Privacy Policy

Policy on Privacy of Personal Information

 

The Heights Ski & Country Club. will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), a federally enacted act to protect personal information that is collected, used or disclosed. For the purposes of this Policy, personal information means information about an identifiable individual, exceeding what is normally on a business card or in a telephone book, i.e., name, title, business address or telephone number. Any reference to a guest within this Policy is in reference to personal information and not business information.

 

PIPEDA is based on ten (10) fundamental and internationally recognized principles, as follows:

 

1. Accountability

 

2. Identifying Purpose

 

3. Consent

 

4. Limiting Collection

 

5. Limiting Use, Disclosure & Retention

 

6. Accuracy

 

7. Safeguards

 

8. Openness

 

9. Individual Access

 

10. Challenging Compliance

 

 

The Heights Ski & Country Club. has implemented policies and procedures to give effect to these principles, including:

 

1. Implementing procedures to protect personal information.

 

2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by The Heights Ski & Country Club.

 

3. Training staff and communicating information to staff about Horseshoe Resort’s policies and procedures.

 

4. Developing information to explain Horseshoe Resort’s policies and procedures to Guests.

 

 

These principles are explained in more detail below:

 

1.ACCOUNTABILITY

 

The Heights Ski & Country Club. is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for Horseshoe Resort’s compliance with PIPEDA.

 

2.IDENTIFYING PURPOSE

 

The Heights Ski & Country Club. will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If The Heights Ski & Country Club. intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the guest to which the personal information relates prior to using such personal information. The Heights Ski & Country Club. shall only collect, use and disclose personal information about Guests for the following purposes:

 

1. to facilitate return visits and, wherever possible, to meet Guests’ personal preferences;

2. to advise Guests of goods and services by or by arrangement with the company;

3. to improve the offering of goods and services to Guests;

4. to assist The Heights Ski & Country Club. in the collection of fees and other charges owing with respect to services rendered by The Heights Ski & Country Club.;

5. to assist The Heights Ski & Country Club. in revenue management with respect to the Resort;

6. to assist The Heights Ski & Country Club. in communication with users of the Resort for the purpose of promoting the use of the Resort;

7. to assist an entity with whom The Heights Ski & Country Club. has an agreement relating to the collection of fees and other charges in connection with the use of the Resort.

 

The Heights Ski & Country Club. does not sell or trade personal information about Guests to any third party agencies.

 

Guest inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by The Heights Ski & Country Club. or referred to the Chief Privacy Officer.

 

3.CONSENT

 

The knowledge and consent of Guests is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. The Heights Ski & Country Club. will seek consent for the collection of personal information at the time of collection, wherever possible. The Heights Ski & Country Club. will make a reasonable effort to ensure that Guests are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Guests to reasonably understand how their personal information will be used or disclosed by The Heights Ski & Country Club.

 

Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Guests will be considered when obtaining consent. For example, where Guests provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Guest Satisfaction Surveys, where the choice to respond is the Guest’s.

 

In certain circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the Guest. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. Seeking consent my be impossible or inappropriate when there is an emergency threatening the Guest’s life, health or security, or where the Guest is a minor, seriously ill or mentally incapacitated.

 

Although information may be publicly available, The Heights Ski & Country Club. will treat this in accordance with PIPEDA principles. Moreover, The Heights Ski & Country Club. may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

 

The use of The Heights Ski & Country Club. will be considered consent to collect, use and disclose personal information for stated purposes.

 

Copies of the The Heights Ski & Country Club. Privacy Policy will be published on the Horseshoe Resort website at www.HorseshoeResort.com.

 

A Guest may withdraw consent by providing reasonable notice to The Heights Ski & Country Club.’s Privacy Officer. The Heights Ski & Country Club. will inform the Guest of any implications of such withdrawal. Any withdrawal of consent will still allow The Heights Ski & Country Club. to use and disclose a Guest’s personal information in order to collect or enforce payment of amounts owing as a result of a Guest’s previous or continuing use of the Resort. Subsequent use of the Resort will automatically provide consent for the collection, use, disclosure and retention of personal information.

 

4. LIMITING COLLECTION

 

The collection of personal information will be limited to that which is appropriate in the circumstances.

 

The Heights Ski & Country Club. collects some information about prospective Guests using technology, so it may not be readily apparent to prospective Guests that it is being collected. For instance, when a prospective Guest visits our website, their IP address is collected so that we know how many visits we have had by separate individuals. An IP address is often associated with the place from which a prospective Guest enters the Internet like their Internet Service Provider (ISP), their firm or company or their university. This information is not personally identifiable.

 

The Heights Ski & Country Club. may use “cookie” technology to obtain non-personal information from its online visitors for certain purposes. The cookie is stored on their computer to allow them to get back into certain areas of the website with as minimal delay as possible. We do not extract personal information in this process nor do we disclose this information. Cookies are tools that allow us to update and improve our sites.

 

5.LIMITED USE, DISCLOSURE & RETENTION

 

The Heights Ski & Country Club. will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the guest or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.

 

The Heights Ski & Country Club. may disclose a Guest’s personal information to third parties retained by The Heights Ski & Country Club. for the purposes of billing such a Guest for the use of The Heights Ski & Country Club. Properties and/or facilities, and to collect and enforce payment of amounts owing by such Guests.

 

Certain The Heights Ski & Country Club. employees and third party agents may be given access to a Guest’s personal information collected by The Heights Ski & Country Club. in so far as their duties require access for the purposes outlined above. The Heights Ski & Country Club. employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.

 

Personal information that has been used to make a decision about a Guest will be retained in accordance with the The Heights Ski & Country Club. document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. The Heights Ski & Country Club. retains personal information of a Guest only for as long as it is required for The Heights Ski & Country Club.’s business purposes or as required by federal and provincial laws.

 

6.ACCURACY

 

The Heights Ski & Country Club. will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

 

The Heights Ski & Country Club. will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. The Heights Ski & Country Club. will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.

 

Access to a Guest’s personal information on record with The Heights Ski & Country Club. may be requested by that Guest in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, The Heights Ski & Country Club. will refer the Guest to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provide by them. To access your personal information, refer to “How to contact us”.

 

7.SAFEGUARDS

The Heights Ski & Country Club. will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Team Members of The Heights Ski & Country Club. who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. As a condition of employment all new employees/agents must sign the The Heights Ski & Country Club. Confidentiality Agreement. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Care will be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.

 

8.OPENESS

 

The Heights Ski & Country Club. will make readily available to Guests specific information about its policy and guidelines relating to the management of personal information. The Heights Ski & Country Club. will be open about its policy and procedure with respect to the management of personal information, and Guests will be able to acquire information about these policies easily and in a form that is generally understandable. This policy and any related information is available at all times on the Horseshoe Resort Website, www.HorseshoeResort.com, under Privacy. To contact The Heights Ski & Country Club., refer to “How to contact us”.

 

9.INDIVIDUAL ACCESS

 

The Heights Ski & Country Club. will inform a Guest of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. The Heights Ski & Country Club. will assist a Guest in the preparation of a request for access when such a Guest requests assistance. The Heights Ski & Country Club. will inform the Guest whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible. There may, however, be situations in which The Heights Ski & Country Club. will not be able to provide access to all the personal information that it holds about a Guest, although these situations will be limited and specific, and permitted or required by law. For example, The Heights Ski & Country Club. will not be able to provide access to a Guest’s personal information where giving such access would likely reveal personal information

 

about a third party, unless that third party’s personal information can be severed from the Guest’s personal information. If The Heights Ski & Country Club. refuses a request for access, the Guest will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Guest of their recourse.

 

The Heights Ski & Country Club. will require that Guests requesting access to their personal information provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit The Heights Ski & Country Club. to provide an account of the existence, use and disclosure of the Guests’ personal information.

 

The Heights Ski & Country Club. will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.

 

The Heights Ski & Country Club. will respond to a Guest’s request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. The Heights Ski & Country Club. may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Guest will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.

 

The Heights Ski & Country Club. may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Guest, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

 

A Guest will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.

 

10. CHALLENGING COMPLIANCE

 

A Guest will be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer. The Heights Ski & Country Club. will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.

 

The Heights Ski & Country Club. will inform Guests who make inquiries or lodge complaints of the existence of the relevant complaint procedures. The Heights Ski & Country Club. will

 

investigate all complaints, and if a complaint is justified, The Heights Ski & Country Club. will take appropriate measures, including amending policies and procedures.

 

HOW TO CONTACT US:

 

If you have any questions or comments about this Privacy Policy or you feel that your concerns or complaints have not been resolved to your satisfaction, please contact us

 

If the issue is still not resolved to the your satisfaction, you may file a complaint with the Privacy Commissioner of Canada at privcan@fox.nstn.ca or by calling 1-800-282-1376.