Our
commitment to privacy:
The Brampton Guardian, a division of Metroland Printing,
Publishing & Distributing Ltd. a wholly owned
subsidiary of the Torstar Corporation, knows that protecting
the privacy and confidentiality of your personal information
is important to consumers. This Privacy Code governs The
Brampton Guardian newspaper and bramptonguardian.com.
Collection, use and disclosure of personal information by
us and our affiliates are governed by the Personal Information
Protection and Electronic Documents Act (the "Act"),
and any applicable provincial legislation. This Privacy Code
explains what personal information is collected from its customers
and how it is used. It also explains how you can ask questions,
make suggestions, and complain about our privacy practices.
This
Privacy Code applies to personal information (see below) collected
by us, including our websites. Be aware that our websites
may contain links to other websites provided and maintained
exclusively by third parties not subject to this Privacy Code.
Please review the privacy policies on any external websites
to determine their information handling practices. For a listing
of our affiliates, please go to www.torstar.com
and click on Torstar Properties, or call Customer Service
at 905-454-4344 for information.
This
Privacy Code is available to the public in electronic form
at www.bramptonguardian.com
and in paper form from The Brampton Guardian, 7700 Hurontario
St., Unit 201, Brampton, On L6Y 4M3. If you have any additional
concerns or questions, we encourage you to contact us and
we will address your concerns to the best of our ability.
Please read this Privacy Code carefully, and check
back periodically as we update it from time to time. By submitting
your personal information to us, you signify your agreement
to the terms and conditions of this Privacy Code.
What is personal information?
Personal information is any information about an identifiable
individual. Personal information does not include the name,
title, business address or telephone number of an employee
of an organization. Information used solely for journalistic
purposes is exempted from the Act.
We
are responsible for personal information under our control.
Our employees are informed about the importance of privacy
and receive periodic information to update them about our
Privacy Code and related policies. In addition, Torstar Corporation,
our parent company, has appointed a Chief Privacy Officer
to oversee personal information-handling practices of The
Brampton Guardian and its affiliates.
Children:
If you are under 18, be sure to obtain your parent or guardian's
permission before you send any personal information to us,
or anyone else, over the Internet. We encourage parents to
get involved with their children's online usage and to be
aware of the activities in which they are participating.
What
personal information do we collect, and why?
We collect personal information for specific, limited purposes.
Information is collected by fair and lawful means.
We
collect personal contact information (for example, name, address,
email address and telephone numbers) if you: sign up for a
newsletter; subscribe to a newspaper; register on an online
forum or website, or to attend a paid event; purchase any
product from us; are a classified advertiser or auction participant;
or provide it to us when you attend a trade or consumer show.
This information is used to fulfill your request, provide
targeted advertertising and respond to your inquiries. From
time to time it may be used to provide reward points or apply
credit, as applicable in the circumstances.
*
We retain your subscriber ID and passwords so that upon request
by you and receipt of identification we may remind you of
them.
*
If you enter a contest or other promotion, we use your personal
contact information to administer the contest or promotion
including contacting, announcing and promoting prizewinners.
*
We collect demographic information, as well as purchase history
and a list of promotions offered to you ("history"),
in order to gain a better understand ing of your interests
so that we may develop better products and services, and to
determine eligibility for our products and services.
*
We may also use demographic, personal contact and history
information from time to time to contact you about changes,
enhancements or other notices related to goods or services
you requested and which we provide. In addition, we may use
this information to send you offers or information from us,
our affiliates and from selected sponsors or advertisers ("Marketing
Offers"). If you do not wish to receive Marketing Offers,
you may opt-out at any time by following the procedure set
out in our opt-out policy (see below).
*
We keep notes and special instructions on file for classified
advertisers and subscribers to help us fulfill your request
and provide customer service. We may tape or monitor your
telephone calls with our customer service representatives
for quality assurance purposes.
*
We collect credit card information if you: subscribe to a
newspaper; register on a paid website; enter a paid contest;
register to attend a paid event; purchase any product from
us; are a classified advertiser or an auction participant.
This credit card information is used for the purpose of fulfilling
your order.
*
If you choose to opt-out of any use of your personal information
in accordance with our opt-out policy, we keep your contact
information on a list so that your request can be honoured.
If you complain to any of our departments, we collect your
contact information and the nature of your complaint, for
the purpose of investigating and responding to you.
*
If you are a freelancer, or other service provider, we collect
your social insurance number for tax reporting purposes and
your contact information in order to pay you. We may also
collect financial information from freelancers or other service
providers and from advertisers (for example, banking details
and credit history) to assess credit risk, sales data to prepare
royalty reports and other information to help us evaluate
your services.
*
If you use any of our websites, we may assign an internet
cookie. An internet cookie is a small text file that a website
stores on your internet browser and that can collect and store
information. We use cookies to better understand how you use
our websites, to make sure our ads and dynamic content are
served correctly and to improve the performance of our websites.
For example, a cookie may recall a set of preferences you
have set for our website and record items that you have registered
for. Storing cookies on your web browser allows us to present
you with custom web pages and other content that are tuned
with your preferences. For example, if you are a registered
user, you may see a welcome page with your name on it. These
activities are invisible to you, and are generally intended
to improve your internet surfing convenience. Unless you have
set your preferences so that you will be alerted when a cookie
is being stored on your computer, you won't know about it.
If
you are concerned about cookies, it is possible to turn them
off in your web browser preferences. However, please be aware
that by disabling cookies, you may not be able to use all
portions of our websites, particularly pages requiring registration.
We
may place advertising or other links on our sites that originate
from outside advertisers. If you view these ads, the advertisers
may assign a cookie. We do not control these cookies, nor
are we responsible for any marketing or other use of your
name by these advertisers.
*
We generally use your personal information for the purposes
of: managing, administering, collecting or otherwise enforcing
accounts; maintaining business records for reasonable periods
of time and generally managing and administering our business;
and meeting regulatory, legal, insurance, audit, security
and processing requirements.
*
Occasionally, we ask our customers to complete market research
surveys. Survey results are aggregated and shared with our
advertisers, sponsors and affiliates in a manner that does
not disclose personal information.
*
Other than as permitted or required by law, purposes for the
collection, use or disclosure of personal information, which
are not set out in this Privacy Code, will be set out at the
time of collection. You will be given a reasonable opportunity
to opt-out of any additional purposes no later than the time
of collection.
To
whom do we disclose personal information, and why?
We may disclose your personal information under the following
circumstances:
*
In order to provide you with Marketing Offers (see above),
we may disclose your personal contact information to affiliates
and selected sponsors and advertisers. If you do not wish
to receive Marketing Offers, you may opt-out at any time by
following the procedure set out in our opt-out policy (see
below).
*
We may transfer your personal information to service providers
acting on our behalf in order to perform processing and other
specialized services, for example, prize fulfillment of our
contests, collection of overdue accounts, product delivery,
or credit card processing.
*
We may disclose your personal information to our affiliates
for internal audit, management, billing, administrative or
other business purposes.
*
We may disclose your contact information on a confidential
basis to our advertisers for the sole purpose of newspaper
delivery verification.
*
When we need to disclose your personal information to unrelated
parties, for example, if we find you have violated any stated
terms of service or conditions of purchase, or if we need
to comply with applicable laws and lawful governmental requests,
other legal and regulatory authorities and other legal reasons.
*
We may disclose your personal information to parties connected
with the contemplated or actual financing, insuring, sale,
assignment or other disposal of all or part of our business
or assets, including for the purposes of determining whether
to proceed or continue with such transaction or business relationship
or fulfilling any records or other reporting requirements
to such parties. We will require such parties to treat your
personal information in accordance with this Privacy Code
and to use and disclose it only for the purposes for which
it was collected.
Consent
and opt-out policy.
In general, we seek consent to use your personal information
in accordance with our opt-out policy. Except as set out in
this section, we obtain your express opt-in consent to use
or disclose sensitive personal information.
If
you do not wish to receive Marketing Offers, you may opt-out
at any time by doing any of the following:
*
follow the instructions at the bottom of any email Marketing
Offer you receive.
*
inform your telemarketer at the time you are called with a
Marketing Offer.
*
call Customer Service at 905-454-4344 and
request that your personal information not be used for Marketing
Offers.
*
email Customer Service at l.drury@thebramptonguardian.com
and request that your personal information not be used for
Marketing Offers.
Please
allow a reasonable time (approximately 2-4 weeks) for processing
of your request.
Generally,
by providing us with your personal information, we will assume
that you consent to our collection, use and disclosure of
such information for the purposes identified or described
in this Privacy Code, if applicable, or otherwise at the time
of collection. We reserve the right to use and disclose your
personal information without consent where required or permitted
by law, for example, if we have reasonable grounds to believe
the information could be useful when investigating a contravention
of a federal, provincial or foreign law, in order to protect
or defend our legal interests, or to comply with applicable
laws and lawful governmental requests.
Safeguards:
We maintain personal information in a combination of paper
and electronic files. We take technical, contractual, administrative
and physical security measures to protect your personal information.
When you provide credit card information to use, we work to
help protect the security of your credit card information
by using industry standard secure sockets layer (SSL) encryption
technology.
Please
be aware that email is not a secure medium, and any personal
information you send to us by email could be intercepted.
If your communication is very sensitive, or includes information
such as your credit card number, you should not send it electronically
unless the email is encrypted or your browser indicates that
the access to our website is secure. Materials posted to online
forums such as bulletin boards or chat rooms are public, not
secure and may be viewed by anyone. Any personal information
you post may be collected and used by anyone and may result
in unsolicited messages from other internet users.
How
to access and correct your personal information.
We provide you with the means to access, update, edit or delete
certain subscriber or registration information you have provided
at any time by going to the appropriate page on www.bramptonguardian.com
and changing or deleting such information as desired. Alternatively,
you may call Customer Service at 905-454-4344
and we will make the changes upon receipt of appropriate evidence
We
will give you access to the information we retain about you
within a reasonable time, upon written request, satisfactory
identification and proof of entitlement. In some cases, we
may not provide access to personal information in our possession
or control. If we deny your request, we will advise you in
writing of the reason for the refusal and you may challenge
our decision.
How
to challenge our privacy practices.
We encourage you to contact us with any questions or concerns
you have about your privacy or this Privacy Code. If you have
a question concerning our Privacy Code, would like a copy,
or if you have a complaint, please contact Customer Service
at:
The
Brampton Guardian
7700 Hurontario St.,
Unit 201,
Brampton, ON
L6Y 4M3
905-454-4344
l.drury@thebramptonguardian.com
Customer
Service can successfully deal with many issues. If you prefer,
or if after contacting Customer Service, your concerns or
questions have not been resolved to your satisfaction, you
can contact Torstar Corporation's Chief Privacy Officer in
writing as follows:
Chief
Privacy Officer
Torstar Corporation
One Yonge Street, 6th floor
Toronto ON
M5E 1P9
Fax: (416) 869-4183
This
Privacy Code was last updated on 2 November 2004