Privacy Policy

Riverstone Golf and Country Club strives to serve its members based on our Mission, Vision, Beliefs and Values system. The RGCC is committed to protecting the privacy of its members and clients. The Riverstone Golf and Country Club website is operated in accordance with this same set of values. All personal information reported via this website or otherwise is done so in accordance with the following privacy policy.

Personal Information

Your privacy is very important to us. The RGCC office collects and uses member personal contact information for internal use only, in order to manage membership and benefits offered through the club. We do not share your contact information with any unaffiliated third parties.

The information you provide to the RGCC – such as your name, address, etc. – allows the RGCC to inform you about events and activities and to notify you of issues, events or special offers that may be of interest to you. By becoming a member or by requesting information or registering for events offered by RGCC, you are giving the RGCC permission to contact you by way of the information you provide. Members may customize their communications preferences by contacting Program Administrator at programadmin@riverstonegolf.com or (905) 794‐8483, ext. 0.

In addition, the following is considered when collecting personal information:

• Staff may not use confidential information from RGCC to further their own personal interests.
• No staff shall create or participate in the creation of a false or misleading record.

Aggregate Data

Aggregate data is information that consists of the sum of members’ personal information, but does not include identifying factors. In other words, it does not allow an outsider to identify an individual. Such aggregate information may be used by the RGCC in order to improve the club and the programs and services we provide to ou members. RGCC may also share aggregate information about its members and clients – not individual data – with sponsors, potential sponsors and other parties to help them better understand RGCC members and their interests.

Protecting Your Personal Information

Members trust the RGCC management and staff to protect the confidentiality and accuracy of their personal information and to repect the sensitivity of the information.

No personal information about you will be collected in future unless you choose to provide that information to the association. The RGCC does not use techniques that collect personal information about you without your knowledge. Any personally identifiable data about customers or website visitors is stored securely and used only for the purpose for whic it is provided to us.

RGCC management and staff are expected to exercise due diligence in the protection of personal information. This includes, but is not limited to, such physical measures as the locking of file cabinets, the securing of personal computer databases, password protecting mobile devices and shredding appropriate documents. We understand the importance of protecting personal information. For that reason, we have taken the following steps:

Paper information is either under supervision or secured in a locked or restricted area. The office is locked when not occupied and the building is locked with onsite security officers in the evenings and on weekend.

Electronic hardware is either under supervision or secured in a locked or restricted area at all times (including in a home office). In addition, passwords are used on computers (including in a home office). All of our cell phones are digital; these signals are more difficult to intercept.

When remotely accessing the RGCC systems, management or a staff member must do so from a secure environment using his or her own computer or one supplied by the RGCC. Management or staff member must not access the RGCC from publicly accessible systems, such as an Internet Café or a friend or relation’s computer, since confidential material may inadvertently remain on the outside system after accessing the RGCC.

• Paper information is transmitted through sealed, addressed envelopes or boxes by Canada Post or a reputable company, by staff or picked up by person who asks for it by name of recipient (files are kept out of sight in reception area until picked up).
• Electronic information is transmitted through a direct line.
• When we need to mail or fax your information to an external party that has a privacy agreement with the RGCC, the communication is clearly marked “private and confidential” whether externally on the package, on a fax coversheet or email identifying the privacy clause.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External parties with required access to personal information must enter into a privacy agreement with us.

Retention and Destruction of Personal Information

We need to retain personal information for some time to ensure that we can answer any questions you might have about the servics provided and for our own accountability to external regulatory bodies. At the present time we usually keep our member files indefinitely. Our member and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients, newsletters and marketing activities for a few months after the newsletter or marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.

Access to Information

You have the right to see what personal information we hold about you and we will provide you with copies of the information wih appropriate notice (3‐5 business days). We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. We may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyon else who received the earlier information.

RGCC Website

The operating system for the RGCC website (www.Riverstonegolf.com ) may automatically record some general information about your visit, such as:

• The Internet domain for your Internet service provider, such as “company.com” or “service.ca” and the IP address of the computer accessing the website, such as “ppp‐55”;
• The type of browser (such as “Netscape version x” or “Internet Explorer version x”) you are using;
• The type of operating system you are using (such as Macintosh, Unix, or Windows);
• The date and time you visit our site and the web pages that you visit on our site, along with the address of the previous website you were visiting, if you linked to us from another website.
• If you are logged into this site, your user name will be recorded along with the date and time of your visit, which pages you viewed, etc.

RGCC may use this information for statistical analysis, to help us make our site more useful to visitors. We may disclose this information in aggregate only to third parties such as sponsors, clients or advertisers and/or use it for auditing purposes.

The RGCC website may use “cookies” that identify you as a return visitor. A cookie is a piece of data that a website can send to your browser, which may then store the cookie on your hard drive. So, when you come back to visit RGCC’s website again, information can be tailored to suit your individual preferences. The goal is to save you time and provide you with a more meaningful visit and to measure website activity. Browsers such as Netscape allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.

Specifically, we use cookies in order to allow members to access features (i.e. “Remember Me” function) without logging into the website each time.

When You Leave The RGCC Website

This policy discloses the privacy practices for the RGCC website (www.Riverstonegoldf.com ). However, the RGCC website contains links to other sites. Once you link to another site, you are subject to the privacy and security policies of the new site. RGCC encourages you to read the privacy policies of all websites you visit, especially if you share any personal information.

Payment Data

All credit card or bank account information is collected and sent to our payment partner for use in payment approval and procesing only. RGCC does not retain your credit card information. The RGCC’s payment partner is ETS and TD Bank. For further information on ETS and TD Bank privacy policy, please see www.ets.com and www.tdbank.com .

For more information, please contact RGCC’s Privacy Officer:

Grover Braund
General Manager
Riverstone Golf and Country Club
95 Don Maniker Road
Brampton, Ontario
Email: gbraund@riverstonegolf.com

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Officer. They will acknowledge receipt of your complaint; ensure that it is investigated properly and that you are provided with a formal decision and reasons in writing.

This policy is made under the Personal Information and Protection of Electronic Documents Act. This Act also sets out some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private secto. The Commissioner can be contacted at:

112 Kent Street, Ottawa, Ontario, K1A 1H3
Phone: (613) 995‐8210 / Toll‐Free 1‐800‐282‐1376
Fax: (613) 947‐6850 / TTY (613) 992‐9190 http://www.privcom.gc.ca