Privacy Policy

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Privacy Policy

Privacy Policy

Introduction

Cogeco Peer 1 (“Cogeco Peer1”) provides to its business customers a suite of information technology services (data transport, colocation, cloud and managed services, and dedicated hosting), with data centres as well as points-of-presence in North America and Europe.

At Cogeco Peer1, we understand the importance of protecting your privacy. For this reason, we have business procedures and security safeguards in place to protect your personal information and any data you process using our services; we put privacy at the heart of how we operate.

Cogeco Peer1 is committed to providing transparency to its customers with respect to its practices in handling their personal information and data. This Privacy Policy sets out the standards, responsibilities and obligations of Cogeco Peer1 in respect of any personal information provided to Cogeco Peer1. It is intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirements of rules established by applicable privacy laws and standards in the jurisdictions in which we operate.

Application and Scope

This Privacy Policy applies to any personal information (as defined below in the section entitled “Definition of Personal Information”) collected or generated by Cogeco Peer1. Individuals, about whom personal information is collected by Cogeco Peer1, are protected by the rights and safeguards contained in this Privacy Policy.

To ensure our commitment to transparency is met, we will provide further information in prominent notices and policies where relevant explaining how Personal Information is collected and used so that you can make an informed choice whether to provide your personal information to Cogeco Peer1 or do business with us. For example, Cogeco Peer1 has adopted a Website Privacy and Cookie Policy which provides additional and more specific information on Cogeco Peer 1 personal information management practices which pertain to its website.

Cogeco Peer1 also abides by the principles set out in the Corporate Privacy Commitment, listing the essential principles constituting the Cogeco Group’s commitment to privacy.

As Cogeco Peer1 provides products and services to commercial customers, it only receives and processes limited amounts of personal information. The personal information that our customers process using our services is not within the scope of this Privacy Policy (this information would be subject to these customers’ privacy policies), although we are committed to protecting this information through the security systems and controls we have put in place.

Definition of Personal Information

For the purposes of this policy, when we refer to personal information, we usually mean any information about an identifiable individual. Depending on the jurisdiction in which we operate, this may include, for example, email addresses you have provided, contact details you have given in connection with an account with us, or such other information you have given us to receive information about or use our services. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be your personal information.

Collection and Use of Personal Information

We collect most of our information about you directly from you, with your consent for the purposes outlined below. 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 Peer1 will not collect or use personal information for any other or new purpose without obtaining consent, unless required or authorized by law.

Cogeco Peer1 generally collects personal information for the following purposes:

Contact information: We collect personal information to establish, develop and preserve our business relationships with customers and other individuals with whom we deal with. We will 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 for our services in order to create, establish and administer your account, to provide services, and to respond to inquiries. We will also use personal information to establish or verify the eligibility and credit of persons that use, or intend to use, one or more of the products or services offered by Cogeco Peer1.

Security and accuracy: We use personal information to authenticate the identity of our customers,, to preserve the privacy of our customers contacting Cogeco Peer1 by telephone, electronic means or otherwise and to ensure our records are accurate in order to protect customers and Cogeco Peer1 from error and fraud.

Management and quality: We collect personal information for internal training and quality assurance purposes, and to manage our businesses and ensure the efficiency, reliability and security of our systems and networks.

Customer Service: From time to time we may also use personal information to conduct surveys on the quality of our products, services or customer service, to provide our customers with offers for additional products and services that we feel may be of interest to our customers or to provide personalized products and services as well as product recommendations and to understand and assess the interests, wants and changing needs of customers with a view to improving our products and services and developing new ones.

Human Resources: If you have applied for employment with Cogeco Peer1, 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 Peer1 as well as other career development resources.

Your Consent

Cogeco Peer1 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 or other printed or electronic communications. In general, by purchasing our services you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy.

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.

Withdrawing your consent

Your consent to us collecting and using your personal information may be withdrawn at any time on reasonable notice and subject to any legal or contractual restrictions. Without such consent, Cogeco Peer1 may limit the services or products it provides you. You may also withdraw your consent as follows:

  • Email. You can always limit the communications that Cogeco Peer1 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.
  • Postal marketing, Telephone marketing and Quality control communications. You may decide that you prefer Cogeco Peer1 not to use your personal information to promote new and/or additional products and services which may be of interest to you and refuse that we contact you by mail or telephone for marketing or 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.

 

 

Sharing of Personal Information with Third Parties

Your personal information may be made available by Cogeco Peer1 to third-parties or service providers to fulfill the purposes set out in this Privacy Policy. Cogeco Peer1 will NOT sell, rent or trade your personal information to any third party. Only those employees of Cogeco Peer1 or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information.

We may hire service providers, including affiliates, to perform services on our behalf, for example the collection of customer accounts, customer credit verification and installation of services. We provide them with the limited amount of information which is necessary in order for them to provide the services required and they are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. Cogeco Peer1 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 Peer1 itself.

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.

We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

Cross-border Transfer of Personal Information

In some cases, personal information that we manage may be transferred, processed and stored outside the jurisdiction in which it was collected, and therefore may be available to government authorities under lawful orders and laws applicable there.

Disclosure of Personal Information as Permitted or Required by Law

From time to time, Cogeco Peer1 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 Peer1 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. Cogeco Peer1 does not voluntarily comply with requests for personal information from government or law enforcement authorities that do not meet these standards.

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.

Security of Personal Information

We will use reasonable security measures to protect your personal information against unauthorized access. Cogeco Peer1 has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.

Retention

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. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. Cogeco Peer1 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 Peer1 respects your right to access and correct your personal information. Additionally, Cogeco Peer1 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.

Privacy Shield Statement

Cogeco Peer 1’s U.S. based entities participate in the EU-U.S. Privacy Shield framework and therefore adhere to and comply with the Privacy Shield Principles – more details about which can be found at https://www.privacyshield.gov (Privacy Shield Website) – and are also subject to the investigatory powers and enforcement of the Federal Trade Commission. Our participation in the Privacy Shield applies to all personal data that is subject to our Privacy Policy, which can be found here, and is received from the European Union and/or European Economic Area. We will remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process such personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles unless it’s shown such processing occurs through no fault of our own.

Any complaints related to the Privacy Shield Principles can be directed to us in accordance with the “How to Contact Us” section of our Privacy Policy. For any complaints that cannot be resolved directly, Cogeco Peer 1 has chosen to cooperate with EU data protection authorities (DPAs) and comply with the information and advice provided to it by the DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles) concerning personal data considered by this Privacy Policy that is transferred from the EU (including human resources data in the context of the employment relationship). If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you. In addition, we perform periodic self-assessments to verify that we are compliant with the Privacy Shield Principles and that the provisions of our Privacy Policy remain accurate and fully implemented.

A binding arbitration option will also be available to address any residual complaints not resolved by any other means. More information on this can be found on the abovementioned Privacy Shield Website.

How to Contact Us

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Cogeco Peer1 has about you, please contact:

Ross Woodham, Privacy Officer Cogeco Peer1
413 Horner Ave, Toronto
ON M8W 4W3, Canada

North America: +164 7243 6314 Europe: +44 2380 926 337
By e-mail: privacy@cogecopeer1.com

Change of Privacy Policy

Cogeco Peer1 will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Privacy Policy may therefore change from time to time. We will post any privacy policy changes on our website and, if the changes are significant, we will provide a more prominent notice.

On the same or similar subject, you may want to review our other policies:

This Privacy Policy was last updated on 27 July, 2016.

Please note that both the English and French versions of our Privacy Policy have equal legal value.