SOCIÉTÉ EN COMMANDITE OTOGO (hereafter, “OTOGO”) hereby informs you of the use we make of the information we collect when you visit our websites (or our social media platforms or specialized applications), when you sign up for our services and when you visit the sites of our affiliates via a hyperlink authorized by us (hereafter, the “Site”). Thus, this Privacy Policy (hereafter, the “Policy”) describes how we collect, use, disclose and process the information you provide to us.

PERSONAL INFORMATION

1. What does “Personal Information” (hereafter, “PI”) mean and how is it collected?

PI is information about an identifiable individual, i.e. information that can be used to identify you. In certain circumstances, namely when you sign up for our various services or request information, or as part of newsletters or contests, OTOGO asks you to enter your first and last name, address, email address and various other information in a form on your screen. We may also collect your geolocation data in order to respond to your requests and to direct you to the appropriate sales department.

Our servers may also collect your computer’s IP address and the name of your Internet service provider. In most cases, that information in not PI but rather Navigation Data, and we refer you to the “Navigation Data” section below to better understand our policy relating thereto.

2. How is the PI used?

Collecting PI allows us to provide our services, to offer you and direct you to a service more relevant to your needs, to improve and personalize the content, interface and features of the Site based on the information collected, to contact you in order to respond to your requests and, if you informed us that you so desire, to send you occasionally information via email. This data is also used for monitoring purposes and to improve the use.

3. Is the PI shared with third parties?

We do not transfer, sell or disclose your PI in any manner whatsoever to any third parties, including our advertisers, other clients or partners, without obtaining your prior consent. Notwithstanding the foregoing, your PI may be disclosed to: (i) OTOGO’s subsidiaries and affiliated companies, (ii) third-party companies hired by OTOGO to store and process such information in the name and on behalf of OTOGO, pursuant to contractual agreements that ensure the confidentiality and security of such PI and iii) OTOGO’s partners, to redirect you to the appropriate distributor. In the latter case, OTOGO’s partners are the ones responsible for the confidentiality of your PI in accordance with their own policies and OTOGO assumes no responsibility with respect thereto.

Please note that OTOGO may use the services of suppliers located outside of Canada. As a result, in rare cases, the applicable laws in such foreign countries may allow the PI to be disclosed to judicial, quasi-judicial or government authorities.

4. Do we receive PI from third parties?

When you use or social media partner’s single sign-on (namely Facebook and Google), we may receive your email address, as well as your public profile information. If you wish to control such information, you must configure your privacy settings on the applicable social networks.

We use Salesforce’s services for our data management platform, to categorize the visitors on our Sites, and also to propose more suitable advertisements on other Internet sites, the whole, based on anonymized data (email, telephone number and use).

5. How is the PI stored and for how long?

The PI collected is saved on servers which are inaccessible to the public and protected with appropriate security measures. Accordingly, rest assured that appropriate security measures are in place to protect your data against loss, theft and unauthorized reviewing, copying, use and modification.

We keep the PI only to the extent that it remains necessary or relevant for the purposes mentioned in the Policy or as required by law. Accordingly, we will destroy your PI after two years if your account remains inactive or after one year if you did not create an account.

6. What are the risks?

Notwithstanding the above, and despite our good will and the measures we put in place, no data transmission on the Site or generally on Internet is completely guaranteed or entirely risk-free. For this reason, we cannot guarantee the absolute security of your PI and, accordingly, we cannot accept any responsibility for its use or misuse by third parties, its interception during transmission via Internet, or if it is subjected to hacking or fraud.

Be vigilant, our Site may contain links to other websites managed by third parties. Such links are only offered to you for your enjoyment. Activating those links will make you leave the Site. Be aware that the Site and OTOGO have no control over such third party websites and that, in any case, listing such links on the Site does not create any liability for OTOGO. You should also be aware that certain third parties may collect your data without our knowledge, such as your IP address and your navigation data. We do everything we can to prevent this from happening, but some third party practices remain beyond our control.

Furthermore, the voluntary sharing of PI during chat sessions via messaging, on a blog or on any interactive page where you make a public contribution by posting online content that you generate is not covered by this Policy. It is important to be vigilant when you communicate your PI through such means and we encourage you to review our Terms of use. OTOGO declines any responsibility in relation thereto. We advise you to always remain cautious and careful when you are online and navigate the Internet and when you create Internet content, in particular, by adding comments.

7. Can you access your PI?

Yes, you can access the PI that applies to you or ask that it be rectified by submitting a written request at infovieprivee@quebecormedia.com. We will be able to respond to your request only if we have a personalized file about you (which is the case when you shared PI with us or when you consent to share PI with us).

NAVIGATION DATA

1. What does “Navigation Data” mean, and how is it collected?

Navigation Data is anonymous data about your browsing activity or your device. For example, it includes the data related to your IP address, your browsing history, the content of those pages, the number of clicks you make, your type of device, the site you came from and the site you are going to when you leave ours, your approximate geographic location, your email, as well as the ads and videos viewed on the site.

The Navigation data is collected by using “cookies”, which are small data files that are recorded on the hard drive of your electronic device when you navigate on this site. The cookies are sent automatically by this site’s server to the browser of your device and are recorded, by default, on its hard drive.

The Navigation data is anonymous and, accordingly, is not used by us in order to discover your identity (by matching or any other method). It is only used for the purposes described below.

2. Who collects the Navigation data?

The Navigation data is or may be collected, in whole or in part, by (i) us, namely OTOGO, its subsidiaries and affiliated companies (hereinafter “us”) and (ii) certain companies with whom we collaborate for commercial or non-commercial purposes (such as our advertising partners, content partners, companies which may acquire some of our assets, or service, solution or technological platform providers associated with this site) (“Partners”).

The data which we may collect or which may be collected by our Partners is regarded as “non-sensitive” and is in depersonalized form. In addition, our Partners are legally bound to adhere to the recognized principles governing the protection of personal information and to respect their own privacy protection policies.

3. How is the Navigation data used?

This information is collected in order to allow us:

(a) to generate statistical data concerning our level of readership, the performance and use of our sites and their contents and the type of person interested therein;

(b) to improve your browsing experience. For example, your browser data [namely the language, time zone and plug-in) will be offered to you, by default, during your subsequent visits on this site, so that you will not need to enter your specific settings repeatedly; and

(c) to provide you with ads related to your interests such as, for example, ads related to the sites and contents you viewed.

4. How can you prevent your Navigation data from being collected?

You can simply delete at any time, from your browser, the cookies present on your computer or completely deactivate the feature that keeps or stores cookies on this site. Certain features also allow you to deactivate some cookies and to keep only those you want. If this is of interest to you, review your browser settings.

If you choose to deactivate those cookies, you will still be able to access the information on this site. However, if the cookies are deactivated, this site will treat you as a new user every time you visit and will show you only random and non-personalized ads.

Certain advanced features on this site may also be inadvertently affected, since some cookies provide the interconnections between the site’s various pages. If the deactivation affects your browsing, we invite you to contact us, at any time, at our contact details available on this site.

August 16, 2021