Effective date: August 2023
How this Policy Works
- WHAT PERSONAL INFORMATION DO WE COLLECT
- HOW WE COLLECT PERSONAL INFORMATION
- WHY DO WE COLLECT PERSONAL INFORMATION
- TRANSFER AND STORAGE OF YOUR PERSONAL INFORMATION
- DISCLOSURE OF YOUR PERSONAL INFORMATION
- DATA SECURITY
- DATA RETENTION
- THIRD-PARTY WEBSITES
- PERSONS UNDER THE AGE OF 18
- ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
- WITHDRAWING YOUR CONSENT
- CONTACT INFORMATION AND CHALLENGING COMPLIANCE
1. WHAT PERSONAL INFORMATION DO WE COLLECT?
For the most part, we do not collect Personal Information in connection with your use of the Website. However:
- we store cookies on the devices of certain visitors of the Website, as described in Part X. Cookies
- we may collect information, such as your Internet Protocol address (e.g. IP address)
- we may collect Website usage data. Like most other websites, we may monitor traffic patterns, website usage, and related website information to optimize your visit to our website (“Usage Data”). This Usage Data may include information such as your browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
2. HOW WE COLLECT PERSONAL INFORMATION
We may collect Personal Information about you in various ways, including:
- Directly from you when you provide it to us (e.g. contacting us); and
- Automatically as you navigate through our Website (e.g., via cookies).
3. WHY DO WE COLLECT YOUR PERSONAL INFORMATION
We use collected Personal Information for various purposes, such as:
- To respond to inquiries and provide visitor support;
- To monitor and analyze the usage of our Website;
- To identify and track our employees who visit our Website so that we may distinguish them from regular visitors (i.e. non-employee visitors) of our Website;
- For any other purposes that are disclosed to you and to which you consent; and
- For any purposes required or authorized by law.
4. TRANSFER AND STORAGE OF YOUR PERSONAL INFORMATION
We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian privacy laws. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country.
If you are located outside Canada and choose to provide information to us, please note that your data, including Personal Information, may be transferred to Canada and processed there or in other countries.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
- to other companies within the Catena Media corporate group for the purposes described above;
- to third parties that provide services to us or on our behalf;
- to third parties that assist Catena Media in the provision of services to you (such as couriers);
- to third parties whose services we use to conduct our business (such as web hosts and email services providers);
- in accordance with applicable law, to a buyer (or potential buyer) or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Catena Media’s assets or shares, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Catena Media about you is among the assets to be directly or indirectly transferred or to be transferred;
- to any other person as disclosed by us, and consented by you, when you provide the Personal Information;
Additionally, we may disclose your Personal Information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
- to enforce or apply our agreements with you;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Catena Media, our employees, our customers, or others;
- in situations where sharing or disclosing your information is required in order to offer you the products or services you have requested; and
- to professional advisors, including lawyers, auditors, bankers, insurers, and consultants, to obtain advice or other professional services.
6. DATA SECURITY
The security of your Personal Information is important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Additionally, to reduce the risk of unauthorized access or disclosure of your Personal Information, our employees, agents, and contractors may access your Personal Information only if they have a need to know and only if they are subject to appropriate confidentiality obligations.
Our servers are protected by firewalls. We also use encryption and pseudonymization where appropriate to reduce the risk of a security incident. Nevertheless, the transmission and storage of information via the Internet is not completely secure. While we endeavour to keep your Personal Information safe, our collection, use, and disclosure of your Personal Information is not without risks. For example, our security safeguards may be compromised by viruses, hacking attempts, or physical break-ins. Consequently, we cannot guarantee the security of your Personal Information. If your Personal Information was wrongfully accessed, there is a risk that you may suffer a harm. We are not responsible for circumvention by any malicious actor of any privacy settings or security measures used by the Website or by our systems.
Data Breach Management
In the event of a data breach, we have established procedures to quickly respond to and, to the extent possible, contain or mitigate the breach. In accordance with applicable law, we will promptly notify you and the applicable privacy regulators where legally required to do so.
If you have reason to believe there has been a data breach involving the Website or any Personal Information in our custody or control, please immediately contact us at [email protected].
7. DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will retain your Personal Information only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The exact retention period for a particular item of Personal Information will depend on a number of factors, such as the nature of the Personal Information, the reason why the Personal Information was collected, legal requirements, the sensitivity of the Personal Information, and the risk of harm that would flow from its unauthorized access or disclosure. At the end of the applicable retention period for a particular item of Personal Information, we will either dispose of that Personal Information or anonymize it.
Under some circumstances we may anonymize your Personal Information before the end of its retention period.
By anonymize, we mean to irreversibly modify your Personal Information so that it no longer can be associated with you.
We may use anonymous data for any legitimate business purpose without further notice to you or your consent.
8. THIRD-PARTY WEBSITES
9. PERSONS UNDER THE AGE OF 18
We do not intend to collect Personal Information from anyone under the age of 18. If you are under 18 years of age, do not use the Website. If you believe that we have collected the Personal Information of anyone under the age of 18, please contact our Privacy Officer at [email protected] or at the address provided in the Contact Information section below. If we learn we have collected or received Personal Information from a person under 18, we will delete that Personal Information, subject to any legal requirements.
10. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you, subject to certain exceptions. To request access to your Personal Information, please email your access request to our Privacy Officer at [email protected].
Before we grant you access to your Personal Information or make your requested changes, we may request specific information from you to help us confirm your identity and your right to access or to make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Privacy law provides certain exceptions to our obligation to provide you with access to your Personal Information. Examples of such exceptions include:
- Information protected by solicitor-client privilege.
- Information that is part of a formal dispute resolution process.
- Information that is about another individual that would reveal their Personal Information or confidential commercial information.
- Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].
11. WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, send your withdrawal of consent to [email protected]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
- What are Cookies?
- Cookies are small files placed on your computer or device by a website when you visit it. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners or operators of the site.
- We use a specific cookie to identify visitors who are employees of Catena Media referred to our Website from our internal system. This allows us to distinguish between regular visitors and employees visiting for work-related purposes such as Website maintenance.
- The identified employee visitor's actions will be logged as one client ID, helping us to avoid logging the user each time they navigate to a new webpage. This assists us in streamlining internal website operation.
- Once the cookie is placed, it will also be used for site analytics by tools such as Google Analytics, Google Ads, Hotjar, Optin, http://customer.io, and Voluum.
- How To Control Cookies
For further details, please consult the help menu in your browser.
14. CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Attention to: Privacy Officer
By e-mail: [email protected]
By letter to us at: Catena Media Canada Ltd. 8661-201 Street – 2nd Floor Langley, BC V2Y 0G9
If any complaint or inquiry is not handled to your satisfaction, you may contact:
Privacy Commissioner of Canada
112 Kent Street
Toll free: 1.800.282.1376