Galt Country Club Limited (the “Club”) is devoted to preserving and safeguarding the privacy of
our members, guests, and clients. We abide by the pertinent privacy and anti-spam laws and manage personal information in a way that aligns with the principles reflected in such legislation. This document outlines our commitment to privacy protection and how we handle personal information.

Privacy Statement:

Our dedication to safeguarding privacy entails the following:

• Assigning a responsible individual and providing internal accountability for upholding privacy protection
• Establishing, maintaining, and enforcing privacy protection practices and making information about these practices available upon request
• Collecting, using, and disclosing personal information only when reasonably necessary
• Ensuring that personal information collected by us or on our behalf is accurate and complete to the best of our ability
• Implementing reasonable security measures to prevent loss, unauthorized access, collection, use, disclosure, copying, modification, disposal, and other comparable risks to personal information under our control
• Providing access to personal information and the right to correct it, as required by law
• Retaining personal information as mandated by law and in accordance with designated retention periods
• Maintaining a process for receiving and addressing complaints and other feedback related to privacy matters.

Personal Information:

Typically, we gather personal information necessary for the Club’s operations, such as contact details, demographic information, and individual preferences.

Objectives for collecting personal information are as follows:

• Process membership applications
• Manage memberships
• Provide secure access to our facilities, products, and services
• Customize services to meet personal preferences
• Communicate details about our facilities, products, and services
• Manage surveys, contests, and promotions
• Enhance our facilities, products, services, and marketing strategies
• Make informed business decisions

We generally make individuals aware of these purposes and any other relevant ones during or before collecting personal information. Simultaneously, we usually direct individuals to our management team if they require additional information.

Securing your Personal Information:

We take reasonable measures to safeguard personal information from unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction. Periodically, we engage third-party information security experts to evaluate our security protocols for potential improvement. Our commitment to safeguarding personal information also extends to information transferred to service providers who assist us in communication, personal information management, and similar activities. We carefully choose, retain, and oversee our service providers to ensure that personal information is reasonably protected.

We primarily process and store personal information within Canada, either by ourselves or by Canadian based service providers. When personal information is processed or stored by non-Canadian service providers (including our affiliates), we carefully select, retain, and manage them with a focus on maintaining reasonable protection and managing any security risks posed by unique social or political factors.

Website Privacy:

We maintain websites that may require individuals to register by providing us with personal information. Our use and disclosure of personal information collected through the registration process is governed by this policy and our privacy practices.

Cookies:

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Help remember and process the items in the shopping cart.

• Understand and save user’s preferences for future visits.
• Keep track of advertisements.

• Compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future.
• We may also use trusted third-party services that track this information on our behalf.

• You can choose to have your computer warn you each time a cookie is being sent, or you can choose to
turn off all cookies. You do this through your browser settings. Since browser is a little different, look at
your browser’s Help Menu to learn the correct way to modify your cookies.

Disabling cookies in their browser:

If you turn cookies off, some of the features that make your site experience more efficient may not function properly. Some of the features that make your site experience more efficient and may not function properly.

Third-party disclosure:

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

Third-party links:

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

We have implemented the following:

• Demographics and Interests Reporting
• DoubleClick Platform Integration
• We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functionsas they relate to our website.
• You will be notified of any Privacy Policy changes on our Privacy Policy Page and you can change your personal information: By emailing us, logging in to your account or calling us

Third-party Behavioral Tracking:

We allow third-party behavioral tracking

CASL:

The Canadian Anti Spam Legislation is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions
• Process orders and to send information and updates pertaining to orders.
• Send you additional information related to your product and/or service
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

Accordance with CASL, we agree to the following:

• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Monitor third-party email marketing services for compliance, if one is used.
• Honour opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

Communications:

We frequently reach out to Members to share information about our facilities, products, services, and promotions, but always with their consent. Additionally, we offer Members the option to opt-out of receiving these communications. Whenever we send commercial electronic messages, we adhere to the relevant regulations outlined in Canadian anti-spam legislation, as far as they are applicable. If at any time you would like to unsubscribe from receiving future emails, you can email us at marketing@galtcountryclub.com. You may also follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.

More Information:

If you have any questions or concerns with respect to our privacy practices, please do not hesitate to call our Privacy Officer at:

Galt Country Club Limited
750 Coronation Blvd,
Cambridge, ON N1R 8E3
Phone: (519) 621-7020
Email: marketing@galtcountryclub.com

Our Management Team will endeavour to answer your questions or concerns as quickly and completely as possible. If you wish to make a formal complaint about our privacy practices, please forward your complaint in writing to our General Manager. Who will acknowledge receipt of your complaint and ensure that the matter is investigated promptly. You will also be provided with a written notice outlining the decision reached by the Club after investigating your complaint, the reasons for such decision and any steps taken or that will be taken by the Club in connection with your complaint. If you are unhappy with the decisions reached by the Club, or have a general inquiry about privacy legislation, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for disputes relating to the privacy legislation. You can contact the Information and Privacy Commissioner at:

112 Kent Street
Ottawa, ON
K1A 1H3
Phone: 1 (800) 282-1376
Fax: (613) 947-6850
Email: info@privcom.gc.cawww.privcom.gc.ca

The Club reserves the right to amend this Privacy Policy at any time and from time to time and we encourage you to refer back to this Privacy Policy regularly. Any amendment to this Privacy Policy will apply to the Personal Information collected, used or disclosed from and after the date of such amendment.