Privacy Policy

LIMURU COUNTRY CLUB
PRIVACY NOTICE

Introduction

This notice sets out how Limuru Country Club (“the Club”, “we”, “our”, “us”) handles personal information, and acknowledges the Club’s obligations under the Data Protection Act 2019 (DPA 2019) and other relevant privacy laws and regulations.

In undertaking our activities and functions, we may collect, hold, use, disclose and otherwise handle personal information about individuals such as you (you, your).

In this document, ‘personal information’ and ‘sensitive information’ have the same meaning given by the DPA 2019.

• Personal information means information or an opinion about an individual who is identified or who is reasonably identifiable.
• Sensitive information is a type of personal information, and includes health information, genetic information, and information about an individual’s criminal record, sexual orientation or practices, racial or ethnic origin, religious beliefs and affiliations, philosophical beliefs, political opinions, membership of political, professional and/or trade associations, and some aspects of biometric information.

Scope

By engaging with the Club, attending the Club’s facilities, using our website at www.limurucountryclub.co.ke, and/or providing the Club (or a person acting on behalf of the Club) with personal information about you or another person, you:

• acknowledge this Policy;
• agree that we may collect and handle personal information, including in the course of our activities and functions as set out in this Policy; and
• acknowledge and agree that other Club policies (as provided to you) may apply to our handling of personal information, in addition to this Policy.

This Policy applies to the collection or handling of most personal information about current and former employees, and also applies to the Club’s handling of personal information about contractors, and applicants for employment with the Club.

How do we collect personal information?

The Club collects personal information in a range of circumstances including when:

• you enquire about, apply to become, or are a member of the Club;
• you are a visiting player (or team member) to the Club’s facilities;
• you register to participate in a program or clinic run at the Club’s facilities;
• your register to participate in third party events and programs that will be hosted by the Club (such as certain programs offered by Kenya Golf Union, Kenya Ladies Golf Union and Junior Golf Foundation among others);
• you are a prospective or actual official for an event at the Club’s facilities;
• you register or attend a Club event, or an event hosted at the Club’s facilities;
• you engage the Club to host an event for you;
• you subscribe to receiving promotional updates about the Club and our activities;
• you make an enquiry with us, or acquire other products or services from us;
• you or the organisation your work for is engaged in business dealings with us;
• you apply to, or do, work or volunteer work for us; and/or
• you are involved in other relevant dealings with us.

We collect personal information directly from you in various ways, including: telephone enquiries, in person, by email, when you visit or communicate with the Club through our websites, written correspondence, club surveys, the visitors’ and temporary members’ register, interviews, or from a third party (e.g., a reference), mobile applications, social media sites and other digital platforms.

There are times when we may collect your information from third parties or a public source. For example, sometimes we may collect personal information from the country’s golf governing bodies, a visiting player’s club, those who play a round with you (e.g. where one player submits the results on behalf of a group), a player’s coach, manager or representative, and in the case of a minor from their parent or legal guardian.

If we are unable to collect the personal information we require, or the information provided is incorrect or incomplete, this may affect our ability to interact with you, such as our ability to assess or process your membership nomination or provide you with our services.

If you provide us with personal information about another person you represent, and we collect it on the basis that, that person agrees to our collection and handling of their personal information in accordance with this Policy.

The kind of personal information we collect

The personal information the Club collects will vary depending on the nature of the interaction with us.

In some limited circumstances we may also collect sensitive information. For example, if you attend a Club event, we may collect health information such as dietary and special access information, or if you apply for a position with the Club we may collect sensitive information as part of a pre-employment medical screening, criminal history check or when confirming residency status. Sensitive information will be used and disclosed only for the purpose for which it was collected, for a directly related secondary purpose within reasonable expectations, or for another secondary purpose with consent or where the privacy laws allow (e.g., a use or disclosure required or authorised by another law).

Examples of the kinds of personal information we may collect, amongst others, are detailed below.

Purposes for collection, storage, use and disclosure of personal information

The Club may collect, store, use and disclose your personal information for the primary purpose of collection, and for other reasonably expected secondary purposes which are related to that primary purpose, and as otherwise permitted by law.

Generally, these purposes may include:

• to assess and process membership nominations;
• to manage memberships;
• to administer and coordinate events, programs and clinics, including participation in those for players, teams, officials and others;
• to manage player handicaps;
• to respond to your enquiries, and arrange the supply of services and products;
• to manage payments and refunds;
• to organise and coordinate functions and events;
• to operate our facilities;
• to assess potential suppliers and to administer their contracts;
• to help us manage and enhance our operations and services;
• to adhere to corporate governance requirements;
• to respond to emergency situations invoicing or requiring medical treatment;
• to administer, manage and provide you with access to the Club’s website and social media channels;
• to communicate with Members;
• to provide surveys and obtain feedback;
• to produce our quarterly newsletter and send other promotional communications
• to produce a List of Members;
• to assess applications for employment; and
• as otherwise required for our general business operations (for example, maintenance of our business records, compliance with our legal and insurance obligations, for performance reporting, research, product development and planning, statistical purposes, and as part of any business sale or asset sale process).

The Club may disclose your personal information to certain third parties, such as our service providers or other third parties relevant to the product or service to be provided by us. For example:

• other golf clubs for the purpose of reciprocal arrangements;
• other members for the purposes of organising and coordinating functions and events and providing services;
• Kenya Golf Union and its affiliates
• our service providers such as marketing agencies, mail houses, delivery partners or contractors;
• companies we work with in staging events and engage to carry out functions and activities on the Club’s behalf including marketing;
• our professional advisers, including our accountants, and auditors, and our insurers;
• where relevant, player representatives (coach, manager, medical staff etc);
• where relevant, sporting bodies and/or Games Organising Committees, World Anti-Doping Agency and other state sporting bodies;
• government and law enforcement bodies as required by law.

Apart from the above instances, we may also collect, store, use and disclose your personal information with your consent and as otherwise permitted by the privacy laws.

Marketing and Communications

Members are subscribed to receiving promotional communications, unless they opt-out.

We may use your personal information, where you are a member or if you have subscribed to receiving promotional communications, to provide you with information about our activities, and to provide you with our newsletters, reports, invitations and requests for support. We may do so using a number of different mediums (for example by phone, mail, email, social media, SMS etc), subject to your preferences.

You can opt-out at any time by contacting our Privacy Officer on the details below, or by using unsubscribe functionality in an electronic marketing communication.

Website

The Club’s website uses standard web browser features called “cookies” or “web beacons” (electronic images that allow the website to count visitors who have accessed a particular page and to personalise their experience) on our digital platforms to help us improve your experience. We or our service providers may also use cookies or web beacons to collect aggregated data about use of the website. We use the following types of cookies, as will your browser:

• Analytics cookies that remember users’ computers or mobile devices when they visit our digital platforms. They keep track of browsing patterns and help us to build up a profile of how users use our digital platforms. We use that information for customer analytics and to serve advertisements and information that we think might be of particular interest to users.
• Service cookies that help us to make our digital platforms work efficiently; to remember users’ registration and login details and their settings preferences; and to detect what device users are using and adapt how our digital platforms present our services according to the screen size of that device.

If you wish to limit or prevent the use of these technologies, you can configure your browser or device to do so. However, if you choose to do so, this may limit the functionality of some parts of our website. Please refer to our cookie policy for further details about the cookies and other similar technologies we use.

Sharing personal information with Kenya Golf Union (KGU) and its affiliate bodies

Kenya Golf Union is the national governing body for golf in Kenya, and is responsible for Kenya’s golf course rating and handicapping system and database. This system (and database) is made available to the Club and other participating clubs, and to their members, through the handicap and tournament management app.

When you play at Club facilities as a member, as a visitor from another participating club, or in a program offered through or by KGU, then on your request the Club may provide details of your results directly to KGU for these purposes. Such purposes include the accessing and maintenance of daily handicaps, to manage and administer golf operations such as competitions, events, memberships, scoring and other operations supported by the handicapping platform, and to manage golf products and services supported by the handicapping platform and app such as tee, lesson and program bookings. By making such requests you represent that you are familiar with, and agree to your personal information being collected and handled by KGU in accordance with their privacy practices. You should ensure that you remain familiar with KGU’s privacy policy as updated from time to time.

Members of the Club and other participating clubs can access the handicapping platform or app. When signing up, you agree to the KGU Terms of Use and you acknowledge that your personal information will be collected and handled by KGU in accordance with their privacy practices.

The Club is not responsible for the way in which KGU collects and handles personal information of the Club members and other individuals, which may differ to the practice of the Club.

Storage of your personal information

We may hold your personal information in electronic formats on our technology systems, and those of our contractors or suppliers, and in hard copy.

We may retain your personal information, including in our IT system back-up records, to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud, to resolve disputes, and as otherwise permitted by law.

The transfer of data over the Internet is inherently insecure. We cannot guarantee the security, during transmission, of any personal information electronically provided to us, including via our website. Please bear this in mind when transmitting personal information to us.

Third party websites

The Club’s website, emails and other material provided by the Club, may contain links to or addresses for third party websites. The Club is not responsible for the privacy, security or handling of personal information via those websites. You should review the privacy policy and terms of use for those websites each time you visit them.

How do we keep personal information accurate and up to date?

It is important that your personal information held by the Club is accurate and up to date.

You can request the Club to correct the personal information we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading.

These requests should be made in writing to our Privacy Officer via the contact details shown below. Upon receipt we may first request further information from you to verify your identity.

You may seek access to your personal information

You may seek access to personal information the Club holds about you. All access requests should be made in writing to our Privacy Officer via the contact details shown below. We will require you to verify your identity and to specify what information you require. No fee will be incurred for making an access request.

Complaints

If you have any concerns or complaints about the way we handle your personal information, please contact the Club’s Privacy Officer using the details listed below.

Complaints must be in writing. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response. We will endeavour to respond as quickly as possible, which generally, will be within 14 days of receiving your complaint. The investigation may include, for example, gathering the relevant facts, locating and reviewing relevant documents and speaking to relevant individuals. If the matter is more complex and our investigation may take longer, we will let you know. If you are not satisfied with our response, you can refer your complaint to the Office of the Data Protection Commissioner.

Updates to this Policy

This Policy may be amended and replaced from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.

Updates will take effect from the date the updated Privacy Policy is published on our website, or as otherwise notified to you. You should review our Privacy Policy each time you visit our website, club or provide us with personal information.

Enquiries

If you have any questions about privacy-related issues, please contact the General Manager as follows:

Name: Stephen Mugo Kamau

Email: manager@limurucountryclub.co.ke

Phone: 0114-475904/ 0722-645941

Address: P.O Box 10-00217

Limuru

This version of the Policy was published on 15 January 2026.