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Nanaimo Golf Club Privacy Policy

Our commitment to your privacy

1.1 We are committed to respect and protect our members’ privacy and to ensure they have a secure
online experience, in accordance with British Columbia’s Personal Information Protection Act (PIPA) and
Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

Accountability

2.1 We promise to be responsible for maintaining and protecting all personal information of our members
under our control. In fulfilling this mandate, we have designated a staff member as our Privacy Officer to
be accountable for ensuring we are in compliance with the following 10 Privacy Principles:
  1. Be accountable
  2. Identify the purpose
  3. Obtain consent
  4. Limit collection
  5. Limit use, disclosure, and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual access
  10. Challenging compliance

Purpose of collection

3.1 Unless the purposes for collecting personal information are obvious and you voluntarily provide your
personal information for those purposes, we will communicate the purposes for which personal
information is being collected, either orally or in writing, before or at the time of collection.
3.2 We will only collect member information that is necessary to:
a) Open and manage your member account.
b) Send out member communications and notices.
c) Maintain a member roster as required by the Societies Act and to allow fellow members to contact
you about club activities.
d) Conduct member surveys in order to enhance the services we provide.

Consent

4.1 We will obtain your consent either orally, electronically or in writing, to collect, use or disclose your
personal information (except where, as noted below, we are authorized to do so without consent).
4.2 Your consent will be implied when the purpose for collecting using or disclosing your personal
information would be considered obvious and you voluntarily provide your personal information for that
purpose. Your consent will also be implied when you do not opt out of receiving communications where
you have a reasonable opportunity to opt-out of having your personal information used.
4.3 We may collect, use or disclose your personal information without your knowledge or consent:
a) When it is permitted or required by law.
b) In an emergency that threatens your life, health, or personal security.
c) When it is available from a public source (e.g., a telephone directory).
d) When we require legal advice from a lawyer.
e) To collect a debt.
f) To protect ourselves from fraud.
g) To investigate an anticipated breach of an agreement or a contravention of law.
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Online collection of information

5.1 Our website, nanaimogolfclub.ca, captures personal information identifiable to you, including your email
address, only when you specifically give it to us. No personal information is automatically collected
when you visit our site.
5.2 Non-personal information relating to site traffic and usage is gathered in our server logs for internal
evaluation to help us better serve you. We analyze these logs in an effort to constantly improve the
value of our content and services. The logs do not contain personally identifiable information, nor do we
make any attempt to link the traffic information on the site with the individuals who actually visit the
site. From time to time, we may break down overall usage statistics according to a user's domain name,
browser type and MIME type by reading information from the browser string. Again, we make no efforts
to associate this information with individual users.

Use, disclosure and retention

6.1 Your personal information will only be used or disclosed for the purpose for which it was collected,
unless you have otherwise consented, or when it is required or permitted by law or disclosure is
authorized by PIPA or PIPEDA.
6.2 We do not sell, rent, loan, trade, or lease your personal information to anyone else unless we have your
consent to do so.
6.3 We will retain your personal information only for as long as necessary to fulfill the identified purposes or
a legal or business purpose.

Accuracy

7.1 Your information is maintained in as accurate, complete and up-to-date form as is necessary to fulfill the
purposes for which it is to be used.
7.2 You may update the personal information in your online member profile at any time to ensure its
accuracy and to reflect your choice for the visibility of various types of information to other members.
You can change other personal information by sending a written request to the Club’s office, providing
sufficient detail to identify the personal information and the correction being sought.

Appropriate safeguards

8.1 We take all reasonable effort to ensure the security of your personal information in order to protect is
from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks,
and take appropriate measures when destroying your information.
8.2 All activity in the Members Only section of our website utilizes SSL (Secure Socket Layer), a protocol that
provides website authentication and encryption of transactional data. Your personal information
contained within this area of the website, including your member profile, tee-time bookings and
member statements, is secured via SSL at all times. As the first and most widely adopted security
protocol, SSL is supported by all major browsers and web servers.

Openness

9.1 We are open about our policies and procedures, including how we manage your personal information.
This Privacy Policy is available to all members on our website and mobile app.

Individual access

10.1 You have the right to access your personal information, subject to exceptions outlined in PIPA and
PIPEDA. To do so, you must make a request to access your personal information in writing to the Club’s
office and provide sufficient detail to identify the personal information being sought.
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10.2 We will make the requested information available within 30 business days, or provide written notice of
an extension where additional time is required to fulfill your request. If requested, we will also tell ypu
how we use your personal information and to whom it has been disclosed if applicable.
10.3 As permitted by applicable law, we may charge a minimal fee for providing access to personal
information, in which case we will inform you of the cost and request further direction from you on
whether or not we should proceed with your request.
10.4 If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and
the recourse available to you.

Challenging compliance

11.1 Any complaints, concerns or questions that you may have about our compliance to this Privacy Policy
must be submitted in writing to our Privacy Officer. You can contact our Privacy Officer:
a) by email to privacy@nanaimogolfclub.ca, indicating "Privacy Officer" in the subject line,
b) by fax to 250-758-9612, or
c) by regular mail to:
Privacy Officer
Nanaimo Golf Club
2800 Highland Blvd
Nanaimo BC V9S 3N8
Canada
11.2 We will investigate all complaints. If we find that a complaint is justified, we will take appropriate
measures, including, if necessary, amending our policies and practices.
11.3 If our Privacy Officer is unable to resolve your concern, you may also write to the Information and
Privacy Commissioner of British Columbia.

Changes to this policy

12.1 We reserve the right to change or update this policy from time to time without notice.
To learn more
For more detailed information about your privacy rights in Canada, please visit the website of the Office of the
Privacy Commissioner at priv.gc.ca or call toll free at 1-800-282-1376.