INFORMATION PRIVACY POLICY

The Orchard Golf and Country Club recognizes the essential importance of privacy, security and
information protection to members, guests and all stakeholders. As a private membership golf and country
club, with business processes, management structures and technical systems, we are committed to provide
protections across our operations and ensuring that personal information is protected from collection to
disposal.

This Information Privacy Policy is effective 01 January, 2018.

WHAT THE ORCHARD COLLECTS

To improve our services, it is important that we collect, use, process and analyze your personal
information when it is reasonable and necessary.

A. FROM MEMBERS, SUCH AS CURRENT, TERMINATED, APPLICANTS AND SHAREHOLDERS

  1. Information you provide to us when you apply for membership, such as your name, family
    members, nationality, contact details, Tax Identification Number (TIN) and vehicle(s) information;
  2. Billing/payment information used to pay your bills, particularly your credit card account and its
    information. However, details of the payment instrument are captured and processed by the
    payment gateway service provider; and therefore, beyond our control.
  3. Information to determine eligibility to participate in online and other system-related services, such
    as SMS Tee Time Reservation, Members Monthly Tournament and Saturday Shotgun
    Reservation, (e-Bill) Statement Of Accounts via Mailer, (Online Billing) Statement Of Accounts via
    Website, etc.;
  4. Information you fill out in any forms (paper/e-form/i-form), such as, when you wish to contact us to
    send your concerns and to register at our members portal;
  5. Information you give us when you communicate with The Orchard and/or any of our departments
    (e.g., Membership, Golf, Sports, Executive Office, Management Information Systems, Marketing,
    etc.), such as with respect to inquiries and complaint details on the quality and reliability of our
    service;

B. FROM EMPLOYEES, SUCH AS CURRENT, SEPARATED, AND APPLICANTS

  1. Information you submit when you apply at The Orchard for work, including what is contained in
    your resume/curriculum vitae and application form;
  2. Information we collect during the processing of your application, such as testing results,
    employment offer, results of character investigation, and pre-employment medical assessment;
  3. Information we collect and maintain about you during your employment, such as your payroll
    information, including but not limited to government mandated and third party remittances like
    SSS, Philhealth, and Pag-ibig contributions, taxes, bank account information; wages; entitlements
    and benefits ; health and welfare benefits; medical and dental care records; beneficiary and
    emergency contact information; training and certifications, performance evaluation; sanctions;
    employment changes / work history;
  4. Information we retain about you even after your separation from service, such as beneficiaries,
    and contact information;
  5. Any other information you voluntarily provide for any legitimate purpose declared at point of
    collection of such information.

C. FOR OUR VENDORS, CONTRACTORS, SUPPLIERS INCLUDING CONCESSINAIRE AND SERVICE PROVIDERS

  1. Information you submit to The Orchard in your application for accreditation, processing of
    payments, such as, your name, tax identification number, address, contact details, banking
    information;
  2. Any other information you voluntarily provide for any legitimate purpose declared at point of
    collection of such information.

D. FROM GUESTS/VISITORS

  1. The information you provide when you enter our premises such as, but not limited to, your name,
    address, vehicle type and plate number or conduction sticker number;
  2. Any other information you voluntarily provide for any legitimate purpose declared at point of
    collection of such information.

WHAT THE ORCHARD DO WITH THE GATHERED INFORMATION
The Orchard stores, processes, and analyzes the information that you provide to us for purposes,
including, but not limited to:

A. FOR OUR SHAREHOLDERS

  1. providing and continuously improving our services, as well as managing your account
  2. responding to your inquiry, concern or complaint
  3. sending information about our programs and service offerings that may be of interest to you
  4. sending messages related to your account notifications, updates, alerts, and other information
    that you request
  5. enabling us to accept bill payments according to your enrolled payment mode
  6. verifying your identity when you access your account through the various arrangement channels
    (e.g., e-mail, website, phone text/call, walk-in)

B. FOR OUR EMPLOYEES

  1. evaluating your eligibility for initial employment, including the verification of your qualifications and
    character references (background checking)
  2. administering your pay, statutory deductions, entitlements, and benefits
  3. complying with applicable statutory and regulatory requirements and submissions
  4. conducting performance reviews and rewards
  5. establishing appropriate training and/or developmental interventions
  6. administering disciplinary action and sanction
  7. collecting and maintaining contact information
  8. maintaining your employment records
  9. processing employee work-related claims (e.g. worker compensation, insurance claims, etc.)
  10. developing health and wellness programs

C. FOR OUR VENDORS, CONTRACTORS, SUPPLIERS INCLUDING CONCESSINAIRE AND SERVICE PROVIDERS

  1. verifying and confirming your identity as a vendor as part of your accreditation
  2. conducting business with you
  3. establishing and managing business relationships with you
  4. facilitating the payment of your invoices for any goods or services you have delivered/rendered
  5. complying with statutory, legal and regulatory requirements
  6. updating or maintaining your vendor account information
  7. establishing details of your authorized contact persons for the goods and/or services you supply

D. FOR OUR GUESTS/VISITORS

  1. establishing your identity
  2. recording the purpose of your visit
  3. monitoring visitor’s activities inside the company premises, including ingress and egress of
    equipment, vehicle, etc.

INFORMATION SECURITY
The Orchard is committed to ensure that your information is secure. The Orchard shall undertake and
implement reasonable organizational, physical, and technical security measures in collecting, receiving,
transmitting, storing, and disposing your personal information.

In addition, we recommend that you install anti-virus software on any such device before accessing the
internet. You are responsible for the security of your information once it reaches you or your
representative in any medium, including but not limited to written correspondences, bills, emails, system
applications, and on-line accounts. You should take appropriate measures to ensure that any medium or
device you use to monitor or manage your account is secure and not accessible to anyone without
permission.

LOGS COLLECTION
Your personal information may be collected by our logging processes in case of logical and physical
access to our systems and/or premises. When necessary, personal information may be retrieved for
security purposes.

PERSONAL DATA RETENTION AND DISPOSAL
We keep your personal data only for as long as necessary:
A. for the fulfillment of the declared, specified, and legitimate purposes provided above, or when the
processing relevant to the purpose has been completed or terminated;
B. for the establishment, exercise or defense of legal claims; or
C. for other business purposes that are consistent with standards established or approved by regulatory
agencies governing The Orchard;
Thereafter, your personal data shall be disposed or discarded in a secure manner that would prevent
further processing, unauthorized access, or disclosure to any other party or the public.

CONTROLLING YOUR PERSONAL INFORMATION
You may request for a copy of your personal information in our possession, or have it corrected if you
believe that it is inaccurate or incomplete.
If you wish to request for a copy of your personal data, or have it corrected or deleted, please reach out to
us through our contact information found below. We will promptly respond to your request.

Edmund D. Remo
Data Protection Officer
Tel. No.: (02) 982-2000 / (046) 416-5931 extension 2560
e-mail: DPO@theorchardgolf.com

CHANGES TO POLICY
The Orchard & Country Club reserves the right to revise or modify this Information Privacy Policy, as
necessary.

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