Heritage Palms Golf & Country Club (“HPGCC,” “the Club,” “we,” “us,” or “our”) respects the privacy of our members, residents, guests, website visitors, app users, and other individuals who interact with the Club. We are committed to maintaining appropriate standards of confidentiality and protecting personal information entrusted to us.
 
This Privacy Policy describes the types of personal information we may collect, how we use and disclose that information, the technologies we may use to collect it, and the choices and rights available to individuals under applicable law.
 
This policy applies to HPGCC’s website, member portal, mobile application, social media accounts, electronic communications, visitor management systems, and other digital platforms or services that link to this policy (collectively, the “Services”). It also applies to personal information collected through certain interactions with the Club, including membership-related activities, reservations, event registrations, inquiries, and other Club operations.
 
By using the Club’s services and amenities, you acknowledge and agree to the terms and conditions of this policy. Please review it periodically, as it may be updated to reflect changes in our practices, technology, or legal obligations.
 

1. Personal Information We Collect

The information we collect depends on how you interact with HPGCC and which Services you use. Information may include the following categories: 

Contact and Identification Information
We may collect information such as your name, mailing address, email address, telephone number, member or account identification information, and other information you provide when communicating with the Club, accessing the member portal, registering for an event, making a reservation, or using Club services.
 
Membership and Club Activity Information
To support Club operations, we may collect and maintain information related to membership accounts, household or authorized-user records, event registrations, dining and facility reservations, recreational activities, communications, and other Club-related transactions or interactions.
 
Website, Application, and Device Information
When you access our website, member portal, or mobile application, we may collect information such as your Internet Protocol (IP) address, browser type, device type, operating system, referring website, pages viewed, access times, general location information, and information about how you interact with our digital Services.
 
Location Information and Geofencing
If location-based features are implemented and enabled in the HPGCC mobile application or other Club technology, we may collect or process location information from your device, subject to applicable permissions, settings, and law.
 
Geofencing uses virtual geographic boundaries around designated locations. When a device meets the applicable location and permission requirements, geofencing technology may be used to support location-based features, notifications, or Club communications. Depending on the technology and settings, this may involve the use of device location data, GPS, Bluetooth, Wi-Fi, or other location-related signals.
 
Location information may be used to support Club operations, communicate relevant information, enhance the member or guest experience, and provide location-based features or notifications. The specific information collected and how it is used will depend on the technology implemented and the permissions granted by the user.
 
You may be able to manage or disable location permissions through your device settings. Disabling location access may limit the availability or functionality of certain location-based features.
 
Communications and Correspondence
We may collect information contained in communications with HPGCC, including emails, telephone calls, text messages, social media messages, online forms, surveys, and other correspondence. Where permitted by law, communications may be recorded or retained for customer service, operational, administrative, security, or recordkeeping purposes.
 
Payment and Transaction Information
When you make an eligible payment or transaction through a Club service, we or our authorized payment processors may collect information necessary to process the transaction. Payment card information may be handled by third-party payment processors in accordance with their security practices and applicable requirements.
 
Visitor and Vendor Information
To support community security and visitor management, HPGCC may collect information provided by members, residents, guests, vendors, or other authorized individuals in connection with visitor registration, access authorization, or related operational procedures. This may include names, contact information, visit details, vehicle information, and other information necessary for the applicable purpose.
 
Employment and Business-Related Information
If you apply for employment or otherwise conduct business with HPGCC, we may collect information relevant to the application or business relationship, such as contact details, employment history, qualifications, and other information you voluntarily provide, or that may lawfully be obtained from authorized third parties.

 

2. How We Collect Personal Information

HPGCC may collect personal information through the following methods:

• Directly from you: When you provide information through our website, mobile application, member portal, forms, reservations, registrations, surveys, email, telephone, text messages, or other communications.
• Through Club operations: When information is provided or generated in connection with membership administration, visitor management, facility reservations, event participation, Club transactions, and other authorized activities.
• Automatically through technology: When you use our website, mobile application, or other digital Services, including through cookies, device identifiers, analytics tools, and similar technologies.
• Through location-based technologies: Where implemented and permitted, through location services, geofencing, or other technologies used to support location-dependent features.
• From authorized third parties: Where appropriate and permitted by law, from service providers, payment processors, event or reservation platforms, social media platforms, technology providers, and other organizations that support Club operations.

 

3. How We Use Personal Information

HPGCC may use personal information for legitimate Club, administrative, operational, security, and communication purposes, including to:

• Provide and administer membership services, member accounts, and authorized access to Club resources.
• Process reservations, event registrations, payments, and other Club-related transactions.
• Communicate Club news, announcements, event information, operational updates, policy changes, and other relevant information.
• Operate and maintain our website, mobile application, member portal, and other digital Services.
• Support visitor management, access authorization, security, safety, and related Club operations.
• Provide location-based features or notifications where geofencing or other location technologies are implemented and enabled.
• Personalize and improve the functionality and usability of our digital Services.
• Evaluate usage patterns, troubleshoot technical issues, and improve communications and member experiences.
• Conduct surveys, obtain feedback, and assess interest in Club programs, amenities, and events.
• Maintain appropriate business, membership, financial, and administrative records.
• Protect the rights, property, safety, and security of HPGCC, its members, residents, guests, employees, and other individuals.
• Detect, investigate, and respond to suspected fraud, unauthorized access, security incidents, or other potentially unlawful activities.
• Comply with applicable laws, regulations, legal processes, and other legal obligations.
• Fulfill another purpose disclosed to you at the time information is collected or otherwise permitted by applicable law.

 

4. How We Disclose Personal Information

HPGCC does not disclose personal information indiscriminately. We may share information as reasonably necessary for Club operations, the purposes described in this policy, or as otherwise permitted or required by law.
 
Authorized Club Personnel
Information may be made available to authorized employees, management, contractors, or other personnel who need it to perform their assigned responsibilities.
 
Technology and Service Providers
We may share information with service providers that support our operations, including website and application hosting providers, membership management systems, reservation and event platforms, payment processors, visitor management providers, communications services, analytics providers, and other technology or administrative service providers.
 
These providers may process information on our behalf as necessary to deliver their services, subject to applicable contractual requirements and law.
 
Location and Geofencing Technology Providers
If location-based features are implemented, certain information may be processed by the technology providers responsible for supporting those features. The information involved will depend on the system used, its configuration, the permissions granted, and the applicable service provider's role.
 
HPGCC should review the applicable provider's privacy practices and contractual terms to determine precisely what location information is collected, where it is processed, how long it is retained, and whether it is shared with additional parties.
 
Payment and Transaction Providers
Information may be shared with authorized payment processors and financial service providers to facilitate transactions, prevent fraud, and maintain appropriate financial records.
 
Social Media Platforms
When you interact with HPGCC through social media, information may be processed by the applicable platform. Content you post publicly, including comments, photographs, or other interactions, may be visible to other users in accordance with that platform's settings and policies.
 
Legal, Safety, and Security Purposes
We may disclose information when reasonably necessary to comply with applicable law, legal process, or governmental requests; enforce Club policies or agreements; investigate suspected misconduct; address security incidents; or protect the rights, property, and safety of HPGCC and others.
 
Business or Organizational Changes
Information may be disclosed as necessary in connection with a reorganization, transfer of operations, or other organizational transaction, subject to applicable law and any required protections.
 
With Your Authorization or at Your Direction
We may disclose information when you authorize us to do so, direct us to share it, or otherwise provide information for a purpose that makes the disclosure reasonably necessary and lawful.
 
HPGCC does not sell personal information for monetary consideration. Any sharing of personal information for advertising or other purposes will be subject to applicable law and the Club's actual practices. Where required by law, we will provide applicable notices and choices regarding such sharing.
 

5. Cookies and Other Tracking Technologies

Our website and digital Services may use cookies, pixels, web beacons, analytics tools, device identifiers, and similar technologies to support functionality, understand usage, maintain security, and improve the user experience.
 
These technologies may collect information such as browser type, device information, pages visited, interactions with content, session activity, and other technical or usage information.
 
Website Analytics
HPGCC may use analytics services to understand how visitors use our website and digital Services, identify technical issues, and improve navigation, content, and functionality. The information collected and the providers involved will depend on the tools implemented.
 
Third-party analytics providers may process information according to their own privacy policies and applicable agreements.
 
Cookies and User Choices
Depending on your browser and the technologies in use, you may be able to manage cookies through your browser settings or through any preference controls provided on the website. Blocking certain cookies may affect the functionality of some features.
 
Please note that browser cookie settings do not necessarily control location permissions or data collection through a mobile application.
 
Mobile Application Permissions
Certain application features may require permission to access device functions or information, such as location or notifications. You may be able to grant, limit, or revoke these permissions through your device settings. The availability of particular features may be affected by your choices.
 
Third-Party Tracking Technologies
The practices of third-party providers may differ from those of HPGCC. Where third-party technologies are used, users should review the relevant provider's privacy policy and available privacy controls.
 

6. Location Services and Geofencing

If HPGCC implements or uses geofencing or other location-based technologies, those technologies may help deliver relevant information or enable certain features based on a device's location in relation to designated geographic areas.
 
Depending on the system, location-based services may be used for purposes such as:

• Delivering relevant Club information or notifications.
• Supporting location-dependent mobile application features.
• Enhancing the delivery of Club communications and operational information.
• Supporting authorized Club activities and services.

 
The precise capabilities and uses will depend on the technology selected by HPGCC and how it is configured.
 
Location information may be considered sensitive personal information under certain laws. HPGCC will handle such information in accordance with applicable legal requirements and the permissions or choices provided by users.
 
Your Choices Regarding Location Information
You can review your device's privacy settings to determine whether the HPGCC mobile application has permission to access your location. Depending on your device and application, you may be able to allow location access only while using the application, allow access in the background, or disable access altogether.
 
You may also be able to disable push notifications through your device or application settings. Disabling location access or notifications may prevent certain location-based features from functioning.
 
Location permissions and notification preferences are separate controls. Turning off one does not necessarily disable the other.
 

7. How Long We Retain Personal Information

HPGCC retains personal information for as long as reasonably necessary to fulfill the purposes described in this policy, support Club operations, maintain appropriate records, comply with legal obligations, resolve disputes, and enforce applicable agreements or policies.
 
Retention periods may vary depending on the type of information, the purpose for which it was collected, applicable legal or recordkeeping requirements, the nature of the relationship with HPGCC, and the requirements of relevant service providers.
 
When information is no longer required for a legitimate purpose, HPGCC will take appropriate steps to dispose of it or otherwise handle it in accordance with applicable law and retention practices.
 

8. Links to Third-Party Websites and Services

Our website, mobile application, emails, and social media accounts may contain links to websites, applications, or services operated by third parties.
 
HPGCC does not control the privacy practices, security measures, or content of independent third-party services. Accessing those services may subject you to their separate terms and privacy policies.
 
We encourage you to review the privacy policies of third-party services before providing personal information through them.
 

9. Social Media and Public Communications

HPGCC may maintain social media accounts to share Club information, announcements, events, photographs, and other content.
 
Information you choose to post, comment on, or share through a public or third-party social media platform may be accessible to other users and may be handled in accordance with the platform's privacy practices.
 
If you communicate with HPGCC through social media, we may use the information you provide to respond to your inquiry or address the matter raised. Please avoid posting sensitive personal information in public comments or other publicly accessible areas.
 

10. Information Security

HPGCC uses reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction.
 
However, no website, mobile application, electronic communication, or information storage system can be guaranteed to be completely secure. Although we take reasonable steps to protect information, we cannot guarantee absolute security during transmission or storage.
 
Members and other users should take appropriate precautions to protect their account credentials, devices, and personal information. If you believe your account or information has been compromised, please contact the Club through its established communication channels.
 

11. Privacy Rights and Choices

Depending on your state of residence and applicable law, you may have certain rights regarding personal information collected about you. These rights may include, where applicable:

• Access: Request access to certain personal information held about you.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of certain personal information, subject to legal and other applicable exceptions.
• Data Portability: Request a copy of certain personal information in a portable format where required by law.
• Opt-Out Rights: Opt out of certain processing activities, such as targeted advertising, the sale or sharing of personal information, or certain profiling activities, where applicable.
• Consent Choices: Withdraw consent where processing relies on your consent, subject to applicable law.
• Appeal: Appeal certain decisions concerning a privacy request where such a right is provided by law.

 
The availability and scope of these rights vary depending on the applicable law and the circumstances of the request. Certain information may be retained or processed where permitted or required by law, including for legal compliance, security, recordkeeping, or the establishment or defense of legal claims.
 
To submit a privacy-related inquiry or request, contact HPGCC through the Club's established contact channels and identify the nature of your request. The Club may need to verify your identity and, where applicable, the authority of an authorized representative before responding.
 
HPGCC will review and respond to eligible requests within the time periods required by applicable law. If a request cannot be fulfilled in whole or in part, we will provide an explanation where required.
 

12. Text Messages and Electronic Communications

HPGCC may communicate with members and other individuals through email, text messages, mobile application notifications, and other electronic channels.
 
Depending on the communication preferences and permissions you provide, messages may include membership or account information, reservations, event announcements, operational updates, Club news, reminders, and promotional or informational communications.
 
Text Messaging
If you provide your mobile number, you consent to receive text messages from HPGCC.
 
Message frequency may vary, and message and data rates may apply depending on your wireless plan. Where supported, you may opt out of text messages by replying STOP and request assistance by replying HELP. Additional instructions may be provided in the applicable message or enrollment process.
 
Consent to receive text messages is not a condition of purchasing goods or services where prohibited by law.
 
HPGCC will handle text-message consent and related information in accordance with applicable law and the terms of the messaging program. Any restrictions on sharing mobile numbers or text-message consent data must reflect the Club's actual practices and agreements with its messaging providers.
 
Email Communications
You may manage or opt out of email communications using the unsubscribe instructions included in the message, where available. HPGCC may continue to send necessary administrative, account-related, security, or operational communications where permitted by law.
 
Mobile Application Notifications
You may be able to enable or disable application notifications through your device settings or the application's available preferences. Disabling notifications may limit your ability to receive certain timely Club communications.
 

13. Children's Privacy

HPGCC's digital Services are not intended to knowingly collect personal information from children in circumstances where parental consent is required and has not been obtained.
 
Where applicable law requires parental or guardian consent for the collection or processing of a child's personal information, HPGCC will follow those requirements.
 
If you believe that personal information has been collected from a child in a manner inconsistent with applicable law, please contact the Club through its established communication channels so the matter can be reviewed.
 

14. Florida Residents and Applicable Law

HPGCC operates in Florida and handles personal information in accordance with applicable federal and state laws.
Depending on the nature of the information collected, the Services used, and the individual's circumstances, additional privacy protections or rights may apply. Nothing in this policy is intended to limit any rights available under applicable law.
 

15. Changes to This Privacy Policy

HPGCC may update this Privacy Policy periodically to reflect changes in Club operations, digital Services, technology, applicable laws, or privacy practices.
 
When changes are made, the revised policy will be posted on the HPGCC website with an updated revision date. Where required by law, HPGCC will provide additional notice or obtain consent before implementing material changes.
 
We encourage members, residents, guests, and other users to review this policy periodically.
 

16. Contact Us

If you have questions about this Privacy Policy or wish to submit a privacy-related inquiry or request, please contact Heritage Palms Golf & Country Club, Incorporated through the official contact information provided on the HPGCC website.
 
Heritage Palms Golf & Country Club (HPGCC)
Fort Myers, Florida
Please do not include sensitive personal information in a general inquiry unless it is necessary and you have been directed to an appropriate secure channel.