1. PURPOSE
 
To protect the privacy and confidentiality of Member and Guest information.
 
2. POLICY
 
Your privacy is important to the London Club, Limited (“the Club”). We strive to provide you with the best customer service, treating you fairly and with respect. You have shared important personal information with us, and you did this so we could serve you better. To uphold your trust, we are also committed to meeting the privacy standards applicable to you. The purpose of this policy is to tell you what personal information we collect, how we use it, whether we disclose it to anybody else, how long we keep it, and how you can request access to your personal information.
 
Accountability:
We are responsible for the personal information under our control, and we have designated a Privacy Officer (General manager) along with a Privacy working group (Controller, marketing Manager) who are responsible for our compliance with this policy and with privacy legislation. If you wish to contact our Privacy Officer and/or our Privacy working group, you can do one of the following:
 
By telephone – 519-434-6889
By email – [email protected]
By mail – 177 Queens Avenue, London, Ontario, N6A 1J1

This policy will always be available in the office, on the Club website, or by contacting the Privacy Officer and/or Privacy working group. Any changes or amendments will be posted on our website and announced through our newsletters.

 
Purposes of Collection:
We ask you for personal information to establish and serve you as a member or customer. We consider personal information to mean information recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. Business contact information is not generally considered personal information. We obtain most of our information about you directly from you. We collect personal information from Our Members, Our Prospective Members, Our Party Customers, Our Employees, guests of Members, and other individuals who make inquiries with us or purchase goods and services from the Club. Listed below are the types of personal information we collect, and for what purpose we collect this information.
 
 
 
Prospective Members:
Prospective members will be asked to complete a Membership Application form, which will require you to provide personal information for the purpose of assessing your eligibility for membership. This may include, but not be limited to, your name, address, phone number, email
address, birth date, payment information, occupation, and employment.
 
Members:
Once accepted to membership, we may collect additional personal information from you in the course of providing our services to you. This may include your name, address, phone number, e-mail address, which will be used for general business use and inclusion in the annually
produced Membership Roster (in print and electronic form through the members-only password protected area of our website). Your membership status will also be published in our Membership Roster. This will permit us and other members of the Club to contact you.
 
We may also take your photograph for identification purposes and publication on our on- line Membership Roster and our Point-of-Sale system. From time to time, we may also take photographs during Club events. Photographs may be published throughout the Club and on
our website.
 
We may continue to use your birth date to determine your eligibility for membership classifications or other products for which you may qualify because of your particular age group.
 
We may continue to use your payment information such as account number, credit card number, and the name and address of your bank. This may be used to assess your eligibility for membership in the Club. We will also use this information to process payments of membership
fees and charges for other goods and services. We will also maintain information regarding the purchases you have made at the Club for accounting purposes.
 
We may continue to use information about your occupation and employer to determine potential areas of expertise of our members, to possibly seek insight on specialized issues from you. Further, as we make every effort to support our members, it may be used when seeking a specific good or service for the Club for which we are seeking a supplier.
 
Parties/Events:
When you are organizing a private party/event at the Club, we will need to collect personal information from you to provide our services to you. This may include, but not be limited to, your name, address, phone number, email address and payment information (including
credit card number).
 
Guests and Other Individuals:
If you visit the Club as the guest of a member, if you make inquiries about the Club, and/or if you purchase goods or services at the Club or provide goods and services to the Club, we may collect personal information from you. This may include your name, address, e-mail address, phone number, and payment information (including credit card number) where it is necessary for the purpose of providing our goods and services to you, receiving goods and services from you, or for answering your inquiries.
 
Consent:
Consent is required for the collection of personal information and the subsequent use or disclosure of this information. Your provision of personal information to the Club means that you agree and consent that we may collect, use, and disclose your personal information in
accordance with this Privacy Policy. In addition, specific authorizations or consents may be obtained from time to time. The reasonable expectations of the individual are considered when using this information.
 
If you submit an application on behalf of a family member, you represent that you have obtained consent from them, even though they may not be present during the application process, to the collection, use and disclosure of their personal information for the identified purposes.
 
Limiting of Collection, Use, Disclosure:
We only collect the information we need and only use it for the purposes explained to you. When you apply for membership, we indicate in the application form how we intend to use your information. Likewise, when a private party customer signs a Banquet Contract, we will indicate on the agreement how we intend to use your information. If we wish in the future to use it for another purpose, we will ask for your consent at that time.
 
We may contact employers or other personal references to verify information that you have given us. We will not do this without your consent, but please remember that if you do not give your consent we may not be able to grant your membership application.
 
In some cases, we may engage service providers located outside of Canada and we may need to share your personal information with them for the purpose of obtaining services. Therefore, some personal information collected by the Club may be retained in countries other than
Canada (such as the United States) where privacy laws may offer different levels of protection from those in Canada and Personal Information may be subject to access by and disclosure to law enforcement agencies in those jurisdictions.
 
We do not sell your personal information to third parties. We may share some of your
personal information with third parties such as our 3^rd party app and reciprocal clubs’ organizations of which we are affiliated with. We may also disclose your personal information where we are required or permitted by law to do so.
 
We retain your information only as long as it is required for the reasons it was collected. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. If there are legal requirements relating to the period of time which we must retain your personal information, we comply with those requirements. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.
 
Accuracy:
You have the right to request that personal information, which you believe to be inaccurate, be corrected. We will make every reasonable effort to keep your information accurate and up-to date. Having accurate information about you enables us to give you the best possible service.
 
You can help by keeping us informed of any changes, such as email update, if you move or change telephone numbers. If you find any errors in our information about you, let us know immediately.
 
Protecting Information:
We use your personal information only for the purposes identified above and access to your personal information is limited to those employees, service providers, members of the Board, and members of the London Club, Limited who need to have access to it.
 
We will protect your information with appropriate safeguards and security measures, by physical measures, organizational measures, and technological measures.
 
Providing Information Access:
You have a right to access the personal information which we have about you. We may charge a reasonable cost (e.g., photocopying, mail charges) to the individual making the request. The Club reserves the right to decline to provide access where the information request would
disclose the personal information of another individual, disclose trade secrets or other confidential business information, is subject to solicitor-client or litigation privilege, is not readily retrievable, could reasonably result in harm if disclosed, or other grounds permitted by law. If you wish to access this information you should contact our Privacy Officer and/or Privacy working group who will be pleased to assist you.
 
On-Line Privacy Concerns:
Our web servers track general information about visitors such as their domain name, time of visit, IP address, type and version of browser and which pages are being accessed. This information is used only in aggregate form, to better serve visitors by helping us to:
 
Manage our site;
Diagnose any technical problems; and
Improve the content of our website.
 
When you go directly to the information portion of our website and move from page to page, read pages or download content onto your computer, we learn which pages are visited, what content is downloaded, and the (browser) address of websites that was visited immediately
before coming to our website. However, none of this is directly associated with you as an individual. It is measured only in aggregate.
 
We use this information to find out how many people visit our website and which sections of the site is visited most frequently. This helps us to know what type of information is most useful to you so that we can improve our site and make it easier for you to access information. We
record the statistical information on the numbers of visitors to our website, but no information about you in particular will be kept or used.
 
When you send us an e-mail or when you ask us to respond to you by email, we learn your exact email address and any information you have included in the email. We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We will not sell your email address to anyone outside the London Club, Limited. We may use your email address to send you information about news or specific events that we believe may be of interest to you. If you don’t want us to contact you by email with this information, you may tell us so at any time. If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, you may ask us to remove you from the list at any time.
 
We have no control over the content of third-party websites that individuals may access through hyperlinks at our website. We encourage everyone to read the privacy policy of every website they visit.
 
Some portions of our website are accessible only to members and require a valid Login ID and password. Such personal information will only be used for authentication purposes and other purposes as stated in this Policy.
 
Respecting and Responding to your Privacy Concerns:
If you contact us, we will explain your options of refusing or withdrawing consent to the collection, use or release of your information, and we will record and respect your choices. In most cases, you are free to refuse or withdraw your consent at any time by contacting our Privacy Officer and/or Privacy working group.
 
If you have a complaint related to this Privacy Policy, or any of our procedures, please contact our Privacy Officer and/or Privacy working group. We will endeavor to respond to your request within 30 days. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Policy and practices if necessary.
 
If we are not able to resolve your concerns, you may contact the Office of the Privacy Commissioner of Canada at 613-995-8210 or toll-free at 1-800-282-1376.