You are entering into a legally binding agreement, read the following terms and conditions carefully.
As an organization engaged in commercial activities, we are committed to complying with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), and with any other Canadian and provincial privacy laws applicable to our operations.
You must be 18 or older to use our Services. Minors under 18 and at least 13 years of age are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission and under their direct supervision. We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Service. If you are under 13, please do not attempt to register for our Service or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
1. INFORMATION THAT WE COLLECT FROM YOU
1.2. Whenever you interact with our Service, we automatically receive and record technical information such as your device, IP address, “cookie” information (as described in in Section 5 Cookies), the version of your operating system (“OS”), and the page you requested. When you use the Service on a mobile platform, we may also collect and record your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), your device name, and your location (based on your IP address). We may also collect information regarding your activity on the Service (both individually and on an aggregate basis).
1.5. We may also collect some personal information through system logs and cookies. For further information on our practices in relation to cookies, please refer to section 5 below.
2. USE OF YOUR PERSONAL INFORMATION
2.1. Depending upon your relationship with us, your Personal Information may be used to create a personal account and/or user profile, and to help manage our relationship with you and with any affiliated, reciprocal and preferred access golf clubs with which Pacific Links has a relationship (“Network Clubs”).
2.4. You agree that we may use your Personal Information to let you know about our other products and services that may be of interest to you including but not limited to services that may be the subject of direct marketing and we may contact you to do so by telephone, SMS, as well as by e-mail and social media. It is always your choice whether to continue receiving such marketing materials and updates from us and if you no longer wish to receive such information, you should refer to the unsubscribe process on our Website, email and other communications.
2.5. You agree that we may also share Personal Information with third parties, including without limitation Affiliate Clubs, in order to let you know about goods and services which may be of interest to you (by post, telephone, mobile messaging (e.g. SMS, MMS etc.), social media and/or e-mail) and to help us analyse the information we collect so that we can administer, support, improve and develop our business and our relationship with you. Personal Information shared with such third parties will be used in accordance with such third parties’ own privacy practices which we do not have control over, so you should review such privacy practices before agreeing to have your Personal Information shared with such third parties.
2.6. If you do not want us to use your data in this way or change your mind about being contacted in the future, please let us know by using the contact details set out in section 14 below and/or amending the permissions section of your profile accordingly.
2.7. Please note that by submitting information regarding the Website, us, or our relationship, you irrevocably consent to us using such information on the Website and in any marketing or advertising materials without any compensation whatsoever. For this purpose, we will not specifically identify you in relation to such disclosure unless you consent to us doing so.
2.9. In addition to the other permissions granted herein or otherwise, you grant us permission to use your Personal Information to:
2.9.1. manage your personal account, if created;
2.9.2. facilitate our relationship with you and Network Clubs;
2.9.3. marketing of Pacific Links and Network Clubs;
2.9.4. facilitate analysis of and improvements to the Website and our business operations;
2.9.5. aggregate data related to visitation and use of the Website; and
2.9.6. facilitate our business relationships.
3. LAWFUL BASIS FOR PROCESSING
3.1. For individuals in the European Union (“EU”) and the European Economic Area (“EEA”) we will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent); via contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)); to protect vital interest; and when we have “legitimate interests”, which includes direct marketing. Where we process Information based on consent you may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.
3.3. Where we rely on legitimate interests as a basis for Personal Information processing, you have the right to object. We may process your Information, including personal data, for the purposes of our legitimate interests or for the legitimate interests of third parties including our partners, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your Personal Information to:
• Protect you, us, or others from threats (such as security threats or fraud)
• Comply with laws that apply to us
• Enable or administer our business, such as for quality control, consolidated reporting, and customer service
• Manage corporate transactions, such as mergers or acquisitions
• Engage in direct marketing;
• Understand and improve our business or customer relationships generally
If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us at email@example.com.
4. DISCLOSURE OF YOUR PERSONAL INFORMATION
4.4. The third parties with whom we share your information, including without limitation Network Clubs, may contact you about other products or services that may be of interest to you. They may contact you by post, telephone, mobile messaging (e.g. SMS, MMS, etc.) as well as by e-mail or social media. If you change your mind about being contacted by these companies in the future, please let us know by using the contact details set out in section 14 below and/or by amending your personal account accordingly, if applicable.
4.6. We may use the Personal Information that you provide to us if we are under a duty to disclose or share your Personal Information in order to comply with, and/or where we believe we are under a duty to comply with, any applicable legal obligation; or in order to protect our rights and enforce any agreement or support any relationship we have with you. This includes exchanging Personal Information with other companies and other organisations for the purposes of fraud protection and prevention.
5. COOKIES AND LOCATION CONTROLS
5.2. Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the site. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are only used where you ask us to remember your login details for when you next return to the site and will last for a longer duration.
5.3. Some of the cookies used by our Website are served by us, and some are served by third parties who are delivering services on our behalf. Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note that by blocking or deleting cookies used on our Website you may not be able to take full advantage of our Website if you do so.
5.4. We use Google Analytics, which Google uses the information shared by sites and apps to deliver our Service, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on our partners’ sites and apps. To learn more about the Company’s use of Google Analytics and what Google Analytics does, please see How Google uses information from sites or apps that use or services.
Updates to your browner or operating system may affect functionality of the opt-out add-on. Learn about managing add-ons for Chrome here. If you are not using Chrome, check directly with the manufacturer of your browser to determine whether add-ons will function properly on the browser version that you are using.
The latest versions of Internet Explorer sometimes load the Google Analytics opt-out add-on after sending data to Google Analytics. Therefore, if you are using Internet Explorer, the add-on will set cookies on your computer. These cookies ensure that any collected data is immediately deleted from the collection server. Please make sure that third party cookies aren’t disabled for your Internet Explorer browser. If you delete your cookies, the add-on will, within a short timeframe, reset these cookies to ensure that your Google Analytics browser add-on remains fully functional.
The Google Analytics opt-out browser add-on does not prevent data from being sent to the website itself or in other ways to web analytics services.
Learn about how Google Analytics collects, uses, and processes data here.
Learn about the cookies Google Analytics uses here.
5.6. We are continually striving to develop improved ways of managing your cookie preferences. As new technologies and solutions emerge, the cookies policy set forth in this section 5 may be updated to reflect any such advances in technology and preference management tools.
5.7. You may be able to set your Internet browser or mobile device to block cookies or other tracking/recording tools, including cookies associated with our websites or Services, or to indicate when a cookie is being set by us. However, it is important to remember that our Website or Service may not function properly if your cookies or location are disabled. We do not support the Do Not Track browser setting. Do Not Track (or DNT) is a preference you can set in your browser to let the websites that you visit know that you do not want them collecting certain information about you. For information and instructions about how to manage your cookies, refer to your Internet browser’s or mobile device’s technical information. Further information on how to adjust your cookie preferences through your browser is available at the external, third-party informational website www.allaboutcookies.org.
6. SECURITY AND DATA RETENTION
6.1. We take technical, administrative and physical security steps designed to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We have implemented procedures designed to limit the dissemination of your Personal Information to only personnel with a business "need-to-know" or whose duties reasonably require such information.
6.3. Where you have chosen a password which allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. Unless we negligently disclose your password to a third party, we will not be liable for any unauthorised transactions entered into using your name and password.
7. ACCESSING AND UPDATING
7.1. You have the right to see the Personal Information we hold about you ("Access Request") and to ask us to make any changes to ensure that it is accurate and up to date. Upon receipt of your written request, we will, within a reasonable time, provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner. We will advise you in writing if we cannot meet your requests within this time limit.
7.2. If you wish to do this, please contact us using the contact details set out in section 14 below. We may charge you a fee to meet our administrative costs in providing this information to you.
7.3. Please note that we may request that you provide sufficient identification before we provide you with the Personal Information that we hold. Any such identifying information shall be used only for this purpose.
8. CASL DISCLOSURE
8.1. Canada’s Anti-Spam Legislation (“CASL”) sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them.
8.2. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org and we will promptly remove you from email communications.
9. EU/EEA DATA SUBJECT RIGHTS
9.1. We are not established in the EEA; however, individuals located in certain countries, including the EU/EEA, have certain rights related to their Personal Information subject to any exemptions provided by law. Subject to any exemptions provided by law, EU/EEA users have the following rights:
• Delete Personal Information: You can ask us to erase or delete all or some of your Personal Information (e.g., if it is no longer necessary to provide the Service to you).
• Change or Correct Personal Information: You can edit some of your Personal Information through your account. You can also ask us to change, update or fix your Personal Information in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Personal Information: You can ask us to stop using all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Information is inaccurate or unlawfully held).
• Right to Object: If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Right to Access and/or Take Your Personal Information: You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine-readable form.
• You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries are available here.)
You may contact us using the contact information below, and we will consider your request in accordance with applicable laws.
10. CALIFORNIA PRIVACY RIGHTS
10.1. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: P.O. Box 128, Sparta MI 49345. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.
10.2. California Do Not Track Disclosure: Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.
11. CAN-SPAM ACT DISCLOSURE
11.1. The CAN-SPAM Act sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them.
11.2. If, at any time, you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from email communications.
15.1. You can help by keeping us informed of any changes such as a change of delivery address for Orders or telephone number. If you would like to access your information, if you have any comments, queries and requests relating to our use of your Personal Information or if you find any errors in our information about you, please contact us at:
Pacific Links Privacy Officer
c/o Pacific Links Canada Services Inc.
255 Duncan Mills Road, Suite 307
Toronto, Ontario, Canada
Pacific Links International ("Pacific Links") provides members with a premium golf experience through an
innovative international membership structure focused on the Asian golfer.
Pacific Links Golf Network offers them access to the finest collection of high
quality golf clubs in the world. Since 2012, the Pacific Links Golf Network of
Affiliated and Reciprocal clubs has grown to almost 350 properties located in
32 countries around the world. We are committed to protecting the privacy of the personal information of members of Pacific Links and visitors to our Website.
- the “Website”) or otherwise.
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, 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 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 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:
- 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.
255 Duncan Mills, Suite 307
Toronto, ON, Canada
TEL.: 647 350 4200
All inquiries and concerns will be fully investigated and responded to by our Privacy Officer.