Cogeco Connexion Inc. (“Cogeco”) regroups the Canadian operations of Cogeco Communications Inc. and provides to its consumers and business customers in Québec and Ontario video, Internet and telephony services through its two-way broadband fibre networks.
Application and Scope
Cogeco also abides by the principles set out in the Corporate Privacy Commitment, listing the essential principles constituting the Cogeco Group’s commitment to privacy.
Definition of Personal information
Collection and Use of Personal Information
We collect most of our information about you directly from you, with your consent. We usually collect your name, address, phone number(s) and email address, as well as other account and payment information, including information pertaining to your use of our products and services when you register to Cogeco services. We may also obtain personal information about you from third parties, with your consent. For example, for credit evaluation purposes, we may need to determine your creditworthiness through contact with an independent credit reporting agency.
Cogeco generally collects personal information from or about its customers and other individuals with whom it deals, and thereafter uses it, for the following purposes:
- to establish, develop and preserve its business relationship respectively with its customers and other individuals with whom it deals;
- to create, establish and administer customers’ accounts and to respond to customer or supplier inquiries;
- to provide the products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
- to authenticate the identity and preserve the privacy of customers contacting Cogeco by telephone, electronic means or otherwise;
- for internal training and quality assurance purposes;
- as necessary, to establish or verify the credit of persons that use, or intend to use, one or more of the products or services offered by Cogeco;
- to manage its businesses and ensure the efficiency, reliability and security of its systems and networks;
- to meet legal and regulatory requirements and allow Cogeco to meet contractual requirements relating to the products and services provided to customers;
- to ensure its records are accurate and to protect customers and Cogeco from error and fraud;
- to understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones;
- to provide personalized products and services as well as product recommendations to customers. For instance, and to the extent permitted by law, Cogeco may use subscribers’ product and service usage information, their postal codes or publicly available information (such as demographic information) to provide recommendations, advertising and to suggest products and services; and
If you have applied for employment with Cogeco, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Cogeco as well as other career development resources.
Cogeco obtains consent from the individuals concerned for the collection, use or disclosure of personal information through various means: orally or through written documents, including agreements, forms, welcome kits as well as printed or electronic communications. The form of consent sought by Cogeco will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law.
In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
- when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
- to collect a debt; and
- to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.
Right to Withdraw Consent
Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, Cogeco may limit the services or products it is able to provide customers. You may also withdraw your consent as follows:
- Mail marketing, Telephone marketing and Quality control communications. You may decide that you prefer Cogeco not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below.
- Commercial Electronic Communications. You can always limit the communications that Cogeco sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account. If you have any questions about your choices or if you need any assistance with opting-out, please refer to our Anti-Spam Commitment.
Sharing of Personal Information
- Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Cogeco to perform work on its behalf, including for the collection of customer accounts, customer credit verification, installation of services and quality control assessment. We may also share your information with other communication service providers, companies involved in supplying customers with communications or directory-related services or to other communications companies for the efficient and effective provision of communications services. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. Cogeco will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Cogeco itself.
- As permitted or required by law. From time to time, Cogeco may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. In these circumstances, Cogeco will protect the interests of its customers by making reasonable efforts to ensure that orders or demands comply with the laws under which they were issued, that it discloses only the personal information that is legally required and nothing more, and that it does not comply with casual requests for personal information from government or law enforcement authorities. We do not automatically notify subscribers upon such legally binding disclosures, although we will answer subscribers’ inquiries on this issue unless prohibited by law or by a court order. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
- Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
- Other types of sharing. We may provide your information to lenders, credit bureaus, credit grantors and reporting agencies, subject to applicable law. We may also disclose, on an aggregated basis, to regulators, marketing partners, providers, statistics such as, for example, the number of our subscribers residing in a given area or postal code which were exposed to certain TV content, advertising, suggestions or promotions. We may also disclose our customers’ personal information to an individual who, in the reasonable judgement of Cogeco, is acting on behalf of the individual in question, such as through a power of attorney.
Only those employees of Cogeco or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about customers.
We do not knowingly collect personal information from children. To purchase our products and services, you must obtain the consent of your parent or legal guardian if you are under the age of majority and such consent is a requirement in the jurisdiction of your residence. If we learn we have collected or received personal information from a child without parental confirmation, we will delete that information. If you believe we might have any information from or about a child, please contact us using the contact information detailed in the How to Contact Us section below.
Cogeco generally collects and uses personal information from or about its website visitors and users as follows:
- Information you provide. In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following types of information:
- Inquiries. We may collect your name, contact information, e-mail address and any information you provide us when you make an inquiry or contact us through our website. We will only use this information to provide you with the information requested or to contact you in order to answer your questions and/or requests.
- Requests for a Product and/or Service. We may collect your name, contact information, e-mail address and any other information provided to us when you sign up to receive our newsletter or when you participate in a contest or promotion run by Cogeco or when you submit a request or an order for a Cogeco product and/or service. We will only use this information to process and answer your request or to manage our everyday business needs in connection with such participation or request.
- My Account. We may collect your information when you log-in on our website through My Account and interact with us through your account. For instance, you may decide to subscribe to pre-authorized payments and modify your account information or other preference settings. We will only use the information that you provide us in accordance with this Policy.
- Satisfaction Survey. When you visit our website, you may, from time to time, be invited to participate to a satisfaction survey. In such case and if you decide to participate to our survey, we may collect your postal code, email address and other information deemed important to complete such survey. We will only use your information for quality assurance purposes.
- Technical information. When you visit our website, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the products advertised on our website are available in your area or that we are not showing you the same ads repeatedly. We treat this information as personal information when it is associated with your account or contact information. For instance, we may collect and use the following type of information when you visit and/or interact with us on our websites:
- Google Analytics: We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
- Google AdWords: We use Google AdWords Remarketing to advertise Cogeco across the Internet and to advertise on third party websites (including Google) to previous visitors to our websites. AdWords remarketing will display ads to you based on what parts of the Cogeco website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
- Mobile Apps. In the event that you download and/or use any of our applications, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access when the user is outside of Canada.
Personal Information Outside of Canada
While Cogeco is using reasonable measures, when possible, to favor Canadian communication routing as well as Canadian providers, your personal information may in some situations be routed through foreign jurisdictions, such as the United States. In some cases, personal information that we manage may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there. Cogeco will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Cogeco itself.
Security of Personal Information
We will use reasonable security measures to protect your personal information against unauthorized access. Cogeco has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. For example, we use industry-standard encryption technology to secure sensitive personal information when it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software.
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. For example, we usually retain customer information as long as we need to provide services to a subscriber, and for a period of 3 years after the business relationship ends, unless otherwise compelled by the law to retain such information, or in the case of a litigation, or potential litigation]. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. Cogeco has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access.
Access and Correction
Cogeco respects your right to access and correct your personal information. If you have an online account with us, you can log into My Account at any time to access and update the information you have provided to us. Additionally, Cogeco complies with all laws regarding access and correction. If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.
How to Contact Us
Caroline Dignard, Chief Privacy Officer
COGECO CONNEXION Inc.
5 Place Ville-Marie, Suite 1700
Montréal, Québec H3B 0B3
By phone: 514-764-4700
By e-mail: email@example.com
On the same or similar subject, you may want to review our other policies:
- Corporate Privacy Commitment
- Anti-Spam Commitment