1.0 Introduction
PGCI has created and manages an internet based Membership management system focused on providing unique services to private golf club Members around the world. The publicly accessible pages of the site are limited in their collection and use of personal information, while the password protected member pages of the site requires additional personal information to be provided. PGCI collects this information in order to provide its site Guests and Members with the best and most unique experience in the provision of these services.
This Privacy Policy applies to all Guests and registered Members of the PGCI site (collectively referred to as “Users”).
PGCI publishes this Privacy Policy to reaffirm our commitment to maintaining the privacy of our Guests and Members and inform you of our practices concerning the collection and use of information you provide us.
PGCI reserves the right to make changes to any part of this Privacy Policy in its sole discretion, at any time and without prior notice. Continued use of the web site by a Guest or Member following any such change will constitute acceptance of those changes. If we decide to revise in whole or in part this Privacy Policy, we will post the revised Privacy Policy along with the date it was revised, on the site so Users are aware of our information practices. To continue to stay informed about this important issue, please check this Privacy Policy frequently.
To make this Privacy Policy as easy to read as possible, PGCI has simplified certain sentences by substituting defined terms for certain concepts. Accordingly, the capitalized terms used throughout this Privacy Policy shall have the meanings assigned to such terms in Section 9 (“Definitions”) of this Privacy Policy.
2.0 PGCI's Privacy Pledge
PGCI makes the following pledge to you:
2.1 PGCI is committed to protecting the privacy of its Users at all times.
2.2 PGCI will not share User Information and other Personally Identifiable Information with any third parties, other than those described in Sections 5 in this Privacy Policy.
2.3 PGCI maintains security standards and procedures designed to protect User Information and other Personally Identifiable Information. We will continue to test and update our technology to improve our ability to protect User Information and other Personally Identifiable Information.
3.0 Consent To Use Information
By using the services provided by the PGCI site, each User consents:
3.1 to the collection and use by PGCI of all information that the User provides to PGCI
3.2 to PGCI’s use of all information that is provided to PGCI on behalf of that User, and all information that PGCI collects based on that User's use of the Services, including, without limitation, all User Information and other Personally Identifiable Information.
4.0 Our Policies Regarding the Collection of Information
At PGCI, our goal is to provide Users with quality information and Services. We are also committed to providing Users with responsive, personalized service, and keeping Users informed about new information, products, and services that may be of immediate interest to Users or that can help Users derive the greatest value from the Site.
User Information is at the heart of our ability to provide superior service to the Users. We describe in this Privacy Policy the types of User Information and other Personally Identifiable Information that we collect, and how and why we may share that User Information and other Personally Identifiable Information with others.
A Guest who browses the PGCI Web site is not required to reveal any Personally Identifiable Information, such as name, address, or telephone number, unless they are subscribing to a Guest service such as the newsletter or the completion of the first stage of the Membership application. PGCI Web servers collect other information such as the make of a Guest's browser software and the Internet domain name of the location from which the Guest enters. This information helps us diagnose technical problems and manage our sites by tracking user interests.
The primary reason that we collect and maintain User Information and other Personally Identifiable Information is to serve our Guests and Members and to administer our Member relationships. PGCI may collect User Information and other Personally Identifiable Information from a variety of sources, such as the following:
4.1 Information Users provide to us, such as information in the application process.
4.2 Information we receive from a Guest when subscribing to our newsletters or information updates.
4.3 Information about transactions by Users as part of the Services or other User experiences with PGCI, such as the information we receive when a Member submits a Request to Play, comments or suggestions.
We collect User Information and other Personally Identifiable Information in a number of ways, such as the following:
4.4 During the Application Process:
4.4.1 In order to use our password controlled Member Services, each User will be asked to complete the application process, which requires providing certain application information to PGCI. The application will then be reviewed and approved by PGCI to ensure the application details meet the minimum standards for approval. During the approval stage the user will be designated as a Pending Member.
4.4.2 All Members will select a “pseudo” name within the system, such that they can remain anonymous until they choose to release select User Information and Personally Identifiable Information to another PGCI Member.
4.5 Guest Subscription for Information:
4.5.1 We will collect some User Information and Personally Identifiable Information to be able to provide the service of sending to the Guest at their request, certain information updates. This information will be limited to Guest name, Guest e-mail address, several general preferences and how they found our site.
4.6 Using Credit Cards for Payment:
4.6.1 We collect credit card information for billing purposes. For the convenience of our Members, PGCI at the Member’s option, store the credit number in our secure database for the Members’ ease of use in using to purchase products or services from PGCI.
4.6.2 We will not use, or share credit card information for any other purpose
4.7 Log Files:
We track information about each User's usage of the Services in log files. We use this information as follows: to analyze trends, to administer the Services, to track statistical information about how Users use the Services and to gather broad demographic information for aggregate use.
PGCI does link information regarding a User's usage of the Services to the User's Personally Identifiable Information. Cookies are used as follows:
4.8 Use of Cookies Generally:
4.8.1 A cookie is a piece of data stored by each User's browser that contains information about the user of a computer. Cookies help Web sites recognize return Guests. When you return to a Web site you visited before and that Web site uses cookies, your browser gives this data back to the Web site's server.
4.8.2 Contrary to reports about cookies and online privacy, cookies do not contain viruses and most cannot reveal any Personally Identifiable Information about you unless you willingly provide it as a user on a Web site.
4.8.3 You will find that cookies are an industry standard and are used at most major Web sites in much the same way we use them here at PGCI. You can learn most everything there is to know about cookies at www.cookiecentral.com. We also encourage you to read the privacy policies of all Web sites you visit before you accept cookies from these Web sites.
4.8.4 You can set your browser to reject or to accept cookies. You have the option to reject cookies when you are just browsing the Web and accept cookies when you want to use the Services.
4.9 PGCI's Use of Cookies:
4.9.1 The PGCI Service places a cookie on the hard drive of each User's computer. If a User rejects any cookie offered by the Service, that User may not use the features of the Sevice.
4.9.2 PGCI stores your User ID in your cookie.
4.9.3 PGCI uses your cookie to make your experience with the Services more efficient and effective. For instance, by setting a cookie for a Product on a User's hard drive, the User does not have to log in to the Product more than once, which saves time.
4.9.4 Setting cookies also enables PGCI to track and target the interests of Users.
4.10 Surveys and Promotional Activities:
4.10.1 From time to time PGCI may request information from Users via voluntary participation in promotional or market research activities.
4.10.2 The information that we request may include contact information (such as name and business address), and demographic information (such as zip code and age level).
5.0 Our Policies Regarding the Use and Disclosure of Information
5.1 Information Use and Sharing
Other than what is detailed herein this Section 5, PGCI will not share User Information and other Personally Identifiable Information with any third parties. We may use and share the User Information and other Personally Identifiable Information that we collect among various departments within PGCI and its subsidiaries that perform functions such as servicing User accounts, preparing reports regarding Services use, market research, and promotional activities.
We use the User Information and other Personally Identifiable Information we maintain about Users and their use of the Services, including application information, as follows:
5.1.1 To help us identify Users - To help us prevent unauthorized persons from accessing User Information and other Personally Identifiable Information and the Services that we make available to specific Users for their use.
5.1.2 To provide superior service - We use User Information and other Personally Identifiable Information to respond quickly and efficiently to User needs.
5.1.3 To deliver the Services the site is designed to deliver - The site is designed to allow a member to search and read limited Personal Information about another Member, this is one of the core features of the site.
5.1.4 To tell you about new or enhanced services and/or Services - By understanding more about Users and their use of the Services, we can better meet User needs and determine how other Services could be of value to Users.
5.1.5 To send out E-mail Updates:
5.1.5.a) Once a User completes the application process, PGCI may keep the User updated via e-mail on important news and events concerning PGCI, the Service, and other information that PGCI deems relevant.
5.1.5.b) Members will be receiving a number of e-mail notifications including but not limited to; request to play notices, wish list updates, confirmation of purchases made.
5.1.5.c) By accepting the License Agreement and this Privacy Policy and by using any Service, each User agrees that PGCI may contact the User by e-mail with respect to PGCI and any aspect of the Services whatsoever.
5.1.6 To improve and develop our information and Services:
5.1.6.a) Every Service that we offer is designed to reflect the ways Users actually use the system.
5.1.6.b) We collect and analyze information about the Services so that we can tailor new types of information and Services to meet User demands.
5.2 When it comes to sharing User Information and other Personally Identifiable Information outside PGCI, we do so only for specific purposes. We share User Information and other Personally Identifiable Information with third parties as follows:
5.2.1 We reserve the right to share User Information and other Personally Identifiable Information with other third parties that are subcontracted by PGCI to perform specific services on our behalf, such as Paymentech our credit card transaction company.
5.2.2 We reserve the right to share all User Information and Personally Identifiable Information with third parties who act as independent contractors to help us administer the Services, such as data centers that host our servers and technical system consultants who program our hardware and Software.
5.2.3 We reserve the right to share User Information and Non-Identifying Information in the form of aggregated demographic information that is not linked to Personally Identifiable Information with our subsidiaries, advertisers, and other third parties.
5.2.4 We reserve the right to disclose certain User Information and Personally Identifiable Information to government agencies and consumer reporting agencies as permitted or required by applicable law. PGCI may make these disclosures for specific, limited purposes, such as verifying individuals' identities (reducing fraud and identity theft).
5.2.5 PGCI will also disclose a User's User Information and Personally Identifiable Information when and to the extent we believe, in good faith, that we are legally compelled to do so pursuant to an order of a court of competent jurisdiction or other governmental body (including, without limitation, such disclosures required by applicable securities laws as are necessary to comply therewith or with the rules and regulations of any applicable stock exchange). In such an event, PGCI will use reasonable efforts to do the following:
5.2.5.a) Give the User reasonably prompt written notice of such requirement so that the User has an opportunity to comment thereon or object thereto and to preserve the confidential nature of the User Information and Personally Identifiable Information that PGCI is required to disclose.
5.2.5.b) At the User's expense, use commercially reasonable efforts to cooperate with any of the User's efforts to preserve the confidential nature of the User Information and Personally Identifiable Information that PGCI is required to disclose.
5.3 Merger’s, Acquisitions or Other Business Transitions
Should PGCI find itself being part of a merger with another company or companies, being acquired by a third party or if business direction requires the sale of particular assets, User Information and other Personally Identifiable Information will most likely be part of the transfer of company assets, in order to complete these activities.
5.4 Our Policies Regarding the Use and Disclosure of Information About Former Users
For a period of time after a User relationship ends, our policies and practices regarding the use and disclosure of User Information about former Users are the same as those regarding the collection and disclosure of User Information and other Personally Identifiable Information about existing Users. See additional information under the heading in Section 6 of this Privacy Policy. However, after the relationship ends, we may use such User Information and other Personally Identifiable Information about former Users less and less over time. We reserve the right to eventually remove such User Information and other Personally Identifiable Information about former Users from our records.
5.5 Links to Third Party Web Sites
The PGCI Privacy Policy applies solely to the Services provided by the PGCI site. The Services may contain links to Web sites owned and operated by third parties. Any User's use of third party Web sites is at their own risk and subject to any terms and conditions of use, policies regarding the collection of information, privacy policies, and other practices and procedures for such Web sites. PGCI is not responsible for any such terms and conditions of use, policies regarding the collection of information, privacy policies, or other practices and procedures of the third party Web sites that a User may access through hot links found in the PGCI Services. We cannot guarantee how these third parties use cookies or whether they place cookies on your computer that may include User Information and other Personally Identifiable Information. We encourage Users to be aware when they leave the PGCI web site and to read any terms and conditions of use, policies regarding the collection of information, privacy policies, and other practices and procedures of each Third Party Web site before Users provide them with any User Information and other Personally Identifiable Information.
6.0 Information Confidentiality and Security
PGCI is committed to prevent any unauthorized access to each User's User Information and other Personally Identifiable Information. We maintain procedures and technology designed to prevent such unauthorized access.
6.1 Security Programs
No one can guarantee that data transmission over the Internet will be 100% secure. Nevertheless, PGCI has taken technical, administrative, and physical steps to protect against unauthorized access to User Information and other Personally Identifiable Information used to administer its User accounts. All such information is handled securely within PGCI and its immediate authorized service providers, and is not disclosed to unauthorized third parties.
6.2 User IDs and Passwords
Each User is responsible for maintaining the confidentiality of his or her User ID and password, and are responsible for all activities that occur under his or her User ID and password, including, without limitation, all related User Information and other Personally Identifiable Information. Each User agrees to immediately notify PGCI of any unauthorized use of his or her User ID or password or of his or her User Information and other Personally Identifiable Information or any other breach of security regarding the Services or his or her User Information and other Personally Identifiable Information. PGCI will not be liable for any Loss whatsoever arising from a User's failure to comply with these security requirements and each User agrees to hold PGCI harmless from any and all Losses that arise from that failure to so comply.
In addition, Users agree to maintain the confidentiality of their login name and password and also agree not to provide any other individual with their login information for the purposes of gaining access to and using the Services provided in the PGCI site.
7.0 Tips To Help You Protect User Information
If any User suspects that someone has had unauthorized access to his or her PGCI account, or access to his or her User Information and other Personally Identifiable Information, such as his or her User ID or password, the User should send an email to support@privategolfconnections.com immediately so we can take appropriate action to protect the User and his or her User Information and other Personally Identifiable Information.
If you have any questions or concerns regarding PGCI data protection practices, please send an e-mail message to PGCI's Web site administrator at webmaster@privategolfconnections.com.
8.0 Definitions
For all purposes of this Privacy Policy, the terms used throughout this Privacy Policy shall have the meanings set forth below:
8.1 “Guest” means a person who visits the PGCI website and does not become an Approved Member. Guests are free to enjoy using the Services and information provided on the public side of the PGCI site.
8.2 “Pending Member” means a user that has completed the PGCI application process and PGCI has yet to review the application and thus has not yet approved the Pending Member to become an Approved Member of PGCI. The Pending Member is not able to use and enjoy all the Services offered to Approved Members until they are notified of their Approved status.
8.3 “Approved Member” means a user that has completed the PGCI application process and PGCI has reviewed the application and has approved the Member to become an Approved Member of PGCI. The Approved Member is now able to use and enjoy all the Services offered to Approved Members.
8.4 “User Information” means any information about a User, that (i) PGCI has an obligation to keep confidential or use for limited purposes or (ii) PGCI has any legal obligation to keep confidential or use for limited purposes, including under the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, any laws regarding invasion of privacy, or other privacy laws. “User Information” does not include publicly available information.
8.5 “Non-Identifying Information” means information that, taken alone, cannot be used to identify or locate a Person, including, without limitation: age or date of birth, gender, occupation, education, ZIP code with no address, interests, hobbies, golfing preferences, playing time preferences, income. “Non-Identifying Information” refers to this type of information, regardless of whether such information is collected along with, or is linked to, Personally Identifiable Information.
8.6 “Personally Identifiable Information” means information that can be used to identify or locate a Person, including, but not limited to; e-mail address, name, street address, phone number, fax number, credit card number, Social Security number or similar government identification, personal photo and tax identification number.
8.7 “Privacy Policy” means this “Privacy Policy” as it may be amended from time to time.
8.8 The terms “we,” “us,” and other similar terms shall be deemed to refer to PGCI, as appropriate.
8.9 The terms “you,” “your,” and other similar terms shall be deemed to refer to User and all individual Users, as appropriate.
© Private Golf Connections Inc., 2006.
