Privacy Policy for the App - Uplands Golf Club

Privacy Policy

Policy Name: Privacy Policy	Policy Number: ADM-26-001
Policy Scope: General Manager, members	Policy Owner: GM
Effective Date: June 26, 2026	Review Date: June 2029

1.0 Purpose
The Uplands Golf Club (UGC) is committed to protecting the privacy and security of individual’s Personal Information, both through the normal course of business, and for those who

visit “http://www.uplandsgolfclub.com” (the “Website”), or
use the UGC App.

The purpose of this Privacy Policy is to inform individuals what Personal Information may be collected from them by UGC when conducting normal business activities, as well as when individuals visit the UGC Website.
This Privacy Policy also outlines:

how such information will be used by UGC and/or other persons or entities with whom

such information may be shared,

an individual’s choices regarding the collection, use and distribution of such information,
an individual’s ability to edit, update, correct or delete such information, and
the security procedures that UGC has implemented to protect an individual’s privacy.

2.0 Definitions
“Consent” means voluntary agreement to the collection, use and disclosure of Personal Information for specified purposes. Consent may be express or implied. Express Consent can be given orally or in writing. Implied Consent exists when UGC can reasonably infer Consent based upon a UGC member’s action or inaction. Implied Consent to publish a UGC member’s name, address, phone number and photo is given in the application for membership. Implied Consent for the use of photos at events and other activities at the Club. Implied Consent to publishing the name, address, and phone number of a participant is given using registration forms by all members in tournaments, or golf programs.

“Geofence” means a virtual boundary that can be placed around a particular geographic area, using satellite technology, in order to track, record or limit the movements of a person or vehicle.

“Personal Information” is any information that can be used to distinguish, identify, or contact a specific individual. This information can include an individual's opinions or beliefs, as well as facts about, or related to, the individual. Examples of personal information include social insurance number, age, marital status, and language. Exceptions: business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered Personal Information.

“Precise Location Data” means any real-time, granular information pinpointing the geographic position of a user’s mobile device. This data is collected via the UGC Member Mobile Application (“the App”) utilizing technologies such as Global Positioning Systems (GPS), Wi-Fi network triangulation, cellular towers, and Bluetooth low-energy beacons.

“Privacy Officer” is the UGC General Manager who is accountable for ensuring compliance with the Privacy Policy by all UGC Committees, staff, members and contractors.

“UGC App” refers to the Jonas System Clubhouse Online App which provides ready links to the UGC website and related services to its members utilizing GPS, Wi-Fi, cellular towers and Bluetooth low-energy beacons.

3.0 Scope
Federal and Provincial privacy legislation was implemented in 2000 and 2004 – the Federal legislation, ‘Personal Information Protection and Electronic Documents Act’ (PIPEDA) in 2000, and the Provincial legislation ‘Personal Information Protection Act’ (PIPA) in 2004. Both pieces of legislation apply to UGC activities related to Personal Information as UGC is registered as a corporation under the Societies Act and therefore considered a private sector organization under the privacy legislation. This Privacy Policy guides UGC activities related to Personal Information and the rights of UGC members and individuals doing business with UGC. It applies to the activities of all Committees and staff.

4.0 Policy Statement

4.1 Accountability
UGC is accountable and responsible for Personal Information under its control. UGC has designated a Privacy Officer who is accountable for UGC’s compliance with this policy. The UGC Secretary is responsible for overseeing implementation of the Privacy Policy on behalf of the UGC Executive Committee and Board.

4.2 Identifying the Purpose for Personal Information Collection
UGC will state the purpose for collection of Personal Information when it is collected. The Personal Information will be used only for the identified purpose.

4.2.1 Mobile Geofencing Purposes: When members download and interact with the App, UGC establishes geofences around club property, including the clubhouse, practice facilities, and golf course perimeter, to automate and improve club operations. Precise Location Data may only be collected for the following purposes:

Member Service Automation: Triggering arrival notifications to ensure operations staff have the member’s golf bags ready for play.
Health and Safety Alerts: Automatically matching a member's location inside a dining geofence with saved profile notes to alert food & beverage staff of critical food allergies.
Emergency Communication: Delivering critical safety alerts and course evacuation protocols directly to members' devices during lightning or severe weather incidents.
Targeted Enhancements: Pushing real-time notifications about club specials, pro-shop events, or dining promotions when the member is on club property.
On Course Monitoring: Pace of play or real-time notifications on entry into environmentally sensitive areas.

4.3 Consent
UGC will obtain consent to collect, use and/or disclose Personal Information as required to conduct UGC business and provide service to UGC members, except where UGC is required by law to do so without consent. Consent can be expressed, implied or given through an authorized representative, such as a lawyer or agent. A UGC member may withdraw consent for use of provided information via written notice to the Privacy Officer where their Personal Information is not required to administer their accounts or for other bona fide UGC business or communication reasons.

4.3.1 Location Tracking Consent and Opt-Out:
Geofencing functions require express, opt-in consent from the user via their device's operating system settings. UGC will not track a member's location unless they explicitly permit the App to access location services. Members retain full control and may alter these permissions or completely opt out at any time by modifying their device settings (e.g., changing location access to "Never"). Members acknowledge that disabling location services will prevent the App from deploying automated arrival notifications, real-time allergy alerts, and localized safety warnings.

4.4 Sharing Information
UGC will not sell or trade Personal Information to unaffiliated third parties, except successors in interest, without Consent. UGC reserves the right to contact UGC members regarding account status, changes to membership agreements, campaigning, and balloting for UGC elections, and any other matter that might affect members’ service and/or records. UGC may disclose Personal Information in special cases when there is reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) UGC's rights or property, other UGC Website users, other UGC members or anyone else that could be harmed by such activities. UGC will disclose Personal Information when the law requires it upon written request from the appropriate authority.

4.4.1 Application Service Processors: UGC shares Precise Location Data with our mobile application developer and club management software vendors (e.g., Jonas Club Software) strictly to execute the geofenced features outlined in Section 4.2.1. These third-party processors are

bound by strict confidentiality agreements,
prohibited from selling, renting, or repurposing member location data, and
required to maintain security standards compliant with PIPA (pp. 2, 5).

4.5 Limits on Collection
UGC will limit collection of Personal Information to that which is reasonable and necessary to maintain member, guest and customer relationships with UGC.

4.6 Limits on Use and Disclosure
Personal Information will only be used or disclosed for the purposes described in this Privacy Policy. UGC will destroy Personal Information records as soon as it is reasonable to assume that retention is no longer necessary.

4.7 Protection of Children
The Website is a general audience website that is not specifically designed or targeted at children. UGC does not knowingly collect, use, or disseminate any personally identifiable information from children under the age of 13. If, however, UGC becomes aware that personally identifiable information regarding a child under the age of 13 has been collected at the Website, UGC will use such information for the sole purpose of contacting a parent or guardian of the child to obtain verifiable parental consent. If UGC cannot obtain Consent after a reasonable period, or if when contacted, a parent or guardian requests that UGC does not use or maintain such information, UGC will make every reasonable effort to delete it from its records. Upon request by a parent or guardian, UGC will provide a description of the specific types of Personal Information collected from a child who is under the age of 13.

4.8 Accuracy
UGC will endeavor to ensure that the Personal Information it is using, or disclosing is as accurate and complete as possible.

4.9 Safeguarding Information
UGC will protect the Personal Information in its custody or control by making security arrangements to prevent unauthorized access, collection, or use.

4.10 Third Party Links (contained within Website)
Occasionally, at its discretion, UGC may include or offer third party products or services on its Website or include links to the websites of other parties. These third-party websites have separate and independent privacy policies. UGC has no responsibility or liability for the content and activities of these linked sites. Nonetheless, UGC seeks to protect the integrity of its Website and welcomes any feedback about these sites. As always, it is prudent to review the website privacy policy of any website that visited as the terms and conditions of those websites could be different from the UGC Website.

4.11 Openness and Compliance
UGC is open about the policies and procedures it uses to protect Personal Information. These policies and procedures will be made available in writing and electronically to UGC members and, with the approval of the Privacy Officer, to other groups for bona fide purposes.

4.12 Providing Access
UGC members and registered UGC program participants have the right to access their Personal Information held by UGC. Upon written request, unless prevented by law, UGC will provide access in a timely manner to their Personal Information in UGC’s control and a description of how this information is used.

4.13 Complaints
Complaints concerning handling of a UGC member’s Personal Information will be accepted by the Privacy Officer in writing. The Privacy Officer will provide a written response to the UGC member making the complaint and provide a copy of the reply to the Executive Committee.

5.0 Procedures

5.1 Procedures for Privacy Policy Implementation
The UGC General Manager shall be responsible for the day-to-day implementation of the Privacy Policy.

5.2 Collection of Information

All club forms shall identify the purpose for collecting Personal Information.
Consent to publish UGC member contact information, likenesses (photographs) in theclub Roster, Newsletter, Website, and other distributed UGC documents is implied upon application for UGC membership. UGC members may opt out of having their address and telephone number shown in the UGC Roster, Newsletter, Website or other distributed UGC documents by requesting such in writing to the General Manager. The names of members, membership status shall be included, and no opting out will be permitted.
Personal Information collected shall be limited to information required for registration and safe participation in UGC programs. This may include information such as medical, financial, or insurance information pertinent to the activity.
Precise Location Data collected via the App is processed in real time and is not permanently stored or archived by UGC. Historical location telemetry logs are automatically overwritten or permanently destroyed within 48 hours of collection, unless required briefly to audit a specific security or lightning evacuation incident. All location data transmitted between member devices, club networks, and cloud application servers is fully encrypted in transit.
Liability waivers may be required for UGC’s programs and services. UGC may refuse program registration or facility use upon failure of a UGC member, guest, or program participant to sign the required forms as presented.
Surveys of UGC members shall only be conducted with the approval of the UGC Board.

5.3 Protection of Records

No member, employee or other person is permitted to disclose the Personal Information of a member to a non-member.
Contact information listed in the most current UGC Roster may be provided to other club members. UGC member contact information is available to all staff via JONAS (the UGC Management System).
UGC member account access and information is only available to UGC’s administrative staff, UGC’s accounting staff, UGC’s auditors, the applicable member, and any authority with the legal right to have such access.
Delinquent account information is provided monthly to the Board, the list is distributed at the meeting, but all copies are retained by the UGC General Manager for administrative purposes.

5.4 Access to Member Records
UGC member account or Personal Information in UGC’s records may not be shared with anyone other than the member, their spouses (joint member), or their legal guardian or representative. A member may review their UGC membership and JONAS file upon written request to UGC’s General Manager.

5.5 Security

UGC member records are maintained in locked cabinets behind locked doors. Old records are archived, also in a locked room in a locked office and are kept for a period as deemed necessary by UGC’s General Manager.
At disposal, all UGC member and account information is shredded by UGC staff or a commercial documents disposal company.
All UGC staff sign a confidentiality agreement upon initiation of employment with UGC.
The JONAS system uses password protection on all workstations, and central application is password protected.
The club’s computer system server is maintained in a locked room behind locked doors.

System back-up is done automatically daily to a remote facility via the internet.

UGC’s wireless internet access system is independent of UGC’s computer system.
The security applied to UGC computer systems, networks, and physical facilities will be reviewed by the General Manager on an annual basis to identify potential improvements. Recommendations for improvements will be given to UGC’s Executive Committee.
Email groups will be restricted to registered activity groups such as Juniors or Intermediates who have approved the use of the information for such purposes. Consent for use of Personal Information in this manner is implied via registration.
UGC’s security cameras monitor the driving Range in a manner that does not interfere with the privacy of members or their guests. Video records are retained for 3 weeks on a hard drive.

5.6 Employee Records

UGC employee records shall be maintained by the General Manager and maintained in a locked cabinet.
Payroll information is kept in a secure binder located in a locked office. The payroll service (Payworks) are required to retain employee pay records and account information in a secure and confidential manner.

5.7 Surveillance
The General Manager may approve the use of webcams, closed circuit television or other surveillance technology to support UGC operations. Notice of the use of surveillance equipment must be given to members and employees and signs must be posted to inform visitors and the public.