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1. PRELIMINARY REMARKS
For KO Media Inc. (hereinafter “KO”, “we” or “our”), the protection of the details and information we collect when you visit our website or the sites of our affiliated companies is of great importance and our privacy practices are in accordance with the laws in force in Quebec and Canada.
a) you visit the website https://www.ellecanada.com/ or the sites of our affiliated companies that are hyperlinked (hereinafter the “Site”);
b) you use the ELLE CANADA magazine subscription system (the “Subscription” section at https://secure.ellecanada.com/magazine-subscription.php?;
d) you register to receive communications, newsletters, updates, special offers;
e) you participate in contests and/or promotions.
2. PERSONAL INFORMATION
DEFINITION OF “PERSONAL INFORMATION”
“Personal Information” is any information that relates to a natural person making it possible to identify her/him such as, but not limited to, her/his name, surname, residential address, e-mail address, home telephone number, cell phone number.
2.2 COMPLIANCE WITH THE TEN (10) PRINCIPLES THAT FORM THE FOUNDATION OF THE STANDARD CODE FOR THE PROTECTION OF PERSONAL INFORMATION.
We undertake to comply with the following ten (10) privacy principles as set out in the Model Code for the Protection of Personal Information (CAN / CSA-Q830-96) and enshrined in the Personal Information Protection and Electronic Documents Act (S.C. 2000, Ch. 5).
You can get the full text of the Model Code for the Protection of Personal Information from the Canadian Standards Association (in English only). You can also order the Model Code for the Protection of Personal Information by writing to the following address:
178, Rexdale Boulevard
Etobicoke (Ontario) M9W 1R3
Telephone: 1 800 463-6727 or (416) 747-4044
2.3 OUTLINE OF THE TEN (10) PRINCIPLES OF THE STANDARD CODE FOR THE PROTECTION OF PERSONAL INFORMATION
a) Principle 1 – Responsibility
All our employees are responsible for the application of and adherence to the principles set out in this Policy. You can forward your questions and comments to our Customer Service Department, at the above-mentioned address, and the person designated to process them will respond to you as soon as possible.
(b) Principle 2 – Identifying purposes
The purposes for which your Personal Information is collected are determined in advance or at the time of collection. If we wish to collect, use and / or disclose your Personal Information for purposes other than those set out in this Policy, we will provide you with prior information and obtain your consent.
c) Principle 3 – Consent
We are committed to obtaining your free and informed consent for the collection, use or disclosure of your Personal Information, except as may be provided by law.
d) Principle 4 – Limiting Collection
The collection of your Personal Information will be limited to what is necessary for the purposes we have indicated, and we will collect it lawfully and honestly.
e) Principle 5 – Limitation of use, communication and conservation
Your Personal Information will not be used or disclosed for purposes other than those for which it was collected, unless you have given your informed consent or as required by law. We will retain your Personal Information only for the period necessary to fulfil the specified purposes.
f) Principle 6 – Accuracy
We take reasonable steps to keep your Personal Information accurate, complete and as current as possible. You can help maintain the accuracy of your Personal Information by informing us of any changes to your file and also, notifying us of any error you notice, by contacting our Customer Service department in writing, whose contact details are listed at the end of this Policy.
g) Principle 7 – Security measures
We have implemented industry-standard security measures to protect your Personal Information with security safeguards appropriate to the level of sensitivity. Our security measures are reviewed periodically and improved as needed.
Despite these precautions, you should know that no data transmission over the internet is completely safe. When you disclose Personal Information on a website, this information may be intercepted, collected and used. This applies to information shared on message boards, discussion forums, and even e-mails. You transmit this information at your own risk, no matter who you send it to, and we can not be held responsible if information is intercepted and used by third parties.
h) Principle 8 – Transparency
We will make available to you, upon request, any information regarding our policies and practices regarding the management and protection of Personal Information.
i) Principle 9 – Access to Personal Information
We undertake, on request, to inform you of the existence of Personal Information about you, the use that is made of it, its communication to third parties, and to allow you to consult it. You will also be able to challenge the accuracy and completeness of your Personal Information and have the appropriate corrections made. Requests for access to Personal Information may be made through our Customer Service Department, the details of which are provided at the end of this Policy.
j) Principle 10 – Complaints and requests for access to Personal Information
For all questions, concerns or complaints regarding this Policy, or for a request for access to your Personal Information, please do not hesitate to contact our Customer Service Department, whose contact details are listed at the end of this Policy.
2.4 CONSENT FOR THE COLLECTION OF PERSONAL INFORMATION
In certain circumstances, we will ask you to provide certain personal information, for example, to register on the Site in the “My Account” section, to participate in contests, to subscribe to the magazine ELLE CANADA or to write comments.
All Personal Information is collected with your consent and you are free, at any time, to accept or not to provide Personal Information. However, in the event of refusal, you will not be able to access the sections of the Site that require that you provide such Personal Information.
a) Third Party Personal Information
When you provide us with Personal Information belonging to another person, for example, to offer a subscription to ELLE CANADA magazine as a gift, we assume that you have obtained the valid consent of that person to collect, use, disclose, treat and protect this personal information in accordance with this Policy.
If you are under the age of eighteen (18), please obtain permission from a parent or guardian before providing us with personal information.
2.5 USE OF YOUR PERSONAL INFORMATION
We collect, use and / or disclose your Personal Information for the following purposes:
- To provide you with the product, service or information you requested;
- To provides customer service;
- To help us evaluate and improve our Site by adapting its content to your needs and personal preferences;
- To communicate with you, inform you of new offers and promotions as well as any facts or events that may interest you;
- To organize and administer contests and/or surveys;
- To allow us to ensure the quality of the exchanges and to apply the rules of propriety in the sections where you can share your comments;
- To create and maintain our customer accounts;
- To carry out commercial operations;
- To process payments and recover, if necessary, outstanding debts;
- To identify and protect against errors, fraud, theft and other illegal activities;
- For any other purpose for which you have given your consent at the time you provided your Personal Information.
2.6 SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
In accordance with this Policy and the ten (10) principles of the STANDARD PERSONAL INFORMATION CODE, we may share some of your Personal Information for the purpose of providing you with services. We will then take reasonable steps to ensure that Personal Information shared with third parties is protected and retained in accordance with the principles set out in this Policy, but we can not guarantee this, nor can we be held liable in this regard.
We wish to make it clear that we will not disclose your Personal Information to advertisers, customers, partners or third parties without prior written consent. Notwithstanding the foregoing, we may disclose your Personal Information to the following individuals and organizations, in the contexts set out below:
a) To service providers
We may transfer your Personal Information to service providers acting on our behalf for the purposes mentioned in this Policy. It could, for example, be a company or organization whose services have been selected for:
- Management of subscriptions to ELLE CANADA magazine. Online subscriptions can be found at https://secure.ellecanada.com/magazine-subscription.php? and are managed by KCK Global Limited. To facilitate and speed up the online subscription process, we may transfer some of your personal information to KCK Global Limited;
- Credit card information and payments for your online purchases are processed using industry standard encryption technology. The information provided is the information required to process your payment.
b) To our affiliates
We may share your personal information with our affiliates to better serve you and inform you of all our products and services.
c) To our business partners
Occasionally, we may share your Personal Information by sharing our customer lists with organizations we have handpicked and who wish to share products and services that they feel may be of interest to you.
d) In the context of commercial transactions
We may participate in the sale, merger, reorganization or transfer of some or all our business. As part of these transactions, we may disclose your Personal Information to the acquirer or new organization. In this case, we will require that the confidentiality of your Personal Information be protected by the acquirer or the new organization in accordance with this Policy and the applicable laws regarding the protection of Personal Information.
e) Under the laws
In addition to the contexts mentioned above, we could for example communicate your Personal Information:
- to our legal counsel;
- to a government agency authorized to obtain such Personal Information;
- if we have reason to believe, in good faith, that disclosure of the Personal Information may be useful in an investigation of an illegal or fraudulent activity;
- to comply with an order or decision of a judicial body or court.
2.7 TO AVOID SHARING OR HAVING YOUR PERSONAL INFORMATION DELETED
You may at any time request that the Personal Information we hold about you not be shared under (a), (b) (c) and (d) of the preceding section or that it be deleted. Simply send an email to our Customer Service Department, whose contact details are listed at the end of this Policy, to request that the Personal Information about you not be shared or that it be removed from our databases.
3. BROWSING INFORMATION
3.1 DEFINITION OF ” BROWSING INFORMATION”
“Browsing Information” is general information and statistical data concerning your browsing activity on the Site or the nature of your device (computer, tablet or mobile device), your browsing history, the duration of your visit to the Site, the pages viewed, the order in which pages are viewed, the content of these pages, the number of clicks, your general geographic location (country or province), and the advertisements and videos you view on the Site.
3.2 COLLECTION OF “BROWSING INFORMATION”
Browsing on the Site means that you consent to the collection of Browsing Information in the manner and for the purposes set out in this Policy. Browsing Information is collected using identifiers commonly known as “cookies” or small data files that are installed by our server on your device. A permanent cookie is installed during your first visit and other cookies, permanent or temporary, may be used depending on the applications and choices you make during your next visits to the Site.
The Browsing Information is not Personal Information and is not used to discover your identity. They are used for the purposes described below.
You can, however, at any time delete the cookies on your device or disable the feature that allows archiving them by consulting the configuration options of your web browser. If you make this choice, you will still be able to access the information on the Site, but you will be considered a new user each time you visit.
3.3 USING YOUR “BROWSING INFORMATION”
We collect your Browsing Information for the following purposes:
- To measure your interest in our promotions, special offers and parts of our Site;
- To generate statistical data regarding the performance of our Site, the use of its content, its traffic;
- To improve communication between our server and your browser;
- To improve your browsing experience by offering, for example, your choice of language and other settings that are unique to you and that you will not have to enter repeatedly.
3.4 LINKS TO EXTERNAL WEBSITES
Please note that the Site contains hyperlinks in the form of advertisements which, when clicked, will redirect you to external websites operated by other companies or organizations that may be subject to different privacy policies regarding protection of personal information. We have no control over these websites or the way the confidentiality of Personal Information is managed. Once you leave our Site, this Policy no longer applies, and you will be governed by the policies of the new site you visit, and no liability is assumed. can be engaged in any way.
3.5 MODIFICATION OF THE POLICY
3.6 CUSTOMER SERVICE
651 Notre-Dame West, suite 550
Montreal (Quebec) H3C 1H9
Email: [email protected]
3.7 PRIVACY COMMISSION OF CANADA
The Office of the Privacy Commissioner of Canada can also answer some of your questions and you may contact this organization for information. By telephone, free of charge: 1-800-282-1376. Via the Website: https://www.priv.gc.ca
Personal Information Protection and Electronic Documents Act (L.C. 2000, Ch. 5). https://laws-lois.justice.gc.ca/eng/acts/P-8.6/page-1.html
Model Code for the Protection of Personal Information (CAN / CSA-Q830-96, published March 1996 and confirmed in 2001 https://laws-lois.justice.gc.ca/eng/acts/p-8.6/page-11.html
The Act Respecting the Protection of Personal Information in the Private Sector http://legisquebec.gouv.qc.ca/en/ShowDoc/cs/P-39.1