PRIVACY POLICY
6358098 Canada Inc., operating under
Golf Exécutif Montréal
(514) 767-1855
999 Boulevard de la Forêt, Île des Soeurs, Montréal, QC, H3E 1X9
Our goal at the Golf Exécutif Montréal (the « Golf », « we » or « us ») is to provide our clients and visitors (« you » , « clients » or « visitors ») to our website (the « Website ») with excellent service. In providing you with this service, we may collect, use and disclose certain personal information (as defined in section 2.1) about you and therefore protecting your personal information is a priority.
We respect your privacy and manage your personal information reasonably, with appropriate safeguards, particularly for sensitive personal information. We fully comply with applicable privacy legislation, which sets out the basic rules for how organizations may collect, use and disclose personal information.
In this privacy policy (the « Privacy Policy »), we will inform you about how and why we collect, use and disclose your personal information and how we obtain your express consent where required.
Our privacy commitment includes ensuring the accuracy, confidentiality, and security of personal information collected and allowing you to request access to, and correct, as needed, your personal information.
Please note that we may update this Privacy Policy from time to time and amend it to reflect changes in legislation or other business changes, and your continued use of our services or use of our Website signifies your consent to such changes. You can review this Privacy Policy at any time on our Website at https://www.golfexecutifmontreal.com/en/privacy-policy/ or in person at the Golf to stay informed as to how we are protecting your personal information.
SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to the Golf, its employees, its associated corporations and their respective employees as well as to any service providers collecting, using or disclosing personal information on behalf of the Golf. When you provide your personal information to us by subscribing to a package, or otherwise using the Golf features or services, including our Website, you agree to the terms of this Privacy Policy and consent to our collecting, using and disclosing of your personal information as set out in this Privacy Policy.
COLLECTING PERSONAL INFORMATION
The term « personal information » is used in this Privacy Policy to mean information about an identifiable individual but does not include business contact information, publicly available information or statistical and aggregated information that cannot be used to identify you as an individual.
Unless the purposes for collecting personal information are obvious and you voluntarily provide your personal information for those purposes, we will tell you the reasons for collecting your personal information, either orally or in writing, before or at the time of collection.
The personal information that we collect may include: name, residential and email address and other contact information, date of birth, emergency contact, information about your employment and other information related to your use of our facilities. We may also collect your credit card number in certain cases. For visitors to our Website, we may collect IP addresses as set out below.
Generally, we only collect personal information that is necessary to fulfill the following purposes:
• to subscribe to one of the packages offered by the Golf and to best provide our services;
• to better understand your needs and preferences;
• to recommend programs, merchandise and services if you have expressly consented to this or if you have purchased a package or otherwise used our services;
• to develop, improve, market and provide programs and services such as by client surveys or special offers;
• to facilitate and enhance your use of our Website;
• for fundraising;
• for collection purposes;
• to prevent fraud with respect to both you and us; and
• as otherwise permitted or required by law or regulation.
We collect personal information about you directly from you and in some cases automatically when you visit or use our Website.
NON-PERSONAL INFORMATION AND WEBSITE USAGE
We gather certain broad non-personal information about Website use. This aggregated information, which does not identify you as an individual, includes the number of unique visitors, the frequency with which they visit and the programs and services preferred. We look at the data in summary form, rather than on an individual basis. We gather this information so we can, for example, learn how many people visit our Website, see which pages are the most and least viewed, and identify which websites are referring visitors to our Website and related information. The non personal information we collect is used to measure and improve the effectiveness of our Website or enhance the experience for our clients and visitors. We treat this information as personal information if it is ever associated with your contact information or with the information that you provided the Golf with upon the purchase of a package offered by the Golf or on another occasion.
Cookies. We use cookies to collect information about how the Website is used. A cookie is a small removable text file that is stored on your device that identify browser/IP address each time you visit our Website. An IP address is the unique numeric identifier assigned to each computer browser accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by your Internet Service Provider (ISP), your IP address can be used to identify the computer originating a message. We may use cookies to create profiles of visitors, detailing their stated and inferred preferences, in order to facilitate a more personalized web browsing experience, including by providing more personalized products and services that are tailored to your needs. We may also use cookies to collect aggregated statistical information about how our Website and its features are used. If you are a package holder and create a holder account or otherwise join our Website, these cookies enable you to store your password for fast logon and other conveniences.
Most web browsers contain controls that allow you to block or delete cookies (this is usually done through privacy settings), or to notify you when a request to set one is made. You do not need to enable cookies to visit our Website; however, certain features of our Website may depend on the use of cookies. Accordingly, if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies.
Pixel tags, also known as beacons or clear GIFs, help us better manage content on our Website by informing us what content is effective. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly on Website pages. A La Presse pixel tag may be added to our Website pages that creates a cookie on visitors’ computers and is automatically deleted from their computers after sixty (60) days. This same pixel tag may record the IP address of the visitor to our Website in the La Presse database and be used to retarget them with ads (remarketing). We have been advised that an IP address which is collected is deleted from the La Presse database after seven (7) days.
Google Analytics. The Golf currently uses Google Analytics to provide statistics about the visitors to our Website. Google Analytics tracks and analyzes statistical information, including, without limitation, search engines, display advertising, pay per-click networks, email marketing and digital collateral such as links within PDF documents. A Google Analytics Global Site Tag is added to all our Website pages to collect the IP address of visitors to our Website and certain non-identifiable information. The Site Tag is anonymized as soon as technically feasible before being stored in Google’s database. Information on visitors Website use is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt out of our use of Google Analytics on your data by visiting the Google Analytics opt out page at http://www.google.com/settings/ads.
Google Ads. We may use Google Ads Remarketing to advertise across the Internet and to advertise on third party websites (including Google) to previous visitors to our Website. Google Ads Remarketing will display ads to you based on what parts of the Website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors to our Website or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our Website, so that they may show you ads relating to that page. If you do not wish to participate in our use of Google Ads Remarketing, you can opt out by visiting Google’s Ads Preferences Manager at http://www.google.com/ads/preferences.
CONSENT
We will obtain your consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without your consent).
Your consent may be provided in writing or electronically, and particularly may be collected by an authorized representative of the Golf when you enter into a package subscription contract. In some cases, your consent may be implied where the purpose for collecting, using or disclosing your personal information would be considered obvious and you voluntarily provide personal information for that purpose. Your consent may also be implied where you are given reasonable notice and an opportunity to opt-out of your personal information being used for mailings to market new services or products or fundraising, and you have not opted out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service to you or the withdrawal of consent would frustrate the performance of a legal obligation), you can withhold or withdraw your consent for the Golf to use your personal information in certain ways. If you decide to withhold or withdraw your consent to certain uses of your personal information, this may restrict our ability to provide you with particular services. If this happens, we will explain the situation to assist you in making your decision.
We may collect, use or disclose personal information without your knowledge or consent in certain limited circumstances which the law permits, including the following:
• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency situation that threatens an individual’s life, health, or personal security;
• When the personal information is considered at law to be publicly available (e.g., where published in a telephone directory);
• When we require legal advice from a lawyer;
• For collection purposes;
• To prevent fraud with respect to both you and us; and
• To investigate an actual or anticipated breach of an agreement or a contravention of law.
USING AND DISCLOSING PERSONAL INFORMATION
We will only use or disclose your personal information where necessary to fulfill the purposes identified above, or such other purposes as may be identified at the time of collection.
We will not use or disclose your personal information for any additional purpose unless we obtain your further consent to do so.
Except as provided in section 5.4, we will not sell or share client or visitor lists or other personal information to third parties unless we obtain your express consent to do so or as permitted by law.
From time to time, we may share personal information with third parties who have been engaged to carry out certain functions or services on our behalf, such as to process the mailing of information to clients, or to administer certain events. In each case, we will share only the personal information required by the third party to perform the function or services for which they have been retained. All service providers are required to keep personal information confidential, protect it using the same safeguards as employed by the Golf, use it only for the purpose for which it was disclosed and not disclose the information to third parties for their own use.
In some cases, your personal information may be stored or processed outside of Canada and may therefore be subject to the laws of those countries.
RETAINING PERSONAL INFORMATION
We will retain personal information only as long as is necessary to fulfill the identified purposes or as required by law.
If we use personal information to make a decision that directly affects the client or visitor, we will retain that personal information for at least one year so that the individual has a reasonable opportunity to request access to it.
SECURING PERSONAL INFORMATION
We are committed to ensuring the security of your personal information and protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
We protect personal information using a range of measures, consistent with industry practices for the protection of similar information. These safeguards will include the following methods of protection:
(a) Physical measures such as locked filing cabinets and restricted access to offices and facilities;
(b) Organizational measures such as restricted, “need-to-know” access; and
(c) Technological measures such as the use of passwords, encryption and intrusion detection software.
Any service providers performing services on our behalf must provide the same level of security safeguards as the Golf itself provides.
We will use appropriate security measures when destroying client’s or visitor’s personal information such as ensuring deletion or anonymization of electronically stored information and safely disposing of all paper documents.
We will continually review and update our security policies and controls as technology changes to ensure that our security systems are appropriate and effective.
PROVIDING ACCESS TO YOUR PERSONAL INFORMATION
You have a right to access your personal information, subject to limited exceptions provided by law, such as information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial reasons, or information that is subject to solicitor-client privilege.
We will make the requested information available within thirty (30) business days, or provide written notice of an extension where additional time is required to fulfill the request.
A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform you of the cost and request further direction from the client or visitor on whether or not we should proceed with the request.
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 the client or visitor.
ENSURING THE ACCURACY OF YOUR PERSONAL INFORMATION
We will make reasonable efforts to ensure that your personal information is accurate, complete and up-to-date, particularly where it may be used to make a decision about you or disclosed to another organization.
You may request correction of your personal information at any time if you determine that it is inaccurate or incomplete. A correction request may be made by contacting the Golf by phone at (514) 767‑1855, by email at vieprivee@golfexecutifmontreal.com or in person at the Golf.
If your personal information is shown to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we have disclosed the personal information in the previous year.
QUESTIONS OR COMPLAINTS
Protecting your personal information is a priority at the Golf. If you have any questions or complaints about the collection, use and disclosure of your personal information, please contact us at the following address:
Golf Exécutif Montréal
999 Boulevard de la Forêt
Île des Soeurs, Montréal, QC, H3E 1X9
vieprivee@golfexecutifmontreal.comRevised: September 1st, 2018