I. Introduction
Windermere Golf and Country Club ("Windermere") recognizes the importance of privacy and recognizes the sensitivity of personal information received by us in the course of our business. We recognize our obligation to maintain the confidentiality of our members' and clients' information, and recognize our obligations concerning the personal information that we collect, use or disclose in the course of our operations. This policy has been developed with those obligations in mind.
II. Website
Our website contains links to other websites which are not governed by our privacy policy. The information contained in this website does not and shall not constitute a business/client, or agency relationship with Windermere or any of its employees or affiliates. The information contained in this website is public information.
Please also be aware that our website contains a page reserved for members only. This page is protected by login and password requirements and is only available to members and employees of Windermere. This page intends to facilitate member to member communication and includes the posting of the following information:
Name;
Home address;
Home telephone number;
Tee times; and
Club facility bookings.
Consent to post such information is obtained on an annual basis in the form of a mail-out Privacy Statement, which also seeks to maintain the accuracy of such information. You may contact the Privacy Officer, as noted below, at anytime to withdraw your consent and such information will be removed from the website within a reasonable period of time.
III. Consent to the Collection, Use and Disclosure of Personal Information
As a member or client of Windermere, by submitting demographic and payment information on our website or to our organization, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. Please note that Windermere does not collect, use or disclose your personal information without your consent, unless it is mandated under the applicable legislation.
IV. Collection, Use and Disclosure of Personal Information
Where practical, we endeavour to collect personal information directly from the person to whom the information pertains. When necessary, we will collect personal information from other sources. By becoming a member or using the services provided by Windermere, an individual consents to our necessary collection, use or disclosure of the individual's personal information in order to properly provide the requested service to the individual. It is our policy to collect personal information about individuals other than our members and clients in accordance with the provisions of the Personal Information Protection Act of Alberta ("PIPA"). When we collect, use or disclose personal information, we will make reasonable efforts to insure that it is accurate and complete.
Collection
Specifically, Windermere collects the following personal information:
Registration and Account information that is necessary for us to provide the products and services you may purchase from Windermere; and
"Cookies" - small parcels of text that are sent from our server to your computer in order to record your personal preferences when visiting our website and create a more personalized experience on Windermere's website.
Use
Windermere only uses your personal information for business related purposes (i.e. to provide services to you and to administer our business incidental to providing services such as member and client billing).
Disclosure
Windermere will not disclose your personal information to any individual or organization unless it falls into one of the following categories:
It is required under by law that the information be disclosed;
You have consented to Windermere disclosing such information by creating an account or requesting information about a specific product or service or in any other way;
The disclosure of such information is to a third party organization that we have hired to fulfill a role in our operations, such as our back-up server providers, our credit card payment processor, our customer service representatives and any other organization or independent contractor that Windermere has hired;
Please note that Windermere requires all third party contractors that we hire to acknowledge our strict adherence to the provincial privacy legislation and requires them to be aware of our privacy policy and to have a comprehensive policy of their own; however, we are not in any way liable for any breach of such legislation made by any of our third party contractors.
We may disclose personal information in the circumstance that Windermere is involved in a "business transaction" as defined in PIPA - a transaction consisting of the purchase, sale, lease, merger or amalgamation or any other type of acquisition or disposal of, or the taking of security interest in respect of Windermere or any portion of Windermere or its business activities. Windermere further vows to disclose only the minimal amount of personal information that may be necessary in a particular situation and furthermore, will require the utmost discretion in doing so.
Windermere will not sell or in any way transfer your individual personal information to any external marketing firm or other organization for any reason without your consent.
V. Security of Personal Information
We recognize both the importance and necessity of protecting the personal information of our members and clients. We recognize as well our legal obligations to protect the personal information we have collected about our members and clients and about other individuals during the course of business. We have therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.
VI. Requests for Access to Personal Information
PIPA permits individuals to access records containing their personal information, subject to certain exceptions set out in the legislation. We will respond to requests in the time allowed by the legislation and we will make a reasonable effort to assist applicants to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits us to charge.
VII. Request for Correction of Personal Information
The law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. We will:
Correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
Decide not to correct the personal information, but annotate the personal information that a correction was requested but not made.
VIII. Communications by Email
We will imply your consent to use email to send personal or confidential information unless you expressly notify us that you do not want to be contacted by this form of communication.
IX. Changes to this Privacy Policy
We may review and change our Privacy Policy without notice, from time to time, in order to update our privacy commitment to you in keeping with current privacy laws.
X. Contact Information & Resources
If you have any questions with respect to our policies concerning the handling of your personal information, would like to obtain a complete version of our Privacy Policy or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Chief Privacy Officer at:
Windermere Golf and Country Club
Attention: Wade Hudyma, Chief Privacy Officer
19110 Ellerslie Road SW
Edmonton, Alberta, T6W 1A5
Telephone (780) 988-5501
Email: wadeh@windermeregcc.com
If you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If, after our Privacy Officer has reviewed and responded to your concern, you remain dissatisfied, you may wish to contact the Information and Privacy Commissioner at:
Office of the Information and Privacy Commissioner of Alberta
410, 9925-109th Street
Edmonton, Alberta, T5K 2J8
Telephone: (780) 422-6860
Website: http://www.oipc.ab.ca