We value the trust that you have placed in Lora Bay Golf Limited Partnership (“Lora Bay”, “we”, “our”, or “us”) and protecting your personal information is our priority. This Privacy Policy (“Policy”) discloses the practices of Lora Bay regarding the collection, use, safeguard, disclosure, transfer, access, disposal and other processing (collectively, “Processing”) of Personal Information of individuals who engage with Lora Bay for our support, services or otherwise, use the Lora Bay iOS application provided by Jonas Club Software (the “Application”), visit our website(s), including
https://www.lorabaygolf.com/ (the “Website” and together with the Application, our “Platform”), or contribute to Lora Bay’s social media platforms.
What Personal Information is being collected? Lora Bay may collect Personal Information that includes, but is not limited to, contact and identifying information, profile information and login credentials, booking and transaction details, payment information, and location and device information.
- For the full list and more information, see “Types of Personal Information Collected and Purposes of Processing” and “Methods of Collection of Personal Information” below.
For what purposes? Lora Bay may process your Personal Information for purposes including but not limited to, providing our products and services, such as allowing golfers to book tee times, manage their accounts, order food and beverages through the app, assisting our customers, improving our products and services, and generally maintaining our business and complying with applicable laws.
- For more information, see “Types of Personal Information Collected and Purposes of Processing” and “Methods of Collection of Personal Information” below.
Who is Lora Bay sharing my Personal Information with? Lora Bay may share certain types of Personal Information with third parties, including but not limited to, our vendors and affiliates and other service providers that we use to assist us in providing our products and services and running our business and other third parties as required by law. In certain cases, these service providers may collect and use or otherwise Process your Personal Information for their own purposes, including but not limited to marketing and advertising, data analytics, service improvements, or fraud prevention.
- For more information, see “Sharing of Personal Information with Third Parties” and “Request for Information About Third Party Processing” below.
What are the risks? Despite the security precautions taken by Lora Bay, no organization can fully eliminate the risks associated with the Processing of Personal Information. There is always a risk that your Personal Information could be subject to a security breach or otherwise be subject to unauthorized access, use or disclosure.
- For more information, see “Protecting Your Personal Information” below.
For the purposes of this Policy, “Personal Information” shall mean information that can identify an individual directly or indirectly through reasonably available information. Personal Information does not include information that is used solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.
This Policy is Lora Bay’s way of making sure you are fully informed of Lora Bay’s Personal Information handling practices and policies relating thereto.
This Policy is effective as of the “Last Updated” date, above, and will remain in effect except with respect to any of its provisions that are changed in the future. We reserve the right to change this Policy at any time. Changes, modifications, additions, or deletions will be effective immediately upon their posting to the Platform or upon you being otherwise notified. Your continued use of our Platform or any other products and services after we post any such modifications will constitute your acknowledgement of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “Last Updated” date found at the beginning of this Policy when we post changes to it.
Subject to certain legal and contractual limitations, you have the right to withdraw your consent from us Processing your Personal Information. This may limit our ability to provide you with our services, including access to the Platform, act on your behalf, or engage with you as you would like. To withdraw your consent to certain Processing by Lora Bay, you may declare to our designated Privacy Officer (contact information provided below) in writing, at any time, of your desire to withdraw consent. Lora Bay will inform you of the implications of such withdrawal within thirty (30) days of your written request. Any withdrawal of consent will apply thereafter and not to information handling practices that have been previously undertaken based on prior consent. We may, however, collect, use or disclose Personal Information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Lora Bay will not knowingly obtain consent from those individuals who are minors, seriously ill, or mentally incapacitated and we shall therefore obtain consent from a parent, legal guardian or person having power of attorney of such an individual.
If you are an individual under the age of majority, you must access or use the Website only with the permission and involvement of your parent or guardian.
The Personal Information which Lora Bay may collect includes, but is not limited to:
- Account and identity information: name, email address, mobile number, member number or customer ID, club affiliation, and password or other credentials. We use this to create and manage your account, authenticate you, communicate with you about bookings, orders, and service updates, and administer loyalty or membership features you choose to use.
- Login credentials: profile information and login credentials for the Application, including your username and password. We use this information to authenticate you and secure the Application.
- Profile and preferences: notification and marketing preferences, tee-time and course preferences (for example, preferred times, party size), and optional information you add to your profile. We use this to personalize the Application experience and communications. You may manage push notification preferences at any time through the Application settings or through your iOS device settings.
- Booking and transaction details: tee-time reservations and history (course, date/time, party size, cancellations/no-shows), food and beverage orders (items, price, delivery or pickup details), and receipts. Where you add guests to a booking, we also collect the guest information you provide (such as guest names) solely to fulfill the booking. You may choose to sync your bookings to your device calendar; this requires calendar access on your device, which you can grant or revoke through your iOS device settings at any time. You may also choose to have booking confirmations emailed to any address you provide. We use this information to provide and manage the services you request, support customer service, prevent fraud, and perform operational reporting for the club. Lora Bay uses separate third-party booking platforms for dining, tee-time and Golf Simulator reservations. Please see “Sharing of Personal Information with Third Parties” and "Services governed by this Policy" below for more information.
- Account and billing statements: your club account summary, statement period, and credit book balance are displayed in the Application, sourced from the club's Jonas property management system. This financial data is read-only within the Application. If you use the in-Application option to contact the Lora Bay accounting team, the Application will send an email on your behalf to Lora Bay’s accounting staff. We use this information to give you access to your membership financial records and to respond to billing inquiries you initiate.
- Payment information: the Application does not collect or process payment card information for food and beverage orders placed through the Application. Orders and bookings submitted through the Application are fulfilled at Lora Bay’s on-site point of sale. Payment for those orders is handled in one of two ways: (1) charged to your club member account for settlement at the club, or (2) processed at the physical Point of Sale terminal using Global Payments. No card data is entered into or stored by the Application for these transactions. If you wish to dispute a charge, please contact Lora Bay club directly. For Golf Simulator bookings and tee-time reservations. payment is processed through a third-party booking platform; see “Sharing of Personal Information with Third Parties” and "Services governed by this Policy" below for more information.
- Location information: approximate location from your device (if enabled) to find nearby clubs, surface relevant tee times, and support on-course delivery or pickup. You can control location sharing in your device settings; the Application functions but some features may be limited if you disable location.
- Device and usage information: device type and identifiers, operating system, Application version, IP address, language, diagnostic and crash data, and in-Application interactions (such as screens viewed, buttons tapped). We use this to secure the service, troubleshoot, measure and improve performance, and develop new features.
- Communications and support: messages or inquiries you send through the Application, email, or phone (including support tickets and, where permitted, call recordings). We use this to respond to requests, improve service quality, and keep records of your instructions.
- Photos and media you choose to share: optional profile photos or images you upload in connection with service requests (for example, to help staff locate you on course). We use this only to provide the requested service.
- Contacts: if you choose to import contacts to invite playing partners or form groups, we process those contacts solely to facilitate the invitations you initiate. You can remove imported contacts at any time.
- Other: other information which you voluntarily provide to us, our service providers, our employees, or our contractors.
We may also Process your Personal Information as needed to comply generally with applicable laws and statutory requirements.
We may collect, use and share aggregated information such as statistical or demographic data for any purpose. Aggregated information could be derived from your Personal Information but is not considered “personal information” in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated information with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.
Personal Information may be collected by Lora Bay in a number of ways, including in person, through our Platform, by mail, by email, and from third parties whom you have authorized to disclose Personal Information to us. Third parties that we receive Personal Information from may include GolfNow, OpenTable and USchedule when you use those platforms to make purchases or reservations as described in the “Services governed by this Policy” section below.
If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.
Personal Information is collected by Lora Bay when you subscribe for and create an account on our Platform. In order to create and administer your account and authenticate you, we will collect your email address (i.e., your username) and a password that you create. You will also have the option to add information to your account profile. You are required to keep your username and password secure and not share it with anyone else.
The Application includes a roster section that displays club member information to other logged-in members. At minimum, member names are visible to all members using the Application. This visibility is a feature of club membership and the Application. You may opt out of displaying your information to other members through the privacy settings in the “Roster” section of the Application. You will have the option to select: “Hide me from Member Roster”, “Hide me from Tee Sheet”, and/or “Hide me from Event Attendance List”. If you have questions about what information is displayed in the roster, please contact the Privacy Officer.
For the purpose of maintaining quality service, telephone calls to Lora Bay’s customer services lines may be recorded. If your call is subject to a quality assurance program, you will be advised prior to speaking to a representative.
Lora Bay may collect Personal Information through cookies on our Platform. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our Platform again. This helps us to understand your preferences based on previous or current Platform activity, allowing us to provide you with improved services, tailor our content to meet your needs and for advertising purposes. We also use cookies and navigational data to gather information regarding the date and time of your visit and the information for which you searched and viewed, or on which of the advertisements displayed on our Platform you clicked.
The Platform may use retargeting ads to advertise online. Retargeting uses cookies from third-party vendors like Google to track visitors. This tracking enables the third-party vendors to display our ads to people on various sites across the internet based on their visits to our Platform.
We may also use web beacons (small pieces of data that are embedded in images on the pages of our Platform) and auditing software to track page views and entry and exit points to and from our Platform. We may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form and will not contain any Personal Information.
You may have the option to deactivate certain cookies upon your access and use of the Platform. However, if you deactivate cookies, you may be unable to fully utilize and access all areas and features of the Platform. Some third-party service providers may also place their own cookies on your browser. Note that this Policy only covers Lora Bay’s use of cookies and does not include use of cookies by such third parties.
When you visit the Platform, we may also collect clickstream data (e.g. server address, domain name, device type, browsing software) which may be stored on the Platform’ server. This information can be combined with information you have provided to us which will enable us to analyze and better customize your visits. We may use clickstream data for traffic analysis or e-commerce analysis of the Platform, to determine which features of the Platform are most or least effective or useful to you.
Platform features may be accessible from web-enabled mobile devices. On some devices, functionality may be limited. If you use mobile-enabled services provided by our Platform, we may receive information about you from your mobile device. This may also include information about your precise location if you have enabled location-based services on your mobile device. Some devices may allow you to opt-out of this collection or access, and in those cases, you may be able to subsequently stop the collection or access. Please review your device settings for more information.
When you first launch the Application, you will be shown an Apple App Tracking Transparency prompt asking whether to allow the Application to track your activity across other companies' applications and websites. This tracking may be used to measure the effectiveness of advertising and to deliver interest-based ads on other platforms. If you deny tracking, the Application will continue to function normally. You may change your preference at any time by going to iOS Settings > Privacy & Security > Tracking and toggling the permission for the Application.
If you post a review, make a comment, or otherwise submit Personal Information on a public forum such as social media accounts or public forums, your communications may be viewable by the public. When voluntarily disclosing Personal Information about yourself to other users, we are unable to control what may be done with that content. You should take all necessary precautions to protect your private information by not posting or publishing any information that you do not want in the public domain. While we strive to provide the highest level of confidentiality, you should review your personal privacy settings to further restrict any or all parts of your profile or other certain content or information.
Although you are entering into an agreement to disclose your Personal Information to Lora Bay pursuant to this Policy, we may delegate our authority for Processing of your Personal Information to third-party individuals and organizations who assist us with providing our products and services and administering our business, and for such other purposes as set forth below, including:
- Affiliated, associated, and related companies that assist us with providing our products and services and otherwise running our business.
- Suppliers, vendors, service providers, agents, and contractors, including companies we use for storage, processing, and delivery of our products and services.
- Administrative and technical support, including cloud storage providers, software providers, IT support, and data analytics providers.
- Parties in connection with proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets.
In certain cases, our service providers may Process your Personal Information for their own purposes. These purposes may include, but are not limited to, sending you marketing and advertising messages, performing analytics on your data, implementing service improvements, or for fraud prevention. Any such Processing is governed by the respective service provider’s own privacy policy and not this Policy.
We do not store your booking or payment information for online purchases or reservations. This information is shared directly with our third-party payment service and booking providers including GolfNow, OpenTable and USchedule. Each of these booking and reservation providers processes payment card information (credit/debit card, gift card, coupon) directly through their own payment service providers. Lora Bay does not receive, store, or process any payment card data entered on these platforms. Please see “Services governed by this Policy” below for more information.
We may also disclose Personal Information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk.
If you believe that a third party has inappropriately disclosed your Personal Information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
Lora Bay takes care to ensure that Personal Information you provide to us is accessed internally only by individuals that require access to perform their tasks and duties, and externally only by service providers and other third parties with a legitimate purpose for accessing it. We will not use or disclose any collected Personal Information outside of the purposes described in this Policy unless you have otherwise consented or it is required or permitted by law.
Lora Bay takes reasonable steps to keep your Personal Information as accurate, complete and up-to-date as necessary to fulfill the purpose for which your Personal Information has been collected. If desired, you may verify the accuracy and completeness of your Personal Information in our records with our Privacy Officer.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date Personal Information in your file, we will remedy any such errors on a timely basis. You may request correction of the Personal Information we hold about you, though we may need to verify the accuracy of the new information you provide to us. If inaccurate Personal Information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
The Application includes a delete account option in the settings. Deleting your account removes your login credentials and online access only — you will be logged out of all devices and will no longer be able to view your profile, statements, or make bookings through the Application. Your underlying club membership record, booking history, and account data are retained in the club's Jonas property management system as part of your membership and to meet legal, regulatory, and contractual obligations. Deleting your account does not delete your club membership data.
To request deletion of your club membership data, please contact the Privacy Officer directly. Any deletion requests will be subject to any legal or contractual retention requirements that may apply.
Lora Bay will store your Personal Information only for as long as is reasonably necessary to fulfill the purpose for which the Personal Information was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Once your Personal Information is no longer needed, we will securely and effectively dispose of it.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this anonymized information indefinitely without further notice to you.
You may request access to your Personal Information, which enables you to receive a copy of the Personal Information we have collected from you and information about how we are Processing it.
We may need to request specific information from you to help us confirm your identity and right to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. Lora Bay may not always be able to comply with your request for access to Personal Information for specific reasons which you will be notified of, if applicable, in our response to your access request.
You have the right to receive information that identifies any third-party companies or individuals that we have shared your Personal Information with, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information by contacting our Privacy Officer.
You also have the right to opt-out of certain Personal Information Processing, including the disclosure of Personal Information to third parties which is not reasonably necessary for providing the products and services you’ve requested or as otherwise required by law.
Lora Bay uses industry standard measures, including administrative, organizational, technical, and physical safeguards, to help protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We implement measures and processes to help us keep your Personal Information secure and to maintain its quality. We regularly review our security and related policies to adapt the technology as new threats evolve and monitor our systems to help ensure the highest level of availability. If you have any questions about the security of our Platform, you can reach out to our Privacy Officer.
Access to private, sensitive and confidential information, including Personal Information, is restricted to authorized employees or contractors with legitimate business reasons. Lora Bay’s employees and contractors understand the importance of keeping your Personal Information private. All employees and contractors are expected to maintain the confidentiality of Personal Information.
Despite the foregoing security measures and significant steps Lora Bay has taken to protect your Personal Information, no organization can fully eliminate all security risks associated with the Processing of Personal Information. With that in mind, we cannot guarantee the security of any Personal Information provided to or received by us. We encourage you to keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.
In the event there has been a breach of our security safeguards which involve your Personal Information, including the unauthorized access, use or disclosure of your Personal Information, loss of your Personal Information, or other breach, and where there is a risk that significant harm will come to you as a result of that breach, Lora Bay will notify you and, if required, the applicable privacy commissioner or other data protection authority.
The Platform and our other products and services are governed by the provisions and practices stated in this Policy. Our Platform may contain links to third-party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Platform, and that we are not responsible for the privacy practices of third-party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use and disclose your Personal Information.
We currently include links to the following third-party applications and platforms within our Platform:
- Dining reservations — OpenTable: dining reservations made through the Application are processed by OpenTable. When you make a dining reservation, you provide your first name, last name, phone number, email address, and any special requests directly to OpenTable. Special requests may include dietary restrictions or other health-related information, which may be considered sensitive Personal Information. We encourage you to review OpenTable's Privacy Policy before submitting a reservation.
- Golf Simulator bookings—USchedule: golf simulator bookings are handled through the USchedule third-party booking platform. When you tap "Book Time" in the Golf Simulator section, you are redirected to that platform, which has its own login, Privacy Policy, and Terms of Service that you must accept before proceeding.
- Tee-time reservations— GolfNow: tee-time reservations are make through the third-party GolfNow platform. When you select “Book a Tee Time”, you are redirected to the GolfNow widget. You may continue as a guest or sign up for or login with a GolfNow account. The GolfNow widget has its own Privacy Policy and Terms and Conditions that you must accept before proceeding.
- Third-party links: the Application may also contain links to other third-party websites or platforms, such as YouTube instructional videos in the Help section. When you follow these links, you leave the Lora Bay Application environment.
Personal Information provided to our service providers may be stored outside of Canada. You acknowledge and agree that, as a result, your Personal Information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
Your privacy is very important to us. We are happy to provide you with a copy of this Policy in an alternative, accessible format and to discuss any of its contents with you.
Lora Bay’s Privacy Officer is responsible for the implementation of this Policy and monitoring our adherence to its terms and all applicable laws. The Privacy Officer also handles questions and concerns about our Policy, as well as Personal Information access requests and complaints. You may also seek advice from the applicable privacy commissioner or other data protection authority and, if appropriate, file a written complaint with such data protection authority.
Lora Bay’s Privacy Officer may be contacted at:
Privacy Officer, Lora Bay Golf Limited Partnership
Great Gulf, 351 King Street East, 13th Floor, Toronto, ON M5A 0L6
[email protected]
416-449-1340
69119706.5