PRIVACY STATEMENT
Your privacy is a priority for Chartwell Golf and Country Club, located at 1 Chartwell Drive, Severna Park, MD 21146, (“Chartwell,” “we,” or “us”) and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer or your device and that enable your identification. This Privacy Statement describes how we process personal information about you that we collect through the website and application operated and controlled by us from which you are accessing this Privacy Statement (collectively, the “Platform”). This Privacy Policy only addresses information collected directly through or from our Platform – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the Platform, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.
This Privacy Statement is incorporated into Chartwell's Terms and Conditions for the Platform by reference, as if set forth fully therein. By using the Platform, you agree to the terms and conditions of this Privacy Statement.
If you have any questions concerning this Privacy Statement, please email Chartwell at [lbickel@chartwellgcc.com].
1.         Privacy of Children.  The Platform is not intended for individuals under the age of 18. The Platform does not knowingly collect personal information online from users in this age group. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 18, please contact us.  We strongly recommend that minors ask their parents for permission before sending any information about themselves to anyone over the Internet and we encourage parents to teach their children about safe internet use practices
2.         Collection of Personal Information.

1. “Personal Information” is information that identifies you as an individual, such as: name, email address, postal address, telephone number, and email address. 
2. We may collect and process the following Personal Information about you:
   1. Information that you provide by filling in forms on the Platform. This includes information provided at the time of registering to use the Platform, subscribing to of our services, posting material, or requesting further services. We may also ask you for information when you enter a promotion sponsored by us or when you report a problem with the Platform.
   2. If you contact us, we may keep a record of that correspondence.
   3. We may also ask you to complete surveys that we use for research purposes, although you are not required to do so.
   4. Information that you provide in order to benefit from a particular feature or participate in a particular activity, such as when you sign up to receive emails from us, request a brochure, schedule an activity, or sign up for a newsletter.
3. Through your use of the Platform, we may also gather certain information about your use of the Platform that does not identify you individually, but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Platform. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you visit the Platform. We may also collect information regarding user traffic patterns and site usage. This Traffic Data does not, however, contain anything that can personally identify you. It is used to analyze and improve the Platform and to provide our users with a fulfilling Internet experience. Please see the section below in this Privacy Statement regarding Passive Information Collection for more information about our use of cookies and other technologies.
4. We may combine your Personal Information with other information we have collected from you, whether on- or offline, including, for example, your membership history or Traffic Data.  We may also combine your Personal Information with information we receive about you from other sources, such as our affiliates, publicly available information sources, and third parties.  We treat the combined information as Personal Information.

3.         Use of Personal Information Collected.  We use the personal information we collect to provide our services to you, to measure and improve those services, and to provide you with user support.  In addition, we use personal information:
 

• to respond to your inquiries and fulfill your requests.
• to send you important information regarding our relationship with you or regarding the Platform, changes to our terms, conditions, and policies and/or other administrative information. 
• to create and manage your personal account with Chartwell.
• to send you promotional communications that we believe may be of interest to you.  You may opt-in separately to receive e-mail messages from the Platform.  If you sign up for these features of the Platform, email communications will be sent to the email address that you provide to the Platform.
• to personalize your experience on the Platform by presenting offers tailored to you.
• to allow you to participate in contests and similar promotions, and to administer these activities.  Some of these activities have additional rules, which could contain additional information about how we use and disclose your personal information, so we suggest that you read these rules carefully.
• to administer blogs, chat, and other social media on our Platform.
• for our business purposes, such as data analysis, audits, developing new services, enhancing the Platform, improving our services, identifying Platform usage trends, and determining the effectiveness of our promotional campaigns. 
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• for any other purpose specified at the point of collection.

 
Note that we may use and share information that does not identify you, such as aggregate statistics and demographic information, without restriction, to the extent permitted by applicable law.
 
4.   Disclosure of Personal Information to Third Parties.  Except as set forth herein or with your consent, any personal information that you provide to Chartwell through the Platform will not be disclosed to third parties not affiliated with Chartwell. We may disclose personal information as follows:

• to our third party service providers who provide services such as Platform hosting, data analysis, payment processing, IT services, customer service, email and direct mail delivery services, credit card processing, auditing, and other services, in order to enable them to provide services.
• by you, on message boards, chat, profile pages, blogs, and other social networks to which you are able to post information and materials.  Please note that any information you post or disclose through these social networks may become public information depending on your privacy settings both on the Platform and the social media platform on which the information is posted or disclosed. 
• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• otherwise, with your consent.

While Chartwell may undertake efforts to see that any third party to which Chartwell discloses personal information is under an obligation to use the personal information solely for the purposes for which the information was disclosed, such third parties are independent third parties over which Chartwell exercises no control. Chartwell is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of third parties.
5.         Passive Information Collection, Use, and Choices
As you navigate the Platform, certain information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:

1. Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
2. Through your device: If you access the Platform through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Platform.
3. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Platform, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Platform. More specifically, we use cookies to:

(i) recognize your computer or device to make your use of the Platform easier, such as to remember your locations of interest and other preferences with the Platform;
(ii) gather statistical information about use of the Platform in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it; and
(iii) select which offers are most likely to appeal to you and display them while you are on the Platform.
To learn more about cookies, please visit http://www.allaboutcookies.org.

4. Using Monitoring Tools: The Platform may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Platform and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, compiling statistics about Plaftorm usage and response rates, and tracking the activities of users of the Platform and e-mail recipients.
5. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Platform, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Platform usage levels, helping diagnose server problems, and administering the Platform.
6. Analytic Tools: We also use tools and third party services to collect information about usage of the Platform, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page. Generally speaking, Google Analytics collects information on how often users visit the Platform, what aspects of the Platform they visit when they do so, and what other websites users visited prior to accessing the Platform. The Platform makes use of Google Analytics services for demographics and interest reporting, You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.

If you are uncomfortable with the idea of your Personal Information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, and turning off location-based services. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Platform, you may be required to provide us with certain information. If you do not wish to provide that information through the Platform or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Platform.  At this time, the Platform does not respond to Do Not Track (DNT) signals.
6.   Links to Other Platforms. The Platform may also contain links to third party websites, for the convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Platform, any information you disclose on that website is not subject to this Privacy Statement. It is possible that these links may be used by third parties or others to collect personal or other information about you. Chartwell is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites.
7.   Social Media.  Some aspects of the Platform may allow you to interface with other websites, social media, and other online services, such as Facebook. We will diligently work to identify these aspects of the Platform to you, for example, by identifying them with the applicable third party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Platform through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services.  For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.
8.   Security Measures and Communicating with Chartwell.  Chartwell has implemented features designed to prevent the loss, misuse, alteration, or unauthorized release of or access to personal information provided to us.  However, the confidentiality of any communication or material transmitted to or from Chartwell via the Platform or via email cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the Platform’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Chartwell is not responsible for the security of information transmitted via the Internet.
9.   Access to and Ability to Correct Personal Information; Opt-Out Right.  You may modify, correct, change or update your personal information by emailing Chartwell at [lbickel@chartwellgcc.com]. Except as necessary to obtain the services or information requested, you may opt out of having your personal information, which has been voluntarily provided by you to Chartwell through email, contact forms, or other online avenues, prospectively retained by Chartwell by contacting Chartwell.
10.  California Residents.  California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request by email to [lbickel@chartwellgcc.com].
11.  Right to Change Privacy Statement.  Chartwell reserves the right at any time to modify, alter or update this Privacy Statement. Your use of the Platform following any changes means that you agree to follow and be bound by the Privacy Statement as changed. Any change to this Privacy Statement shall be effective as to any visitor who has visited the Platform before the change was made. It is the obligation of users visiting the Platform before the change to learn of changes to the Privacy Statement since their last visit.
Dated: March 1, 2018
Copyright © 2018 Chartwell Golf and Country Club; All rights reserved.