Privacy Statement

Information We Collect

What Types of Information Do We Collect?

1. 1. “Personal information” means information that can be used to identify an individual. Examples of Personal Information that we collect, use and disclose (as further set out in the “To Whom Do We Disclose Personal Information” section below) include your contact information (name, address, phone number or email address) and billing information (credit card number or banking information). Personal information does not include publicly available information. In most cases, we collect Personal Information when you purchase or subscribe to a product or service that we offer. Occasionally, we may also collect Personal Information from a third party based on your consent or as otherwise permitted by law.
   2. Non-Personal Information, as defined above; and
   3. Public Activities Information: means information gathered based on actions that you take on our Properties that are designed to be visible to other Users, such as comments or recommendations

When Do We Collect Personal Information?

We collect Personal Information when you provide, post or upload it to us or one of our Properties, such as, without limitation, when you fill out a form, post a comment or subscribe to a newspaper.

Using log-ins, cookies, device information and internet protocol (“IP”) addresses, we identify you and log usage data when you visit our Properties, such as when you view or click on content or ads, perform a search, install or update one of our mobile apps, or share articles.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Properties and devices. We also allow third parties to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also opt-out of our use of cookies and similar technologies that allow third parties to track your behavior.

Why Do We Collect Personal Information and How Do We Use It?

We identify the purposes for which we may collect, use and disclose your Personal Information at the time that you provide such information to us. Consent is also secured when we collect your Personal Information, except where permitted or required by law.

We may use your Personal Information to:

1. 1. contact you through email, mobile phone, notices posted on our Properties, text messages and push notifications;
   2. send messages about the availability and methods of use of our products, services and Properties, as well as with respect to, security or other service-related issues. Please note that you may change your communication preferences at any time but you cannot opt-out of receiving service messages from us, including security and legal notices;
   3. provide network updates, reminders, and promotional messages from us and our partners;
   4. conduct research for the further development of our Properties in order to provide you and others with a better, more intuitive and personalized experience, as well as to drive growth and engagement on our Properties;
   5. investigate, respond to and resolve complaints and service issues (e.g., bugs);
   6. produce and share aggregated insights using Non-Personal Information. For example we may use your data to generate statistics about our Users, to calculate ad impressions served or clicked on, or to publish User demographics for a Property; and
   7. target (and measure the performance of) ads to Users both on and off our Properties, directly or through a variety of partners, using the following data, whether separately or combined:

• • Data from advertising technologies on and off our Properties, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • User-provided information (e.g., profile, contact information);
  • Data from your use of our services, products and Properties (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.);
  • Information from advertising partners and publishers; and
  • information inferred from data described above.

The manner in which we use your Personal Information will depend on which products you use or Properties you visit, how you use those products and the choices you make in your settings. With the assistance of automated systems and using digital inferences, we use the data that we collect to personalize our Properties so that they can be more relevant and useful to you.

Examples of Type of Information Collected, Stored and Used

Use of Technology

How Does Our Technology Monitor Our Properties?

Postmedia’s Properties may place technologies (typically small data files) such as “cookies”, “web beacons”, “tags and scripts”, and local storage objects (“LSOs”) such as HTML5, that websites or applications commonly write to your computer or device and contain information that can help identify you each time you visit one of our Properties. Postmedia uses these technologies to measure website and application activity and traffic patterns, to log your activity, to develop analytics, and to store your reading and behaviour history. If and to the extent that we share any of this information with third-party vendors and advertising networks to deliver advertisements on our Properties, it is shared as Non-Personal Information. Third parties may also place and access these or similar technologies on your devices for the purpose of delivering Customized Experiences such as advertisements directed at your interests. Postmedia does not have access to, nor control over, the use of tracking technologies by such third parties. As such, the placement of these third-party technologies on your computer or devices is subject to the terms, conditions and policies of such third-party vendors and advertising networks. You may choose to set your computer or device to reject these technologies. However, some features available on our Properties may rely on these technologies, and any rejection of the same may impact your ability to use features on our Properties.

How Does Our Technology Monitor Our Properties?

Postmedia supports responsible political advertising on our Properties and will accept political ads by all registered Canadian political parties. New in 2019 is the requirement under Bill C-76 requiring digital platforms accepting regulated political advertising to maintain a digital ad registry. Postmedia’s ad registry can be found at adregistry.postmedia.com.

Collection and Use of Usage Information

From time to time, we collect certain usage information from our servers that relates to the use of our Properties. We use this information for statistical analysis and to improve our Properties, for example, by enhancing pages or features that are visited frequently. On occasion, we may share this information with our affiliates or other third party vendors or service providers to provide them with an indication of the amount of interest in our Properties for advertising purposes and to help us plan for technical improvements.

To Whom Do We Disclose Personal Information?

We will share your Personal Information with our affiliates to provide and develop our Properties. We may also combine information internally across the different Properties covered by this Privacy Policy to help our Properties be more relevant and useful to you and others.
Postmedia may share your Personal Information with third party service providers in order to enable them to provide services on our behalf. We use third parties to help us provide products and services on our Properties (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform any tasks on our behalf and are obligated not to disclose or use it for other purposes. Some service providers may be located outside of Canada where Personal Information may be subject to the laws of those jurisdictions.

We do not share your Personal Information with any third-party advertisers or ad networks for their own advertising use except for: (i) hashed or device identifiers (to the extent they are Personal Information in some countries); (ii) with your permission or (iii) data already visible to any Users of the Properties. However, if you view or click on an ad on or off our Properties, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of cookies, identify you. Advertising partners can associate Personal Information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith reasons to believe that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Properties (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of our Users, personnel, or others. We attempt to notify Users about legal demands for their Personal Information when appropriate, in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We can also share your Personal Information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your Personal Information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

How do we retain and safeguard your personal information?

How can you access your personal information?

For Personal Information that we have about you:

• Delete Personal Information: You can ask us to erase or delete all or some of your Personal Information (e.g., if it is no longer necessary to provide products or services to you).
• Change or Correct Personal Information: You can edit some of your Personal Information through your account, as applicable. You can also ask us to change, update or fix your Personal Information in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Personal Information: You can ask us to stop using all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Information is inaccurate or unlawfully held).
• Right to Access and/or Take Your Personal Information: You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form.