2uz Inc. (“2uz”) and its affiliates and subsidiaries (collectively, the “2uz Companies”) are committed to controlling the collection, use and disclosure of personal information provided by the customers and employees of each 2uz Company and have adopted this Privacy Policy to ensure the accuracy, confidentiality and integrity of such personal information.

Application
This Privacy Policy applies to personal information that a 2uz Company collects, uses or discloses in respect of its customers or employees in the course of its commercial activities.

Definitions
The following defined terms are used throughout this Privacy Policy:

2uz – means 2uz Inc.

2uz Companies – means, collectively, 2uz Inc. and all of its subsidiaries with respect to their operations in Canada, and a 2uz Company means any one of them.

customer – means an individual who:
(a) subscribes for, uses, or applies to use, the products or services of a 2uz Company;

(b) corresponds with a 2uz Company;

(c) uses a website owned by a 2uz Company; or

(d) enters a contest sponsored by a 2uz Company.

employee – means an employee, former employee or pensioner of a 2uz Company and, for the purposes of this Privacy Policy, includes the directors, shareholders and security holders of 2uz.

personal information – means information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization. Publicly available information, such as a public directory listing of names, addresses, telephone numbers and electronic addresses, is not considered personal information.

privacy legislation – means Canada’s federal private sector privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and substantially similar provincial privacy legislation including Alberta’s Personal Information Protection Act, British Columbia’s Personal Information Protection Act, and Quebec’s An Act respecting the protection of personal information in the private sector.

The Ten Privacy Principles
This Privacy Policy has been developed in accordance with the standards set out in PIPEDA and is modelled after the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96. Accordingly, the ten principles of fair information practices (the “Principles”), as identified by the Canadian Standards Association, have been adopted by the 2uz Companies and represent a formal statement of the minimum requirements to be adhered to by each of the 2uz Companies for the protection of personal information collected from the customers and employees of the 2uz Companies.

Principle 1 – Accountability
Each 2uz Company is responsible for the personal information under its control and shall designate one or more individuals who shall be accountable for the company’s compliance with the procedures and principles set out in this Privacy Policy.

1.1 Accountability for compliance by each 2uz Company with this Privacy Policy and the Principles rests with 2uz’s Privacy Officer. Please see Principle 10, below, to obtain the contact information for our Privacy Officer.

1.2 Each 2uz Company shall be responsible for the personal information in its possession or custody, including information that has been transferred to a third party for processing. Each 2uz Company shall use contractual or other appropriate means to ensure a comparable level of protection while the information is being processed by a third party.

1.3 The 2uz Companies have implemented policies and practices to give effect to the principles and procedures set out in this Privacy Policy, including:

(a) implementing procedures to protect personal information such as the adoption of physical, organizational and technological security measures;

(b) establishing procedures to receive and respond to complaints and inquiries through the establishment of a confidential e-mail address; and

(c) training and communicating to staff information about the 2uz policies and practices.

Principle 2 – Identifying Purposes
Each 2uz Company will identify the purpose for which personal information is collected at or before the time the information is collected. The purposes for which personal information is collected, used or disclosed by a 2uz Company must be those that a reasonable person would consider are appropriate in the circumstances.

2.1 The 2uz Companies collect and use your personal information primarily for the purpose of providing you with the products and services you have requested from us, including the daily delivery of news and related content through 2uz television and online properties.

2.2 Your personal information is used to communicate with you about your account and to provide you with information related to other 2uz publications and services. If you indicated that you were interested in receiving offers or information from selected 2uz sponsors or advertisers, your personal information would also be used to contact you or to send you e-mail materials and other mailings about products and services that might be of interest to you. You always have the option, however, to tell us not to share your personal information with other 2uz Companies or to exclude you from offers for other products or services.

2.3 Each 2uz Company will document the purposes for which personal information is collected in order to comply with the Openness principle (See Principle 8) and the Individual Access principle (See Principle 9).

2.4 The purposes for which personal information is collected shall be specified at or before the time of collection to the customer or employee from whom the personal information is collected. Depending upon the manner in which the information is collected, this shall be done orally or in writing.

2.5 When a 2uz Company proposes to use personal information that has been collected for a purpose not previously identified, it will identify the new purpose before using such personal information. Unless the new purpose is required by law, or consent is otherwise not required pursuant to privacy legislation, the consent of the individual shall be obtained before the personal information is used for the new purpose.

2.6 Individuals responsible for collecting personal information on behalf of a 2uz Company will explain to customers and/or employees the purposes for which the information is being collected, including any purposes that may not be immediately obvious to the individual.

2.7 The purposes for which the personal information of employees is collected may include, but is not limited to:

(a) administering payroll and employee benefit programs;
(b) conducting performance evaluations and discipline;
(c) effecting employee training;
(d) conducting internal reviews, investigations and complaint resolution processes;
(e) participating in union negotiations and labour arbitrations;
(f) facilitating transactional due diligence reviews; and
(g) complying with legal and regulatory obligations.

2.8 The purposes for which the personal information of customers is collected may include, but is not limited to:

(a) processing commercial transactions;
(b) communicating with customers;
(c) establishing and maintaining commercial relations;
(d) developing, marketing or providing products and services;
(e) recommending particular products and services;
(f) conducting market research and surveys;
(g) managing and developing business opportunities;
(h) conducting investigations and complaint resolution processes;
(i) administering contests or other promotions;
(j) facilitating transactional due diligence reviews; and
(k) complying with legal and regulatory obligations.

2.9 Anonymous or “non-personal” information gathered by a 2uz Company through its web site may be used for technical, research and analytical purposes. Information collected through surveys, existing files and public archives may be used by a 2uz Company to analyze its markets and to develop or enhance service offerings.

Principle 3 – Consent
Except where required or permitted by law, the knowledge and consent of the individual are required for the collection, use or disclosure of personal information.

3.1 Consent is required for the collection of personal information and the subsequent use or disclosure of this information. Generally, each 2uz Company will seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to the use or disclosure of personal information may be sought after the information has been collected but before the personal information is used (for example, when a 2uz Company wants to use information for a purpose not previously identified). In obtaining consent, the 2uz Companies shall use reasonable efforts to ensure that a customer or employee 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 customer or employee.

3.2 In certain circumstances personal information may be collected, used or disclosed without the knowledge and consent of the individual. For example, a 2uz Company may collect or use personal information without the knowledge or consent of its employees and/or customers if the collection or use of personal information is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated or if seeking the consent of the individual 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. Personal information may also be used or disclosed without the knowledge or consent of the individual in the case of an emergency where the life, health or security of an individual is threatened. A 2uz Company may disclose personal information without knowledge or consent to a lawyer representing the company, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.

3.3 The 2uz Companies will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.

3.4 In obtaining consent, the 2uz Companies will take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees. Consent will not be obtained through deception. For example:

(a) A customer who enters a contest online would reasonably expect that his or her relevant contact information (name, phone number, personal identification) would be collected and used to identify the customer if and when he or she was selected as a contest winner. However, the customer would not reasonably expect that this information would be used for a purpose other than the administration of the contest, without the customer’s knowledge and consent.
(b) An individual filing an application for employment with a 2uz Company would reasonably expect that his or her age and marital status would be used for the purposes of administering benefit plans.
(c) An employee filing an application for 2uz’s dental coverage plan would reasonably expect that the relevant information (employee identification number, name, date of birth) would be collected, used and communicated to third parties in accordance with the dental coverage and for such period of time as the coverage was in effect.

3.5 The way in which a 2uz Company seeks consent may vary, depending on the circumstances and the type of information collected. A 2uz Company will generally seek express consent when the information is likely to be considered sensitive. It will rely on implied consent where collection and use of the personal information is directly related to a transaction or exchange of information in which the individual is directly participating. Consent may also be given by an authorized representative (such as a legal guardian or a person having power of attorney).

3.6 Consent may be obtained in any one of the following ways:

(a) an application form may be used to seek consent, collect personal information and inform the individual of the use that will be made of the personal information. By completing and signing the form, the individual is giving consent to the collection and the specified uses;
(b) a check-off box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of their information to third parties;
(c) consent may be given orally when information is collected over the telephone; or
(d) consent may be given at the time that individuals use a product or service.

3.7 Generally, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for the 2uz Companies to collect, use and disclose personal information for all identified purposes.

3.8 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The 2uz Companies will inform individuals of the implications of withdrawing consent. Customers and employees may contact the relevant 2uz Company for more information regarding the implications of withdrawing consent.

Principle 4 – Limiting Collection
The 2uz Companies shall limit the collection of personal information to that which is necessary for the purposes identified by the company. Personal information shall be collected by fair and lawful means.

4.1 The 2uz Companies will not collect personal information indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified. Each 2uz Company shall specify the type of information collected as part of its information-handling policies and practices, in accordance with the Openness principle (Principle 8).

4.2 The requirement that personal information be collected by fair and lawful means is intended to prevent a 2uz Company from collecting information by misleading or deceiving individuals about the purpose for which information is being collected. Consent to the collection of personal information must not be obtained through deception.

4.3 The 2uz Companies use a browser feature called a “cookie” to collect information anonymously and track user patterns on 2uz websites. A cookie is a small text file that is placed on your hard disk by a website. “Cookies” contain a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our websites. Cookies tell us which pages of our websites are visited and by how many people. The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on our websites.