MAPLE DOWNS GOLF & COUNTRY
CLUB PRIVACY POLICY
Effective Date: June 15, 2026
Last Reviewed: June 15, 2026

Maple Downs Golf & Country Club ("Maple Downs," the "Club," "we," "our," or "us") is committed to protecting the privacy, confidentiality, accuracy, and security of the personal information entrusted to us by our members, guests, visitors, employees, volunteers, and business partners. This Privacy Policy describes how Maple Downs collects, uses, discloses, retains, and safeguards personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and other applicable Canadian privacy laws.

1. ACCOUNTABILITY
Maple Downs is responsible for personal information under its custody and control. The General Manager serves as the Club's Privacy Officer and is responsible for overseeing compliance with this Privacy Policy and applicable privacy legislation. The Privacy Officer may designate other individuals to assist in fulfilling these responsibilities.

2. COLLECTION AND USE OF PERSONAL INFORMATION
Maple Downs collects personal information only for purposes that are reasonable and necessary to provide Club services, operate Club facilities, administer employment relationships, and fulfill legal and contractual obligations. Personal information may include, but is not limited to:

Members, Guests and Visitors
• Name, address, telephone number, and email address;
• Membership and account information;
• Payment and billing information;
• Event registration and participation information;
• Preferences and communication choices;
• Information collected through our website and the Maple Downs Custom App;
• Device and usage information related to Club systems and applications; and
•Geolocation information where applicable and authorized.

Employees and Volunteers
• Employment applications and resumes;
• Payroll and compensation information;
• Emergency contact information;
• Benefits administration information;
• Training and performance-related information; and
• Other information reasonably required for employment or volunteer administration.

Personal information may be collected in person, by telephone, through written correspondence, by email, through our website, through the Maple Downs Custom App, or through other lawful means associated with Club operations.

Maple Downs may collect, use, and disclose personal information for the following purposes:
• Administering memberships and member accounts;
• Providing access to Club facilities, programs, tournaments, and events;
• Processing payments and maintaining financial records;
• Communicating with members regarding Club operations, governance matters, events, services, and promotions;
• Delivering services and functionality through the Maple Downs Custom App;
• Responding to inquiries, requests, feedback, and complaints;
• Collecting and analyzing member feedback, survey responses, service usage trends, and engagement information to improve Club programs, facilities, services, and the overall member experience;
• Improving Club facilities, programs, services, and member experiences;
• Administering employment and volunteer relationships;
• Ensuring the safety and security of members, guests, employees, volunteers, and Club property;
• Meeting legal, regulatory, insurance, and contractual requirements; and
• Providing information regarding Club services, dining, programs, tournaments, events, and other activities that may be of interest to members.

The purposes for which personal information is collected will be identified before or at the time of collection. In circumstances where the purpose is obvious and the information is voluntarily provided, consent may be implied.

3. CONSENT
Knowledge and consent are generally required for the collection, use, and disclosure of personal information except where otherwise permitted or required by law.

Providing personal information to Maple Downs is voluntary; however, choosing not to provide certain information may limit our ability to provide services, benefits, access privileges, participation opportunities, employment opportunities, or certain App features.

Where personal information is collected through electronic systems, websites, the Maple Downs Custom App, or location-based technologies, Maple Downs will obtain any consent required by applicable law.

Individuals may withdraw consent at any time, subject to legal, contractual, or operational restrictions and reasonable notice. Withdrawal of consent may affect the availability of certain services, App features, employment administration functions, or member benefits.

4. GEOLOCATION AND GEOFENCING
Maple Downs may offer members access to location-based features through the Maple Downs Custom App (the "App").

When enabled by a member, the App may use geolocation technologies, including GPS, Wi-Fi, Bluetooth, cellular network information, and similar technologies, to determine the approximate or precise location of a member's mobile device.

The Club may establish virtual geographic boundaries ("geofences") around Club facilities, parking areas, event venues, practice facilities, and other locations relevant to Club operations.

When a member using the App enters, exits, or remains within a geofenced area, Maple Downs may collect and process location information for purposes including:
• Providing location-based notifications, communications, and member services;
• Facilitating member arrival notifications, check-in, attendance verification, and participation in Club events and activities;
• Improving operational efficiency and service delivery;
• Enhancing member convenience and experience while using Club facilities;
• Supporting safety, security, and emergency response procedures;
• Analyzing facility utilization and App functionality;
• Improving Club services, operations, and member engagement; and
• Complying with legal, regulatory, insurance, or contractual obligations.

Location information collected through the App will only be used for legitimate Club purposes and in accordance with applicable privacy laws.

Location information is not continuously monitored and is collected only when location services are enabled by the member and permitted by the device operating system.

Location services are optional and may be enabled or disabled by members through their mobile device settings or within the App. Disabling location services may limit the functionality of certain App features and member services.

By enabling location services within the Maple Downs Custom App, members consent to the collection, use, and disclosure of location information as described in this Privacy Policy.

5. LIMITING COLLECTION, USE, DISCLOSURE, AND RETENTION
Maple Downs limits the collection of personal information to that which is necessary for identified purposes.

Personal information will only be used or disclosed for the purposes for which it was collected unless additional consent is obtained or the use or disclosure is otherwise permitted or required by law.

The Club may share personal information with trusted third-party service providers who perform services on our behalf, including technology providers, software vendors, payment processors, communication platforms, professional advisors, payroll providers, and providers supporting the Maple Downs Custom App.

Such service providers are required to maintain appropriate safeguards and may only use personal information for authorized purposes.

Personal information may be processed or stored by service providers located outside Ontario or Canada. In such circumstances, personal information may be subject to the laws of those jurisdictions.

Maple Downs maintains records retention practices that establish retention periods based on legal, operational, accounting, regulatory, and business requirements.

Personal information will be retained only for as long as necessary to fulfill the identified purposes and comply with applicable legal obligations. Personal information that is no longer required will be securely destroyed, deleted, or anonymized.

6. ACCURACY OF INFORMATION
Maple Downs will make reasonable efforts to ensure that personal information is accurate, complete, and current as necessary for the purposes for which it is used.

Members, employees, and volunteers are encouraged to notify the Club promptly of any changes to their personal information.

7. SAFEGUARDS
Maple Downs protects personal information using physical, organizational, and technological safeguards appropriate to the sensitivity of the information.

These safeguards are designed to protect personal information from loss, theft, unauthorized access, disclosure, copying, modification, or misuse.

While no method of data transmission or storage can be guaranteed to be completely secure, Maple Downs takes reasonable precautions to safeguard personal information and regularly reviews its security practices.

8. PRIVACY BREACHES
Maple Downs maintains procedures for identifying, investigating, documenting, and responding to privacy breaches involving personal information.

Where a privacy breach creates a real risk of significant harm, Maple Downs will notify affected individuals and report the breach to the Office of the Privacy Commissioner of Canada, as required by law.

Maple Downs will maintain records of privacy breaches in accordance with applicable legal requirements.

9. COOKIES AND WEBSITE TECHNOLOGIES
A cookie is a small file stored on a user's device when visiting a website. Maple Downs may use cookies and similar technologies on its website and digital platforms to:
• Improve website functionality and performance;
• Remember user preferences and settings;
• Analyze website traffic and usage patterns;
• Enhance user experiences;
• Support security and administrative functions; and
• Improve the functionality of the Maple Downs Custom App and related services.

Most web browsers automatically accept cookies; however, users may adjust their browser settings to decline cookies or receive notifications when cookies are being used.

Disabling cookies may affect the functionality of certain portions of the Club's website or digital services.

10. ELECTRONIC COMMUNICATIONS
Maple Downs may send electronic communications regarding Club operations, governance matters, billing, events, dining programs, tournaments, promotions, and other Club-related activities.

Recipients may unsubscribe from promotional or marketing communications at any time in accordance with applicable law.

Operational, governance, billing, safety, and membership-related communications that are necessary for Club administration may continue to be sent where permitted by law.

11. OPENNESS AND TRANSPARENCY
Maple Downs will make information about its privacy practices readily available to members and other interested individuals.

This Privacy Policy may be updated periodically to reflect changes in legal requirements, technology, Club operations, the Maple Downs Custom App, or privacy practices. The most current version will be made available by the Club and on the Club's website and other Club communication channels where applicable.

12. ACCESS TO PERSONAL INFORMATION
Upon written request and subject to applicable legal restrictions, individuals may be informed of the existence, use, and disclosure of their personal information and may request access to that information.

Individuals may also request corrections to inaccurate or incomplete personal information.

In certain circumstances permitted by law, Maple Downs may be unable to provide access to information that contains references to other individuals, is subject to legal privilege, or is otherwise restricted by law.

13. THIRD-PARTY WEBSITES AND SERVICES
The Maple Downs website, the Maple Downs Custom App, or Club communications may contain links to third-party websites, applications, or services. Once a user leaves a Maple Downs-controlled platform, this Privacy Policy no longer applies.

Maple Downs is not responsible for the privacy practices, content, or security of third-party websites, applications, or services. Users are encouraged to review the privacy policies of any third-party platforms they access.

14. QUESTIONS, REQUESTS, AND COMPLAINTS
Questions, requests for access or correction, concerns, or complaints regarding this Privacy Policy or the handling of personal information may be directed to:

Ryan Bradshaw
General Manager & Privacy Officer
Maple Downs Golf & Country Club
11101 Dufferin Street Maple, Ontario L6A 1A2
Telephone: (905) 832-0880 ext. 234
Email: [email protected]