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Roustan Media Ltd.’s (“Roustan Media”) Privacy Policy has developed as an extension of our commitment to combine the highest-quality products and services with the highest level of integrity in dealing with our clients. The Policy is designed to assist you in understanding how we collect, use, and safeguard the personal information you provide to us and to assist you in making informed decisions when using our products and services and receiving news and related content through our online properties. It reflects our commitment to protecting the privacy and confidentiality of the personal information entrusted to us by our clients. This Policy will be continuously assessed against new technologies, business practices, client needs, and any applicable laws.

COLLECTION OF PERSONAL INFORMATION

Roustan Media has organized its business into three strategic platforms: Content, Print, and Media. Each of our platforms collects personal information from clients where such information is required for the provisions of a particular product or service, and/or where consent has been obtained from the user to collect personal information for one or more specific purposes. For all users under the age of 16, parental consent will be required.

Content and Print: Our Content and Print platforms collect personal information that may include a user’s name, address (postal and/or e-mail), and telephone number, as well as banking, financial, credit card and/or credit information.

As an agent involved in data processing, variable imaging, and direct mailing, we may also obtain personal information from third parties such as our clients, list owners, and other media owners. Typically, the personal information is provided to us with specific instructions on how it is to be used. We will make every reasonable effort to ensure that any such personal information is used for the purposes stipulated, that it is stored accurately and securely, and that it is subject to strict terms of confidentiality.

Media: Our Media platform may collect personal information through surveys, questionnaires, and other means. In addition to name, address (postal and/or e-mail), telephone number, and transaction information, we may collect demographic information (i.e. age, gender, income, occupation, and education) and opinions of subscribers, or potential subscribers, to our magazines and other print properties. Personal information will only be collected through our Media platform where users consent to the data being used for one or more specific purposes and/or where it is required for the provision of a particular product or service. For more details, please visit our Magazine websites.

Modes of Collection: Roustan Media collects personal information about clients through various applications and order forms, including credit applications, surveys, and questionnaires, face-to-face interactions, and our online properties. For certain transactions, we may obtain personal information about a client from third parties, such as consumer reporting agencies.

USE OF PERSONAL INFORMATION

Roustan Media uses the personal information we collect to provide clients with our products and services, manage our business, and comply with regulatory and industry requirements. More specifically, we use personal information to create and maintain client accounts, communicate with our clients, supply clients with our products and services, and provide them with information about new products and services that we believe would be of value to them. Roustan Media will get a user’s express consent before engaging in any profiling or direct marketing. Where appropriate, we may also use information about client interests and preferences, as well as feedback we receive from surveys to improve our products and customer services. Roustan Media will make every reasonable effort to ensure that data is processed transparently and lawfully, stored accurately and with the appropriate level of security, and is kept in a simple and accessible form.

DISCLOSURE OF PERSONAL INFORMATION

Content, Print and Media: Depending on the nature of the products and services our clients require, our Content, Print, or Media platforms may disclose personal information to other business platforms or divisions of Roustan Media, financial institutions, credit reporting agencies, and third-party service providers, such as data processing and marketing companies.

Media: In addition to the disclosures outlined in the preceding paragraph, our Media platform may disclose personal information to advertisers, third-party service providers including providers of marketing and promotional services, and other organizations that offer products or services that we believe would be of value to our clients.

Other: We will request your express consent to use and disclose your personal information for specific types of transactions on the application or other forms used in connection with those transactions. Roustan Media will make every reasonable effort to obtain your express consent before processing data, but may, in limited circumstances, imply your consent to use and disclose your personal information in accordance with this Policy where it would be reasonable to do so (i.e. in connection with a mailing renewal subscription). Roustan Media will obtain your express consent before using or disclosing your personal information for any purpose not identified in this Policy.

Roustan Media discloses personal information where required to do so by law and may disclose personal information to our purchaser or new corporate entity in the event of a sale, merger, or substantial restructuring of our business.

USE OF COOKIES

Similar to other commercial websites, our website utilizes a standard technology called “cookies” and web server logs to collect information about how our websites are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our websites, and the websites visited immediately before and after visiting our websites. Information from cookies or web server logs is collected on an aggregate basis. None of this information is associated with the user as an individual and is not processed, stored, or used in a manner that allows Roustan Media or any third-party to build an individualized or identifiable profile about any user.

If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses to your email(s). Roustan Media will provide the same protections for these electronic communications that we employ in the maintenance of non-electronic information, such as that received by mail and telephone.

LIMITING THE USE AND DISCLOSURE OF PERSONAL INFORMATION

Subject to contractual and other legal obligations, users are entitled to withdraw their consent to the use and disclosure of their personal information at anytime. Users have the right to limit or vary some or all of the processing of their personal information. Users can also object to any direct marketing and profiling related to direct marketing. If you would like to limit Roustan Media’s disclosure, use, or processing of your data completely or in part, then please contact our Privacy Officer. Withdrawing your consent to process personal information or limiting the processing of this information may preclude Roustan Media from offering certain products or services, if the processing of the restricted personal information is integral to the provision of those products or services.

ACCURACY OF PERSONAL INFORMATION

Roustan Media will make every reasonable effort to ensure that users’ personal information is accurate, complete, up-to-date, relevant and limited to the purpose for which it was given. We may update the personal information of users in our records from time-to-time, for instance, where current information is required for the provision of a product or service. Please inform us of any change of name, address, or other information. If you have any questions about the accuracy of the personal information Roustan Media has collected about you, please contact our Privacy Officer. If we have disclosed inaccurate information about you to a third-party, we will, without undue delay, make every reasonable effort to contact the third-party in order to rectify the inaccurate information.

ACCESS AND ERASURE OF PERSONAL INFORMATION

If you have any questions pertaining to the collection, storage, use, or disclosure of your personal information, or if you simply want to know whether we have collected and/or stored any of your personal information, then you may contact our Privacy Officer. Roustan Media will respond to your request for access in accordance with the applicable privacy legislation. In the event that we refuse access to you, we will provide you with the reasons for our refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

Roustan Media will respond to user requests to be forgotten or to have their personal information erased without undue delay and in accordance with the applicable privacy legislation. We will provide the user with notification when this request is complete, and where such requests are refused, Roustan Media will provide the reasons for refusal upon request.

QUESTIONS OR CONCERNS

To access your personal information, inform us of changes you believe need to be made to that information, request that we investigate a concern you have about our personal information practices, or obtain further information about this Policy and the practices outlined herein, please use the below information to contact us.

CONTACT

Roustan Media Ltd.
260 Adelaide Street East, Suite 47
Toronto, Ontario M5A 1N1
E-mail: [email protected]

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