Effective Date: January 31, 2024
 
The Country Club of Harrisburg, Inc. and its affiliates (collectively, “Country Club of Harrisburg”) are committed to privacy and to transparency in our information practices. In this Privacy Policy (“Policy”), we describe our collection, use, disclosure, and processing of personal information that we collect online via our websites, mobile applications, as well as related to our products and services.
 
1. Scope of this Policy


This privacy policy describes, generally, how The Country Club of Harrisburg handles and processes personal information related to:
 

• the use of our websites, mobile applications, and associated services that link to this privacy policy (collectively, the “Website”)
• our former, current, and prospective customers, partners, and vendors
• individuals who communicate with us
• individuals who use our products and services and individuals whose personal information we receive in providing the services
• individuals who visit our buildings and property

 
Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This privacy policy is intended to describe our overall privacy and data protection practices. 
 
This Policy does not apply to the personal information we process relating to our employees and non-employee workers and job applicants and candidates who apply for employment with us.
 
In this Policy, our use of the term “personal information” includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.
 
2. What Personal Information We Collect


When you interact with us, we may collect and process the following categories of personal information:

• Identifiers such as your name, the company you are associated with, your role with your company, your company address, your address, your phone number and email address;
• Account information, such as your user ID, password, and security questions;
• Your demographic information;
• Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement;
• Your geolocation data;
• Information you may voluntarily submit to us;
• Your participation in marketing and other events;
• Visual information; and
• Our communications with you, including whether you opened an email that we sent to you, clicked on any links contained in the email, and information about the device you used to do so.

 
For users of our Website:  when you visit the Website, certain personal information may be passively collected, meaning it is gathered without your actively providing it.  This data may include your IP address, location (city/state/country), Website usage information, and device information. 
 
Categories of sources of personal information: We may collect personal information directly from you, as well as automatically related to your use of our Website and other services, as well as from third parties.  For example, we collect personal information:
 

• from you, either directly (i.e., through information you submit to us, including via forms that you may complete and submit through our Website) or indirectly (i.e., by observing your actions on our Website or in our buildings or on our property)
• from the content of surveys that you may complete
• from ‘cookies’ and other similar tools deployed on parts of our Website
• from our clients in connection with us providing professional services to them
• from data analytics providers
• from government entities
• from service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business)
• from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

 
Sensitive Information:  Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements. Where you provide us with such information without request from The Country Club of Harrisburg, we reserve the right (but do not have any obligation) to erase any such information at our discretion.
 
Information about children:  We do not knowingly collect personal information online from persons age sixteen and younger.  We reserve the right to delete any data identified as having been provided by such persons at our discretion.
 
3. What We Do with Your Personal information


We may process your personal information for the following purposes:

• Performing and managing the contract we have with you or the company you are associated with;
• Providing training;
• Registering you for and communicating with you about events;
• Managing our relationship with you;
• Communicating with you;
• Improving and operating our Website;
• Analyzing and improving our business, including to better understand how individuals access and use our Website and services;
• Analyzing advertising campaigns;
• Sending you promotional and marketing communications about our products or services or promotions;
• Defending our legal rights;
• To protect the safety and security of people and property;
• Auditing, reporting, corporate governance, and internal operations, including relating to audits, accounting, and legal functions, and relating to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business; and
• Complying with our legal obligations.
   

We do not use your personal information for profiling or for any other automated decision making purposes, and we do not sell your personal information.
 
4. Information Sharing


The Country Club of Harrisburg will process some of your personal information locally.  As an organization, however, many of our activities can also be carried out by processing or consolidating information about you in specific or centralized databases and systems.  As a result, your information may be shared with other entities within Country Club of Harrisburg in accordance with applicable laws, this Privacy Policy, any applicable specific local policy, and to support our business purposes.
 
As a general rule, we do not share your personal information with anyone outside Country Club of Harrisburg.  However, we may share your personal information with certain third parties that perform business functions or provide services to us, including with the following categories of recipients: event registration service providers, vendor invoice tracking service providers, contract management service providers, and data processing vendors.
 
Your personal information may also be shared for legal reasons (e.g., to prevent crime or fraud, or to comply with a court order or legislation) or with your consent.  We may disclose personal information that we collect or you provide in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, reorganization, or asset sale, or in the unlikely event of bankruptcy.
 
 
5. Data Retention


We store personal information as needed to accomplish the purposes identified in this Policy and to meet legal requirements, including legal and compliance requirements regarding records retention, resolving disputes, and enforcing our agreements.  This means that we may be required to maintain your personal information, for example, to: (1) comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us); (2) to exercise, establish or defend legal claims; and/or (3) to protect against fraudulent or abusive activity on our services and systems. 
 
We may retain different categories of information for different periods of time for the instances stated above. Retention periods for records maintained by us, including those containing personal data are established based upon business need, statutory and regulatory record keeping requirements in the geographies where we do business, and legal obligations.  If you have any further questions about our handling of personal information, please contact us using the contact details below.


 
6. How We Manage this Policy


We will update this Policy from time to time and notify you of any changes by posting the revised Policy on our Website.
 
7. Contact Us


If you have questions or concerns regarding this Privacy Policy or our data protection practices, please contact us by emailing [email protected] or writing to:
 
The Country Club of Harrisburg, Inc.
401 Fishing Creek Valley Road
Harrisburg, PA 17112