Privacy Policy

Introduction

Cogeco Media Acquisitions Inc. and its affiliates (“Cogeco Media”), wholly owned subsidiaries of Cogeco Inc., own and operate thirteen (13) radio stations across most of Québec with complementary radio formats serving a wide range of audiences, as well as various websites and Cogeco Nouvelles, the most important private news radio agency in Québec.

At Cogeco Media, we know that the protection of your privacy is important to you. For this reason, we have taken steps to ensure that any personal information that you provide to Cogeco Media is protected by a range of robust business procedures and rigorous security safeguards to ensure that your information is kept confidential and used only for the purposes detailed in this Privacy Policy.

Cogeco Media is committed to providing transparency to its customers with respect to its practices in handling their personal information. To that end, this Privacy Policy is a formal statement of rights and obligations concerning the minimum requirements for the protection of personal information provided to Cogeco Media. It is intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirements of rules established by the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as other applicable privacy laws and standards.

Application and Scope

This Privacy Policy generally applies to any personal information (as defined below in the section entitled Definition of Personal Information) collected or generated by Cogeco Media or anyone acting as an agent on our behalf from or about its customers, which may include potential customers. As such, customers are protected by the rights and safeguards contained in this Privacy Policy and they explicitly agree to its terms.
When used in this Privacy Policy, the term “customer” may include, for instance, an individual who:

  • listens to any Cogeco Media radio station;
  • corresponds or interacts with Cogeco Media through various means, including for a job application;
  • participates in a contest or promotion run by Cogeco Media or anyone acting on our behalf or subscribes to Cogeco Media radio stations or its newsletters;
  • buys a gift certificate and/or products and/or services through MyRadioShop.ca; and
  • uses any other Cogeco Media products and/or services.

This Privacy Policy also governs personal information collected about Cogeco Media’s websites users and explains how we use and disclose personal information that we collect from people who visit and otherwise interact with us through our various websites most of which are accessible via http://www.cogecomedia.com/en/ (“website” or “websites”). It also explains how we use cookies and similar technologies.

Cogeco Media also abides by the principles set out in the Corporate Privacy Commitment, listing the essential principles constituting the Cogeco Group’s commitment to privacy.

Definition of Personal Information

When used in this Privacy Policy, and consistent with PIPEDA, personal information means “any information about an identifiable individual”. This may include, for example, your name, contact information, e-mail address and other information required to participate in a Cogeco Media contest or promotion, information relating to your membership or account with us and the services you use and subscribe to, as well as any complaints documented in a file. It may also include other types of more technical information such as users’ IP addresses, user IDs, meta-data (e.g. who our customer communicated with, when and where this communication occurred), browser history (pages accessed, date of access, location when accessed), but only when this information can identify you as an individual. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Collection and Use of Personal Information

We collect most of our information about you directly from you, with your consent. We usually collect your name, address, phone number(s) and e-mail address, as well as information pertaining to your use of our products and/or services or your participation in a Cogeco Media contest or promotion. We may also obtain personal information about you from third parties, with your consent.

Cogeco Media generally collects personal information from or about its customers, and thereafter uses it, for the following purposes:

  • to manage its contests or promotions;
  • to establish, develop and preserve its business relationship respectively with its customers;
  • to create, establish and administer customers’ memberships or accounts and to respond to customer or supplier inquiries;
  • to provide the products or services that it offers or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
  • to authenticate the identity and preserve the privacy of customers contacting Cogeco Media by telephone, electronic means or otherwise;
  • for internal training and quality assurance purposes;
  • to manage its businesses and ensure the efficiency, reliability and security of its systems and networks;
  • to meet legal and regulatory requirements and allow Cogeco Media to meet contractual requirements relating to the products and/or services provided to customers;
  • to ensure its records are accurate and to protect customers and Cogeco Media from error and fraud;
  • to understand and assess the interests, wants and changing needs of customers with a view to improving its products and/or services and developing new ones;
  • to provide personalized products and/or services as well as product and/or service recommendations to customers; and
  • subject to our customers’ Right to Withdraw Consent provided in this Privacy Policy, to conduct surveys on the quality of our products or services or to provide our customers with offers for additional products and/or services that we feel may be of their interest or that we believe meets their changing needs.

If you have applied for employment with Cogeco Media, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Cogeco Media as well as other career development resources.

Unless required or authorized by law, Cogeco Media will not collect or use personal information for any other or new purpose without obtaining further consent. For details on the type of information that we collect via our websites and on how we use and disclose this information, please refer to the Website Privacy section of this Privacy Policy.

Your Consent

Cogeco Media obtains consent from the individuals concerned by the collection, use or disclosure of personal information through various means: orally or through written documents, including agreements, forms as well as printed or electronic communications. The form of consent sought by Cogeco Media will vary according to the sensitivity of the personal information, the reasonable expectations of the customers and any requirements or standards established by law.

In general, by submitting information to us by participating in a Cogeco Media contest or promotion or in connection with using Cogeco Media products and/or services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy and in the Cogeco Media Terms and Conditions. Moreover, by visiting, interacting with and/or using our websites, you agree to benefit from, be bound by, the terms and conditions of this Privacy Policy.

In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:

  • where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
  • when information is being collected, used or disclosed for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information; and
  • to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.

For more information on how Cogeco Media may disclose your personal information, please refer to the section Sharing of Personal Information of this Privacy Policy.

Right to Withdraw Consent

Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, Cogeco Media may limit the services or products it is able to provide customers. You may also withdraw your consent as follows:

  • Mail marketing, Telephone marketing and Quality control communications. You may decide that you prefer Cogeco Media not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by e-mail or telephone for quality control purposes. If this is the case, you may advise us by contacting us using the information detailed in the How to Contact Us section below.
  • Commercial Electronic Communications. You can always limit the communications that Cogeco Media sends to you. To opt-out of commercial e-mails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you in the event of particular circumstances.

For information on how you can limit the type of information that we collect, use or disclose about you when you visit and/or use our websites, please refer to the Website Privacy section of this Privacy Policy.

Sharing of Personal Information

Your information may be made available by Cogeco Media to third-parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. Cogeco Media will NOT sell, rent or trade your personal information to any third party. However, we may disclose your personal information when authorized by law or as follows:

  • Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Cogeco Media to perform work on its behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. Cogeco Media will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Cogeco Media itself.
  • As permitted or required by law. From time to time, Cogeco Media may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. In these circumstances, Cogeco Media will protect the interests of its customers by making reasonable efforts to ensure that: orders or demands comply with the laws under which they were issued, that it discloses only the personal information that is legally required and nothing more, and it does not comply with casual requests for personal information from government or law enforcement authorities. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
  • Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
  • Other types of sharing. We may provide your information to lenders, credit bureaus, credit grantors and reporting agencies, subject to applicable law. We may also disclose our customers’ personal information to an individual who, in the reasonable judgement of Cogeco Media, is acting on behalf of the individual in question, such as through a power of attorney.

Only those employees of Cogeco Media or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about customers.

For information on how you can limit the type of information that we collect, use or disclose about you when you visit and/or use our websites, please refer to the Website Privacy section of this Privacy Policy.

Website Privacy

Cogeco Media generally collects and uses personal information from or about its websites visitors and users as follows:

  • Information you provide. In many cases, we collect personal information directly from you when you visit or use our websites. For instance, we may collect the following types of information:
    • Inquiries. We may collect your name, contact information, e-mail address and any information you provide us when you make an inquiry or contact us through our websites. We will only use this information to provide you with the information requested or to contact you in order to answer your questions and/or requests.
    • Requests for a Product and/or Service. We may collect your name, contact information, e-mail address and any other information provided to us when you sign up to receive our newsletters, when you participate in a contest or promotion run by Cogeco Media or when you submit a request or an order for a Cogeco Media product and/or service. We will only use this information to process and answer your request or to manage our everyday business needs in connection with such request or participation.
    • Membership. We may collect your information when you log-in on our website through your account. For instance, you may decide to modify your membership or account information or other preference settings. We will only use the information that you provide us in accordance with this Privacy Policy.
    • Satisfaction Survey. When you visit our websites, you may, from time to time, be invited to participate to a satisfaction survey. In such case and if you decide to participate to our survey, we may collect your postal code, e-mail address and other information deemed important to complete such survey. We will only use your information for quality assurance purposes.
  • Technical information. When you visit our websites, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our websites, including the IP address of your computer and which browser you used to view our websites, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our websites or enhance the experience for our customers. For instance, it may be used to ensure that the products advertised on our websites are available in your area or that we are not showing you the same ads repeatedly. We treat this information as personal information when it is associated with your membership, account or contact information. For instance, we may collect and use the following type of information when you visit and/or interact with us on our websites:
    • Google Analytics: We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our websites. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
    • Google AdWords: We use Google AdWords Remarketing to advertise Cogeco Media across the Internet and to advertise on third party websites (including Google) to previous visitors to our websites. AdWords remarketing will display ads to you based on what parts of the Cogeco Media websites you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our sites or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our websites, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google's Ads Preferences Manager.
    • Interest-based Advertising. Cogeco may also allow a limited number of trusted third parties to install cookies on your hard drive from our websites. Our websites may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about you, such as your page views on our website, your information requests or purchases on our websites. We do not provide any personal information to advertisers or to third party sites that display interest-based ads on our websites. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on our websites are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on our websites directly to your browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by our Privacy Policy. Please contact them directly for more information about their privacy practices. You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada. Please visit the DAAC opt-out page for more information.
  • Your Choice with Cookies. You can block the use of cookies by activating the settings in your browser. The « Help » feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our websites. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
  • Privacy Policies of Third Parties. This Privacy Policy only addresses the use and disclosure of information by Cogeco Media. Other websites that may be accessible through Cogeco Media websites have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
  • Mobile Apps. In the event that you download and/or use any of our applications, we may require and collect information directly from you. We may also record geolocation information.

Personal Information Outside of Canada

While Cogeco Media is using reasonable measures, when possible, to favor Canadian communication routing as well as Canadian providers, your personal information may in some situations be routed through foreign jurisdictions, such as the United States. In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there. As mentioned above, Cogeco Media will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Cogeco Media itself.

Security of Personal Information

We will use reasonable security measures to protect your personal information against unauthorized access. Cogeco Media has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. For example, we use industry-standard encryption technology to secure sensitive personal information when it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software.

Retention

Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. Cogeco Media has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access.

Access and Correction

Cogeco Media respects your right to access and correct your personal information. If you have an online membership or account with us, you can log into your account at any time to access and update the information you have provided to us. Additionally, Cogeco Media complies with all laws regarding access and correction. If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.

How to Contact Us

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Cogeco Media has about you, please contact:

Marie Claude Laroche, Director of Legal Affairs
COGECO MEDIA INC.
800 De la Gauchetière Street West, Suite 1100
Montréal, Québec,  H5A 1M1
By phone: 514-787-7903
By e-mail: MarieClaude.Laroche@cogecomedia.com

Change of Privacy Policy

Cogeco Media will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Privacy Policy may therefore change from time to time. We will post any privacy policy changes on our websites and, if the changes are significant, we will provide a more prominent notice.

Please note that this version does not substantively change the way we treat personal information compared to the previous version of the Privacy Policy.

On the same or similar subject, you may want to review our Corporate Privacy Commitment.

This Privacy Policy was last updated on April 28, 2017.

Please note that both the English and French versions of our Privacy Policy have equal legal value.