Privacy Policy

SkyLife Club Inc. (“SkyLife”). will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), a federally enacted act to protect personal information that is collected, used or disclosed. For the purposes of this Policy, personal information means information about an identifiable individual, exceeding what is normally on a business card or in a telephone book. Any reference to a person within this Policy is in reference to personal information and not business information.
PIPEDA is based on ten (10) fundamental and internationally recognized principles, as follows:
1. Accountability
2. Identifying Purpose
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure & Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance
SkyLife has implemented policies and procedures to give effect to these principles, including:
1. Implementing procedures to protect personal information;
2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by SkyLife;
3. Training staff and communicating information to staff about the policies and procedures of SkyLife and its facilities; and
4. Explaining the policies and procedures of SkyLife and its facilities to members and guests.
These principles are explained in more detail below:
1. ACCOUNTABILITY

SkyLife is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for SkyLife’s compliance with PIPEDA.
2. IDENTIFYING PURPOSE
SkyLife will, as appropriate, identify and document the purposes for which it collects personal information at or before the time the personal information is collected. Only personal information that is necessary for those identified purposes will be collected. If SkyLife intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the person to which the personal information relates prior to using such personal information. SkyLife shall only collect, use and disclose personal information for the following purposes:
1. to facilitate return visits and, wherever possible, to meet members and guests’ personal preferences;
2. to advise members and guests of goods and services by or by arrangement with the SkyLife;
3. to improve the offering of goods and services to members and guests;
4. to assist SkyLife in the collection of fees and other charges owing with respect to services rendered by SkyLife and their affiliates and or partners;
5. to assist SkyLife in revenue management with respect to the operation of SkyLife;
6. to assist SkyLife in communication with members and guests for the purpose of promoting the use of SkyLife Club;
7. to assist an entity with whom SkyLife has an agreement with the collection of fees and other charges in connection with the use of SkyLife Club; and
8. to meet legal and regulatory requirements.
SkyLife does not sell or trade personal information about individuals to any third party agencies.

Inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by SkyLife’s Chief Privacy Officer or other qualified person.
3. CONSENT

The knowledge and consent of persons is required for the collection, use or disclosure of personal information, except where permitted or required by law. SkyLife will seek consent for the collection of personal information at the time of collection, wherever possible. SkyLife will make a reasonable effort to ensure that persons are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow such persons to reasonably understand how their personal information will be used or disclosed by SkyLife. Skylife 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.
Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of persons will be considered when obtaining consent. For example, where persons provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Member/Guest Satisfaction Surveys, where the choice to respond is that of the person.

In certain circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the person. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. Seeking consent my be impossible or inappropriate when there is an emergency threatening the person’s life, health or security, or where the person is a minor, seriously ill or mentally incapacitated.
Although information may be publicly available, SkyLife will treat this in accordance with PIPEDA principles. Moreover, SkyLife may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.
The use of SkyLife will be considered consent to collect, use and disclose personal information for stated purposes.
Copies of the SkyLife Privacy Policy will be published on the SkyLife website at www.skylifeclubs.com.

Subject to legal or contractual restrictions, a person may withdraw consent by providing reasonable notice to SkyLife’s Privacy Officer. SkyLife will inform the person of any implications of such withdrawal. Any withdrawal of consent will still allow SkyLife to use and disclose a person’s personal information in order to collect or enforce payment of amounts owing as a result of a person’s previous or continuing use of SkyLife’s facilities and services. Subsequent use of SkyLife’s facilities and services will automatically provide consent for the collection, use, disclosure and retention of personal information.
4. LIMITING COLLECTION
The collection of personal information will be limited to that which is appropriate in the circumstances.

SkyLife collects some information about prospective persons using technology, so it may not be readily apparent to prospective persons that it is being collected. For instance, when a prospective person visits our website, their IP address is collected so that we know how many visits by individuals we may have had. An IP address is often associated with the place from which a prospective person enters the internet like their Internet Service Provider (ISP), their firm or company or their university. This information is not personally identifiable.
SkyLife may use “cookie” technology to obtain non-personal information from its online visitors for certain purposes. The cookie is stored on their computer to allow them to get back into certain areas of the website with as minimal delay as possible. We do not extract personal information in this process nor do we disclose this information. Cookies are tools that allow us to update and improve our sites.
5. LIMITED USE, DISCLOSURE & RETENTION
SkyLife will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the person or as required by law or otherwise . Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.
SkyLife may disclose a Person’s personal information to third parties retained by SkyLife for the purposes of billing such a Person for the use of SkyLife Properties and/or facilities, and to collect and enforce payment of amounts owing by such Persons.
Certain SkyLife employees and third party agents may be given access to a Person’s personal information collected by SkyLife in so far as their duties require access for the purposes outlined above. SkyLife employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.
Personal information that has been used to make a decision about a Person will be retained in accordance with the SkyLife document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. SkyLife retains personal information of a Person only for as long as it is required for SkyLife’s business purposes or as required by federal and provincial laws.
6. ACCURACY
SkyLife will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
SkyLife will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. SkyLife will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.

Access to a person’s personal information on record with SkyLife may be requested by that person in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, SkyLife will refer the person to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provided by them. To access your personal information, refer to “How to contact us”.
7. SAFEGUARDS
SkyLife will take reasonable steps to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use modification or destruction, through security safeguards appropriate to the sensitivity of the personal information. Employees and agents of SkyLife who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. As a condition of employment, all new employees/agents of SkyLife must sign a Confidentiality Agreement. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Care will be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
8. OPENESS
SkyLife will make readily available to persons specific information about its policy and guidelines relating to the management of personal information. SkyLife will be open about its policy and procedure with respect to the management of personal information, and persons will be able to acquire information about these policies easily and in a form that is generally understandable. This policy and any related information is available at all times on the SkyLife Website, www.SkyLifeClub.com, under Privacy. To contact SkyLife, refer to “How to contact us”.

9. INDIVIDUAL ACCESS
SkyLife will inform a person of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. SkyLife will assist a person in the preparation of a request for access when such a person requests assistance. SkyLife will inform the person whether or not it holds personal information about such person, and will indicate the source of any such personal information, when possible. There may, however, be situations in which SkyLife will not be able to provide access to all the personal information that it holds about a person, although these situations will be limited and specific, and permitted or required by law. For example, SkyLife will not be able to provide access to a person’s personal information where giving such access would likely reveal personal information about a third party, unless that third party’s personal information can be severed from the person’s personal information. If SkyLife refuses a request for access, the person will be informed in writing of the refusal, setting out the reasons for the refusal and informing the person of available recourse.
SkyLife will require that persons requesting access to their personal information provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit SkyLife to provide an account of the existence, use and disclosure of such persons’ personal information.

SkyLife will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.

SkyLife will respond to a person’s request to access such person personal information within a reasonable time, and in any event not later than 30 days after receipt of the request. SkyLife may be entitled to a 30 day extension to respond, in limited circumstances, in which case the person will be notified of such an extension, the new time limit, the reasons for extending the time limit, and such person’s right to make a complaint to the Privacy Commissioner with respect to the extension.
SkyLife may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the person, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

A person will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.
10. CHALLENGING COMPLIANCE
A person will be able to address a challenge concerning compliance with the above principles to SkyLife’s Chief Privacy Officer. SkyLife will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.
SkyLife will inform persons who make inquiries or lodge complaints of the existence of the relevant complaint procedures. SkyLife will investigate all complaints, and if a complaint is justified, SkyLife will take appropriate measures, including amending its policies and procedures.

HOW TO CONTACT US:
If you have any questions or comments about this Privacy Policy or you feel that your concerns or complaints have not been resolved to your satisfaction, please contact us:
o by telephone at 705-835-7875
o by facsimile at 705-835-7873
o in writing to the Chief Privacy Officer, SkyLife, 1101 Horseshoe Valley Road, Comp 10, R.R. #1, Barrie, Ontario L4M 4Y8
o or in person at 1101 Horseshoe Valley Road, Horseshoe Valley, Ontario
If the issue is still not resolved to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada at privcan@fox.nstn.ca or by calling 1-800-282-1376.