R4Z Data Corp. (“R4Z Data”) and its affiliates and subsidiaries (collectively,
the “R4Z Data Companies”) are committed to controlling the collection, use and
disclosure of personal information provided by the customers and employees of
accuracy, confidentiality and integrity of such personal information.
collects, uses or discloses in respect of its customers or employees in the
course of its commercial activities.
R4Z Data – means R4Z Data Corp.
R4Z Data Companies – means, collectively, R4Z Data Corp. and all of its
subsidiaries with respect to their operations in Canada, and a R4Z Data Company
means any one of them.
customer – means an individual who:
(a) subscribes for, uses, or applies to use, the products or services of a R4Z
(b) corresponds with a R4Z Data Company;
(c) uses a website owned by a R4Z Data Company; or
(d) enters a contest sponsored by a R4Z Data Company.
employee – means an employee, former employee or pensioner of a R4Z Data Company
shareholders and security holders of R4Z Data.
personal information – means information about an identifiable individual, but
does not include the name, title, or business address or telephone number of an
employee of an organization. Publicly available information, such as a public
directory listing of names, addresses, telephone numbers and electronic
addresses, is not considered personal information.
privacy legislation – means Canada’s federal private sector privacy legislation,
the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and
substantially similar provincial privacy legislation including Alberta’s
Personal Information Protection Act, British Columbia’s Personal Information
Protection Act, and Quebec’s An Act respecting the protection of personal
information in the private sector.
The Ten Privacy Principles
in PIPEDA and is modelled after the Canadian Standards Association Model Code
for the Protection of Personal Information, CAN/CSA-Q830-96. Accordingly, the
ten principles of fair information practices (the “Principles”), as identified
by the Canadian Standards Association, have been adopted by the R4Z Data
Companies and represent a formal statement of the minimum requirements to be
adhered to by each of the R4Z Data Companies for the protection of personal
information collected from the customers and employees of the R4Z Data
Principle 1 – Accountability
Each R4Z Data Company is responsible for the personal information under its
control and shall designate one or more individuals who shall be accountable for
the company’s compliance with the procedures and principles set out in this
1.1 Accountability for compliance by each R4Z Data Company with this Privacy
Policy and the Principles rests with R4Z Data’s Privacy Officer. Please see
Principle 10, below, to obtain the contact information for our Privacy Officer.
1.2 Each R4Z Data Company shall be responsible for the personal information in
its possession or custody, including information that has been transferred to a
third party for processing. Each R4Z Data Company shall use contractual or other
appropriate means to ensure a comparable level of protection while the
information is being processed by a third party.
1.3 The R4Z Data Companies have implemented policies and practices to give
(a) implementing procedures to protect personal information such as the adoption
of physical, organizational and technological security measures;
(b) establishing procedures to receive and respond to complaints and inquiries
through the establishment of a confidential e-mail address; and
(c) training and communicating to staff information about the R4Z Data policies
Principle 2 – Identifying Purposes
Each R4Z Data Company will identify the purpose for which personal information
is collected at or before the time the information is collected. The purposes
for which personal information is collected, used or disclosed by a R4Z Data
Company must be those that a reasonable person would consider are appropriate in
2.1 The R4Z Data Companies collect and use your personal information primarily
for the purpose of providing you with the products and services you have
requested from us, including the daily delivery of news and related content
through R4Z Data television and online properties.
2.2 Your personal information is used to communicate with you about your account
and to provide you with information related to other R4Z Data publications and
services. If you indicated that you were interested in receiving offers or
information from selected R4Z Data sponsors or advertisers, your personal
information would also be used to contact you or to send you e-mail materials
and other mailings about products and services that might be of interest to you.
You always have the option, however, to tell us not to share your personal
information with other R4Z Data Companies or to exclude you from offers for
other products or services.
2.3 Each R4Z Data Company will document the purposes for which personal
information is collected in order to comply with the Openness principle (See
Principle 8) and the Individual Access principle (See Principle 9).
2.4 The purposes for which personal information is collected shall be specified
at or before the time of collection to the customer or employee from whom the
personal information is collected. Depending upon the manner in which the
information is collected, this shall be done orally or in writing.
2.5 When a R4Z Data Company proposes to use personal information that has been
collected for a purpose not previously identified, it will identify the new
purpose before using such personal information. Unless the new purpose is
required by law, or consent is otherwise not required pursuant to privacy
legislation, the consent of the individual shall be obtained before the personal
information is used for the new purpose.
2.6 Individuals responsible for collecting personal information on behalf of a
R4Z Data Company will explain to customers and/or employees the purposes for
which the information is being collected, including any purposes that may not be
immediately obvious to the individual.
2.7 The purposes for which the personal information of employees is collected
may include, but is not limited to:
(a) administering payroll and employee benefit programs;
(b) conducting performance evaluations and discipline;
(c) effecting employee training;
(d) conducting internal reviews, investigations and complaint resolution
(e) participating in union negotiations and labour arbitrations;
(f) facilitating transactional due diligence reviews; and
(g) complying with legal and regulatory obligations.
2.8 The purposes for which the personal information of customers is collected
may include, but is not limited to:
(a) processing commercial transactions;
(b) communicating with customers;
(c) establishing and maintaining commercial relations;
(d) developing, marketing or providing products and services;
(e) recommending particular products and services;
(f) conducting market research and surveys;
(g) managing and developing business opportunities;
(h) conducting investigations and complaint resolution processes;
(i) administering contests or other promotions;
(j) facilitating transactional due diligence reviews; and
(k) complying with legal and regulatory obligations.
2.9 Anonymous or “non-personal” information gathered by a R4Z Data Company
through its web site may be used for technical, research and analytical
purposes. Information collected through surveys, existing files and public
archives may be used by a R4Z Data Company to analyze its markets and to develop
or enhance service offerings.
Principle 3 – Consent
Except where required or permitted by law, the knowledge and consent of the
individual are required for the collection, use or disclosure of personal
3.1 Consent is required for the collection of personal information and the
subsequent use or disclosure of this information. Generally, each R4Z Data
Company will seek consent for the use or disclosure of the information at the
time of collection. In certain circumstances, consent with respect to the use or
disclosure of personal information may be sought after the information has been
collected but before the personal information is used (for example, when a R4Z
Data Company wants to use information for a purpose not previously identified).
In obtaining consent, the R4Z Data Companies shall use reasonable efforts to
ensure that a customer or employee is advised of the identified purposes for
which personal information will be used or disclosed. Purposes shall be stated
in a manner that can be reasonably understood by the customer or employee.
3.2 In certain circumstances personal information may be collected, used or
disclosed without the knowledge and consent of the individual. For example, a
R4Z Data Company may collect or use personal information without the knowledge
or consent of its employees and/or customers if the collection or use of
personal information is clearly in the interests of the individual and consent
cannot be obtained in a timely way, such as when the individual is a minor,
seriously ill or mentally incapacitated or if seeking the consent of the
individual might defeat the purpose of collecting the information such as in the
investigation of a breach of an agreement or a contravention of a federal or
provincial law. Personal information may also be used or disclosed without the
knowledge or consent of the individual in the case of an emergency where the
life, health or security of an individual is threatened. A R4Z Data Company may
disclose personal information without knowledge or consent to a lawyer
representing the company, to collect a debt, to comply with a subpoena, warrant
or other court order, or as may be otherwise required by law.
3.3 The R4Z Data Companies will not, as a condition of the supply of a product
or service, require an individual to consent to the collection, use, or
disclosure of information beyond that required to fulfill the explicitly
specified and legitimate purposes.
3.4 In obtaining consent, the R4Z Data Companies will take into account the
sensitivity of the personal information and the reasonable expectations of its
customers and employees. Consent will not be obtained through deception. For
(a) A customer who enters a contest online would reasonably expect that his or
her relevant contact information (name, phone number, personal identification)
would be collected and used to identify the customer if and when he or she was
selected as a contest winner. However, the customer would not reasonably expect
that this information would be used for a purpose other than the administration
of the contest, without the customer’s knowledge and consent.
(b) An individual filing an application for employment with a R4Z Data Company
would reasonably expect that his or her age and marital status would be used for
the purposes of administering benefit plans.
(c) An employee filing an application for R4Z Data’s dental coverage plan would
reasonably expect that the relevant information (employee identification number,
name, date of birth) would be collected, used and communicated to third parties
in accordance with the dental coverage and for such period of time as the
coverage was in effect.
3.5 The way in which a R4Z Data Company seeks consent may vary, depending on the
circumstances and the type of information collected. A R4Z Data Company will
generally seek express consent when the information is likely to be considered
sensitive. It will rely on implied consent where collection and use of the
personal information is directly related to a transaction or exchange of
information in which the individual is directly participating. Consent may also
be given by an authorized representative (such as a legal guardian or a person
having power of attorney).
3.6 Consent may be obtained in any one of the following ways:
(a) an application form may be used to seek consent, collect personal
information and inform the individual of the use that will be made of the
personal information. By completing and signing the form, the individual is
giving consent to the collection and the specified uses;
(b) a check-off box may be used to allow individuals to request that their names
and addresses not be given to other organizations. Individuals who do not check
the box are assumed to consent to the transfer of their information to third
(c) consent may be given orally when information is collected over the
(d) consent may be given at the time that individuals use a product or service.
3.7 Generally, the use of products and services by a customer, or the acceptance
of employment or benefits by an employee, constitutes implied consent for the
R4Z Data Companies to collect, use and disclose personal information for all
3.8 An individual may withdraw consent at any time, subject to legal or
contractual restrictions and reasonable notice. The R4Z Data Companies will
inform individuals of the implications of withdrawing consent. Customers and
employees may contact the relevant R4Z Data Company for more information
regarding the implications of withdrawing consent.
Principle 4 – Limiting Collection
The R4Z Data Companies shall limit the collection of personal information to
that which is necessary for the purposes identified by the company. Personal
information shall be collected by fair and lawful means.
4.1 The R4Z Data Companies will not collect personal information
indiscriminately. Both the amount and the type of information collected shall be
limited to that which is necessary to fulfill the purposes identified. Each R4Z
Data Company shall specify the type of information collected as part of its
information-handling policies and practices, in accordance with the Openness
principle (Principle 8).
4.2 The requirement that personal information be collected by fair and lawful
means is intended to prevent a R4Z Data Company from collecting information by
misleading or deceiving individuals about the purpose for which information is
being collected. Consent to the collection of personal information must not be
obtained through deception.
4.3 The R4Z Data Companies use a browser feature called a “cookie” to collect
information anonymously and track user patterns on R4Z Data websites. A cookie
is a small text file that is placed on your hard disk by a website. “Cookies”
contain a unique identification number that identifies your browser, but not
you, to our computers each time you visit one of our websites. Cookies tell us
which pages of our websites are visited and by how many people. The use of
cookies is an industry standard and many major browsers are initially set up to
accept them. You can reset your browser to either refuse to accept all cookies
or to notify you when you have received a cookie. However, if you refuse to
accept cookies, you may not be able to use some of the features available on our
Principle 5 – Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than
those for which it was collected, except with the consent of the individual or
as required by law. Personal information shall be retained only as long as
necessary for the fulfillment of the purposes for which it was collected.
5.1 Where a R4Z Data Company intends to use personal information for a purpose
not previously identified, the R4Z Data Company shall document the new purpose
and shall obtain the consent of the individual prior to using the information
for a new purpose.
5.2 A R4Z Data Company may disclose the personal information of its employees:
(a) to human resources, payroll, benefits, information management, medical and
(b) to third party service providers for the purposes of administering payroll
and benefits programs;
(c) to union representatives and labour arbitrators;
(d) to other R4Z Data Companies;
(e) to internal or external legal counsel and auditors;
(f) to the management personnel of each R4Z Data Company;
(g) in the context of providing references regarding current or former employees
in response to requests from prospective employers and/or financial
(h) to prospective parties in the context of a transactional due diligence
(i) where disclosure is required by law.
5.3 A R4Z Data Company may disclose the personal information of its customers:
(a) to third parties who are acting on our behalf as our agents, suppliers or
(b) to other R4Z Data Companies;
(c) to internal or external legal counsel and auditors;
(d) to the management personnel of each R4Z Data Company;
(e) to third parties for the development, enhancement or marketing of R4Z Data
products or services;
(f) to an agent retained by the R4Z Data Companies in connection with the
collection of the customer’s account;
(g) to credit grantors and reporting agencies;
(h) to a third party or parties, where the customer consents to such disclosure;
(i) to prospective parties in the context of a transactional due diligence
(j) where disclosure is required by law.
5.4 Except as required or permitted by law, when disclosure is made to a party
other than a R4Z Data Company or a third party provider of personal information
processing services, the consent of the individual shall be obtained and
reasonable steps shall be taken to ensure that any such third party has personal
information privacy procedures and policies in place that are at least
comparable to those implemented by the R4Z Data Companies. Such third party
service providers are provided only with such information as is necessary in the
circumstances. Personal information provided to third parties may be used only
for the purpose stipulated and is subject to strict terms of confidentiality.
5.5 In the event that a third party service provider is located in the United
States or another foreign country, customer and employee personal information
may be processed and stored in the United States or such other foreign country.
In such circumstances, the governments, courts or 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 (for example, the USA
Patriot Act in the United States). Whenever the R4Z Data Companies engage a
third party service provider, we confirm that its privacy and security standards
5.6 Unless authorized by the customer, the R4Z Data Companies will not sell,
lease or trade the personal information of their employees or customers to third
5.7 Personal information shall be retained only as long as it remains necessary
or relevant for the identified purposes or as required by law. Depending on the
circumstances, where personal information has been used to make a decision about
a customer or an employee, the relevant R4Z Data Company shall retain, for a
period of time that is reasonably sufficient to allow for access by the customer
or employee, either the actual information or the rationale for making the
Principle 6 – Accuracy
Personal information shall be as accurate, complete and up-to-date as is
necessary for the purposes for which it is to be used.
6.1 Personal information used by the R4Z Data Companies shall be sufficiently
accurate, complete and up-to-date to minimize the possibility that inappropriate
information may be used to make a decision about the individual customer or
employee. The extent to which personal information will be accurate, complete
and up-to-date will depend upon the use of the information, taking into account
the interests of the individual.
6.2 Each R4Z Data Company shall ensure that personal information that is used on
an ongoing basis, including information that is disclosed to third parties, is
generally accurate and up-to-date, unless limits to the requirement for accuracy
are clearly set out.
6.3 Customers and employees are responsible for advising the R4Z Data Companies
of any inaccuracies or changes to their personal information. Please inform the
R4Z Data Company to whom you provided your information of any change of name,
address or other personal information. In the event you have questions about the
accuracy of factual information we have collected about you, you will have
access to that information in order to verify and update it. If a R4Z Data
Company has disclosed inaccurate personal information about you to a third
party, such company will be pleased to contact the third party in order to
correct the personal information.
Principle 7 – Safeguarding Personal Information
Personal information shall be protected by security safeguards appropriate to
the sensitivity of the information.
7.1 Each R4Z Data Company will 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
7.2 The nature of the safeguards will vary depending on: (a) the sensitivity of
the information that has been collected; (b) the amount, distribution and format
of the information; and (c) the method of storage.
7.3 Physical measures such as locked filing cabinets and restricted access to
offices, organizational measures such as security clearances and limiting access
on a “need-to-know” basis, and technological measures such as the use of
passwords and encryption have been adopted by each R4Z Data Company.
7.4 Each employee of a R4Z Data Company shall be made aware of the importance of
maintaining the confidentiality of personal information. Our employees have been
trained to respect your privacy at all times and those employees with access to
your personal information shall use your personal information strictly in
7.5 Personal information disclosed to third parties shall be protected by
contractual agreement stipulating the confidentiality of the information and the
purposes for which it is to be used.
Principle 8 – Openness
The R4Z Data Companies shall make readily available to its customers and
employees specific information about its policies and practices relating to the
management of personal information.
8.1 Each R4Z Data Company will be open about its policies and practices with
respect to the management of personal information. Customers and employees shall
be able to acquire information about the policies and practices of each R4Z Data
Company with respect to the management of personal information without
8.2 Such information shall be made available to: (i) customers by writing to R4Z
Data Corp., to the attention of the Privacy Officer at 429 Elizabeth Street, Burlington, ON
L7R 2L8 or at firstname.lastname@example.org, and (ii) employees by contacting the
Human Resources Department at the applicable R4Z Data Company.
Principle 9 – Individual Access
Upon request, an individual shall be informed of the existence, use and
disclosure of his or her personal information and shall be given access to that
information except where a R4Z Data Company is permitted or required by law not
to disclose personal information to the individual customer or employee. An
individual customer or employee shall be able to challenge the accuracy and
completeness of the information disclosed to him or her and have it amended as
9.1 Upon request, a R4Z Data Company shall inform an individual customer or
employee whether it holds personal information about that individual (except
where permitted or required by law not to disclose personal information) and
shall afford the individual a reasonable opportunity to review the personal
information in his or her file at minimal or no cost to the individual. The R4Z
Data Company shall provide an account of the use that has been made or is being
made of the personal information and an account of the third parties to which
the personal information has been disclosed. Where reasonably possible, the R4Z
Data Company shall indicate the source of the personal information.
9.2 In order to safeguard personal information, a customer or employee may be
required to provide sufficient identification information to permit the R4Z Data
Company to account for the existence, use and disclosure of personal information
and to authorize access to the individual’s file. Any such information shall be
used only for this purpose.
9.3 In certain situations, the R4Z Data Companies may not be able to provide
access to all of the personal information that they hold about a customer or
employee. For example, the R4Z Data Companies are not required to provide access
to information if doing so would likely reveal personal information about a
third party or could reasonably be expected to threaten the life or security of
another individual. Similarly, the R4Z Data Companies may not be required to
provide access to information if disclosure would reveal confidential commercial
information, if the information is protected by solicitor-client privilege, if
the information was generated in the course of a formal dispute resolution
process, or if the information was collected in relation to the investigation of
a breach of an agreement or a contravention of a federal or provincial law. If
access to personal information cannot be provided, the R4Z Data Companies shall
provide the reasons for denying access upon request.
9.4 In providing an account of third parties to which it has disclosed personal
information about a customer or an employee, the R4Z Data Company shall attempt
to be as specific as possible. When it is not possible to provide a list of the
organizations to which it has actually disclosed personal information, the R4Z
Data Company shall provide a list of organizations to which it may have
disclosed personal information about the customer or employee.
9.5 The R4Z Data Companies shall promptly correct or complete any personal
information found to be inaccurate or incomplete. Any unresolved differences as
to the accuracy or completeness shall be noted in the individual’s file. Where
appropriate, the R4Z Data Companies shall transmit to third parties having
access to the personal information in question any amended information or the
existence of any unresolved differences.
9.6 If you have any questions about the collection, use or disclosure of your
personal information by a R4Z Data Company, or if you simply want to know
whether we have any of your personal information on file, you may contact R4Z
Data’s Privacy Officer at 429 Elizabeth Street, Burlington, ON
L7R 2L8 or at email@example.com.
Principle 10 – Challenging Compliance
An individual customer or employee shall be able to address a challenge
designated Privacy Officer.
acknowledged in this policy in a timely manner. We may add, modify or remove
10.1 The R4Z Data Companies shall maintain procedures for addressing and
responding to all inquiries or complaints from its customers and employees about
the companies’ handling of personal information.
10.2 The R4Z Data Companies will inform their customers and employees about the
existence of these procedures as well as the availability of complaint
10.3 The R4Z Data Companies shall investigate all complaints concerning
the relevant R4Z Data Company shall take appropriate measures to resolve the
complaint including, if necessary, amending its policies and procedures. A
customer or employee shall be informed of the outcome of the investigation
regarding his or her complaint.
10.4 If you have any questions or concerns about the personal information about
you held by a R4Z Data Company or about the compliance by a R4Z Data Company
L7R 2L8 or at firstname.lastname@example.org.
10.5 Each R4Z Data Company has procedures in place to receive and respond to
complaints or inquiries about its handling of personal information. Each R4Z
Data Company will describe the complaint procedures to anyone who makes
inquiries or lodges complaints.
acknowledged in this policy in a timely manner. We may add, modify or remove
Last revised Wednesday, January 28, 2015.