PRIVACY POLICY

 

Our Commitment
Westmount Golf & Country Club Limited is a premier private club that exemplifies excellence in golf, curling, tennis and social activities for the enjoyment of our members, their families and guests. In furtherance of these goals, Westmount Golf & Country Club Limited (“Westmount”, the “Club” “we”, “us” or “our”) collects and uses the Personal Information of our members, their families and guests and other individuals using our website (the “Website”) and who otherwise submit Personal Information to the Club. We are committed to maintaining the security, confidentiality and privacy of your Personal Information. This document describes our privacy policies concerning the collection, use, disclosure and protection of Personal Information.
Unless otherwise agreed to in writing by the Club, by using the Website or otherwise disclosing Personal Information to the Club you will be deemed to have consented to the terms and conditions set forth in this Policy, including (without limitation), the collection, use and disclosure of your Personal Information by the Club.
IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION TO THE CLUB OR USE THE WEBSITE.
  This Policy applies to Personal Information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. This Policy does not impose any limits on our collection, use or disclosure of the information exempted under applicable privacy legislation, including business contact information and certain publicly available information.
“Personal Information” is defined in Canada’s Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), as information about an identifiable individual, though it does not include the name, business title, business address or telephone number of employees of organizations.
The Club may update this Policy from time to time. We will notify you about material changes by placing a prominent notice on the Website and/or by providing notice to you. However, it is your responsibility to review the most current version of this Policy. If this
Policy is updated, your continued use of this Website and any subsequent submission of Personal Information by you to the Club will be deemed your conclusive acceptance of the most recent version of this Policy.
 

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Accountability
We have designated a Privacy Officer who is accountable for our compliance with this Policy. The Privacy Officer’s contact information can be found at the end of this Policy.
Please note if you are a corporate customer or any other type of organization, are responsible for the legal collection and use of Personal Information of individuals within your organization, in accordance with the principles set out in your privacy policy and the applicable laws in the countries in which you operate. The Club is not responsible for your privacy practices and policies.
Please also note that if you submit Personal Information about your children to the Club, you are agreeing to this Privacy Policy on behalf of your children.
Purposes for Collecting Personal Information
When collecting Personal Information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection. We may collect information from you, including without limitation your e-mail address, website registrations, preferred means of communication, your interaction with our Website (including information such as IP addresses, browser type, language, access times, referring website, etc.) and other information you provide us. We collect, use and disclose your Personal Information for the following purposes:

• to ensure high standards of service to members;
• to enable communication and social interaction between members, and between members and other individuals;
• to communicate with members regarding votes to be held among the Class B shareholders of the Club, including the election of shareholders to the Board of Directors of the Club;
• to develop, manage and deliver our services, events and products to our members, their families, guests and other customers;
• to provide information you request from us;
• to contact our members, either directly or indirectly, about services, events and products that may be of interest;
• to authenticate your identity;
• to compile statistics and to operate and improve our Website and the Club;
• to contact members with service, event and product updates, upgrades and enhancements;
• to monitor your compliance with any of your agreements with us, and to administer the provision or receipt of services or products under those agreements;
• to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or merger;
• to protect us, yourself and others from fraud and error and to safeguard our business interests;
• to collect debts owed to us; and
• to comply with legal and regulatory requirements.

We may transfer your Personal Information across provincial or national borders to fulfil any of the above purposes (including both the necessary and the optional purposes), to parties who may be subject to applicable disclosure laws in those jurisdictions, which may result in that information becoming accessible to law enforcement and national security authorities of those jurisdictions.
When your Personal Information is to be used or disclosed for a purpose not previously identified, the new purpose will be identified to you prior to such use or disclosure, and your consent will be sought unless the use or disclosure is authorized or required by law.
Except as described below, and except with respect to information you post on a public forum, we will not disclose your Personal Information to third parties without your consent.
We occasionally hire other companies to provide services on our behalf, such as hosting websites and conducting surveys. Those service providers will be permitted to obtain only the Personal Information they need to deliver the service in question, and they will be required to maintain the confidentiality of that information.

The Website and Use of Cookies

In connection with the Website we use, or may use in the future, various types of “Cookies”, tags and web beacons in order to collect information, enhance our Website and enhance your user experience. “Cookies” are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and the website faster and easier. They cannot be used to run programs or deliver viruses to your device. In general, cookies do not identify you personally.
 

Third Party Links
The Website may contain links to third party sites, and we recommend and encourage you to read the privacy policies posted on those third-party sites. We are not responsible for the privacy policies or practices of any third party.
 

Consent
As indicated at the top of this Policy, unless otherwise agreed to in writing by the Club, by sharing Personal Information with the Club or by using the Website you will be deemed to have consented to the terms and conditions set forth in this Policy, including (without limitation), the collection, use and disclosure of your Personal Information by the Club.
As a general principle, we will obtain your consent to collect, use or disclose Personal Information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose Personal Information without your knowledge or consent where:

• the information is publicly available, as defined by statute or regulation;
• we are obtaining legal advice; or
• we reasonably expect that obtaining consent would compromise an investigation or proceeding.

Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your Personal Information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions; provided that, you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include the inability of us to provide certain services for which that information is necessary.
Any material, information or other communication (including questions, comments and suggestions) you transmit to us through our Website or our other online sites will be considered non-confidential and non-proprietary. Where necessary for responding to you, we may forward your communications to any of our employees, subsidiaries or affiliates, and you consent to us doing so.

Limits on Collection
We will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the above purposes. We will also collect information as is otherwise authorized by law.

Limits on Using, Disclosing and Retaining Personal Information
We will only use and disclose your Personal Information for the purposes set out above and as authorized by law.
We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law.
We will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to conclude that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
We will take due care when destroying Personal Information so as to prevent unauthorized access to the information.
 

Accuracy
We will make a reasonable effort to ensure that Personal Information we are using or disclosing is accurate, complete and up to date. In some cases, we rely on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate.
If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.
 

Safeguards
We protect the Personal Information in our custody or control by making reasonable security arrangements to prevent theft, loss, unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
Methods of protection include physical, organizational and technological measures.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of Personal Information protection is implemented by the contractors, suppliers and agents who assist in providing services to you.
Confidentiality and security are not assured when information is transmitted electronically.
 

Providing Access
Upon written request and authentication of identity, we will provide you with your other Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within thirty (30) days or provide written notice where additional time is required to fulfil the request.
In some situations, we may not be able to provide access to certain Personal Information. This may be the case where, for example, disclosure would reveal Personal Information about another individual, the Personal Information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain Personal Information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
 

Complaints
Upon your request, we will provide additional information regarding our complaint procedures.
All complaints will be investigated within a reasonable amount of time.
Any inquiries, complaints or questions regarding this policy or our compliance with privacy legislation should be directed in writing to our Privacy Officer as follows:

Westmount Golf & Country Club Limited
50 Inverness Drive
Kitchener, Ontario, Canada N2M 4Z9
Attn: Jason Meier, Privacy Officer
Email: [email protected]
 

Code of Conduct
Discipline Policy
  Any changes or modifications to Westmount Golf & Country Club policies and procedures must be reviewed and approved by the Westmount Board of Directors.


 

Privacy Policy	Issue Date: January 2018
	Revision Number: 1
	Approved by: Board of Directors on April 5, 2023