- Who are we?
- What personal information do we collect?
- Why do we collect your personal information?
- To whom do we disclose your personal information?
- Control of your personal information
- Where is your personal information stored?
- How can you access your personal information?
- How do we protect your personal information?
- Privacy and our Websites
- Canadian Marketing Association
- Contact Us
Appendix 1: What are "fair information practices"?
1. Who are we?
Transcontinental Inc. is the "parent" of a group of companies focusing on the print and media sectors. One of the 10 largest commercial printers in North America, Transcontinental is Canada's largest printer of flyers, books and newspapers, and a strong second in the printing of magazines, catalogues and directories. Through its Canadian and U.S. direct marketing facilities, Transcontinental has the geographic platform and complete service offering needed to cover the entire North American market. The Corporation is also Canada's leading publisher of consumer magazines and the second-largest publisher of local and regional newspapers. In addition, it is engaged in the door-to-door distribution of advertising material, the development and integration of Web solutions, and the electronic aggregation of news and business information.
2. What personal information do we collect?
Canadian privacy legislation defines personal information broadly as information about "an identifiable individual" or as information that allows an individual to be identified. The types of personal information that we may collect from you from time to time include: your name, address, telephone number, e-mail address, your forwarding address (e.g. during a vacation), previous address(es), payment information (for billing purposes), your mailing preferences (such as "no scents", "no wrappers", etc.), delivery instructions, and individual customer service preferences (such as "do not solicit"). In addition, from time to time, we may ask you to provide us with more detailed information regarding your interests, occupation, and background. For example, we sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, products or services may be of interest to them and our readership. Finally, from time to time, we may acquire demographic and other information about you (e.g. your occupation and interests) from an outside organisation, but only if you have previously agreed to allow such an organization to disclose the information to companies such as Transcontinental.
3. Why do we collect your personal information?
We collect your personal information for the purposes listed below:
(a) To provide the product, service or information you requested
If you are a customer of one of our publications, we use your name and address (postal and/or e-mail) in order to deliver the product, service or information you requested and to follow up with you about the transaction (i.e., send a bill, notify you that your subscription is expiring, etc.). If you enter into a contest offered through one of our websites or printed publications, we use your personal information to administer the contest on our own behalf or on behalf of our sponsors.
(b) To process payment
Your credit card number, debit card number, or banking information for pre-authorized payments is used only for processing payments and for presenting you with payment options - not for marketing purposes.
(c) To send you information
From time to time we may send you further information about the publication, its offers, or other products produced under its name.
(d) Other purposes
In addition, from time to time, we may use your personal information for the following purposes:
- to detect and protect Transcontinental and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with Transcontinental policies and contractual obligations;
- to understand your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations;
- to obtain audited statements regarding numbers of subscribers per publication;
- to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Transcontinental;
- for any other purpose we may indicate to you from time to time.
4. To whom do we disclose your personal information?
We may disclose your personal information to the following third parties in the following circumstances:
(a) Disclosure to Service Providers
We may disclose your personal information to other companies that provide services on our behalf, including label printers, invoice printers, fulfillment contractors, auditors, our software developers (including website developers and hosts), data processing, document management and office services. In addition, we may disclose your personal information to an organization or individual retained by Transcontinental to evaluate your creditworthiness or to collect debts outstanding on an account or to our auditors. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose.
(b) Disclosure to Affiliates and Business Units
We may disclose your personal information to any of the companies and business units that form part of the Transcontinental group (i.e. amongst Transcontinental Inc., its subsidiaries and affiliates) in order to serve you better and to provide you with information about our group's products and services.
(c) Disclosure to Trading Partners
From time to time our magazines or websites may make their list of customers available to other carefully screened organizations (such as other magazines, book publishers, banks or charities) that want to let you know about a product or service that might interest you. The material to be sent to you is reviewed by us before the names and addresses (including e-mail addresses) are released to ensure the organization is reputable and material is appropriate and not misleading.
(d) Disclosure in Business Transfers
(e) Law Enforcement and Legal Disclosure
Transcontinental may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Transcontinental has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to Transcontinental's legal counsel.
If you would prefer for us NOT to share your information as described above in sections 4(a)-4(d), simply inform us (see "Contact Us" below).
5. Control of your personal information
At Transcontinental, we want you to be able to maintain control over how we use your personal information. In particular:
You may have the right to "opt out" of some or all of the identified purposes, uses and disclosures listed in sections 3 and 4 above.
You always have the option to instruct us not to use your name, address, e-mail address, etc. beyond providing you with the product, service or information you requested. See "Contact Us" below.
E-mail communications will always include an identification of the sender and an "Unsubscribe" option.
If you receive a mailing from any of our consumer magazines and you wish to know the source of your name (i.e. what list it came from), we will make every reasonable effort to determine the source and provide you with the information. For this request, or to confirm that any personal information we may have is correct, please contact us (See "Contact Us" below). (Note that some account information can be confirmed by visiting the customer care section of our consumer magazine websites).
We regularly use the Canadian Marketing Association "do not mail/do not call" service to remove customers from marketing campaigns. To add your name to this list, see "Canadian Marketing Association" below.
As mentioned above, we may not be able to provide you with our services if you withdraw your consent to our use of your personal information.
6. Where is your personal information stored?
Your personal information is stored in secured locations and on servers controlled by Transcontinental, located either at our offices or at the offices of our service providers. For access to your personal information, please contact our Chief Privacy Officer using the contact information in the "Contact Us" section below.
7. How can you access your personal information?
Upon written request, subject to certain exceptions, Transcontinental will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. Access requests should be sent to our Chief Privacy Officer, using the contact information in the "Contact Us" section below.
8. How do we protect your personal information?
We make every reasonable effort to protect against the loss, misuse, and alteration of personal information under our control. Our security policies are periodically reviewed and enhanced as necessary.
Only authorized employees and suppliers have access to your personal information. Where information is sent to a third party for processing, we make sure, through our contracts with them, that all your information is kept secure. We keep your information for the time we are providing you with a product or service, and for a reasonable time thereafter in the event that you wish to resume service.
We operate secure data networks protected by industry standard firewall and password protection systems. Credit card information is processed using industry-standard encryption and security. We do not collect personal information from bulletin boards or forums. However, we cannot guarantee that personal information voluntarily disclosed in chat rooms or discussion boards will not be collected and used by others, which may result in unsolicited messages to you from other parties.
9. Privacy and our websites
Transcontinental sometimes collects personal information through its various websites. In this section, we provide you with additional information regarding such collection.
Online Communications - In order to provide our website visitors with a product, service or information, visitors may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, subscribing to, reviewing or downloading a publication, participating in contests and surveys. If you are known to Transcontinental as a registered user of an online service, we may combine and store personal information about your use of our websites and the online information you have provided with certain other online and offline information we may have collected.
E-Mail Communications - Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the products and services of Transcontinental and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if recipients decide they do not want to receive any future marketing or promotional e-mails from Transcontinental.
Also, if you send us an email message, we may retain that message and your email address, as well as any response we send you.
Advertisers - If you submit some of your personal information on any Transcontinental website to request information from a third party (such as an advertiser), we are not responsible for any use of your personal information by such third party. Hence, we suggest that you first learn more about such third party's privacy policies prior to submitting your personal information by visiting its website or contacting it by postal mail or telephone.
Opinion Polls - Opinion polls on our websites are anonymous. We do not correlate votes submitted via such polls with names or individual email addresses, unless otherwise disclosed at the point of collection.
Searches - For your convenience, search functions are sometimes provided on our websites. We keep logs of the words searched to learn more about what kind of information our visitors are seeking, and thus improve our services.
Hyperlinks - For your convenience, Transcontinental's websites sometimes contain hyperlinks to websites managed by third parties. By activating these hyperlinks, you will leave Transcontinental's websites for those of the third parties, which may have different privacy policies and practices than Transcontinental. Transcontinental cannot be held liable for the use of such third party websites.
Advertising to Children - We believe that none of Transcontinental's websites appeal directly to children of 13 years old or less. We do not knowingly direct our advertising at children under the age of 13, except as permitted by law.
Individuals Under 18 - No personal information should be submitted or posted on our websites by individuals under 18 years of age without their parent's or guardian's permission. We may request name, address, phone number, email address and date of birth from an individual under 18 years of age for contest participation so that we may notify him or her if selected as a winner. In the event we do so, we will request their parent's or guardian's consent prior to collection.
No information collected from online guests under 18 years of age is used for any marketing or promotional purposes whatsoever by Transcontinental. Unless otherwise disclosed at collection, we do not provide any personal information collected through any Transcontinental website from individuals under 18 years old, regardless of its source, to any third party for any purpose whatsoever.
10. Canadian Marketing Association
Prior to January 1, 2004 some Transcontinental websites may have collected personal information, such as e-mail address, using privacy policies which differ from the statement above. In such cases where information has already been provided, customers will be contacted and informed of the new policy practices before any new use is made of their personal information.
12. Contact Us
Transcontinental Chief Privacy Officer
- Street Address
- 1 Place Ville Marie
- Extended Address
- Suite 3315
- Postal Code
- H3B 3N2
- +1 514 954-2802
What are "fair information practices"?
In Canada, "fair information practices" with regards to your personal information are reflected in a series of principles developed by the Canadian Standards Association and incorporated into Canadian privacy legislation, designed to ensure that companies treat your personal information fairly, protect its confidentiality and provide the means by which individuals can maintain a reasonable level of control over how their personal information is collected, used and disclosed. Transcontinental collects, uses and discloses your personal information by employing "fair information practices" as described in the following ten privacy principles:
Principle 1 - Accountability
Principle 2 - Identifying the Purposes for Collection of Personal Information
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
Principle 4 - Limiting Collection of Personal Information
Transcontinental will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Transcontinental. In addition, Transcontinental will collect your personal information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
Transcontinental will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. Transcontinental will retain your personal information only as long as necessary to fulfil the identified purposes.
Principle 6 - Accuracy of Personal Information
Transcontinental will endeavour to ensure that your personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Transcontinental will update personal information as and when necessary to fulfill the identified purposes or upon notification from the subject individual. Transcontinental will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please feel free to contact us, so that we can update our records.
Principle 7 - Security Safeguards
Transcontinental will protect your personal information by security safeguards appropriate to the sensitivity of the information. For example, the computer servers on which we store your personal information are protected by firewalls and other industry standard security features. In addition, your personal information is only made available to our employees and service providers who have a "need to know" in order to offer you our services or otherwise fulfil the purposes identified in Section 3 above.
Principle 8 - Openness Concerning Policies and Practices
Principle 9 - Individual Access to Personal Information
Upon written request, subject to certain exceptions, Transcontinental will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. If access is denied, Transcontinental will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, Transcontinental will give you a reasonable opportunity to review your personal information. You will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Challenging Compliance