Privacy policy

PRIVACY POLICY AND PERSONAL INFORMATION PROTECTION POLICY

KO Média, its subsidiaries, and affiliated entities (the "Company") recognize the importance of protecting your personal information, which refers to any information about an individual that allows them to be identified directly or indirectly ("Personal Information"). This Privacy and Personal Information Protection Policy (the "Policy") describes the measures implemented by the Company to ensure the protection of Personal Information collected, used, disclosed, processed, and stored in the context of operating the Website (ko-media.ca) and its operational activities.

By transmitting your Personal Information to us, using our Website, or interacting with us, you consent to the collection, use, processing, and disclosure of your Personal Information in accordance with this Policy, which is subject to periodic revisions. Our Policy sets our standards for the collection, use, communication, and retention of your Personal Information.



1. NATURE OF PERSONAL INFORMATION COLLECTED
The collection of Personal Information includes those necessary for our operational
activities, potentially:

  • Your name; 
  • Your mailing address;
  • Your e-mail address;
  • Your billing address;
  • Your telephone number;
  • Your user ID;
  • Your password; and,
  • Your use of the Website.

We may collect Personal Information directly from you, through the Website, or via third parties.

a. Direct Collection from You:

We may collect Personal Information directly from you, for example, when:

  • You contact us with any questions.
  • You browse the Website.
  • You participate in a contest or survey.
  • You apply for a job.
  • You request a quote or proposal.
  • You inquire about our products and services.
  • You create a user account on the Website.
  • You subscribe to our newsletter on the Website.
  • You place an order on the Website.

We do not collect, retain, or process your credit card information during purchase transactions on the Website. Credit card transactions are carried out directly on our service provider's platform. Furthermore, we do not retain your credit card information, although you have the option to save such information in your user account. In this case, our service provider will generate a unique identifier (a “token”) allowing you to make future transactions from your account.

b. Collection Through the Website:

We may also collect information about visitors to the Website or through our online service portal, including:

  • The IP address used to access the Website.
  • A user's location data.
  • Information about your device, operating system, or browser.
  • Information regarding your preferences and browsing habits.

For users who create an account on the Website, we may collect information related to account login history, purchase history, and data related to the use of the online portal through our third-party service providers.

c. Through Third Parties:

We may also collect Personal Information from our partners as part of contract execution. We may access these Personal Information to carry out the tasks entrusted to us by these partners. We retain Personal Information transmitted by these partners solely for the purpose of fulfilling our tasks. We will process
Personal Information only in accordance with the instructions of partners who obtained the necessary consents from the concerned individuals for the transmission of their information.

2. MEANS OF COLLECTING PERSONAL INFORMATION

We may collect your Personal Information in various ways. For example:

  • By telephone.
  • In person.
  • Through our forms.
  • Through our surveys.
  • Through our digital interfaces.
  • Through our other digital properties or websites.
  • Through our service providers.
  • By subscribing to our newsletter.
  • Using cookies.

3. YOUR CONSENT

a. Obtaining Your Consent:

We process your Personal Information with your consent or as permitted or required by law. The manner in which we obtain your consent depends on the circumstances and the sensitivity of the information collected. In general, we will ask for your consent at the time of collecting your Personal Information. We commit to collecting, using, and communicating your Personal Information only for the purposes specified at the time of collection, where applicable. However, if you provide us with Personal Information about someone other than yourself, it is your responsibility to obtain that person's consent to allow us to process their information in accordance with this Policy.

b. Use of Your Personal Information:

In general, the collection of Personal Information aims to allow us to offer you a more personalized service and to better respond to your needs. This information contributes to the improvement of our content, the Website's interface, and the functionalities offered. Additionally, information related to the use of the Website allows us to monitor the quality of our products and services, as well as to enhance your experience by interacting with the Website.

Here are examples of uses of your Personal Information, without limitation, for which we may collect Personal Information:

  • Managing inquiries about our products and services.
  • Personalizing and adapting the browsing experience on the Website.
  • Evaluating an application for a position posted on the Website.
  • Complying with legal and regulatory obligations.
  • Confirming the identity of individuals.
  • Verifying the accuracy of Personal Information and updating it.
  • Improving the online shopping experience, providing relevant information
    about our products and services, or making recommendations.
  • Allowing users to log into their account, conducting searches on the
    Website, or adding items to their shopping cart.
  • Subscribing to our newsletter.
  • Surveying users, offering contests or promotions.
  • Interacting with our customer service.

c. Cases Where Your Consent is Not Required:

We commit not to share Personal Information with third parties without your consent, except in the following cases:

  • Under applicable laws, including laws outside your country of residence, notably to comply with a legal process or to respond to requests from public and government authorities.
  • When legally compelled to do so.
  • To protect our activities and our employees.
  • To protect our rights, our safety, or our property and/or those of our employees, our personnel.
  • To protect your rights and your safety.
  • In the context of a business transaction, for example, in the case of reorganization, merger, sale, assignment, transfer, or other disposition of all or part of our business or other assets, in accordance with the law.

4. ACCESS AND COMMUNICATION OF PERSONAL INFORMATION

a. Employees:

Personal Information is disclosed and accessible to our employees who reasonably need to access it to perform their duties and achieve the objectives of this Policy. The principle of least privilege is followed in granting access to Personal Information, based on the role and responsibilities of employees.

b. Third Parties:

We do not disclose your Personal Information to third parties. However, we may communicate your Personal Information to third parties to the extent necessary to perform a transaction you have authorized, fulfill our obligations, or act within the scope of our operational activities.

We may authorize third parties to access your Personal Information, including our partners, service providers, and independent consultants. In this case, we take measures to ensure that the rules set out in this Policy are respected, and we require service providers to maintain the confidentiality of your Personal Information and
ensure its security. We also require them to use your Personal Information only for the purposes for which it was provided. When our service providers no longer need your Personal Information for limited purposes, we require them to destroy it.

For more transparency, below is a list of categories of third parties that may process your Personal Information:

  • Our employees or our designated representatives may use this information
    for statistical analysis and reporting purposes.
  • Our service providers who help set up, manage, and host our Website,
    surveys, newsletters, forms, or other Website functionalities.
  • Our service providers who provide us with platforms and portals for the
    administration of the Website.
  • The government and other law enforcement bodies under applicable laws.
  • Our advisors and professional service firms.
  • Our marketing, webinar, and customer satisfaction service providers, acting
    on our behalf and facilitating online events, providing marketing
    communications, and collecting feedback from our customers on our service
    levels.
  • Our service providers ensuring the delivery of products you may purchase
    on the Website.
  • Our service providers offering financial transaction processing services,
    including by credit card.
  • Our service providers offering digital advertising services, such as M32.


5. NAVIGATION INFORMATION PROTECTION POLICY

a. Use of Cookies

Our Website uses connection cookies. These are files installed on the hard drive of your device or your browser to collect information such as your preferred language, your browsing history, your browser type and version, your device type, and more. In general, their purpose is to optimize your experience on our Website.
To learn more, please consult the Declaration on the use of navigation cookies: https://www.ko-media.ca/en/pages/politique-de-cookies

Please note that you can configure your browser to limit or refuse cookies or to be notified when a cookie is sent. Instructions for this are provided on each browser's website.

b. Navigation Data

Navigation data includes general data related to your online activity or your device. This information includes details such as your IP address, the history of your visits to the Website, the duration of your visits, the content viewed, the number of clicks made, the type of device used, the origin and destination of your visits, your general location (country or province), as well as encrypted identifiers, emails, and the advertisements viewed (“Navigation Data”).

Navigation Data is not used to reveal your identity. Moreover, we may aggregate information from our different digital properties to create a user profile without allowing the identification of your identity.

Navigation Data may be collected by the Company, its subsidiaries, and affiliated companies, as well as by its service providers, partners, and independent consultants. Our service providers, partners, and independent consultants may also collect aggregated Navigation Data to improve the quality of our Website.

In general, Navigation Data is used to generate statistics about visitors to our Website, the performance of the Website, to improve your browsing experience, and to provide you with targeted advertisements. Your navigation on the Website implies your consent to the collection of Navigation Data, but you can delete or disable this feature at any time via your browser settings. Rest assured that disabling will not prevent you from accessing information on the Website but will result in non-personalized advertisements. However, the proper functioning of the Website and your browsing experience may be affected.

c. Use of Analytical Tools

We use analytical tools and other third-party technologies that may use cookies, such as:

  • Google Analytics to obtain website analytics statistics;
  • Symplify to aggregate information collected on our various websites and
    digital properties as well as to manage the subscription, our newsletters, and
    maintain your purchase history using the Website; and,
  • Shopify for managing financial transactions on the Website, including by
    credit card, maintaining transaction history, as well as the functionalities
    allowing you to create and use your user account.

6. RETENTION OF PERSONAL INFORMATION

The Personal Information collected by the Company is stored on servers inaccessible to the public and benefits from enhanced protection through security measures adapted to their degree of sensitivity. These measures help us prevent the loss, theft, access, copying, use, or unauthorized modifications of your Personal Information. Moreover, to ensure the confidentiality of your Personal Information, we maintain administrative, technical, and physical protection measures to prevent any unauthorized access, use, modification, or disclosure of information under our responsibility.

For the purposes of this Policy, we take reasonable measures to ensure that your Personal Information is stored on servers located in Quebec. However, the communication of Personal Information to certain suppliers may result in their transfer outside of Quebec. In such cases, we will:

  • Conduct risk analyses related to the protection of Personal Information, if
    necessary.
  • Validate in advance the laws and Personal Information protection practices
    applicable in the targeted jurisdiction.
  • Take reasonable and necessary measures to provide adequate protection of
    your Personal Information.

7. DURATION OF RETENTION AND DESTRUCTION OF
PERSONAL INFORMATION

We have implemented measures to comply with our obligations for the retention and destruction of Personal Information. Personal Information will not be retained beyond what is necessary to achieve the purposes for which it was collected. Notwithstanding the foregoing, we will retain your Personal Information when such retention is required to comply with applicable legal obligations, including those specific to the protection of Personal Information.

8. MEASURES FOR THE PROTECTION OF PERSONAL INFORMATION

We have implemented physical, organizational, contractual, and technological security measures to adequately protect your Personal Information against theft, loss, unauthorized access, unauthorized transfer, unauthorized copying, or alteration. Additionally, our employees are bound by confidentiality agreements
and undergo regular training in information security and the protection of Personal Information. We take reasonable measures to ensure that our information technology systems comply with the industry-recommended security frameworks and protocols.

Notwithstanding the foregoing, and despite our commitment and the implementation of security measures, no data transmission over the Website or the Internet in general can be fully guaranteed or protected. Therefore, we cannot guarantee that your Personal Information will be protected against loss, misuse, or
alteration during transmission. Moreover, we accept no responsibility for Personal Information you transmit to us that could be used or misused by third parties, whether due to an interception on the Internet or a breach of computer security.

9. YOUR RIGHTS

As a person whose Personal Information has been collected, you can exercise the following rights:

a. Right to Access, Rectify, or Complete your Personal Information:

We make reasonable efforts to ensure that the Personal Information we collect is accurate and complete for the purposes for which it is used. You can request access to your Personal Information, verify its accuracy, and update it if necessary, subject to the requirements of the law.

b. Right to Withdraw Your Consent:

You can withdraw your consent for your Personal Information to be used for purposes that are not essential to the management and administration of our products and services, our operational activities, our legitimate interest, or to comply with the law.

c. Right to Erasure:

You can request the deletion of Personal Information that is outdated or not justified by the file's purpose.

d. Right to Portability:

Unless it raises serious practical difficulties, you have the right to receive your Personal Information in a structured and commonly used format. We may communicate your Personal Information, at your request, to any person or body.

e. Right to be Informed When Decisions Are Made Automatically:

In certain cases, you can request information about the use of any automated decision-making system and its impact on you. For example, you have the right to request the reasons justifying an automated decision or to present your observations to a member of our team or our customer service.

f. Right to File a Complaint:

Any questions regarding your Personal Information or any complaint arising from non-compliance with the principles set out in the Policy should be addressed to the Personal Information Protection Officer, whose contact details can be found at the bottom of the page.

10. THIRD-PARTY SERVICES

This Policy does not extend to sites, products, or services provided by third parties. We assume no responsibility for the privacy practices of these third parties, and we encourage you to review their privacy policies before using their websites, products, or services. For example, our social network tools such as Facebook,
YouTube, Pinterest, LinkedIn, TikTok, X (formerly Twitter), and Instagram widgets are hosted by third parties. Your use of these tools is subject to the policies of the companies that provide them.

11. MINORS

Minors are not permitted to use the Website. Minor persons (under the age of 14) may use the Website only with the consent of their parents or guardians. If we collect or believe we are collecting Personal Information from minors without the consent of their parents or guardians, we will do our best to delete this Personal Information as soon as possible.

12. POLICY UPDATE

This Policy may be modified from time to time to maintain compliance with the law and to reflect any changes in our Personal Information collection process. We recommend that our users check the Policy from time to time to ensure they are informed of any updates.

13. CONTACT

The Personal Information Protection Officer is responsible for ensuring the protection of your Personal Information and taking necessary measures to guarantee your rights, as described in the previous sections. The contact details of our Personal Information Protection Officer are as follows:

  • Name: Sophie Banford
  • Title: General director
  • Company: KO Média II Inc.
  • Address: 100-651 Notre-Dame Ouest, Montréal QC H3C 1H0
  • Tel.: 514-933-2462
  • Email: sbanford@ko-media.ca

Any request must be sent to the Personal Information Protection Officer in charge of privacy. Then, it will be processed as soon as possible, or no later than thirty (30) days following the receipt date of your written request.