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PRIVACY POLICY


Effective January 1, 2004, the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") came into effect.  In collecting, retaining, disclosing and using Member Personal Information, Pine Ridge Golf Club (the “Club”) will conform with the legislation in all respects.

For this reason, the Club has adopted this Privacy Policy to ensure that any individual’s Personal Information in its control, is protected by appropriate means.  Additionally, the Club has established policies and procedures to comply with this Privacy Policy and has informed and trained its staff with respect to PIPEDA. 
 
As used in this Privacy Policy:
 
"Personal Information" means any information about an identifiable individual.
 
“Member” means a member of Pine Ridge Golf Club.
 
“Other Individual” means an individual who is not a Member of Pine Ridge Golf Club.
 
ACCOUNTABILITY, PURPOSE, COLLECTION AND CONSENT

The Club collects Personal Information about its Members, such as:
  1. Name;
  2. Address;
  3. Phone and facsimile numbers;
  4. Email addresses;
  5. Membership category;
  6. Birth-date;
  7. Previous club information;
  8. Length of membership;
  9. Employer information;
  10. Handicap information; and
  11. Spending levels in both the Pro Shop and the Clubhouse.
This Personal Information is being collected in order for the Club to provide services to its Members, including:
  1. Informing Members of Club information, including upcoming events;
  2. Recording any transactions Members may have with the Club;
  3. Providing House Account statements and other transaction records to Members;
  4. Publishing Members’ names, addresses, phone numbers and membership categories in the Club’s Membership Roster, which is only provided to Members;
  5. Publishing Members’ names, addresses, phone numbers and membership categories in the Club’s online Membership Roster, which is only accessible by Members;
  6. Facilitating the bookings of tee times through the use of the online Tee Sheet, which is only accessible by Members; and,
  7. Providing Members’ names, addresses, phone numbers and email addresses to Club golf league coordinators.
 
Member Personal Information in the possession of the Club will be disclosed to individual’s who identify themselves as being the respective Member and who are verified to be said Member.

The Club will not use Member Personal Information for any purpose, except for those identified above.  Members’ consent to do so may be given either orally or in written form.  In some circumstances a Member’s consent will be implied through the nature of their interaction with the Club.

The Club also collects and may retain and use Personal Information (such as names, addresses, email addresses, telephone numbers, employer information, birth-date, previous golf course memberships, taxation numbers, records of transactions and social insurance numbers) about Other Individuals such as suppliers, consultants, prospective employees, prospective members and past employees.

With respect to Other Individuals, the Club will obtain their consent, when necessary and required by law to collect, use, retain, or disclose the Personal Information necessary to conduct its dealings with them.  The Club will not use their Personal Information for any other purpose.  This consent may be given either orally or in written form.  In some circumstances the Other Individual’s consent will be implied through the nature of the Club’s dealings with them.

If the Club identifies a new purpose for which an individual’s Personal Information could be used, it will obtain their consent before using their Personal Information for that purpose.   The Club does not sell any individual’s Personal Information to third parties.

The Club may collect, use, retain or disclose Personal Information without an individual’s knowledge or consent in circumstances where such collection, use, retention or disclosure is permitted or as required by law.

Subject to certain legal and contractual requirements, individuals can refuse to consent to the Club’s collection, use, retention or disclosure of information about them, or they may withdraw their consent to the Club’s further collection, use, retention or disclosure of information at any time in the future by giving the Club reasonable notice.  However, if a Member refuses or withdraws their consent, the Club may not be able to provide them, or continue to provide them, with services.  Similarly, if any Other Individual refuses or withdraws their consent, the Club may not be able to have any further dealings with them

LIMITING USE, DISCLOSURE AND RETENTION
The Club will retain Personal Information as long as it is required to meet the purpose for which it was collected.  The Club may also retain Personal Information for a longer period if required to do so by law.  When such time limits have expired and the individual’s Personal Information is no longer needed for the purpose that it was collected for, the Club has procedures to destroy, delete, erase or convert the Personal Information to an anonymous form.

ACCURACY
The Club endeavours to keep all individual’s Personal Information that it has in its possession or control as accurate, complete and up-to-date as necessary for the purposes for which it is used.  The Club will update Personal Information only if it is necessary for the purposes for which it was collected and if the information is used on an ongoing basis.  The Club also relies on its Members and Other Individuals to keep certain Personal Information accurate, complete, and current, such as a change in address. 

Despite the Club’s efforts, errors sometimes do occur.  Should an individual identify that the Club holds incorrect or out-of-date Personal Information about them, the Club will make the proper changes.  Where appropriate, the Club will communicate these changes to other parties who may have unintentionally received incorrect Personal Information from the Club. 

SAFEGUARDING PERSONAL INFORMATION
The Club protects all individuals’ Personal Information in its possession or control with reasonable security safeguards to protect such information against loss or theft, unauthorized access, disclosure, copying, use, or modification.  The Club uses a variety of security technologies and procedures to help safeguard individual’s Personal Information. 

OPENNESS
The Club readily makes available to all individuals specific information about the policies and practices relating to the management of Personal Information.  If an individual wishes to obtain a copy of this Privacy Policy or if they have a question, concern or complaint about this Privacy Policy, they can contact the Club’s Privacy Officer:

            Jason Ludke
            Pine Ridge Golf Club
            R. R. #5
            Winnipeg, Manitoba
            R2C 2Z2
Phone: 222-6477
            Fax: 222-5118
            Email: jludke@pineridgegolfclub.com
 
The Club may add, modify or remove portions of this Privacy Policy at any time and such change will become effective immediately.
 
INDIVIDUAL ACCESS
Upon written request, the Club will inform any individual of the existence, use, and disclosure of their Personal Information and will afford access to that information upon payment of any applicable charges.  Individuals are entitled to challenge the accuracy and completeness of the information and have it amended as appropriate. 

Please note that the Club may not be able to provide Personal Information about an individual if it (i) would reveal Personal Information about a third party, (ii) is subject to legal privilege, (iii) contains other confidential information which would be revealed, (iv) is information that was generated in the course of a formal dispute resolution process, (v) relates to an investigation of a breach of agreement or contravention of laws, or (vi) cannot be disclosed for other legal or security reasons. 

CHALLENGING COMPLIANCE
Any individual may challenge the Club’s compliance with PIPEDA.  To initiate a challenge, an individual may begin by contacting the Privacy Officer.  The Privacy Officer will investigate and respond to the challenge.  If the Privacy Officer find such a challenge is justified, he or she will take appropriate measures, including changing Club policies or procedures, to ensure that others will not experience the same problem.  If an individual is unhappy with the Club’s response to their challenge, the Club invites them to contact the Privacy Commissioner directly.