Privacy Policy

Our Commitment To Privacy
The Canadian Society of Club Managers (the “CSCM”) is committed to protecting the privacy and the confidentiality of the personal information on its members, volunteers, employees, corporate partners and other stakeholders.

This Privacy Policy documents our ongoing commitment to privacy and has been developed in compliance with applicable privacy legislation.

What Is The Purpose Of Our Privacy Policy? 
During the course of our various programs and activities, the CSCM may gather and use personal information. Anyone from whom we collect such information should expect that it will be carefully protected and that any use of, or other dealing with, this information is subject to consent. The CSCM’s Privacy Policy has been created to ensure this is achieved.

What Is Personal Information?
Personal information is any information that can be used to distinguish, identify, or contact a specific individual such as your name, contact information, financial information, payment card information, dietary restriction, and purchase history. Business contact information, which are publicly available, or aggregated data, from which the identity of an individual cannot be determined, are not considered to be personal information.

Consent
An individual’s consent is required for the CSCM to collect and/or process personal information when information is collected. Consent can either be express or implied.

We will obtain your express consent to collect, use, and/or disclose personal information, except where we are authorized or required by law to do so without consent. For example, we may collect, use, and/or disclose personal information without your knowledge or consent where:

  • The personal information is publicly available from a prescribed source, such as a telephone directory, membership directory, etc.;
  • The CSCM is collecting or paying a debt;
  • The CSCM has your implied consent.

Express consent may be provided orally, in writing, electronically, through action (such as when you click submit on an e-newsletter subscription form) or otherwise. By providing personal information to us, you agree that we may collect, use and disclose such personal information as set out in this Privacy Policy and as otherwise permitted or required by law. Implied consent is consent that can be reasonably be inferred from an individual’s action or inaction.

Where your consent is required, you may refuse or withdraw your consent to the collection, use and disclosure of your personal information. You should be aware that your choice to refuse or withdraw consent may negatively affect the CSCM’s ability to provide you with certain products or services. If you would like information about the effect, if any, of refusing or withdrawing your consent, you may contact our Privacy Officer at the address indicated below.

Cookies, Web Beacons, & Similar Technologies
(A) Cookies
In browsing the Internet, you will encounter a technology called “cookies”, which are small data files that are saved to your device when you visit our website(s). These are commonly used to provide you specific information from a website, and to provide the website’s operator information about you. We may use both session cookies and persistent cookies. A session cookie is a temporary file which is only active while you are on the website and is erased once you close your browser. Unlike a session cookie, a persistent cookie is not deleted when you close your browser and will remain on your device indefinitely.

These cookies are used to improve navigation on websites and to collect aggregate statistical information. This information may be used for advertising and marketing initiatives after you conclude your session on the CSCM website. The cookies may also track your activity on other websites or social media platforms that you visit after leaving the CSCM website. You may opt out of such tracking by adjusting the cookie settings on your browser.

Visitors that wish to opt out of cookies should review the “help” feature on their web browser’s settings. However, declining cookies may adversely impact the website performance.

(B) Web Beacons
Web beacons are small graphic images or other programming code (also known as “web bugs”, “1x1 GIFs” or “clear GIFs”) used to keep track of your navigation through the website(s) and your electronic communication with us. We may include web beacons in our web pages and email messages. Web beacons or similar technologies may be used for a number of purposes including, without limitation, to count visitors to our website, to monitor how users navigate the website, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed. Web beacons may be used to collect certain personal information (for example, the email address associated with an email message).

(C) Embedded Scripts
An embedded script is a programming code that is designed to collect information about your interactions with our website, such as information about the links on which you click. The code is temporarily downloaded onto your device from our web server or a third party service provider. The code is active only while you are connected to our website, and is deactivated or deleted once you disconnect from the website.

Link To Other Websites
Our websites may contain links to other sites. This Privacy Policy only applies to personal information that we collect, use and disclose. We are not responsible or liable for the privacy practices of third parties, and we strongly recommend that you review their privacy policies before you disclose personal information to them.

Google Analytics
The CSCM website uses Google Analytics to track performance. Google Analytics uses persistent cookies to track visitor sessions, visitors across multiple sessions, and referral sources to our sites. We also track the performance of promotional links to our site using Google Analytics. In compliance with the Google Analytics Terms of Service, at no time is personally identifiable information passed to Google Analytics. Note that Google Analytics stores its data within the United States of America and is subject to US laws. We use this data to understand site performance to serve you better. Those wishing to opt out of Google Analytics data collection should use the Google Analytics Opt Out Browser Add-on.

Limits For Using, Disclosing And Retaining Personal Information
The CSCM keeps personal information for as long as it is necessary for the purposes for which it was collected. Accordingly, we may retain personal information for different lengths of time, depending on the nature of the personal information and the purposes for which it was provided to us. We dispose of personal information in a manner that ensures the continued security of the information.

Accuracy
We will ensure that your personal information is kept as accurate, complete and up-to-date as possible based on information provided to us by you. We expect you, from time to time, to supply us with written updates to your personal information, if applicable.

Safeguarding Personal Information
The CSCM protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

Given that electronically transmitted data is not 100% secure, we make no warranties as to the security of any information you submit electronically, which you do at your own risk or when we transmit such information by such means at your request.

How To Access Your Personal Information
If you wish to access, correct or update your personal information in the CSCM’s records, you may contact our Privacy Officer at the address indicated below. Upon written request and authentication of identity, we will provide you with your personal information under our control and the ways in which that information is being used. Some information may not be accessed, such as information that contains personal information of others, or is otherwise protected under the law. You may also access, correct or update some of your personal information online by following the links on our website.

Residents Of The European Economic Area (“EEA”)
While the CSCM is a Canadian not-for-profit organization, we realize that our websites may be accessed by users from around the world.

For the purposes of applicable EU data protection law, we are a “data controller” of your personal information. Our servers are located in Canada in Toronto, Ontario. Data flow from the EU to Canada has been recognized by the adequacy decision of the European Commission.

If you are located in the EEA, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, port, delete, or limit the use of your personal data. You also have the right to make a complaint to a Data Protection Authority about how the CSCM processes your personal data. If you are a visitor to the CSCM’s websites and wish to exercise these rights, please reach out to us using the contact information below.

Additionally, if you are located in the EEA, please note that we may be processing your information in order to fulfill actions you have asked of us (for example if you register to attend an event or have submitted an information request form through our websites), or otherwise to pursue our legitimate business interests, unless we are required by law to obtain your consent for a particular processing operation.

Changes
The CSCM reserves the right to change this Privacy Policy and it may be updated periodically. These changes may affect the use of personal information. Accordingly, please check for changes regularly.

Accountability
The CSCM is responsible for all personal information under its control. The CSCM has designated a Privacy Officer who is responsible for the CSCM’s compliance with this Privacy Policy.

If you have any questions about our Privacy Policy or your personal information, please contact:

Privacy Officer
703 Evans Avenue, Suite 202A
Etobicoke, ON, M9C 5E9
privacy@cscm.org

Further information on privacy and your rights in regard to your personal information may be found on the website of the Privacy Commissioner of Canada at www.priv.gc.ca.

Effective: April 2020