PRIVACY POLICY

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RLTC Privacy Policy

INTRODUCTION

The Rockcliffe Lawn Tennis Club (the “Club”) is a private-members tennis club located in Rockcliffe Park in the city of Ottawa, Ontario. Throughout the Club’s interactions with Members and the public at large, we are committed to respecting the privacy, confidentiality and security of Personal Information. Capitalized terms in this introduction and in the body of this Privacy Policy are defined below. 

This Privacy Policy is a formal statement of the principles and guidelines that govern our practices at the Club and ensure that we meet, and wherever possible, exceed, the requirements of the Personal Information Protection and Electronic Documents Act and all other applicable federal and provincial laws and regulations. 

The Club will continue to review the Privacy Policy on an ongoing basis to ensure that it remains compliant with legislation and current with the needs of the Club and the public at large.

The Club has established its Privacy Policy using the following eleven principles:

  1. Accountability

  2. Identifying purposes for collection of Personal Information

  3. Obtaining consent for collection, use or disclosure of Personal Information

  4. Limiting collection of Personal Information

  5. Limiting use, disclosure and retention of Personal Information

  6. Accuracy of Personal Information

  7. Security safeguards

  8. Openness concerning policies and practices

  9. Individual access to Personal Information

  10. Breach of Security Safeguards

  11. Challenging Compliance

 

This Privacy Policy does not apply with respect to the Business Contact Information, as defined below, of an Individual that the Club collects, uses or discloses solely for the purpose of communicating or facilitating communication with that Individual in relation to their employment, business or profession. 

 

DEFINITIONS

“Breach of Security Safeguards” means the loss of, unauthorized access to, or unauthorized disclosure of Personal Information resulting from a breach of the Club’s security safeguards;

“Business Contact Information” means any information that is used for the purpose of communicating or facilitating communication with an Individual in relation to their employment, business or profession, and includes, without limitation, that Individual’s:

  • Name;

  • Position name or title;

  • Work address; 

  • Work telephone number;

  • Work fax number; or

  • Work email address. 

 

“Business Transaction” means a transaction that excludes a business transaction of which the primary purpose or result is the purchase, sale or other acquisition or disposition, or lease of Personal Information and includes:

  1. the purchase, sale or other acquisition or disposition of an organization or a part of an organization, or any of its assets;

  2. the merger or amalgamation of two or more organizations;

  3. the making of a loan or provision of other financing to an organization or a part of an organization;

  4. the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities of an organization;

  5. the lease or licensing of any of an organization’s assets; and

  6. any other prescribed arrangement between two or more organizations to conduct a business activity.

 

“Individual” means any Individual who provides the Club with Personal Information and includes, without limitation, Individuals who: (a) correspond with the Club; (b) are Website Users; or (c) are Members;

 

“Member” means an Individual who: (a) is a member of the Club; and / or (b) is an applicant for membership with the Club;

“Personal Information” means information about an identifiable Individual, but does not include aggregated information that cannot be associated with a specific Individual;

 

Personal Information includes, without limitation, an Individual’s:

  • Name;

  • Email address;

  • Residential mailing address;

  • Credit and financial information;

  • Birth dates; and

  • Billing records. 

 

“Services” means any services and / or products that the Club provides to Individuals including all membership services;

 

“Significant harm” means bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property;

 

“Club”, “we”, “our” means the Rockcliffe Lawn Tennis Club, its parents, subsidiaries, affiliates and their respective officers, directors, agents and suppliers;

 

“Club Websites” means a website owned, controlled or managed by the Club, including the following domain: www.rltennis.ca;

Website User” means a user of the Club Websites from which the Club collects Personal Information. 

 

1. ACCOUNTABILITY

1.1 The Club has designated one or more persons within senior management who are responsible for ensuring that the Club complies with the Privacy Policy. The persons so designated have the title of “Privacy Officer”. Other persons may be delegated to act on behalf of the Privacy Officer(s) or to take responsibility for the day-to-day collection and processing of Personal Information. Questions regarding the Club’s collection, use or disclosure of Personal Information or any other matter relating to this Privacy Policy can be directed to the Privacy Officer(s) by using the following contact coordinates: 

 

By mail at:      Privacy Officer

                        465 Lansdowne Rd. N

                        Ottawa, ON   K1M 0Y1

 

By email at:    privacy@rltennis.ca

 

By phone at:    613-749-5494

 

1.2 The Club is responsible for Personal Information in its possession or control, including information that has been transferred to a third party for processing. The Club shall use means to provide an appropriate level of protection while information is being processed by a third party (see Principle 7).

2. IDENTIFYING PURPOSES FOR COLLECTION OF PERSONAL INFORMATION

2.1 The Club shall identify orally, electronically or in writing, the purposes for which Personal Information is collected at or before the time the information is collected. Unless required by law, the Club shall not use or disclose for any new purpose Personal Information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the Individual.

2.2 We may ask for Personal Information only for the following purposes:

  1. To establish and maintain a relationship with Members of the Club;

  2. To allow us to provide ongoing Services and support;

  3. To facilitate communications between Members regarding member-related operations; 

  4. To bill for and collect payment for Services;

  5. To manage, develop and market the Club’s Services and operations; 

  6. To meet legal and regulatory requirements; 

  7. To obtain credit information or provide it to others; and

  1. For any other purpose with explicit consent.

 

2.3 During an Individual’s interaction with the Club Websites, the Club may use a browser feature called a “Cookie”. Cookies are small information packets created by the website and stored on the hard drive of a Website User’s computer. Cookies are used to collect information anonymously and track user patterns on the Club Websites. For example, Cookies might help us determine whether an Individual is a repeat or first-time visitor of the Club Websites.  When visiting the Club Websites, you will be prompted with a notice that explains our use of Cookies. The notice will also ask for your prior consent to receiving and using our cookies. Cookies will not be stored on your devices without your consent. You may withdraw your consent at any time. If you do not wish to consent to our Cookies, or if you withdraw your consent to our Cookies, you may not be able to access all or part of the Club Websites.

 

3. OBTAINING CONSENT FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL INFORMATION

3.1. The Club requires an Individual’s knowledge and consent for the collection, use or disclosure of Personal Information, except in the circumstances described in Sections 3.3 through 3.6 below, where knowledge or consent would be inappropriate. 

 

3.2 In general, implied consent for the Club to collect, use and disclose Personal Information for all identified purposes is obtained in the following circumstances: (1) when an Individual applies to become a Member or to otherwise obtain Services; (2) when an Individual uses Services; (3) when an Individual corresponds with the Club regarding Services; and (4) when an Individual visits the Club Websites. The Club may seek consent to use and disclose Personal Information after it has been collected, but before it is used or disclosed for a new purpose.

 

3.3  The Club may collect, use or disclose Personal Information without an Individual’s knowledge only in the following, exceptional circumstances:

  1. Where it is clearly in the interests of the Individual and consent cannot be obtained in a timely way, such as when the Individual is a minor, seriously ill or mentally incapacitated;

  2. Where it is in relation to the investigation of a breach of an agreement;

  3. Where it is necessary to assess, process or settle an insurance claim;

  4. Where such disclosure is to a lawyer representing the Club;

  5. Where it is to collect a debt;

  6. Where it is to comply with a subpoena, warrant or other court order;

  7. Where it is produced by an Individual in the course of their employment, business or profession and the collection, use or disclosure is consistent with the purposes for which the information was produced;

  8. Where it is for any other purpose otherwise required by law; 

  9. In the case of an emergency where the life, health or security of an individual is threatened; or

  10. If a Breach of Security Safeguards has occurred and disclosure to an organization or government institution that has been notified of the breach is made solely for the purpose of (1) reducing the risk of harm to the individual that could result from the breach; or (2) mitigating that harm.

 

The Club may also disclose Personal Information without an Individual’s knowledge: 

  1. For the purposes of investigating a breach of an agreement or contravention of a law that has been, is being or is about to be committed; and

  2. Detecting or suppressing fraud or of preventing fraud that is likely to be committed. 

 

and it would be reasonable to expect that disclosure with the knowledge or consent of an Individual would compromise the investigation or the ability to prevent, detect or suppress the fraud. 

 

3.5  The Club may also use and disclose Personal Information without an Individual’s knowledge in the context of a prospective Business Transaction if: 

  1. The Club and the other entity(ies) involved in the prospective Business Transaction have entered into an agreement that requires the organization that receives Personal Information:

    1. To use and disclose that information solely for purposes related to the Business Transaction; 

    2. To protect that information by security safeguards appropriate to the sensitivity of the information; and

  2. If the Business Transaction does not proceed, to return that information to the organization that disclosed it, or destroy it, within a reasonable time; and

  1. The Personal Information is necessary

    1. To determine whether to proceed with the Business Transaction; and 

    2. If the determination is made to proceed with the transaction, to complete it. 

 

3.6 If a prospective Business Transaction that is referred to in Section 3.5 is completed, the organizations that are party to that Business Transaction may use and disclose Personal Information, which was disclosed in accordance with Section 3.5, without the knowledge or consent of the Individual if:

  1. The organizations have entered into an agreement that requires them to:

    1. Use and disclose the Personal Information under their respective control solely for the purposes for which the Personal Information was collected, permitted to be used or disclosed before the Business Transaction was completed;

    2. To protect the Personal Information with security safeguards appropriate to the sensitivity of the information; and

    3. To give effect to any withdrawal of consent by an Individual; and 

  2. The Personal Information is necessary for carrying on the business or activity that was the object of the Business Transaction; and

  3. One of the parties notifies the Individual, within a reasonable time after the transaction is completed, that the Business Transaction has been completed and its Personal Information has been disclosed. 

 

3.7 In obtaining consent, the Club shall use reasonable efforts to ensure that the Individual is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Individual. 

 

3.8 The Club will require consent for the collection, use or disclosure of Personal Information as a condition of the supply of Services only if such collection, use or disclosure is required to fulfill the identified purposes.

 

3.9  In determining the appropriate form of consent, the Club shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Individual(s). 

 

3.10 An Individual may withdraw or vary consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact the Club at the contact coordinates listed in Section 1.1 for more information regarding the implications of withdrawing or varying consent.

 

4. LIMITING COLLECTION OF PERSONAL INFORMATION

4.1 The Club shall limit the collection of Personal Information to that which is necessary for appropriate purposes identified by the Club. The Club shall collect Personal Information by fair and lawful means.

 

4.2 The Club collects Personal Information primarily from Individuals, as opposed to third parties. 

 

4.3  The Club may also collect Personal Information from other sources such as credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.

 

5. LIMITING USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

5.1  The Club shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Individual or in the circumstances listed under Section 3.3, above. the Club shall retain Personal Information only as long as necessary for the fulfillment of those purposes or as required by law.

 

5.2 Internally, only Club staff with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Individuals. 

 

5.3       The Club shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous within a reasonable period of time after the Club no longer reasonably requires the Personal Information for legal or business purposes.

 

6. ACCURACY OF PERSONAL INFORMATION

 

6.1  The Club shall strive to keep Personal Information within its possession or control as accurate, complete, and up-to-date as is necessary to: (1) appropriately utilize that Personal Information for the purposes for which it was collected; and (2) minimize the likelihood that inappropriate information may be used to make a decision about an Individual.

 

6.2 The Club shall update Personal Information about Individuals as and when necessary to fulfill the identified purposes or upon notification by the Individual.

 

7. SECURITY SAFEGUARDS

7.1  The Club shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.

 

7.2  The Club shall strive to protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. the Club shall protect the information regardless of the format in which it is held.

 

7.3  The Club shall utilize technological, contractual and other means to provide an appropriate level of protection for Personal Information that is disclosed to third parties for processing. 

 

7.4  All of the Club’s staff with access to Personal Information shall be required to maintain the confidentiality of that information in accordance with this Privacy Policy.

 

7.5 The Club may store and process Personal Information in Canada or another country. In either case, the Personal Information is protected with appropriate security safeguards and subject to the privacy laws and regulations of the host jurisdiction. 

 

8. OPENNESS CONCERNING POLICIES AND PRACTICE

8.1       The Club is committed to informing Individuals about its Privacy Policy and related practices.

8.2       The Club shall make information about its policies and practices as accessible and easy to understand as possible, including:

  1. The title and contact information of the person or persons responsible for enforcement of the Privacy Policy;

  2. Contact information for forwarding any privacy complaints;

  3. The means of gaining access to one’s own Personal Information held by the Club; and

  4. A description of the type of Personal Information held by the Club.

 

8.3  All information relating to the Privacy Policy and related practices can be obtained by sending a request by contacting the Privacy Officer at the coordinates listed in Section 1.1. 

 

8.4 The Club will make available information to assist Individuals in exercising choices regarding the use of their Personal Information.

 

9. INDIVIDUAL ACCESS TO PERSONAL INFORMATION

9.1  The Club shall inform an Individual of the existence, use, and disclosure of their Personal Information upon request, subject to the limitations described in Section 9.3, below. 

 

9.2  Individuals can seek access to their Personal Information by contacting the Privacy Officer(s) at the coordinates listed in Section 1.1. The Club shall afford Individuals a reasonable opportunity to review the Personal Information in the Individual’s file, subject to the limitations described in Section 9.3, below. Personal Information shall be provided in understandable form within a reasonable time and at a minimal or no cost. Individuals may identify any issues with the accuracy or completeness of the information provided and the Club will amend it as needed.

 

9.3 In certain situations, the Club may not be able to provide access to all the Personal Information that it holds about an Individual. For example, the Club may not provide access to information if doing so would likely reveal Personal Information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, the Club may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor – client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement, or a contravention of federal, provincial or foreign laws and / or regulations. If access to Personal Information cannot be provided, the Club shall provide the reasons for denying access upon request unless prevented from doing so by lawful means.

 

9.4  Upon request, the Club shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of use, the Club will provide information about the purposes for which the Personal Information has been and is being used by the organization. In providing an account of disclosure, the Club shall provide a list of organizations to which it may have disclosed Personal Information about the Individual when it is not possible to provide an actual list. 

 

9.5  In order to safeguard Personal Information, an Individual may be required to provide sufficient identification information to permit the Club to account for the existence, use and disclosure of Personal Information and to authorize access to the Individual’s file. Any such information shall be used only for this purpose.

 

9.6       The Club shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Individual’s file. In accordance with the terms of this Privacy Policy the Club may transmit to third parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.

 

10. BREACH OF SECURITY SAFEGUARDS

10.1  The Club is committed to protecting the Personal Information of Individuals in accordance with the safeguards described in this Privacy Policy. In the event of a Breach of Security Safeguards, the Club shall report directly to the Office of the Privacy Commissioner if the breach creates a real risk of significant harm to an Individual.

10.2 Unless prohibited by law, the Club shall, as soon as feasible, notify an Individual of any Breach of Security Safeguards involving the Individual’s Personal Information under the organization’s control if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the Individual. The notification will allow the Individual to understand the significance of the breach and to take steps, if any are possible, to reduce the risk of harm that could result from it or to mitigate that harm. 

10.3  In assessing whether there exists a real risk of significant harm, the Club will consider factors including: (a) the sensitivity of the Personal Information involved in the breach; and (b) the probability that the Personal Information has been, is being or will be misused.

10.4 The Club shall, as soon as feasible, notify any other organization, government institution or part of a government institution of a Breach of Security Safeguards if it believes that the other organization or government institution may be able to reduce the risk of harm that could result from it or mitigate that harm. 

10.5     The Club shall keep and maintain a record of every Breach of Security Safeguards involving Personal Information under its control for a period of 24 months after the day on which the Club determines that the breach has occurred.

 

11. CHALLENGING COMPLIANCE

11.1  An Individual may address a challenge concerning compliance with the above principles to the Privacy Officer at the contact coordinates listed in Section 1.1.

 

11.2  The Club shall maintain procedures for addressing and responding to all inquiries or complaints from Individuals about the Club’s handling of Personal Information.

 

11.3  The Club shall inform Individuals about the existence of these procedures as well as the availability of complaint procedures.

 

11.4  The Club shall investigate all complaints concerning compliance with the Privacy Policy. If a complaint is found to be justified, the Club shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The complainant Individual shall be informed of the outcome of the investigation regarding their complaint.

 

11.5 An Individual may seek advice from the Office of the Privacy Commissioner of Canada (at 1-800-282-1376), and, if appropriate, file a written complaint with the Commissioner’s office. However, the Individual is encouraged to use the Club’s internal information and complaint procedures first. 

Consent for Collect of Personal Information 

When applying for membership or using the Rockcliffe Lawn Tennis Club (the “Club”) services, you must provide personal information, including credit and financial information, to the Club. This information is collected, used and disclosed in accordance with the Club’s Privacy Policy, which follows this message. For additional certainty, you agree to the Club’s collection of your personal information, including your credit and financial information, for the following purposes: 

  1. To allow the Club to establish and maintain a relationship with you, as a member or prospective member;

  2. To allow us to provide ongoing services and support;

  3. To facilitate communications between members regarding member-related operations;

  4. To bill and collect payment for services;

  5. To manage, develop and market the Club’s services and operations;

  6. To meet legal and regulatory requirements; and

  7. To obtain credit information or provide it to others.

By checking the box at the bottom of the Member Registration page, you indicate that you have read and understood this message and the Club’s Privacy Policy and that you consent and agree to the Club’s collection, use and disclosure of your personal information pursuant to these terms. If you do not agree, you may not become a member of the Club or use Club services.

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