Table of Contents.

1. PURPOSE

1.1 Over 100 years of privacy history means maintaining consistency in an ever-changing private and public world. The Vancouver Club (the ‘Club’) is committed to the protection of personal information. This Policy outlines the Club’s commitment to maintain privacy when collecting, using and disclosing personal information of Club members and guests.

1.2 This Policy was developed in compliance with the British Columbia Personal Information Protection Act (‘PIPA’).

2. WHAT IS PERSONAL INFORMATION?

2.1 ‘Personal Information’ is information that allows an individual to be identified but does not include:

(a) Member and guest names or information which would enable us to contact members or guests at their place of employment including their name, position name or title, business telephone number, business address, business email and business fax number;

(b) personal information about members and guests that is publicly available information such as information available from a public registry or contained in a telephone book;

(c) aggregated information that cannot be associated with a specific individual; and

(d) information that is not about a person but is about a company, association or another organization.

3. COLLECTION OF PERSONAL INFORMATION

3.1 Examples of the types of personal information that the Club may collect about its members and guests, include:

(a) Contact information (name, home address, home email address, home phone, and cell phone numbers);
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(b) Date of Birth;

(c) Occupation and professional associations if voluntarily provided by the member or guest;

(d) Emergency contact information if voluntarily provided by the member or guest;

(e) Information regarding guests that you bring to the Club;

(f) Personal preferences, including dietary preferences, allergies and other medical conditions if voluntarily provided by the member or guest;

(g) Information on member and guest reservations and Club events that members and guests attend;

(h) Credit card information and/or banking information for billing purposes;

(i) Images of members or guests on the Club’s video surveillance system (discussed in section 7); and

(j) Details on when you access the Club, including with which device (or person) you authenticated or identified yourself.

4. USE AND DISCLOSURE OF PERSONAL INFORMATION

4.1 The Club uses personal information for the following purposes:

(a) To establish your membership or access to the Club as a guest;

(b) To maintain a record of all members and guests in the Club at any given time;

(c) To establish and maintain a relationship with you and provide ongoing services;

(d) To process membership and other payments to the Club;

(e) To meet legal and regulatory requirements;

(f) To determine member and guests’ interests and preferences in order to market future services to the member or guest. Please note that the Club does not market to individuals under 19 years of age; and

(g) Such other reasons as a reasonable person would consider appropriate in the circumstances.

4.2 The Club may disclose personal information with third parties engaged to assist the Club in providing services or products to members and guests or to carry out one or more of the purposes described above. These service providers are prohibited from using personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed to them by the Club and to comply with the general privacy principles described in this Policy and all applicable privacy laws.

5. LIMITING COLLECTION, USE AND DISCLOSURE

5.1 The Club will limit the collection of personal information to that which is reasonably necessary for the purposes identified.

5.2 The Club will not use or disclose personal information for any purpose other than those for which it was collected (as identified in section 4 of this Policy). Where an additional use or disclosure is necessary, the Club will notify the member or guest prior to or at the time of the additional use or disclosure, unless such notice is not required or permitted by law.

5.3. Personal information will only be disclosed within the Club on a need-to-know basis.

6. CONSENT

6.1 Except where required or permitted to do so without consent, the Club only collects personal information with the member or guests’ consent. In most cases, the Club relies on express consent. However, where the purpose of the collection of personal information is obvious on its face (such as use of a credit card to pay an account), the Club may rely on implied consent.

6.2 In some cases, such as using personal information for marketing the Club’s services to the member or guest, the Club will rely on opt-out consent. (i.e. information will be provided unless the member or guest advises the Club that they do not wish to receive it.)

6.3 The Club only collects personal information where it is necessary to provide the service that the member or guest is seeking and that the Club has agreed to provide. The Club does not use deceptive or misleading practices to obtain consent.

6.4 The Club does not require consent to the collection, use or disclosure of personal information as a condition of the supply of a service by the Club unless such collection, use or disclosure is required to fulfil the aforementioned purposes of collection.

6.5 The Club reserves the right to collect, use or disclose personal information in certain limited circumstances, without the member or guests’ knowledge and consent, where required or permitted by law. Examples of this include:

(a) where it is clearly in the member or guest’s interests and consent cannot be obtained in a timely way;

(b) in order to create aggregate information in order to identify a member or guest’s needs and preferences, and to aid in the development of new services and products;

(c) where it is required, by law, to be disclosed to law enforcement and other government agencies;

(d) where it is reasonable to expect that disclosure with consent would compromise an investigation or proceeding;

(e) where disclosure is for the purpose of complying with a subpoena, warrant or order issued or made by a Court; and

(f) where disclosure is required or authorized by law.

6.6 A member or guest may withdraw their consent to the collection, use and disclosure of personal information in connection with the services that the member or guest has requested from the Club at any time, subject to legal or contractual restrictions and reasonable notice. The Club will inform the member or guest of the implications of withdrawing their consent. If a member or guest wishes to withdraw their consent at any time, please contact the Club’s Privacy Officer (see section 12 for contact information).

7. VIDEO SURVEILLANCE

7.1 The Club may collect personal information of members and guests via the Club’s video surveillance system. The video surveillance is used for the purposes of security and protection of Club property from theft and other crimes.

7.2 The Club’s video surveillance will not be used in any areas where people have a reasonable expectation of privacy such as locker rooms and restrooms. Currently, the Club has video cameras in the following locations: service areas, shared workspaces, fitness facilities, elevators, hallways, the lobby, entrance and exit.

7.3 All video surveillance is overt and only captures images, not audio. The video surveillance is only reviewed in response to a triggering event. For example, if there is a safety incident at the Club, the video surveillance will be reviewed.

7.4 Where a triggering event requires the Club to review video surveillance, the Club may use information collected through video surveillance to make decisions regarding a member or guest’s continued access to the Club, up to and including termination of Club membership.

7.5 Video images may only be reviewed by: (i) individuals responsible for the technical operation of the video surveillance system (for technical purposes only); and (ii) individuals who reasonably need to view the video images for purposes of conducting an investigation into a specific incident, including human resources and/or legal counsel.

7.6 Video images will not be disclosed to third parties unless such disclosure is required for the purposes of conducting an investigation, for law enforcement purposes or as authorized by privacy or other legislation.

7.7 Video images will be erased within 90 days from the date of the recording unless the video image is associated with a specific incident being investigated. If the video image is associated with an incident being investigated or necessary for a prosecution, it will be retained for as long as reasonably necessary in the circumstances of the specific incident in issue.

8. RETENTION

8.1 Personal information will be retained only as long as necessary or required by law or prudent business practices to

9. ACCURACY

9.1 The Club will make all reasonable efforts to ensure that personal information is accurate, complete and current as required for the purposes for which it was collected. If necessary, the Club will correct or amend any personal information if its accuracy is challenged and found to be deficient.

10. PROTECTION OF PERSONAL INFORMATION

10.1 Personal Information will be safeguarded through appropriate measures, including the following as appropriate:

(a) Physical measures such as locked drawers or filing cabinets;

(b) Organizational measures such as restricting access to personal information to designated individuals on a ‘need-to-know’ basis; and

(c) Computer security measures such as encryption and/or password protection.

10.2 Member files will be kept in a secure area with policies to ensure that information on member files is protected from unauthorized access, collection, use, disclosure, copying, modification and disposal. Only duly authorized individuals, who need to have access to such information in order to perform their duties, will have access to such information.

11. ACCESS

11.1 Individuals have the right to request access to their personal information that is under the control of the Club. Upon request, in writing to the Privacy Officer, the Club will inform a member or guest of the existence, use and disclosure of their own personal information and will be given access to that information, to the extent permissible by law. A member or guest may challenge the accuracy and completeness of the information and request that it be amended as appropriate.

12. ACCOUNTABILITY

12.1 The Club is responsible for protecting any personal information under its control and has designated its Chief Financial Officer as the Privacy Officer. Questions or concerns regarding privacy procedures or the Club’s compliance with applicable privacy legislation may be directed to the Privacy Officer by emailing privacy@vancouverclub.ca or by calling 604.331.7004. The mailing address for the Privacy Officer is as follows: The Vancouver Club, 915 West Hastings Street, Vancouver, B.C. V6C 1C6.

12.2 If an individual is not satisfied with the Club’s response, he or she may contact the Office of the Information and Privacy Commissioner in his or her respective province.12.1 The Club is responsible for protecting any personal information under its control and has designated its Chief Financial Officer as the Privacy Officer. Questions or concerns regarding privacy procedures or the Club’s compliance with applicable privacy legislation may be directed to the Privacy Officer by emailing privacy@vancouverclub.ca or by calling 604.331.7004. The mailing address for the Privacy Officer is as follows: The Vancouver Club, 915 West Hastings Street, Vancouver, B.C. V6C 1C6.

12.2 If an individual is not satisfied with the Club’s response, he or she may contact the Office of the Information and Privacy Commissioner in his or her respective province.