What is personal information?
Personal information – as defined in the Personal Information Protection and Electronic Documents Act (PIPEDA) – is "Information about an identifiable person which would include race, age, marital status, religion, employment history, Social Insurance Number, credit history, assets, home address, telephone number and even opinions about that individual."

What personal information do we collect about you?
As part of the registration process, Carlson collects credit card numbers, e-mail addresses, and other personal information from Members who voluntarily apply for a membership in CIBC Club Privileges. Carlson will explicitly ask for the information required to operate the Program and process applications or Memberships. Personal information, including anonymous user and Member tracking identifiers created during the application process, are stored in a secure environment with credit card information encrypted for added security.

Information Sent To Us By Your Browser. Like most commercial websites, we collect information that is sent to us automatically by your web browser when you access this Site. This information typically includes the IP address of your Internet service provider, the type of your operating system, and the type of your browser. The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings. We use this information to create statistics that help us improve our Site and make it more compatible with the technology used by our visitors.

The information provided by your browser does not identify you personally. However, we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we might share our server logs – which contain visitors’ IP addresses – with the appropriate investigative authorities who could use that information to trace and identify individuals. In addition, if you access this Site through an e-mail we have sent you, or if you’ve created a "user identity" during one of your visits, we may link the information provided by your browser to information in our records that identifies you personally.

Information Collected Using "Cookies."  Like many commercial websites, we use "cookies." A cookie is a small text file that is placed on your hard disk by a Web server. Cookies cannot be used to install computer programs or deliver viruses to your computer. We may use two types of cookies – "session cookies” and “persistent cookies."

We may use "session cookies" to assign a randomly-generated unique identification number to your computer. A session cookie expires after you close your browser. We use session cookies to collect information about the ways visitors use our Site – which pages they visit, which links they use, and how long they stay on each page. We analyze this information, known as "clickstream data," to better understand our visitors’ and members’ interests and needs, and to improve the content and functionality of this Site and the Program.

How do we use your personal information?
Information on Member activity at participating golf facilities can be accumulated in order to provide Membership benefits and to continually improve the quality of the Program and Program offerings.

Carlson, CIBC, or InVicta Club may use Member information in top-level aggregated form to attract golf facilities who wish to participate in the Program or provide special offers to Members through the Site.

Do we share your information with other companies?
The personal information provided by cardholders who apply for a Membership is kept secure and confidential. Personal information about Members is confidential and will not be disclosed or used except as permitted by the Member or as required or permitted by law. Information will not be disclosed about Members to third-party organizations or individuals unless:

* The disclosure is required or permitted by law or by warrant authorized by a court of competent jurisdiction;
* The Member gives Carlson explicit and specific prior permission; or
* To update Member information.

Each year, Carlson sends CIBC the active database, including name, address, phone number, and billing number, which is then updated and sent back to Carlson to help Carlson maintain accurate Member information its database. Carlson shares member information (name, city, province and e-mail address) with InVicta for tournaments and specials.

In particular, except as set out below, Members’ e-mail addresses or other personal identifiers will not be provided to participating golf facilities. However, Carlson will disclose Members’ names to InVicta Club and participating golf facilities to operate the program.

There are other, limited circumstances in which we or the companies with which we share your personal information may share or transfer your personal information to unrelated third parties. For example, we may provide personal information to a third party when we believe it is necessary to prevent or investigate a possible crime, such as fraud or identity theft; to comply with a court order or subpoena; to comply with a legal requirement; to protect your vital interests; or in connection with a sale, purchase, merger, reorganization, financing, liquidation, dissolution, or similar event. When we disclose information under these or similar circumstances, we’ll take appropriate steps to limit use and protect the confidentiality of your personal information.

Does our Site use spyware?
Our Site does not use spyware. The term "spyware" refers to a software program that, when installed on your computer, changes settings, displays advertising, or tracks your Internet behavior and reports information back to a central database. Spyware is usually installed on your computer without your knowledge and can be very difficult to remove.

How long do we keep your personal information?
Carlson will retain information about a Member until such time as the individual resigns from the program. Upon resignation, the individual's personal identifying information will be retained for a seven year period in order to answer individual cardholders’ or Members’ questions and abide with federal law. After seven years, personal information will be deleted. Historical aggregated consolidated Program data that may contain non-personally identifiable information from the resignee will be retained.

Do we transfer your personal information outside your country of residence?
This Site and our data are hosted on Web servers located in Canada. Our call centres are also primarily located in Canada, although we may at times use supplemental facilities located in other countries.

When we transfer your personal information to another country, we’ll take appropriate measures to protect your privacy and personal information. In addition, no matter where we transfer your personal information, it will remain subject to the terms of this Policy and your privacy preferences. You should know that different countries have different data-protection laws, some of which provide more protection than others. By using this Site and participating in this Program, you are consenting to the transfer of your personal information to any country in the world, but only in accordance with the terms of this Policy.

How do we protect your personal information?
Security is important to us. Our top priority is to protect the privacy of personal account information.

We maintain appropriate physical, technological, and organizational safeguards to protect your personal information against loss, misuse, unauthorized access or disclosure, alteration, and destruction. For example, our data networks are protected by firewalls and intrusion-detection sensors. Only employees who have a "need-to-know" are authorized to access member accounts, and only after they’ve been trained on our security procedures.

Although we use reasonable measures to help protect your personal information and comply with applicable data security laws, it’s important that you understand that no website or database is completely secure, or "hacker proof." If you believe the security of your account has been breached, please contact the Customer Care Center as soon as possible.

What about links to other websites?
This Site does contain links to other websites. When you access other websites, please take a few minutes to review their terms of use and privacy statements. Carlson is not responsible for the privacy practices of participating golf facilities or the content of their websites. This privacy statement applies solely to information received by Carlson for the purpose of the Program. Participating golf facilities may collect additional information from Members through surveys and forms for their own marketing purposes. When Members provide information while visiting a participating golf facility’s website or establishment, it is the golf facility that collects the information. Please note that the privacy policies of participating golf facilities may differ from those of Carlson. Some participating golf facilities may use cookies on their websites; however, Carlson has no access to or control over these cookies.

How do we enforce our privacy promises?
We communicate our privacy promises to our employees and train employees handling member information on their roles and responsibilities in protecting your privacy. We regularly assess the privacy and security practices of our websites, databases, and other member-information systems to identify ways we can improve our data practices. As an additional control, we've become members of TRUSTe. TRUSTe is an independent, nonprofit organization that certifies privacy policies and monitors privacy practices. Members of TRUSTe must pass a rigorous process to meet TRUSTe’s program requirements and agree to monitoring and TRUSTe’s dispute-resolution process.

Fraud
Carlson may send details of a Member’s purchases to a participating golf facility where the transactions were made to verify that the transactions were completed and have not been cancelled. If Carlson suspects fraud by a Member, Carlson may investigate and report any evidence, including personally identifiable information, to law enforcement and to the courts in the course of seeking remedies in law or equity. Any suspected breaches to the security of the CIBC Club Privileges website should be immediately reported to the Customer Care Center.