Cogeco

Corporate Privacy Commitment

About Cogeco

Cogeco Inc. is a diversified holding corporation which operates in the communications and media sectors. Its Cogeco Communications Inc. subsidiary provides residential and business customers with Internet, video and telephony services through its two-way broadband fibre networks, operating in Québec and Ontario, Canada, under the Cogeco Connexion name,  and in the United States under the Atlantic Broadband brand (in 11 states along the East Coast, from Maine to Florida). Its Cogeco Media subsidiary owns and operates 21 radio stations with complementary radio formats and extensive coverage serving a wide range of audiences mainly across the province of Québec, as well as Cogeco News, a news agency. Cogeco’s subordinate voting shares are listed on the Toronto Stock Exchange (TSX: CGO). The subordinate voting shares of Cogeco Communications Inc. are also listed on the Toronto Stock Exchange (TSX: CCA).

Protection of Personal Information

At Cogeco, we know that the protection of your privacy is important to you. For this reason, we have taken steps to ensure that any personal information that you provide to Cogeco and any of Cogeco Connexion, Atlantic Broadband, Cogeco Media (each, a “corporate entity within the Cogeco Group” and collectively, “corporate entities within the Cogeco Group”) is protected by a range of business procedures and security safeguards to ensure that your information is kept confidential and used only for the purposes detailed in each corporate entity’s Privacy Policy. Every corporate entity within the Cogeco Group must respect privacy and protect the personal information that is entrusted to it.

This Corporate Privacy Commitment applies to all corporate entities within the Cogeco Group worldwide and explains how Cogeco collects, uses and discloses personal information. When we refer to personal information, we mean “any information about an identifiable individual”. This may include, for example, email addresses you have provided, contact details you have given in connection with an account with one corporate entity within the Cogeco group, or such other information you have given to this entity to receive information about or use its services. A corporate entity within the Cogeco group may also gather and hold certain information about you in its dealings with you such as billing history, subscribers and users IP addresses, user IDs and other meta data. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Some of our business operations involve providing products and services to commercial customers as well. In this capacity, while corporate entities within the Cogeco Group that interact with commercial customers do not process personal information, they use comparable confidentiality and standards with these commercial customers as those used with individual customers.

Each corporate entity within the Cogeco Group has its own Privacy Policy, although their practices are always governed by this Corporate Privacy Commitment. If you are interested in the practices of a particular corporate entity within the Cogeco Group, please review the section Privacy Policies of the Cogeco Group below.

Accountability

Policies, procedures, guidelines, business rules and safeguards have been put in place to ensure that your personal information is protected. Our employees and service providers have access to your personal information strictly to enable them to perform their duties and to provide our products and/or services to you. 

Our policies and procedures require all employees of Cogeco to maintain customer confidentiality and data security. In addition, each year, our employees must agree to abide by the rules of our Code of Ethics and the Information and Cybersecurity Policy and are required to certify in writing that they will comply with them.

Each corporate entity within the Cogeco Group strives 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 itself.

Transparency

Cogeco is committed to providing transparency to its customers with respect to the Cogeco Group’s practices in handling their information. To that end, the various corporate entities within the Cogeco Group each adopted policies pertaining to the protection of personal information which are specific to their products, services and/or jurisdiction. These Privacy Policies are intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirements which are applicable in the relevant jurisdictions.

Security of Personal Information

Each corporate entity within the Cogeco Group has implemented security measures that are designed to safeguard your personal information against unauthorized access, such as firewalls, site monitoring and intrusion detection software.

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. Each corporate entity within the Cogeco Group has developed and implemented retention guidelines and destruction procedures for this purpose.

Complaints

Each corporate entity within the Cogeco Group has procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information, and will inform individuals who make inquiries or complaints about the relevant procedures. Each entity within the Cogeco Group will investigate all complaints. If a complaint is found to be justified, the entity will take appropriate measures, including, if necessary, amending its policies and practices.

Privacy Policies of the Cogeco Group

If you desire to obtain more information on our policies or practices which apply to the products or services that you use or which is relevant for your jurisdiction, please review the following:

If have questions or concerns regarding these policies, you will find the relevant contact information of the individual accountable for each corporate entity within the Cogeco Group in each Privacy Policy.

This Corporate Privacy Commitment was last updated on April 13, 2016. Cogeco will review and update its Corporate Privacy Commitment as required to keep current with rules and regulations, new technologies, standards and customer concerns.

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