Cogeco Media Acquisitions Inc. and its affiliates (“Cogeco Media”), wholly owned subsidiaries of Cogeco Inc., own and operate twenty-two (22) radio stations in Québec and one (1) radio station in Ontario 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.
Application and Scope
- 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.
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
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
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.
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 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.
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.
- 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.
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.
- 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.
- 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.
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.
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
On the same or similar subject, you may want to review our Corporate Privacy Commitment.