboro Golf & Country Club Ltd. (the “Club”, “we” or “us”) is committed to maintaining the confidentiality of information that has been provided to us by our Members, Participants, customers and others (referred to in this Policy as “you” or “your” as the context requires). This Privacy Policy has been prepared to confirm such commitment and to assist you in understanding the type of Personal Information (as defined below) that we may collect from you and from others, how we may use that Personal Information, to whom we may disclose it, and how we safeguard that Personal Information and your privacy. We are committed to collecting, using and disclosing Personal Information in a responsible manner, and only to the extent necessary for the services we provide. This Privacy Policy has been developed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Personal Information means information about an identifiable individual. Personal Information would include such things as a person’s name, home address and telephone number, e-mail address, age, gender, height, weight, information about the person’s health, income, activities.
The Club receives and stores information you provide to the Club. If the Club wishes to collect Personal Information from you, we will inform you before gathering the information, and will explain to you how we intend to use the information. The Personal Information that we typically collect from our Members and Participants includes contact information (name, home address, home telephone number, cell phone number and e-mail address) as well as a member’s birth date and the name of a member’s spouse and children. We may also receive information about you from other sources and add it to the Personal Information we have collected. Your contact information may be used in order to reach you to discuss the status of your membership with the Club or to inform you of Club news and activities, to respond to your requests, complete transactions that you initiate, and to meet the legal and regulatory requirements applicable to the Club. The Member’s or Participant’s name is also published in a Club Roster (with a Member’s/Participant’s category of membership) so that other Members/Participants of the Club may contact you. Such information is disclosed to other Members and Participants on our website for the same purpose.
In certain circumstances, PIPEDA provides that the Club may disclose your Personal Information without your consent. Such circumstances include: where required by law or by order of a court or tribunal; where the information is used for the purpose of collecting a debt owed to the Club; where the Personal Information is requested by a government institution to enforce any law; and in the case of an emergency that threatens the life, health, safety, or security of an individual or property of others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. In such circumstances, the Club will not disclose more information than is reasonably necessary.
The Club will not sell or trade any Personal Information that the Club collects. We will not disclose Personal Information to any external organization without your consent, unless we are required to do so by law.
SECURITY OF YOUR INFORMATION
The Club takes all reasonable steps to protect the security and confidentiality of your Personal Information. We protect the Personal Information within the Club’s custody or control with appropriate organizational, technological and physical safeguards. For example, the Club limits access to your Personal Information to only those persons who reasonably have the need to do so. [All of our staff are trained to collect, use and disclose Personal Information only as necessary to serve our Members/Participant’s, customers’ or other person’s needs and in accordance with this Privacy Policy]. Electronically, all of our computers and our computer network may only be accessed with passwords, which are updated regularly.
No system can guarantee absolute security, just as the finest lock cannot guarantee physical security. However the Club takes every reasonable precaution to assure that your data is secure.
THIRD PARTY SERVICE PROVIDERS
The Club may use other agents, contractors, or companies to perform functions and services on its behalf (Examples include delivering packages, sending postal mail and e-mail, its accountants, printers, RCGA) and such parties may have limited access to certain Personal Information that we have collected. [Some of our third party service providers may be located outside of Canada and subject to the laws of foreign jurisdictions].
ACCESSING YOUR PERSONAL INFORMATION
With limited exceptions as set forth in PIPEDA, you are always entitled to access the Personal Information that the Club has collected from you. If the Club cannot provide you with access to your Personal Information, the Club will advise you within 30 days that we are unable to do so, and as per changes to the Club’s Privacy Policy will tell you, if possible, why we cannot provide you with such access.
If you believe that any factual information contained in your Personal Information is incorrect, please advise us so that we can update our records. We will not include your Personal Information in next year’s membership roster upon receiving your request in writing for us not to do so.
USE OF OUR WEBSITE
You can visit most pages on the Club’s website without g1v1ng us any Personal Information about yourself. However, sometimes we do need Personal Information to provide services that you request. The Club only collects Personal Information that you submit voluntarily, such as when you provide your address or other contact information that you choose to provide in order that other Members and Participants of the Club may contact you. By providing us with such information, you consent to our collection and use of your Personal Information for such purposes. We will remove your Personal Information from the Club’s website upon receiving your request in writing for us to do so. [You may also remove this information yourself directly through our website.]
Due to the nature of the internet, however, no data transmission over the internet is fully secure. Please be aware of this before you send us any information through this website as the Club cannot guarantee that any information that you transmit to us will not be intercepted and/or misused by third parties.
USE OF COOKIES
Some of our web pages also use “cookies” to allow us to authenticate a user for private access to member only pages. Cookies are identifiers that a website sends to your browser and stores on your computer to streamline your next visit to our site. We also use cookies to determine the last date you visited our website and our electronic bulletin boards.
If you do not want us to use cookies, you can easily disable them by going to the toolbar of your web browser, and click on the help button. Follow the instructions that will prevent the browser from accepting cookies, or set the browser to inform you when you receive a new cookie. If you choose to modify your browser in this manner, some pages of the Club’s website may not function properly.
OTHER INFORMATION
In addition, the Club [automatically] collects other information such as browser types, operating systems, and the URL addresses of sites clicked to and from our Website.
We may also collect anonymous aggregate information on what pages you access or visit. The aggregate information we collect is used for many different purposes in order to serve you better. Among these purposes is to improve the content of the Club’s Website, provide services such as technical support.
LINKS
The Club’s website may from time to time contain links to other websites that may collect your Personal Information. The Club does not assume any responsibility for their privacy practices or policies, and cannot be held liable for the actions of those third parties. You should review the privacy policies of such parties before providing them with any Personal Information.
RETENTION OF INFORMATION
We only retain Personal Information for as long as is necessary for the purpose for which it was collected. All Personal Information will be disposed of, erased or de identified when appropriate, and in a manner that is secure and which respects your privacy. When we dispose of a Member’s or Participant’s or customer’s information, including Personal Information, our paper files are shredded and information kept electronically is deleted from our computers and computer network. Legal requirements may require us to retain some or all of the Personal Information we hold for a period of time that is longer than that for which we might otherwise hold.
QUESTIONS AND CONCERNS
If you have any questions or concerns with respect to our privacy practices, please do not hesitate to call our Privacy Officer [Controller], at
The Scarboro Golf and Country Club Limited 321 Scarborough Golf Club Road
Toronto, Ontario MlJ 3H2
Phone: (416) 266-4546 [ext. 242]
Fax: (416) 266-1259
@scarborogcc.com
Our Privacy Officer will endeavour to answer your questions or concerns as quickly and completely as possible.
If you wish to make a formal complaint about our privacy practices, please forward your complaint in writing to our Privacy Officer. Who will acknowledge receipt of your complaint and ensure that the matter is investigated promptly. You will also be provided with a written notice outlining the decision reached by the Club after investigating your complaint, the reasons for such decision and any steps taken or that will be taken by the Club in connection with your complaint.
If you are unhappy with the decisions reached by the Club, or have a general inquiry about privacy legislation, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as an ombudsman for disputes relating to the privacy legislation. You can contact the Information and Privacy Commissioner at
Office of the Privacy Commissioner of Canada
30 Victoria Street, pt Floor Gatineau, QC
KlA 1H3
Phone: 1 (800) 282-1376
Fax: (819) 994-5424
Email: info@privcom.qc.ca
Web: www.priv.qc.ca
The Club reserves the right to amend this Privacy Policy at any time and from time to time and we encourage you to refer back to this Privacy Policy regularly. Any amendment to this Privacy Policy will apply to the Personal Information collected, used or disclosed from and after the date of such amendment.
Effective Date: October 26, 2016
Board Approved: October 26, 2016