Updated and Posted - August 12, 2014
PERSONAL INFORMATION DEFINED
In this policy, “personal information” means information about an identifiable individual. This includes but is not limited to your name, address, telephone number, e-mail address, age or date of birth, and banking, credit and financial information.
INFORMATION WE COLLECT FROM YOU
We collect your personal information primarily from you. We may also collect it from other sources including agents and contractors or other third parties who represent that they have the right to disclose the information.
When you make an inquiry on the Website or complete an application for a Pacific Links membership (“Membership”), we may collect from you certain information, including but not limited to the following: a username, password, your first and last name and email address, mailing address, phone number and information regarding the requested membership for which you are visiting the website.
We may collect, use or disclose your personal information only with your consent or as permitted or required by law. By providing personal information to us, you are consenting to its collection, use and disclosure as set forth herein.
We may also obtain your specific consent in an application for Membership or other document, or by facsimile, electronic mail or telephone conversations with our employees or agents.
We also obtain consent from your legal guardian, estate, trustee or person having power of attorney for you in situations where we become aware that you (i) have died (ii) are a minor (iii) have become seriously ill or (iv) are mentally incapacitated.
The form of consent may vary depending upon the circumstances and the type of information, including the sensitivity of the information and your reasonable expectations.
You may opt in to or out of receiving marketing or promotional communications for products and services from us at the time of completing a Membership application or subsequently by contacting us or by online subscribe / unsubscribe. You may withdraw your consent for any other identified purposes at any time, subject to legal and/or contractual restrictions and reasonable notice. We may not be able to provide you with a particular product or service if you withdraw your consent to certain uses of personal information.
WHAT WE DO WITH YOUR PERSONAL INFORMATION
Personal information provided by you in connection with your business relationship with us, may be used by, collected by and/or disclosed by us (including our agents and contractors, potential affiliates, Participating Clubs, partner organizations) for the following purposes:
- to evaluate your Membership application and your eligibility for Membership;
- to enable us to enter into contractual relationships with you;
- for contract management and administration, including but not limited to credit, billing, collection, service, booking and tracking of tee times with Participating Clubs;
- to provide information and services that you request, and to respond to your comments and inquiries;
- to assess the effectiveness of our operations and to improve the quality of our operations and Membership offerings;
- in top-level aggregated form to provide high-level membership statistics (such aggregated reports will not contain personally identifiable information);
- for marketing and promotion of products, goods and services to you;
- to meet legal and regulatory requirements or to disclose information when we believe in good faith we are compelled to do so by a subpoena, court order, regulatory body or similar legal procedure;
- if we believe in good faith that the disclosure is necessary to prevent physical harm or financial loss or to report suspected illegal activity;
- in connection with the financing of or a business sale or acquisition of Pacific Links International; and
- as may be otherwise authorized by you.
If your personal information is to be used or disclosed for any new purposes, we will, to the extent required by law, identify these new purposes prior to such use or disclosure and, if required, obtain your consent.
We will not sell any of your personal information that you provide us or provide to a third party for the purpose of solicitation by a third party.
In some cases personal information may be disclosed, processed and/or stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there.
PRIVACY AND THE INTERNET
On the website we may also collect information that, alone, cannot be used to identify users. Examples of these types of non-personal information include IP addresses, cookies, Internet tags and navigational data.
- An Internet Protocol (IP) address is a number automatically assigned to users’ computers when they access the Internet. This number does not identify the user’s name, e-mail address or other personal information. This information may be used to measure site traffic, to help to understand how people are using the Website and to improve the website and services provided.
- "Cookies" are small text files that our website sends to your browser, which provides information to us about your general Internet usage, such as recognizing repeat visitors and allowing us to understand how and when pages are visited. You may opt to enable a feature in your browser software that will erase cookies or block all cookies, however, some parts of the Website may no longer function properly if cookies are disabled.
- Internet tags are smaller than cookies and tell the Website server information such as the IP address and browser type related to a user’s computer. Tags may indicate how many times a page is opened and which information is consulted.
- Navigational data (including log files) are used for system management, to improve the content of the Website, for market research purposes and to communicate information to visitors. This may include the website you came from, your browser type, domain name and time and date of access.
MAINTAINING THE ACCURACY OF YOUR PERSONAL INFORMATION
We use reasonable efforts to keep your personal information as accurate, complete and up-to-date as necessary to fulfill the purposes for which we collect the information so as to minimize the possibility of using incorrect information about you. We may obtain updated information from you or from an agent or contractor of ours.
You or your agents, legal guardian, estate, trustee or person having power of attorney for you, are responsible for informing us about changes to your personal information that are necessary to fulfill the identified purposes, such as but not limited to: if your name or address changes, if you die, if a proceeding in bankruptcy, receivership, or insolvency is started by you or against you, if you fail to comply with requirements under an agreement with us.
Whenever possible, we will correct information given to an outside organization. If a third party has given us information which you tell us is incorrect, if permitted we will give you the name and address of that party, so that you can correct the information.
SAFEGUARDING YOUR PERSONAL INFORMATION
We take commercially reasonable precautions to protect your personal information (regardless of the format in which it is held) against loss or theft, unauthorized access, disclosure, copying, use, or modification, through safeguards appropriate to the sensitivity of the personal information.
Access to your personal information is only given to our employees who need to know the information and whose duties reasonably so require the information in order to fulfill the identified purposes.
Pacific Links has adopted physical, procedural and technological procedures, including firewalls, in an effort to keep your personal information safe. Our Website uses SSL technology, which is an open protocol for secure data communications across computer networks. Data transmitted over the Internet, however, is not guaranteed to be secure and Pacific Links does not guarantee, warrant or represent that the personal information you provide will be transmitted securely or protected completely against interception, loss, misuse or alteration. Pacific Links accepts no responsibility or liability for any damages that may result where personal information submitted by you has not been securely transmitted, or has been intercepted, lost, misused or altered.
We retain your personal information only as long as necessary or relevant (1) for the identified purposes, (2) as required by law, (3) as required by agreements with third parties related to the provision of Pacific Links’ programs, (4) where we use your personal information to make a decision about you, long enough to allow you access to the information for a reasonable period of time after the decision has been made, and (5) where your personal information is the subject of a request from you, for as long as is reasonably necessary to allow you to exhaust any recourse you may have under the law. We dispose of or destroy your personal information to prevent unauthorized parties from gaining access to the information.
From time to time, Pacific Links may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you therefore have the choice whether or not to disclose the requested information. Information requested may include contact information (such as name, email address and shipping address), and demographic information (such as postal/zip code, age, gender, etc.). Contact information will be used to notify winners and award prizes. Survey information will be recorded on an individual basis for the purpose of monitoring or improving the quality of Pacific Links’ services and program offerings.
Subject to restrictions detailed herein and within reasonable terms, you may obtain access to files on your personal information by making a formal request to our Privacy Officer.
OUR PRIVACY POLICIES AND PRACTICES
You may challenge the accuracy and completeness of your personal information held by us and ask us to amend the information as appropriate. Under certain conditions as permitted or required by law, we may not provide you with access to your personal information kept in our file. Where we refuse your request, we will identify the reasons for refusing the request. If a complaint is found to be justified, we will take appropriate measures including, if necessary, amending our policies and practices.
We have appointed a Privacy Officer who shall be accountable for Pacific Links’ compliance with PIPEDA and this policy. If you have inquiries regarding your personal information held by us or if you wish to address a challenge regarding our compliance with this policy, you may contact our Privacy Officer in writing at the address listed below:
Pacific Links Privacy Officer
c/o Pacific Links Canada Services Inc.
331 Cityview Blvd., Suite 200
Vaughan, Ontario L4H 3M3
All inquiries and concerns will be fully investigated and responded to by our Privacy Officer.