This Policy was last updated on May 8, 2014. We reserve the right to revise this Policy at any time and, as such, you should review its terms each time that you use www.grainews.ca. Any changes to this Policy will be promptly communicated on this page, but will not go into effect until at least five (5) days after they are posted.
Accountability and Openness / Compliance
FBC Communications is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries. We only collect personally identifiable data when it is voluntarily submitted by you through the use of our websites and applications, and are committed to maintaining the accuracy, confidentiality and security of your personal information. We will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information.
FBC Communications has designated a privacy officer (“Privacy Officer”) who is accountable for our compliance with this Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible. All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to [email protected] or by post to:
FBC Communications Limited Partnership
P.O. Box 9800, Station Main
Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user. Users may contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3 or www.priv.gc.ca/complaint-plainte/pipeda_e.asp.
By submitting your personal information, registering with us, or using our applications or websites, you signify your agreement to the terms and conditions of this Policy and to our use of your personal information. You may change or withdraw your consent to the collection, use and/or disclosure of your personal information at any time by contacting the Privacy Officer in writing at either of the address listed above. In some circumstances, a change or withdrawal of consent may affect your ability to use an application and/or our ability to provide you with information, products or services.
Collection and Retention of Information
We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). In most cases, we will collect personal information directly from you when you interact with us with respect to our websites, applications, or any other product or service that we offer. For example, we may request personal information when it is needed to provide certain services, such as granting access to a website reserved for paid subscribers, to enable you to purchase products and services, or to allow you to enter a contest or to take advantage of an online promotion. Occasionally, we may collect personal information from a third party based on your consent or as otherwise permitted by law. Personal information is always collected using means that are fair and lawful.
Personal information that is collected may include, but is not limited to, your contact information (such as name, address, email address, billing and shipping information, email address and telephone number) and, where applicable, credit card or other payment information. Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media.
Users may visit our website without telling us who they are, or revealing any information about themselves. However, like many organizations’ websites, our web server automatically logs certain non-identifying information related to a user’s visit to the website, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed our website, the Internet address of the website from which the user linked directly to our site, the operating system that the user is using, and the pages of the website that the user has visited. We make no attempt to link this information with the identity of individuals visiting our website without express permission. We may, however, review server logs and anonymous traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
If you provide comments or other feedback to us, you agree that such comments or other feedback become the property of FBC Communications, and we may use and disclose them for any purpose provided that we do not associate them with your personally identifiable information.
Cookies and Web Beacons
A “cookie” is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. It tells the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system.
Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use the website or application, but your ability to access certain features and functions may be affected.
Some of our web pages contain an invisible electronic image known as a “web beacon.” Web beacons are similar in function to cookies, but allow websites on different domains to share information. We may use web beacons to transfer your subscription access information between our websites and domains. Web beacons do not transmit any personal information that we collect to any websites that are not owned by FBC Communications or its affiliates.
Purpose – Why We Collect, Use and Disclose Information
We will identify the purposes for which we collect personal information before or when we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. These include:
• to enable you to register to access restricted areas of our websites and/or to subscribe to our applications and services, and to communicate with you regarding their use ;
• to establish, maintain and manage business relations with you so that we may provide you with the information, products and/or services that you request;
• to provide you with personalized Content, and to maximize our ability to provide you with information that is useful and relevant to your operation;
• to process, track and complete online transactions, and to deliver items purchased on-line;
• market research;
• to obtain feedback regarding our websites and applications, and any products and services offered through our websites;
• to verify that any information submitted by you is accurate and complete;
• to communicate with you and to create a record of your involvement with us;
• to track your interests and preferences in order to customize and enhance your use of the Services;
• to send you complimentary issues of our printed publications, and to advise you about contests, promotions and other special offers;
• to conduct polls and surveys;
• to provide you with information and promotional materials regarding FBC Communications and its affiliates, and our products and services;
• to provide you with advertisements, solicitations and information regarding third party products and services that may be of interest to you;
• internal business purposes, such as administering or improving our websites and applications;
• to protect us against error, fraud, theft or damage to our goods, our business or our property;
• to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders;
• any other reasonable purpose for which you provide consent.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request or court order, or to protect our assets, the users of our websites or applications, or the public.
Disclosure to Third Parties
FBC Communications may share your information with its affiliates, who may use it only in accordance with this Policy. Your personally identifiable information is never sold, and will not be shared with third parties unless we provide you with both prior notice and choice.
You acknowledge that, in the course of our supply of products and services to you, we may delegate our authority to collect, access, use, and disseminate your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, and delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them. However, you agree not to hold us liable for the actions of any third party subcontractor, even if we would normally be held vicariously liable for their actions, and understand that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
In some cases, your subscription to our products or services may be owned by your employer or another person who has purchased it on your behalf. By registering to use a subscription which has been paid for by another person, you acknowledge and agree that we may share information about the usage of the subscription with the party who paid for it.
Safeguards – How Information is Protected
We have implemented reasonable physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology, maintain our servers and paper files in locked premises, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations, in order to ensure that information is handled and stored in a confidential and secure manner. Any credit card information that you submit will not be stored on our servers, but rather will be sent to a PCI Level 1-compliant payment processor for storage. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by downloading and using the Services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
Accuracy / Access
FBC Communications has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal information. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal information, and if you demonstrate the inaccuracy or incompleteness of personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to the Privacy Officer at the one of the addresses set out above (see: Accountability and Openness / Compliance).
International Transfer and Storage of Information
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada.
Third Party Content and Links to other Websites
Our websites may contain optional links to advertiser and other third party Internet sites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to FBC Communications websites and applications, and we encourage you to review the privacy policies contained on each Internet site and in each application that you use.
Minors may not use the website or any application unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the application or website in conjunction with and under the supervision of an adult. FBC Communications does not knowingly collect personal information from minors.
You agree that your access to and use of the FBC Communications websites and applications, including this Policy, is governed exclusively by the laws of the Province of Manitoba and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).