Calgary Golf and Country Club – Mobile App Privacy Policy

Effective Date: March 9, 2026

1. Introduction and Scope

The Calgary Golf and Country Club ("the Club," "we," "our," or "us") is committed to protecting the privacy and security of our members' personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard the information you provide through the Club’s official mobile application ("the App"). This policy is designed to comply strictly with Alberta’s Personal Information Protection Act (PIPA) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Information We Collect

We collect only the personal information strictly necessary to provide Club services, process transactions, and enhance your member experience. We do not collect data for third-party marketing, commercial affiliation, or behavioral advertising.

• Account & Identity Information: Name, member number, email address, phone number, and profile picture (if uploaded for the member directory).
• Financial & Transactional Information: Records of chits, statements, and payments processed through the App.
• Operational Data: Tee time bookings, dining reservations, event registrations, and communication preferences.
• Diagnostic Data: Diagnostic data is used for troubleshooting, performance monitoring, and service improvement. Where feasible, this data is de-identified or aggregated and is not used by the Club to identify individual members.

3. Device Permissions and Location Data (Strictly Opt-In)

To utilize certain features, the App may request access to specific device hardware. You retain full control over these permissions via your mobile device's system settings:

• Camera and Photo Library: With your explicit permission, the App may access your device’s camera or photo library strictly for the purpose of allowing you to upload or update your member profile picture. We do not access your photos for any other reason.
• Location Data (Geofencing): Location data is only collected with your permission and only when needed to support location-based Club services. We do not use location data for continuous background tracking beyond what is required for the feature you choose to enable.

4. Protection of Financial Data

The Club adheres to strict Payment Card Industry Data Security Standards (PCI-DSS) to protect you and the Club from financial liability.

• Payment card information is processed directly by our PCI-DSS compliant payment service providers (e.g., Jonas Club Management). The Club does not store full payment card numbers in its own systems through the App.
• All financial transactions initiated within the App are tokenized and securely routed, keeping your sensitive financial data outside of the Club’s direct digital infrastructure.

5. How We Use Your Information

Your information is used exclusively for legitimate Club operations, including:

• Facilitating Club services, reservations, and member account management.
• Processing secure payments for member statements and services.
• Populating the secure, members-only directory (subject to your individual visibility settings).
• Sending important operational notices, security alerts, and Club communications.
• Responding to member inquiries and providing administrative support.

6. Third-Party Integrations & Data Hosting

The Club strictly prohibits the sale, trading, or renting of your personal data to third parties, advertising networks, or data brokers.

• Service Providers: We only share information with trusted third-party service providers (such as our App developer, Jonas Club Software) strictly for the purpose of hosting and operating the App's infrastructure. These providers act solely as data processors on behalf of the Club and are legally prohibited from using member data for their own secondary purposes.
• Data Storage and Transfer: Your data is hosted on secure servers managed by our service providers. If personal information is processed or stored outside Canada by our service providers, it may be subject to the laws of those jurisdictions and may be accessible to foreign courts, law enforcement, or regulatory authorities in accordance with those laws.
• External Links and Embedded Content: The App may feature embedded content (such as Google Maps for directions to the Club). Accessing these features may allow those third-party platforms to collect your IP address or basic interaction data as governed by their respective privacy policies. The Club does not proactively share your member data with these platforms.

7. Data Security and Retention

We implement robust administrative, technical, and physical security measures to protect your personal information against unauthorized access, loss, or alteration. We retain personal information only for as long as necessary to fulfill the identified purposes, to maintain appropriate Club records, and to meet legal, accounting, tax, and regulatory requirements. When personal information is no longer required, it will be securely destroyed, deleted, or anonymized, as appropriate.

8. Your Privacy Rights and Controls

Under PIPA and PIPEDA, you maintain full control over your personal information:

• Access and Correction: You have the right to request access to the personal information the Club holds about you and to request corrections to any inaccuracies.
• Revoking Permissions: You may withdraw consent for optional App features—such as location tracking, camera access, or push notifications—at any time. Revoking these permissions will not impact your ability to use the core financial and booking features of the App.

9. Changes to this Privacy Policy

The Club reserves the right to update or modify this Privacy Policy at any time to reflect changes in our App features, legal obligations, or security practices. When we do, we will revise the "Effective Date" at the top of this page. If we make material changes to how we treat your personal information, we will notify you through an in-app alert or via email. We encourage members to review this policy periodically.

10. Acknowledgment and Consent

By using the App, you acknowledge that your personal information will be handled in accordance with this Privacy Policy. Where required by law, the Club will obtain your consent for specific collections, uses, or disclosures of personal information.

11. Contact Information

If you have questions about this Privacy Policy, wish to access your personal data, request corrections, or have concerns regarding how your information is handled, please contact the Club’s privacy representative:

Lucas Culhane CPA, BCom
Controller
Calgary Golf and Country Club
919 – 50 Ave SW
Calgary, AB T2S 1H8
Main: 403-243-3530
Direct: 403-243-3695
Fax: 403-243-7262
Email: [email protected]
website: www.cgandcc.com