FIRSTs

Privacy Policy

WinnipegFirst.ca respects an individual's right to privacy and is bound at law by the Personal Information Protection and Electronic Documents Act with respect to the manner in which it collects, uses, stores and discloses personal information.

In order to meet its legal obligations and high professional standards, WinnipegFirst.ca has adopted the Interactive Advertising Bureau (IAB) standards in the development of our privacy policy.

The IAB, in furtherance of its mission to promote Interactive Advertising and Commerce, established guidelines for member organizations that set minimum acceptable standards for protecting the privacy of online users. These standards will serve as guidelines by which IAB member organizations can establish individual privacy policies while ensuring the privacy of users is uniformly protected.

WINNIPEGFIRST.CA PRIVACY POLICY
Most recently amended October 28, 2007.

Scope and Application of the WinnipegFirst.ca Privacy Policy:

Personal Information as used in this Privacy Policy means information about an identifiable Person, but not: a) information that is publicly available, such as a Person's name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about WinnipegFirst.ca customers, or number of visitors and average time spent on a website. The WinnipegFirst.ca Privacy Policy applies to the management of Personal Information in any form whether oral, electronic or written. WinnipegFirst.ca reserves the right to amend this Privacy Policy from time to time. The scope and application of the WinnipegFirst.ca Privacy Policy are as follows:

The WinnipegFirst.ca Privacy Policy applies to Personal Information under the custody or control of WinnipegFirst.ca, and includes both employees and non-employee information that is collected, used or disclosed by WinnipegFirst.ca.
- Employees in this context include past and present employees of WinnipegFirst.ca.
- Non-employee Persons includes Individuals, for example viewers, readers, subscribers, advertisers, contest participants, job applicants, Internet users who are exposed to the media content of WinnipegFirst.ca and about whom WinnipegFirst.ca collects Personal Information. Exclusions from privacy protection: The WinnipegFirst.ca Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by a WinnipegFirst.ca Company: a) information that is publicly available, such as a Person's name, address, telephone number and electronic address, when listed in a telephone directory available to the public or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot identify a specific person, such as demographic statistics about WinnipegFirst.ca customers, or number of visitors and average time spent on a website.

Purposes for Collection of Personal Information:

WinnipegFirst.ca has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with individuals and to provide ongoing service; b) to understand individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including for example, to protect or defend a legal interest. WinnipegFirst.ca may also use Personal Information:

(i) to contact the Person from time to time about changes, enhancements or similar notices related to WinnipegFirst.ca products and services;

(ii) if a Person indicated that he/she was interested in receiving offers or information from WinnipegFirst.ca or certain of our selected sponsors or advertisers, WinnipegFirst.ca may send the Person materials about products and services that WinnipegFirst.ca feels may be of interest to the Person; and

(iii) if a Person enters a contest or other promotion offered on a WinnipegFirst.ca website, WinnipegFirst.ca may, under the rules of the promotion and subject to the Person's consent, use the Person's name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion.

Obtaining Consent:
WinnipegFirst.ca will obtain consent from Persons before or when it collects or uses the Personal Information unless otherwise required or permitted by law. In obtaining such consent, WinnipegFirst.ca will disclose the purposes for which it will collect, use and disclose the persons personal information.

A Person's consent can be express, implied, or given through an authorized representative. A Person can withdraw consent at any time, subject to contractual or legal restrictions. WinnipegFirst.ca, however, may collect, use or disclose Personal Information without the Person's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

Note: If any Person at any time has any questions or concerns about WinnipegFirst.ca's privacy practices, the Person can either:

(i) write to us at NewsFirst Publishing, 624-70 Arthur Street, Winnipeg, Manitoba, R3B 1G7; or

(ii) provide information to WinnipegFirst.ca by sending us an email

Refusing or Withdrawing Consent:

Subject to legal and contractual requirements, a Person can refuse to consent to WinnipegFirst.ca's collection, use or disclosure of his or her Personal Information, or may withdraw his or her consent at any time in the future by giving WinnipegFirst.ca reasonable notice. If a Person refuses or withdraws the Person's consent, WinnipegFirst.ca may not be able to provide the Person or continue to provide the Person with some products, services or information which may be of value to the Person.

Internet Aspects:

Personal Information may be collected when a user conducts activities on or related to all websites of WinnipegFirst.ca. WinnipegFirst.ca provides the details below about Internet aspects of WinnipegFirst.ca services and its operations for the purposes of disclosure to all Persons.

INTERNET PROTOCOL ADDRESS (IP ADDRESS)

When the user's web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address." For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time the user logs on.

WinnipegFirst.ca may use the user's IP Address to:

  • facilitate the diagnosis and remedy of a technical problem reported by the users or WinnipegFirst.ca technical team.

  • display (or allow the display by Third Party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user's geographic area.

  • estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.

COOKIES

A cookie is a small text file, which often includes an anonymous unique identifier that is sent to the user's web browser from a website's computers and is stored on the user's computer hard drive. Cookies cannot be used to run programs or deliver viruses to a user's computer. WinnipegFirst.ca may use cookies to:

  • improve the operation and performance of WinnipegFirst.ca and to make WinnipegFirst.ca easier and more convenient to use. For example, cookies help WinnipegFirst.ca provide more personalized services by recalling user preferences on subsequent visits (e.g. language preference). Cookies also allow WinnipegFirst.ca to save passwords and preferences for a user so that the user will not have to re-enter them on the next visit to a WinnipegFirst.ca Site;

  • measure aggregate user traffic and demographic statistics related to WinnipegFirst.ca and advertisements (e.g. number of users, average time spent, average age and similar statistics). This information helps WinnipegFirst.ca to better understand when to update, change or offer new services and provides WinnipegFirst.ca with details as to the performance of Third Party advertisements and content. This information may be reported, in aggregate form only, to WinnipegFirst.ca's current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports;

  • display advertisements. WinnipegFirst.ca and Third Party advertising providers may use cookies when serving advertisements on WinnipegFirst.ca Sites. In some cases, advertisements from Third Party advertisers are delivered to users (in conjunction with WinnipegFirst.ca) by such Third Party advertisers, or by separately contracted advertising providers on their behalf, and not by WinnipegFirst.ca; as such, the Third-party advertisers' use of cookies is subject to their own privacy policies, not the WinnipegFirst.ca Privacy Policy, and users should consult the privacy policies of such Third Party advertisers.

Most browsers are initially set up to accept cookies. If a user prefers, the user can reset his/her browser either to notify the user when the user has received a cookie, or to refuse to accept cookies. The user should understand that while WinnipegFirst.ca do not require a user to use cookies, certain WinnipegFirst.ca will not function properly if a user sets his/her browser to not accept cookies.

WEB BEACONS

Certain WinnipegFirst.ca services may contain electronic images known as Web beacons - sometimes called single-pixel gifs - that allow WinnipegFirst.ca to count users who have visited those pages and to deliver co-branded services. Web beacons are not used to access Personal Information; they are a technique used to compile aggregated statistics about WinnipegFirst.ca service usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. Certain WinnipegFirst.ca services web pages may also contain web beacons placed there by WinnipegFirst.ca advertising partners to help WinnipegFirst.ca determine the effectiveness of WinnipegFirst.ca's Internet advertising campaigns.

LINKS TO OTHER SITES AND ADVERTISEMENTS

A WinnipegFirst.ca service may contain links to other websites and services. While WinnipegFirst.ca tries to link only to sites and services that share WinnipegFirst.ca's high standards and respect for privacy, a user should understand that WinnipegFirst.ca is not responsible for the content of or the privacy practices employed by other companies or websites. This WinnipegFirst.ca Privacy Policy applies only to the WinnipegFirst.ca services related to this WinnipegFirst.ca Privacy Policy.

The majority of the advertisements which are displayed in connection with WinnipegFirst.ca services are served through one or more reputable Third Party advertisement-serving companies which deliver the advertisements to users in conjunction with WinnipegFirst.ca services.

ADDITIONAL INFORMATION

WinnipegFirst.ca automatically collects certain information about the user's computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring website addresses. This information is used by WinnipegFirst.ca to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the WinnipegFirst.ca Companies Sites. Certain WinnipegFirst.ca services may be co-branded and offered in conjunction with another company. If a user registers for or uses such services, both WinnipegFirst.ca Companies and the other company may receive information collected in conjunction with the co-branded services.

THE WINNIPEGFIRST.CA PRIVACY POLICY IN DETAIL Definitions

Collection - the act of gathering, acquiring, recording or obtaining Personal Information from any source, including third parties, by any means.

Consent - voluntary agreement with the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the Person or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of WinnipegFirst.ca. Implied consent is consent that can reasonably be inferred from a Person's action or inaction.

Disclosure - making Personal Information available to a Third Party.

Employee - an employee or independent contractor (including freelancers) of WinnipegFirst.ca.

Individual - any individual concerning whom WinnipegFirst.ca has personal information under it's custody or control.

Person - an Employee or an Individual. Personal Information - information about an identifiable Person, but not: a) information that is publicly available, such as a Person's name, address, telephone number and electronic address, when listed in a public directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about WinnipegFirst.ca customers, or number of visitors and average time spent on a website.

Third Party - a person other than the Person or his agent.

Principle 1 - Accountability

WinnipegFirst.ca is responsible for Personal Information under its custody and control and shall designate a Privacy Officer who is accountable for WinnipegFirst.ca's compliance with the following principles:

1.1 The Privacy Officer is responsible for ensuring the ongoing compliance of WinnipegFirst.ca's compliance with the provisions of the WinnipegFirst.ca Privacy Policy. Other people within WinnipegFirst.ca may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and processing of Personal Information.

1.2 WinnipegFirst.ca is responsible for Personal Information in its custody or under its control, including information that has been transferred to a Third Party for processing. WinnipegFirst.ca shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7).

1.3 WinnipegFirst.ca has implemented policies and procedures to give effect to the WinnipegFirst.ca Privacy Policy, including: a) implementing procedures to protect Personal Information and to oversee WinnipegFirst.ca's compliance with the WinnipegFirst.ca Privacy Policy; b) establishing procedures to receive and respond to enquiries or complaints; c) training and communicating to staff about WinnipegFirst.ca's policies and practices; and d) developing public information to explain WinnipegFirst.ca's policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information

WinnipegFirst.ca has collected and collects Personal Information for the purposes set out below, and shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

2.1 WinnipegFirst.ca has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest. As examples of the above:

(i) WinnipegFirst.ca may from time to time use a Person's Personal Information to contact the Person about changes, enhancements or similar notices related to WinnipegFirst.ca products and services;

(ii) if a Person indicated that he/she was interested in receiving offers or information from WinnipegFirst.ca or certain of our selected sponsors or advertisers, WinnipegFirst.ca may send the Person materials about products and services that WinnipegFirst.ca feels may be of interest to the Person; and

(iii) if a Person enters a contest or other promotion offered on a WinnipegFirst.ca website, WinnipegFirst.ca may, under the rules of the promotion and with consent, use the Person's name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion. Further references to "identified purposes" mean the purposes identified in this Principle 2.

2.2 WinnipegFirst.ca shall specify orally, electronically or in writing the identified purposes to the Person at or before the time Personal Information is collected. Upon request, persons collecting Personal Information on behalf of WinnipegFirst.ca shall explain these identified purposes or refer the Person to a designated person within WinnipegFirst.ca who shall explain the purposes.

2.3 Unless required by law, WinnipegFirst.ca shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Person. Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information The knowledge and consent of a Person are required for the collection, use or disclosure of Personal Information, except where inappropriate.

3.1 Generally, WinnipegFirst.ca shall seek consent to use and disclose Personal Information at the same time it collects the information. However, WinnipegFirst.ca may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.

3.2 In obtaining consent, WinnipegFirst.ca shall use reasonable efforts to ensure that a Person is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Person.

3.3 WinnipegFirst.ca will require Individuals to consent to the collection, use or disclosure of Personal Information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

3.4 In determining the appropriate form of consent, WinnipegFirst.ca shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Persons.

3.5 In general, the use of products and services by an Individual, or the acceptance of employment or benefits by an Employee, constitutes implied consent for WinnipegFirst.ca to collect, use and disclose Personal Information for all identified purposes.

3.6 An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact WinnipegFirst.ca for more information regarding the implications of withdrawing consent.

3.7 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. For example, WinnipegFirst.ca may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual or property is threatened.

WinnipegFirst.ca may also collect, use or disclose Personal Information without knowledge or consent if seeking the consent of the Person might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

WinnipegFirst.ca may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein.

Principle 4 - Limiting Collection of Personal Information

WinnipegFirst.ca shall limit the collection of Personal Information to that which is necessary for the purposes identified by WinnipegFirst.ca. WinnipegFirst.ca shall collect Personal Information by fair and lawful means.

4.1 WinnipegFirst.ca collects Personal Information directly from Individuals or its Employees, where reasonably possible. WinnipegFirst.ca may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.

Principle 5 - Limiting Use, Disclosure and Retention of Personal Information

WinnipegFirst.ca shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Person or as required or permitted by law. WinnipegFirst.ca shall retain Personal Information only as long as necessary for the fulfilment of the purposes for which it was collected, and to fulfil WinnipegFirst.ca's legal and professional obligations.

5.1 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. (See Principle 3.7)

5.2 With respect to its employees, WinnipegFirst.ca may disclose Personal Information: (a) for normal personnel and benefits administration; or (b) where disclosure is required or permitted by law.

5.3 Only those Employees of WinnipegFirst.ca who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of WinnipegFirst.ca, are granted access to Personal Information about Individuals and Employees.

5.4 WinnipegFirst.ca shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes, to meet its legal and professional obligations and as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a Person, WinnipegFirst.ca shall retain, for a period of time that is reasonably sufficient to allow for access by the Person.

5.5 WinnipegFirst.ca shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information

Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1 Personal Information used by WinnipegFirst.ca shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a Person.

6.2 WinnipegFirst.ca shall update Personal Information about Persons as and when necessary to fulfill the identified purposes or upon notification by the Person.

Principle 7 - Security Safeguards

WinnipegFirst.ca shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.

7.1 WinnipegFirst.ca shall take reasonable steps to protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, including secure socket layers for transmission of sensitive information. WinnipegFirst.ca shall protect the information regardless of the format in which it is held.

7.2 WinnipegFirst.ca shall protect Personal Information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and security safeguard as well as the purposes for which it is to be used.

7.3 All employees of WinnipegFirst.ca with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.

Principle 8 - Openness Concerning Policies and Practices

WinnipegFirst.ca shall make readily available to Persons specific information about its policies and practices relating to the management of Personal Information.

8.1 WinnipegFirst.ca shall make information about its policies and practices easy to understand, including:

(a) The title and address of the Privacy Officer to whom inquiries or complaints can be forwarded;

(b) The means of gaining access to Personal Information held by WinnipegFirst.ca; and

(c) A description of the type of Personal Information held by WinnipegFirst.ca, including a general account of its use.

8.2 WinnipegFirst.ca shall make available information to help Persons exercise choices regarding the use of their Personal Information.

Principle 9 - Access to Personal Information

WinnipegFirst.ca shall inform a Person of the existence, use and disclosure of his or her Personal Information upon request and shall give the Person access to that information.

A Person shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

9.1 Upon request, WinnipegFirst.ca shall afford to a Person a reasonable opportunity to review the Personal Information in the Person's file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Person.

9.2 In certain situations, WinnipegFirst.ca may not be able to provide access to all of the Personal Information that they hold about a Person. For example, WinnipegFirst.ca may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, WinnipegFirst.ca may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or if the information was collected as part of journalistic, literary or artistic activities. If access to Personal Information cannot be provided, WinnipegFirst.ca shall provide the reasons for denying access upon request.

9.3 Upon request, WinnipegFirst.ca shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, WinnipegFirst.ca shall provide a list of organizations to which it may have disclosed Personal Information about the individual when it is not possible to provide an actual list.

9.4 In order to safeguard Personal Information, an individual or employee may be required to provide sufficient identification information to permit WinnipegFirst.ca to account for the existence, use and disclosure of Personal Information and to authorize access to the individual's file. Any such information shall be used only for this purpose.

9.5 WinnipegFirst.ca shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Person's file. Where appropriate, WinnipegFirst.ca shall transmit to third parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.

9.6 A Person can obtain information or seek access to his or her Personal Information by contacting a designated representative at the WinnipegFirst.ca office.

9.7 An employee can obtain information or seek access to his or her Personal Information by contacting the President of WinnipegFirst.ca.

Principle 10 - Challenging Compliance

A Person shall be able to address a challenge concerning compliance with the above principles to the WinnipegFirst.ca Privacy Officer

10.1 WinnipegFirst.ca shall maintain procedures for addressing and responding to all inquiries or complaints from Persons about WinnipegFirst.ca's handling of their Personal Information. If any Person at any time has any questions or concerns about WinnipegFirst.ca's privacy practices, the Person can either:

(i) write to NewsFirst Publishing, 624-70 Arthur Street, Winnipeg, Manitoba, R3B 1G7; or

(ii) provide information to WinnipegFirst.ca through the form here.

10.2 WinnipegFirst.ca shall inform Persons about the existence of these procedures as well as the availability of complaint procedures.

10.3 The person or persons accountable for compliance with the WinnipegFirst.ca Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 WinnipegFirst.ca shall investigate all complaints concerning compliance with the WinnipegFirst.ca Privacy Policy. If a complaint is found to be justified, WinnipegFirst.ca shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A Person shall be informed of the outcome of the investigation regarding his or her complaint.

(C) 2007 WinnipegFirst.ca. All Rights Reserved.