PRIVACY POLICY

Last Updated: November 11, 2019

Please read this Privacy Policy carefully before using this platform.

Our Commitment to Privacy

Shaftesbury Inc. (“Shaftesbury”, “we”, “us” and “our”) is committed to protecting your Personal Information (as defined below) by ensuring that your Personal Information is treated with care and is not used or disclosed in ways to which you have not consented. This privacy policy (“Privacy Policy”) explains the ways in which we collect, use and disclose your Personal Information. It applies to any Personal Information that is collected by us, whether it is collected over the telephone, in writing, or electronically via any website, mobile app or other digital platform on which this Privacy Policy appears (the “Platform”).

Shaftesbury will never disclose, sell or lease to any third party any Personal Information that you provide to us without your permission, other than as described in this Privacy Policy, or unless we are required to do so by law.

By providing us with your Personal Information and using our Platform, you accept this Privacy Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Platform or otherwise provide your Personal Information to us.
It is Shaftesbury’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

We may modify, revise or update this Privacy Policy at any time by updating this posting. Each time you use the Platform, the version of the Privacy Policy then posted will apply to that use, so you should check this page each time you use the Platform.

What is Personal Information?
“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, telephone number, fax number and e-mail address.

What Information Do We Collect?
We do not generally collect Personal Information of individuals using our Platform. We do collect the business contact information (i.e., name, position name or title, company, work address, work email address and work telephone number) (collectively or individually, the “Business Contact Information”) of those individuals seeking Media Access to our Platform, as described in our Terms of Use.  However Business Contact Information is not typically considered Personal Information under privacy law.

Personal Information is collected by us only when you directly provide it to us, such as when you provide us with your contact information or send us a question or comment, when you enter a contest we are running, when you meet with us in person, or when you phone us with an inquiry.

Technical Information
Shaftesbury uses Google Analytics to provide statistics about the visitors to our Platform. Google Analytics uses cookies and other identifiers to collect certain information such as your IP address, your device or browser type, and your activity on our Platform such as click rates and bounce rates to measure and report statistics about user interactions on our Platform. Google Analytics collects and analyzes non-personally identifiable information in order to create reports and identify platform trends, without identifying individual visitors. We do not share any Personal Information with Google Analytics.

We use the reports provided by Google Analytics to help us improve our Platform, track the usage of our Platform and improve our search engine optimization.
You can find more information about Google Analytics at the following Google page: https://policies.google.com/technologies/partner-sites.
You can opt out of Google Analytics without affecting how you visit our Platform. For more information on opting-out of Google Analytics across all websites you use, visit this Google page: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631

For What Purposes Do We Collect Information?
Business Contact Information will be used or disclosed solely for the purpose of communicating or facilitating communication with the individual in relation to their employment, business or profession. We collect and use Business Contact Information in order to:
• verify the professional credentials of those seeking Media Access to our Platform and provide such individuals with the Media Password (as described in the Terms of Use); and
• send to media personnel copies of press releases, marketing materials or information about scheduled events, in accordance with applicable law.

We collect and use Personal Information in order to:
• respond to your communications and inquiries;
• meet legal, regulatory and security requirements under federal and provincial laws; and
• investigate any violations of, and enforce compliance with, our Terms of Use.

We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.

We will notify the individual from whom the information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which Personal Information is collected, this may be done orally or in writing.

Disclosure of Personal Information
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law. We do not sell our customer lists or other Personal Information.
We sometimes retain an affiliated company or an independent third party service or technology provider (“Authorized Service Providers”) to perform on our behalf, certain functions in support of the Platform or the products and services we provide. Such functions could include Platform developers, administrators or hosts. Accordingly, in certain instances these Authorized Service Providers will be provided with Personal Information to the extent that it is necessary in the performance of those specific or related services. We obligate all Authorized Service Providers to use and take steps to protect Personal Information in accordance with the requirements of this Privacy Policy.
We may transfer your Personal Information as an asset in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.

Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.

Personal Information of Minors
We do not knowingly track, collect, use or disclose the Personal Information of anyone under the age of 18, without the consent of a parent or legal guardian. However, we cannot always determine the age of persons who access and use our Platform. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or legal guardian to contact us to have this information removed from our records.

Security, Retention and Disposal of Personal Information
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.

While Shaftesbury employs advanced data encryption technology when interfacing with our users, Authorized Service Providers and other partners, you should be aware that there is a residual risk in transmitting any data electronically. Despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings.

Processing and Storage of Personal Information
Your Personal Information may be transferred to, processed and/or stored in a foreign jurisdiction outside of the jurisdiction in which it was originally collected. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction.

Links to Other Websites
Our Platform may provide links or references to websites, mobile applications or other platforms operated by third parties. These third party platforms are not governed by this Privacy Policy but by other privacy policies that may differ from our Privacy Policy. This Privacy Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party platforms, whether linked to this Platform or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party platform or any content on such platform. We encourage you to review the privacy policies of each platform visited before using them or disclosing any Personal Information to third parties.

Correcting Your Personal Information
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by contacting our Privacy Officer as set out below.

Access to Personal Information
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
You may contact our Privacy Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days.

Questions and Further Information
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer, who is ultimately accountable for the handling of all Personal Information in our custody and/or control and for ensuring that the principles described in this Privacy Policy are being complied with. We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Privacy Officer at:

Scott Garvie
Senior Vice President, Business & Legal Affairs
18 Logan Avenue
Toronto, Ontario M4M 2M8
Tel: 416 363-1411 x 115