GGA Partners Inc. and its affiliates (collectively “GGA” or “we” or “us”) provide this Privacy Policy to explain how we collect, use and disclose the personal information we collect when you use our websites and other digital properties (“Sites”), use our products and services, including surveys (“Services”), apply for a role with us, communicate with us, and when you interact with our third party partners and service providers.

For purposes of this Privacy Policy, the term “personal information” means information about an identified or identifiable individual, as more specifically defined by applicable privacy legislation, and GGA is the “data controller”, as defined in privacy legislation applicable in the UK and EU.

If you have any questions about this Privacy Policy or how we handle your personal information, please contact our Privacy Manager using the contact information provided below.

How we collect personal information

We may collect your personal information directly from you when you interact with our Sites, Services, apply for a role with us, or communicate with us. We may also collect your personal information from our third-party partners and service providers. The personal information we collect about you may include the following:

When you interact with our Sites:

• account registration information, such as your username, password, and password hints and security questions, and
• device and connection information, such as cookies and other tracking information, Internet Protocol (“IP”) addresses, browser type, language, and website or other platform access times.

When you interact with our Services:

• contact information, such as your name, mailing address, telephone number(s), and email address(es),
• demographic information, such as your age, gender, household income, net worth, marital status, and occupation,
• information you provide about your family members, including their names, ages, and genders,
• membership information and preferences, including information about the club(s) that you belong to and your recreational, dining, and spending preferences, patterns, and other habits, and
• information we generate about you, including those related to your use of your club’s facilities and services.

When you apply for a role with us:

• contact information, such as your name, mailing address, telephone number(s), and email address(es), and
• information relevant to job applications, such as work and education history, specialized knowledge, and any other information provided as part of the application process, such as pre-employment checks.

When you communicate with us:

• contact information, such as your mailing address, telephone number(s), and email address(es), and
• any personal information contained in your communications with us.

In addition, the information we collect from third party partners and service providers may also include information concerning our Sites, analytics, marketing, and related information. We may collect information about how you interact with our third-party partners and service providers, in addition to how you interact with our websites and platforms.

We will only collect, use, and otherwise process your personal information where we are permitted to do so by applicable privacy legislation, also referred to as a “legal basis” in some jurisdictions. For example, we may process your personal information in order to perform our obligations under a contract with you, where we have your consent to do so, where we are required by law, or where it is in our legitimate business interests (for example, our legitimate interests in improving our products and services, or our legitimate interests in detecting and preventing unlawful activity). If we process more sensitive personal information about you, such as information about criminal offences as part of pre-employment screening, we only do so in compliance with applicable privacy legislation.

It is not a legal or contractual requirement to provide us with your personal information, but if you choose not to, then you may not be able to interact with our Sites, Services, apply for a role with us, or communicate with us.

Our platforms and services are not intended for children. We do not knowingly collect or maintain personal information of children under the age of 16 without permission from a parent or guardian.

How we use personal information

We use personal information for a variety of business purposes, including:

When you interact with our Sites:

• personalizing content that you view on our platforms,
• assessing trends and usage to help develop, evaluate, and improve our products and services,
• identifying patterns of behaviour to offer relevant suggestions and provide a personalized online experience, including through the delivery of targeted advertising and marketing services,
• analyzing our websites performance and functionality,
• compiling statistics and analyzing trends,
• identify documents accessed,
• offering more secure access to your account,
• improving our business operations, and
• detecting, preventing, or suppressing fraud or other prohibited or illegal activities.

When you interact with our Services

• providing client services,
• processing requests to participate in conferences and events, and
• publishing reports and conducting research initiatives.

When you apply for a role with us:

• evaluating and assessing your suitability for a job with us, and
• if applicable, onboarding you as a member of staff.

When you communicate with us:

• responding to your questions, complaints, comments or feedback,
• distributing newsletters and communications to individuals who have signed up to receive correspondence from us, and
• with your consent, communicating with you about new products, services, events, or promotions that may be of interest to you.

More broadly, we may also use your personal information for the purposes of:

• meeting our legal and regulatory requirements, and
• such other uses as may be permitted or required by applicable law.

How we share personal information

We may transfer your personal information to third party service providers with whom we have a relationship and who assist us in providing our products and services. For example, IT service providers, hosting providers, and email providers.

These third-party service providers are acting on our behalf in respect of the personal information that we transfer to them. We only transfer personal information that is reasonably necessary for the purposes intended. When transferring personal information to third party service providers, we implement contractual and/or other means to ensure those third parties provide a comparable level of protection to the personal information. The third parties are prohibited from using your personal information for unrelated purposes. Accountability for any personal information that is transferred to third party services providers remains with us.

These third parties may be based in a different jurisdiction to you, and the privacy laws applicable in those jurisdictions may differ from yours. However, where we transfer your personal information internationally (whether internally or with third parties), we either do so to countries that offer an equivalent level of protection for your personal information, or we implement appropriate safeguards to ensure that your personal information remains protected. For example, standard contractual clauses. If you would like more information about these safeguards, please contact our Privacy Manager using the details below.

We may also disclose your personal information as permitted or required by law. For example, we and our third-party service providers may disclose your personal information to law enforcement, government bodies or other organizations in response to a warrant, subpoena, or other court order. Such disclosures may also be made for the purposes of investigating a breach of an agreement or contravention of law, for detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law.

We may also disclose your personal information to another organization in the event that:

• we buy, sell, or otherwise acquire or dispose of our organization or a part of our organization, or any of its assets;
• we merge or amalgamate our organization with another;
• we make or receive a loan or other financing;
• an organization creates a charge on, or the take of a security interest in or a security on, any assets or securities of our organization;
• we lease or license any of an organization’s assets.

Any such disclosures will be conducted in accordance with applicable law.

How we protect and retain personal information

We take reasonable precautions to protect the personal information that we collect. We have implemented generally accepted standards of technology and operational security to protect the personal information we collect from unauthorized collection, use, disclosure, loss, misuse, alteration or destruction. Only authorized GGA personnel and third-party service providers with a need to know the information are provided access to personal information, and these individuals are required to treat this information as confidential.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as may otherwise be permitted or required by law.

Your Rights

Where granted by applicable law, you may have the right to request access to, and a copy of, the personal information that we have collected about you. You may also have the right to request that any inaccuracies in that information be corrected, or that the personal information we have about you be deleted.

You also may have the right to request that we cease processing your personal information at any time, subject to certain conditions depending on where you are based. If you request to “opt-out” or withdraw your consent for the collection, use and/or disclosure of your personal information, we will inform you of the consequences of doing so before processing your request. If you choose to withdraw your consent for our use of your personal information, this does not affect the lawfulness of our use of your personal information up to that point.

To exercise any of the above-mentioned rights, please contact our Privacy Manager using the contact information provided below.

In addition, you can opt-out of our marketing communications at any time by contacting our Privacy Manager or using the “unsubscribe” mechanism included in the communication; however, you will continue to receive transactional messages from us, as may be relevant, and correspondence relating inquiries, comments, or complaints.

You can also opt-out of our collection and use of cookies. There are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies or to be given the choice of declining or accepting cookies. Please refer to your browser instructions or help screen to learn more about these functions. If you choose to decline cookies, this may impair your ability to access and use some parts of our website.

If you believe that your privacy rights have been violated, or that we have not complied with our Privacy Policy or obligations under relevant privacy law, we encourage you to reach out to our Privacy Manager using the contact information provided below. You also have a right to file a complaint with the applicable privacy regulator.

Third party websites

Our website and affiliate sites may include links to third party websites. If you click on one of those links, you will be taken to a site that may collect information about you. This Privacy Policy does not apply to any linked websites that are operated by third parties. If you follow a link to a third-party website, we encourage you to review the third party’s privacy policies to ensure that they are acceptable to you.

Third Party Tracking/Do Not Track

We may, from time to time, collect information about your online activities, over time and across different websites. When you use our Sites, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Sites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

Automated decision-making and profiling

We do not use your personal information to make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

Updates to our privacy policy

We encourage you to review this Privacy Policy periodically. We may modify or amend this Privacy Policy from time to time in our full discretion without any prior notice or liability to you or any other person. Our Privacy Policy is current as of the “last revised” date which appears at the top of this page.

Contact us

If you have any questions, comments, or concerns regarding our Privacy Policy and practices, please email our Privacy Manager at privacy@ggapartners.com, call us at (905) 475-4017, or write to us at:

Privacy Manager
GGA Partners Inc.
37 Sandiford Drive, Suite 408
Stouffville, Ontario L4A 3Z2