Privacy Notice

ST. ANDREWS COUNTRY CLUB

WEBSITE PRIVACY POLICY

 

Introduction

 

At St. Andrews Country Club (“the Club,” “our,” “us,” or “we”), we respect and believe is it important to protect the privacy of our members and employees.  There are various ways that you might interact with St. Andrews Country Club, and the information you provide when doing so allows us to improve our services.

 

This Privacy Policy applies to St. Andrews Country Club, the “St. Andrews Country Club Websites,” “St. Andrews Country Club Application” and covers our processing activities as a data controller.  This Privacy Policy applies to any Personal Information and browsing information collected and/or owned by us, including, but not limited to, collection through any of our websites (and all of the subdomains located thereon as well as any mobile sites (the “Sites”) and any online feature, service and/or program offered by us (collectively, the “Web Properties”). 

 

The websites of other St. Andrews Country Club 3rd party affiliates and business units are governed by separate terms of use and privacy policies.  We are not responsible for the privacy practices of third parties, even if our websites link to those parties’ websites.  Likewise, this Privacy Policy is not applicable to any other web pages, mobile applications, social media sites, email lists, generic information and Personal Information collected and/or owned by any entity other than St. Andrews Country Club.

 

BY SUBMITTING INFORMATION TO US AND USING ANY OF OUR WEB PROPERTIES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE OUR WEB PROPERTIES OR SERVICES.

 

 

Information We Collect

 

Information Voluntarily Provided

 

We may collect and/or record personal information that you voluntarily provide by completing forms manually on our Sites, through questions you send to us, or through other means of communication between you and us.  The categories of personal information you provide may include (collectively, “Personal Information”):

 

                     First and Last Name;

                     Job Title and Company Name;

                     Family Members;

                     Email Address;

                     Phone Number;

                     Mailing Address;

                     Birthday;

                     Password to Register with Us;

                     Your Personal and/or Professional Interests;

                     Any Other Identifier That Permits Us to Make Contact with You.

 

 

 

Information from Sites Visits

 

We collect, store and use information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes the following information:

 

                     technical information, including the Internet Protocol (“IP”) address, browser type, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;

                     information about your visits and use of the Sites, including the full Uniform Resource Locators (“URL”), clickstream to, through and from our Sites, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and Sites navigation and search terms used.

 

Browsing Information

 

The types of browsing information we collect may include non-individualized, generic information about you when you visit the Web Properties. This may include, among other things, the following categories of information (collectively, “Browsing Information”):

 

                     IP address, or device ID/UDID, protocol and sequence information;

                     Browser language and type;

                     Domain name system requests;

                     Browsing history, such as time spent at a domain, time and date of your visit and number of clicks;

                     HTTP headers, application client and server banners;

                     Operating system;

                     cookies and electronic beacons; and

                     Similar behavioral and usage information.

 

 

How We Use Information

 

As a data controller, we will only use your Personal Information if we have a legal basis for doing so.  The purposes for which we may use and process your Personal Information are as follows:

 

·       To provide you with information and materials that you request from us.

·       To personalize our services and the Sites to you.

·       To update you on services and products and benefits we offer.

·       For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing.

·       To send you information regarding changes to our policies, other terms and conditions and other administrative information.

·       To administer our Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes;

·       To improve our Sites to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Sites; and

·       To keep our Sites safe and secure.

·       To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.

·       To enforce our terms and conditions of service.

 

If you do not wish to provide us with your personal data and processing such data is necessary for the deliverance of membership services to you and to fulfill our member obligations to you, we may not be able to perform our obligations.  Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal.  You can update your details or change your privacy preferences by contacting us through the St. Andrews Country Club membership department or as provided in “Contacting Us” below.

 

Updating Your Information and Opting Out

 

To review, correct, update, delete, object or otherwise limit our use of your Personal Information that has been provided to us, or request portability and/or details of your Personal Information that is held by us, please contact the St. Andrews Country Club membership contact or contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request.  You may also determine which Personal Information is visible to other members via our members only section of our Sites.

 

If you are a member of the Club, you can help to ensure that your Personal Information is accurate and up to date by logging into your account, verifying the information and making any necessary changes.

 

You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you.  You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below. 

 

Disclosure of Your Personal Information to Third Parties

 

We may share your Personal Information with 3rd party vendors as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us).  Personal Information will also be shared with our third-party service providers who assist with the running of the Sites and our services and products including hosting providers, email service providers and payment processing partners.  Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process your Personal Information for specified purposes and in accordance with our instructions.

 

In addition, we may disclose information about you when we believe that such use or disclosure is reasonably necessary to: comply with any legal or regulatory obligation; establish, exercise or defend the rights of St. Andrews Country Club, our staff, members or others; and protect our rights, property or safety, or the rights, property or safety of our members, or others.

 

Security of Your Personal Information

 

The security of your Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it.  We use appropriate measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained, and follow applicable laws regarding the safeguarding of any such information under our control.  No method of transmission over the Internet, or method of electronic storage, can be 100% secure.  Therefore, we cannot guarantee the absolute security of your information.  The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online.  You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

 

Data Retention: How Long We Keep Your Personal Information

 

We will retain Personal Information that we process on behalf of our members for as long as needed to provide services and products to our members.  When you contact us, we may keep a record of your communication to help solve any issues that you might be facing.  Your information may be retained for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement.

 

Your Rights

 

You may request access to, correction of, blocking of and/or deletion of your Personal Information in accord with applicable data protection laws from us if it does not affect our ability to serve our membership. You may also withdraw your consent for us to process your Personal Information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Where your Personal Information is processed by us with your consent or for the performance of a service by automated means, we will provide your Personal Information in a structured, commonly used, machine-readable format to you or a third party you have chosen upon request.

 

Responding to Requests

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure designed to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response. We respond to all legitimate requests as soon as reasonably practicable. If your request is complex or you have made a number of requests it may take longer to respond. We will notify you and keep you updated. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Also, please note that we may refuse a request for blocking and/or deletion where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims.

 

Google Analytics

 

We are obliged to make the following statement from Google Analytics: The Sites use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the Sites analyze how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on websites activity for websites operators and providing other services relating to websites activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

 

Social Features and Personal Information

 

Certain functionality on the Web Properties is specifically designed to permit interactions that you initiate between the Web Properties and third-party websites or services, including third party social networks (“Social Features”).  Examples of Social Features include enabling you to transmit content to the Web Properties from your account on a third-party website or service, and to “like” or “share” our content on the Web Properties to other websites or services.

 

If you choose to use Social Features, information you post or provide access to may be publicly displayed on the Web Properties or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references St. Andrews Country Club (e.g., by using a hashtag associated with us in a tweet or status update), your post may be published on the Web Properties in accordance with the terms of the third-party websites or service. In addition, both we and the third party may have access to certain information about you and your use of the Web Properties and the third-party sites or service. In addition, we may receive information about you if other users of a third party websites give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your “connections” web pages, profile pages, or similar pages on a social networking or other third party websites or interactive service.

 

The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties' privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.

 

Links to Third Party Websites and Third-Party Applications

 

Our Sites may contain links to third party websites. These third-party websites are operated by companies that are outside of our control, and your activities at those third-party websites will be governed by the policies and practices of those third parties.  St. Andrews Country Club does not in any way endorse or make any representations about such third-party websites and applications.  As such, St. Andrews Country Club is not responsible for the privacy practices or content of such third-party websites and applications that are subject to their own privacy policies.  If you choose to access such links, we encourage you to review all third-party sites privacy policies before submitting any of your data.

 

Employment Opportunity Information

 

For individuals interested in job opportunities with us, the Web Properties may allow prospective employees to request additional job opportunity information or submit a response to a job opportunity.  The Web Properties may be used to collect Personal Information from prospective employees for human resources recruitment purposes.  By submitting any of the foregoing information, you consent to its dissemination to, and use by, us and our affiliates. The foregoing also applies to job application inquiries that you may transmit to us other than through the Web Properties.

 

Children

 

We do not sell or market our services to children and the Sites is not intended for or directed at children under the age of 12 years.  As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable information from children under the age of 12.  If you believe that we may have collected Personal Information from someone under the age of 12 (or the applicable age of consent) without proper consent, please let us know using the methods described in this policy.  THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER 12. Parents and legal guardians should be aware that this Privacy Notice will govern our use of Personal Information, but also that information that is voluntarily given by children – or others – in email exchanges, bulletin boards, or the like may be used by other parties to generate unsolicited communications. We encourage all parents to instruct their children in the safe and responsible use of their Personal Information while using the Internet.

 

European Union and Users Outside of the U.S.

 

The Web Properties are hosted in the United States and are governed by United States law. If you are using the Web Properties from outside the United States, please be aware that your Personal Information and/or Browsing Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Web Properties, you consent to your Personal Information and Browsing Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

 

The European Union’s General Data Protection Regulation (Regulation (EU) 2016/679) gives certain rights to European data subjects in relation to their personal data.

Lawful basis for processing. We will only process your personal data when we have a legal basis to do so. When we do process your personal data, we will do so with your consent or because the processing is necessary: for the performance of services for you; to comply with our legal obligations; to pursue our legitimate interests; or to establish or defend a legal claim.

 

Your rights. If applicable, you may have the following rights under some circumstances:

 

                     You may request information about what Personal Information we have about you.

                     You may request rectification, deletion, and limitation of the processing or blocking of your Personal Information as long as this is legally permissible and possible within the framework of our relationship.

                     You have the right to transfer the Personal Information that you have provided us on the basis of a consent or a contract (data portability).

                     If you have given us consent for Personal Information processing, you can revoke it at any time in the same way that you have granted it. The revocation of the consent does not affect the legality of the processing done before you revoked your consent.

 

To exercise your rights, contact us by one of the methods set forth at the end of this Privacy Notice. We will respond to your request within thirty days. We may not be able to accommodate your request in every situation, but if that is the case, we will let you know why. We may charge you an administrative fee for subsequent requests.

 

Complaints: If you are a data subject in the European Union and you believe that our processing of your personal data infringes applicable law, you may submit a complaint with a supervisory authority. The name and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

 

 

Your California Privacy Rights

 

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.  Please contact us for more information if you qualify and have questions.  

 

 

Governing Law and Jurisdiction

 

All matters relating to the Web Properties, and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the State of Florida without giving effect to any choice or conflict of law provision or rule (whether of the State of Florida or any other jurisdiction).

 

Any legal suit, action, or proceeding arising out of, or related to, the Site shall be instituted exclusively in the state or federal courts located in West Palm Beach, Florida.  You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

 

Arbitration

 

At our sole discretion, we may require you to submit any disputes arising from or related to use of the Web Properties to final and binding arbitration under the Rules of Arbitration of the American Arbitration Association applying Florida law.

 

 

Contacting Us

 

If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us as follows:

 

St. Andrews Country Club

17557 Claridge Oval West

Boca Raton, FL 33496

Email: msmith@standrewscc.com

 

Changes to This Policy

 

We regularly review our compliance with our privacy policy.  We also adhere to several self-regulatory frameworks in addition to complying with applicable law.

 

We may change this privacy policy from time to time. If this privacy policy changes, the revised privacy policy will be posted at the “Privacy Policy” link on the Sites home page. In the event that the change is significant or material, we will notify you of the change by revising the link on the home page to read “Newly Revised Privacy Policy.” Please check the privacy policy frequently. Your continued use of the Sites constitutes acceptance of such changes in the Privacy Policy, except where further steps are required by applicable law.  This Privacy Policy was last updated on the date set out at the end of the policy.

 

EFFECTIVE AS OF: December 17, 2019