Privacy Policy

Rare Golf collects, uses and discloses your personal information by employing “fair information practices” as described in the following ten privacy principles and embodied in the Personal Information Protection and Electronic Documents Act:

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1. Accountability:  Rare Golf is responsible for personal information under its control and as a result has designated an individual as the person who is accountable for Rare Golf’s compliance with the ten principles (“Privacy Officer”).  As such:​

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(a) accountability for Rare Golf’s compliance with the principles rests with the Privacy Officer, even though other individuals within Rare Golf may be responsible for the day-to-day collection and processing of personal information.  In addition, other individuals within Rare Golf may be delegated to act on behalf of the Privacy Officer. The Privacy Officer designated by Rare Golf to oversee Rare Golf’s compliance with the principles shall be made known upon request; and

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(b) Rare Golf is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing.  Rare Golf shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

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2. Identifying Purposes:  In general, Rare Golf collects, uses and discloses personal information about you in order to develop and improve algorithms to provide services to you and third parties and to enhance our services.  More specifically, Rare Golf collects, uses and discloses your personal information for the following purposes:

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(a) to provide our software and algorithms with datasets to improve our algorithms;

 

(b) to establish and maintain commercial relationships with clients, suppliers and other third parties, including to administer accounts, collect and process payments, and to fulfill contractual and legal obligations;

 

(c) to provide our services to you related to your submitted information, including labelling, annotation and analysis by individuals and external service providers;

 

(d) to develop and manage our business and operations.  This may include the sharing of personal information by and between Rare Golf personnel and affiliated companies, and with third party service providers and agents, for such purposes; 

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(e) to detect and protect Rare Golf and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with Rare Golf’s policies and contractual and legal obligations;

 

(f) to distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers; 

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(g) to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Rare Golf; 

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(h) to understand and respond to client, supplier and other third-party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;

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(i) to develop, enhance, market, sell or otherwise provide Rare Golf’s products and services;

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(j) to market, sell or otherwise provide products and services of third parties with whom Rare Golf has a commercial relationship;

 

(k) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and

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(l) for any purpose to which you consent. 

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Rare Golf will collect, use and disclose only that personal information necessary for the purposes that have been identified.

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3. Consent:  The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except as permitted by Privacy Laws.  Pursuant to this Privacy Policy, you acknowledge your consent to Rare Golf’s collection, use and disclosure of your personal information, or the personal information of another individual which you provide to Rare Golf, as stated above.  Generally, should a different purpose to the collection, use or disclosure of your personal information be proposed by Rare Golf, Rare Golf shall seek your consent at the same time it collects the information. However, Rare Golf may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed, for a new purpose.  You may withdraw consent at any time to some or all of the purposes indicated below, subject to legal or contractual restrictions and reasonable notice.  Please note, however, that in some circumstances, we may not be able to provide you with our services if you withdraw your consent to our use of your personal information.

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NOTE: In certain circumstances under Privacy Laws, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.

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4. Limiting Collection:  The collection of personal information shall be limited to that which is necessary for the purposes identified by Rare Golf.  Information shall be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information.  In most cases, collection shall be pursuant to appropriate contractual arrangements.

 

5. Limiting Use, Disclosure, and Retention:  Personal information shall not be used or disclosed for purposes other than those for which is was collected, except with the consent of the individual or as required or permitted by Privacy Laws or other Applicable Laws.  Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.

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Rare Golf may collect from and/or disclose your personal information to:

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(a) a person who, in the reasonable judgment of Rare Golf, is providing or seeking the information as your agent;

 

(b) any of the companies and business entities that form part of Rare Golf;

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(c) an organization or individual retained by Rare Golf to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web-site developers and hosts), data processing, document management and office services;

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(d) an organization or individual retained by Rare Golf to evaluate your creditworthiness or to collect debts outstanding on an account;

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(e) financial institutions and credit card providers, on a confidential basis and solely in connection with user account administration (including deposits and payments), fraud investigations and security, and processing of payments and deposits through Rare Golf’s services;

 

(f) a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;

 

(g) our auditors and professional advisors;

 

(h) another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of Rare Golf’s assets related to one or more specific lines of business, subject to the other person or corporation agreeing to manage personal information in accordance with Privacy Laws;

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(i) another company or person for the development, enhancement, marketing or provision of any of Rare Golf’s products or services;

 

(j) an agent or third party retained by Rare Golf in connection with Rare Golf's administration or the provision of Rare Golf's products or services;

 

(k) credit grantors and reporting agencies;

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(l) applicable public authorities where such disclosure is required pursuant to Applicable Laws (including without limitation the Financial Transactions and Reports Analysis Centre of Canada); and

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(m) a public authority or agent of a public authority, if in the reasonable judgment of Rare Golf, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of this information.

 

Except as permitted in this principle, Rare Golf does not provide or sell its customer lists to any outside company for use in marketing or solicitation. 

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6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is possible.  Rare Golf will update personal information as and when necessary to fulfill the identified purposes or upon notification from you.  Rare Golf will not routinely update personal information, unless such process is necessary to fulfill the identified purposes.  If ever your contact and/or other personal information changes, please feel free to contact us so that we can update our records

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7. Safeguards:  Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.  The security safeguards are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.  The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage.  The methods of protection include:

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(a) physical measures, such as locked filing cabinets and restricted access to offices;

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(b) organizational measures, such as security clearances and limiting access on a “need-to-know” basis; and

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(c) technological measures, such as the use of passwords, firewalls and encryption.

 

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8. Openness: Rare Golf shall make readily available to you information about its Privacy Policy and practices relating to the management of personal information.  For example:

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(a) Rare Golf shall be open about its Privacy Policy and practices with respect to the management of personal information. This information shall be made available in a form that is generally understandable;

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(b) the information made available shall include:

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(i) the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;

 

(ii) the means of gaining access to personal information held by Rare Golf;

 

(iii) a description of the type of personal information held by Rare Golf, including a general account of its use;

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(iv) a copy of any brochures or other information that explain Rare Golf’s policies, standards, or codes; and

 

(v) what personal information is made available to related organizations, i.e.: affiliated companies; and

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(c) Rare Golf may make information on its Privacy Policy and practices available in a variety of ways.  The method chosen depends on the nature of its business and other considerations.  For example, Rare Golf may choose to make brochures available in its place of business, mail information to its customers, provide online access, or establish a toll-free telephone number.

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9. Individual Access:  Upon request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

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NOTE:  In certain situations, under Privacy Laws, Rare Golf may not be able to provide access to all of your personal information it holds.  The reasons for denying access will be provided to you upon request.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

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10. Challenging Compliance:  You may wish to address a concern regarding Rare Golf’s compliance with the above principles to Rare Golf’s Privacy Officer.  Rare Golf shall investigate all complaints.  If a complaint is found to be justified, Rare Golf shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and practices.

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