2880 Brighton Rd, Unit 1
Oakville, ON L6H 5S3
Attention: Chief Privacy Officer
Commitment #1: Accountability
Commitment #2: Identifying Purposes for Collecting Personal Information
APG MEDIA will, either directly or through a client, identify to an individual the purposes for which it collects, uses and discloses personal information (the "Purposes"), before or at the time the information is collected, or where the information is to be used or disclosed for a new purpose, before that use or disclosure. The Purposes may include: (a) understanding, developing and administering the Website, blog and other products, services and resources that meet individuals' and clients' advertising-related needs, including by operating, maintaining and improving the features and functionality of the Website, blog and other digital content; processing any User Submissions, ombudsman inquiries or other communications individuals send via the Website or Blog or other digital program; and distributing such Blog or other digital program feeds or weekly updates as may be requested by individuals; (b) communicating with individuals in connection with the purposes in (a); (c) offering individuals and/or their organizations new branding, marketing, advertising-related products, digital marketing and other services and resources that may be of interest to them (provided that such individuals have not opted out of receiving, or having their organizations receive, such offers); and (d) monitoring overall traffic on the Website and Blog or other digital programs and composing and analysing aggregate traffic data and statistics, in each case, on an anonymized basis.
Commitment #3: Obtaining Consent
APG MEDIA will make a reasonable effort, either directly or through a client, to advise an individual as to how personal information will be used or disclosed by APG MEDIA. Generally, APG MEDIA or a client, on behalf of APG MEDIA, will obtain the individual's consent to the collection, use, and disclosure of personal information for the Purposes before or at the time, it collects the information. An individual's consent may be express or implied, depending on the sensitivity of the information.
An individual may withdraw or vary his or her consent on reasonable notice to APG MEDIA, subject to legal or contractual restrictions. APG MEDIA will generally be able to give effect to such withdrawal or variation on thirty (30) days' notice, and will, if it has not already done so, advise the individual of the implications of his or her withdrawal or variation.
Commitment #4: Limits on the Collection of Personal Information
APG MEDIA will limit the personal information it collects to information necessary for the Purposes. APG MEDIA will only collect personal information by fair and lawful means. APG MEDIA will not collect personal information from any third party (other than a client acting on behalf of APG MEDIA) without an individual's consent unless the collection is clearly in the individual's interest and APG MEDIA is unable to obtain consent in a timely way, or as otherwise permitted by law.
APG MEDIA will not, as a condition of supplying a product, service, or resource, require an individual's consent to the collection, use, or disclosure of his or her personal information beyond that reasonably required to supply the product, service, or resource, to comply with its obligations under applicable law or for related internal business or management or legal purposes.
Commitment #5: Limits on the Use, Disclosure and Retention of Personal Information
APG MEDIA will only use, disclose and retain personal information for the Purposes. APG MEDIA will identify any third parties to whom personal information will be disclosed at the time of collection and obtain individuals' consent to such disclosure. For example, APG MEDIA may: (a) disclose personal information to an individual's organization for the purposes of understanding and administering products, services and resources that meet the organization's advertising needs, and communicating with the organization for that purpose, and/or offering the organization new products, services and resources that may be of interest to it (provided that the individual has not opted out of having his or her organization receive such offers); (b) make some information about an individual available to other users of the Website and Blog or other digital program. This may include an individual's name, website and User Submissions, for instance, when the individual engages in certain activities such as posting or submitting comments or other information or materials using Blog or other digital program. An individual's email address will not generally be made available to other users; or (c) transfer personal information to third parties for processing (e.g., data processing or hosting), pursuant to contractual agreements that provide a level of protection for the personal information comparable to that provided by APG MEDIA, as well as assurances that such third parties will not use or disclose the personal information for any purpose other than processing.
Under certain statutory exceptions, APG MEDIA may have a legal duty or right to disclose personal information without individuals' consent. Examples of permitted disclosures of personal information to non-affiliated third parties may include disclosures required to comply with a subpoena or warrant, made pursuant to a request by a government institution, made to an investigative body or government institution where APG MEDIA has reasonable grounds to believe that the information relates to a breach of an agreement or law or disclosures otherwise required by law.
APG MEDIA will use, disclose and retain personal information only for as long as is necessary to fulfil the Purposes or as otherwise permitted or required by law. User Submissions will be archived on Blog or other digital program only so long as the relevant APG MEDIA post is archived. APG MEDIA has established minimum and maximum retention periods and procedures for retaining and destroying personal information.
Commitment #6: Accuracy of Personal Information
APG MEDIA will use reasonable efforts to keep personal information as accurate, complete and up-to-date as necessary for the Purposes. That said, APG MEDIA will not routinely update personal information unless necessary. APG MEDIA expects individuals, from time to time, to inform APG MEDIA of any updates that may be required by contacting APG MEDIA using the contact information above.
Commitment #7: Safeguarding Personal Information
APG MEDIA is committed to protecting the security of personal information. APG MEDIA uses security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and limiting access on a "need to know" basis and technological measures, such as the use of passwords, encryption and other secure methods by which to verify the identity of individuals.
APG MEDIA remains responsible for all personal information transferred to third parties for processing. As such, APG MEDIA ensures that all third parties engaged to perform services on APG MEDIA behalf are required to provide a level of protection for personal information comparable to the level of protection provided by APG MEDIA, and that such third parties are prohibited from using or disclosing personal information for any purpose other than processing.
Commitment #8: Availability of Information about APG MEDIA Policies and Practices
Commitment #9: Access to Personal Information
Upon written request, APG MEDIA will generally tell an individual what personal information it has, what it is being used for and to whom it has been disclosed and will grant the individual access to the information. APG MEDIA will make such information available to an individual in a form that is generally understandable, including by explaining any abbreviations or codes or by employing an alternative format, if required. Written requests, including the individual's name and contact information, should be sent to APG MEDIA Chief Privacy Officer using the contact information above. APG MEDIA will make every reasonable effort to respond to written requests within thirty (30) days of receipt and will advise individuals in writing if for any reason this time limit cannot be met.
APG MEDIA may request individuals who submit written requests to provide sufficient information to enable APG MEDIA to verify their identity. Any such information will be used only for the purpose of identification.
APG MEDIA will not assess any costs to individuals for accessing their personal information without first providing individuals with an estimate of such costs, which will be minimal, if any. Individuals are asked to confirm their wish to proceed in writing within the thirty (30) day notice period set out in any estimate. If an individual does not notify APG MEDIA in writing of his or her wish to proceed within such notice period, then APG MEDIA will deem the individual to have withdrawn his or her request for access and will provide him or her with a written notice to that effect.
An individual may challenge the accuracy and completeness of personal information and request that it be amended. APG MEDIA will, if appropriate, amend the information and advise third parties to whom the information has been disclosed of the amendment.
Commitment #10: Handling Complaints and Questions
Prior to making a complaint to the Chief Privacy Officer, or if a complaint is not resolved to the individual's satisfaction, the individual may also make a complaint to the applicable Privacy Commissioner.