Cogeco Peer 1 and its affiliated legal entities (“Cogeco Peer 1”) provide 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 Peer 1, 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.
Application and Scope
Cogeco Peer 1 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
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 Peer 1 will not collect or use personal information for any other or new purpose without obtaining consent, unless required or authorized by law.
Cogeco Peer 1 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 Peer 1.
Security and accuracy: We use personal information to authenticate the identity of our customers,, to preserve the privacy of our customers contacting Cogeco Peer 1 by telephone, electronic means or otherwise and to ensure our records are accurate in order to protect customers and Cogeco Peer 1 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 Peer 1, 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 Peer 1 as well as other career development resources.
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 Peer 1 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 Peer 1 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 Peer 1 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
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 Peer 1 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 Peer 1 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.
Cogeco Peer 1 may receive personal information from its affiliate entities located in the European Union in order to assist those affiliates in providing services and conducting their business operations. Where Cogeco Peer 1 receives personal information in this manner, it acts as a processor under data protection laws, and the relevant affiliate located in the European Union is deemed to act as the data controller, in accordance with EU data protection laws. For the avoidance of doubt, this does not include personal information uploaded to our systems by the customers of our affiliates in the European Union in respect of which those customers are considered to be the data controllers.
Disclosure of Personal Information as Permitted or Required by Law
From time to time, Cogeco Peer 1 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 Peer 1 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 Peer 1 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 Peer 1 has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.
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 Peer 1 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 Peer 1 respects your right to access and correct your personal information. Additionally, Cogeco Peer 1 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.
Notice to the Data Subjects of Our Customers
If you have provided personal information to our customers, or to customers of Cogeco Peer 1 affiliates, who are using Cogeco Peer 1’s information technology services to store or otherwise process your personal information, all such personal information on our systems is provided and controlled by our customers who are the data controllers under applicable data protection law. Cogeco Peer 1 will not process that personal information except as provided for in the agreement between us (or our affiliate) and the customer. The customers remain responsible for the personal information they collect and process, and are not discharged of their obligations to comply with applicable data protection laws.
Cogeco Peer 1 has no direct relationship with the individuals whose personal information is processed by our customers. If your personal information is on our systems as a result of you having provided it to one of our customers and would no longer like to be contacted by that customer, or you wish to exercise any other data protection rights, please contact that customer directly.
How to Contact Us
Ross Woodham, Privacy Officer Cogeco Peer 1
413 Horner Ave, Toronto ON M8W 4W3, Canada
North America: +164 7243 6314
Europe: +44 2380 926 337
By e-mail: privacy@cogecoPeer 1.com
On the same or similar subject, you may want to review our other policies:
Privacy Shield Statement
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.