Priddis Greens G&CC - Priddis Greens Golf and Country Club

Privacy Policy

Reference: Personal Information
Revised: January 30, 2019
By Order Of: Designated Privacy Officer

PART I: PURPOSE

1.1) Priddis Greens Golf & Country Club (herein referred to as the “Club” or “us” or “we” or “our”), a society incorporated under the Societies Act of Alberta since 1983, is committed to maintaining the confidentiality of information that has been provided to us by the Membership, employees, participants, customers and other individuals (any of whom are individually referred to in this Policy as “you” or “your”). This Policy outlines the Club’s commitment to maintain privacy when collecting, using and disclosing your personal information.

1.2) This Policy was developed in compliance with the Personal Information Protection Act (“PIPA”) in the Province of Alberta. PIPA serves the purpose of governing “the collection, use and disclosure of personal information by organizations in a matter that recognizes both the right of an individual to have his or her personal information protected and the need of organizations to collect, use or disclose personal information for purposes that are reasonable” (Personal Information Protection Act, 2018).

PART II: PERSONAL INFORMATION

2.1) For the purposes of this Policy, “personal information” includes and factual or subjective information, recorded or not, about an identifiable individual. Personal information is information that allows an individual to be identified but does not include: information which would enable us to contact you at your place of employment including your name, position name or title, business telephone number, business address, business email, and business fax number; information that is publicly available from a public registry or contained in a telephone book; aggregated information that cannot be associated with a specific individual; and information that is not about a person but is about a company, association or another organization.

2.2) Examples of the types of personal information that the Club may collect about you include:

a) Contact information (first name, middle initial, surname, home address, personal cellphone number, home telephone number, personal email address, date of birth);
b) Occupation and professional associations if voluntarily provided;
c) Emergency contact information if voluntarily provided;
d) Information regarding guests that you bring to the Club;
e) Personal preferences, including dietary preferences, allergies and other medical conditions if voluntarily provided;
f) Tee sheet reservations; dining reservations; events that you may attend;
g) Credit card information and/or banking information for billing purposes, in compliance with Payment Card Industry Data Security Standard (PCI DSS);
h) Details on when you access the Club, including with which device (or person) you authenticated or identified yourself.

2.3) You have the right to access personal information held by the Club and to challenge its accuracy, if need be. Personal information can only be used for the purposes for which it was collected. If the Club is going to use it for another purpose, consent must be obtained again.

PART III: COLLECTION, USE AND DISCLOSURE

3.1) 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 Club uses personal information for the following purposes:

a) To establish your classification or access to the Club facilities;
b) To maintain a record of all individuals in the Club at any given time; c) To establish and maintain a relationship with you and provide ongoing services;
d) To process membership and other payments to the Club;
e) To meet legal and regulatory requirements;
f) To determine your interests and preferences in order to market future services to you; and
g) Such other reasons as a reasonable person would consider appropriate in the circumstances

The Club will not give, lease or sell your information to any third party, with the sole exception of Alberta Golf who, as the governing body for golf in Alberta, requires your name, date of birth, and personal email address for their handicap cards. Collective non-identifying personal information may be disclosed to third parties to assist the Club in providing services or products. These service providers are prohibited from using collective non-identifying personal information for any purpose other than to provide this assistance and are required to protect this information disclosed to them by the Club and to comply with the general principles described in this policy and all applicable privacy laws.

PART IV: LIMITING COLLECTION, USE AND DISCLOSURE

4.1) The Club will limit the collection of personal information to that which is reasonably necessary for the purposes identified. We will not use or disclose personal information for any purpose other than those for which it was collected. Where an additional use or disclosure is necessary, the Club will notify you prior to or at the time of the additional use or disclosure, unless such notice is not required or permitted by law. Personal information will only be disclosed within the Club on a need-to-know basis.

PART V: CONSENT

5.1) Except where required or permitted to do so without consent, the Club only collects personal information with your consent. In most cases, the Club relies on express consent. However, where the purpose of the collection of personal information is obvious on its face (such as use of a credit card to pay an account), the Club may rely on implied consent.

5.2) In some cases, such as using personal information for marketing the Club’s services to you, the Club will rely on opt-out consent. By providing the Club your personal email address on any application, you consent to receive automated emails from the Club including: tee sheet notifications, golf course delay notifications, marketing campaigns and notices from Club Management and/or Board of Directors.

5.3) The Club only collects personal information where it is necessary to provide the service you are seeking and that the Club has agreed to provide. The Club does not use deceptive or misleading practices to obtain consent.

5.4) The Club does not require consent to the collection, use or disclosure of personal information as a condition of the supply of a service by the Club unless such collection, use or disclosure is required to fulfill the aforementioned purposes of collection.

5.5) The Club reserves the right to collect, use or disclose personal information in certain limited circumstances, without your knowledge or consent, where required or permitted by law. Examples of this include:

a) Where it is clearly in their best interest and consent cannot be obtained in a timely way;
b) In order to create aggregate information in order to identify your needs and preferences, and to aid in the development of new services and products;
c) Where it is required, by law, to be disclosed to law enforcement and other government agencies;
d) Where it is reasonable to expect that disclosure with consent would compromise an investigation or proceeding;
e) Where disclosure is for the purpose of complying with a subpoena, warrant or order issued or made by a court; and
f) Where disclosure is required or authorized by law.

5.6) You may withdraw your consent to the collection, use and disclosure of personal information in connection with the services that you have requested from the Club at any time, subject to legal or contractual restrictions and reasonable notice. The Club will inform you of the implications of withdrawing consent. If you wish to withdraw your consent at any time, please contact the Privacy Officer of the Club.

PART VI: WEBSITE

6.1) You can visit most pages on our website without giving 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 contact information via the online form submissions, including membership, event, feedback, services and employment inquiries, that require the user to ‘submit’ their form with the acknowledgement their personal information will be stored and used to receive an auto-responder personalized message to the email address provided, distribution of personal information including your name, personal email address, telephone numbers to Club Management, and/or receive future marketing campaigns. Any visitor of our website may contact us directly using the general contact information or employee directory provided on the Club’s website.

6.2) 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.

PART VII: USE OF COOKIES

8.1) Cookies are identifiers that a website sends to your browser and stores on your computer to streamline your next visit to that website.

PART VIII: LINKS

9.1) 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.

PART IX: RETENTION AND PROTECTION

10.1) As per Section 35 of the personal information Protection Act (1): “An organization may retain personal information only for as long as the organization reasonably requires the personal information for legal or business purposes”; and (2): “Within a reasonable period of time after an organization no longer requires personal information for legal or business purposes, the organization must a) destroy the records containing the personal information, or 2) render the personal information non-identifying so that it can no longer be used to identify an individual”.

10.2) The Club takes all reasonable precautions to safeguard your personal information, whether the information is kept electronically or otherwise. This involves ensuring that the only individuals who view your personal information are those who reasonably have the need to do so, and that where necessary and appropriate, sensitive personal information may be locked in filing cabinets or in offices. All of our staff are trained to collect, use and disclose personal information only as necessary to serve your needs and in accordance with this Policy. Electronically, all of our computers and our computer network may only be accessed with passwords which are updated regularly.

PART X: QUESTIONS AND CONCERNS

11.1) The Club is responsible for protecting any personal information under its control and has designated its Club Communications Manager as the Privacy Officer. Questions or concerns regarding privacy procedures or the Club’s compliance with applicable privacy legislation may be directed to the Club Communications Manager by phone 403-931-3171, email [email protected], or mail: #1 Priddis Greens Drive, Priddis Greens, Alberta T0L 1W3.

11.2) If you are not satisfied with the Club’s response, please contact the Office of the Information and Privacy Commissioner of Alberta.