Our commitment to privacy: Sway Magazine, a division of the Toronto Star Newspapers Limited (“Sway Magazine”) knows that protecting the privacy and confidentiality of your personal information is important to you. This Privacy Code governs the collection, use and disclosure of your personal information in any form, whether written or electronic, by Sway Magazine and its affiliates. The collection, use and disclosure of your personal information is governed by the Personal Information Protection and Electronic Documents Act (the “Act”), and any applicable provincial legislation. This Privacy Code explains what personal information may be collected from you and how it is used. It also explains how you can ask questions, make suggestions, and express concerns about our privacy practices.
This Privacy Code applies only to personal information collected by Sway Magazine and its affiliates. Be aware that our websites may contain links to other websites that are maintained by third parties who are not required to comply with this Privacy Code and for which Sway Magazine has no responsibility. Please review the privacy policies on any external websites to determine their information handling practices.
This Privacy Code is available to the public through our websites, and in paper form from Sway Magazine. If you have any additional concerns or questions, we encourage you to contact us and we will address your concerns to the best of our ability. Please read this Privacy Code carefully, and check back periodically as we may update it from time to time. By submitting your personal information to Sway Magazine, you signify your agreement to the terms and conditions of this Privacy Code.
What is personal information? Personal information is any information about an identifiable individual.
Sway Magazine is responsible for personal information under its control. Sway Magazine has implemented policies and practices to give effect to this Privacy Code, including training and communicating with our employees about the importance of privacy and implementing security procedures that reasonably protect the personal information you provide to us. In addition, Torstar Corporation, Sway Magazine’s parent company, has appointed a Chief Privacy Officer to oversee personal information-handling practices of Sway Magazine and its affiliates.
What is excluded from privacy protection? This Privacy Code does not impose restrictions on: business contact information, including the name, title, business address or telephone number of an employee of an organization; information collected, used or disclosed solely for journalistic, literary or artistic purposes; publicly available information, such as an individual’s name, telephone number and address when listed in a directory or made available through directory assistance; or information that is aggregated and not associated with a specific individual, including demographic information and statistics.
Children: If you are under the age of 18, be sure to obtain your parent or guardian’s permission before you send any personal information to us, or anyone else. We encourage parents to get involved with their children’s online usage and to be aware of the activities in which they are participating.
What personal information do we collect, and why?
• We collect personal contact information (such as your name, address, email address and telephone numbers) if you: sign up for a newsletter; register on an online forum or website, or to attend a paid event; purchase any product or service from Sway Magazine; are a classified advertiser or auction participant; or provide it to us when you attend a trade or consumer show. This information is used to fulfill your request for information, products or services, to provide targeted advertising, and to respond to your inquiries.
• We will retain your subscriber ID and passwords so that upon request by you we may remind you of them.
• If you enter a contest or other promotion, we use your personal contact information to administer the contest or promotion including contacting, announcing and promoting prizewinners. In addition, sometimes our contest rules provide that we may contact contest entrants with promotions and product information. Those rules will also include a way for you to indicate to us that you do not want to be contacted for this purpose. Some contests may also involve co-sponsors, who have their own privacy practices. In these cases, the contest rules and/or entry forms will indicate that your personal information is being shared with these co-sponsors and will provide you with the ability to opt-out from receiving promotions and product information from them.
• We collect demographic information, as well as purchase history and a list of promotions offered to you, in order to gain a better understanding of your interests so that we may develop better products and services, and to determine your eligibility for other products and services.
• We may also use demographic, personal contact and history information to contact you about changes, enhancements or other notices related to products or services you requested from us and which Sway Magazine provides. In addition, we may use this information to send you offers or information from us, our affiliates and from selected sponsors or advertisers (“Marketing Offers”). If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure below.
• We collect your credit card information if you: register on a paid website; register to attend a paid event; purchase any product from Sway Magazine or through one of our websites. This credit card information is used for the purpose of fulfilling your order.
• If you choose to opt-out of any use of your personal information in accordance with our opt-out policy, we will keep your contact information on a list so that your request can be honoured. If you provide a complaint to any of our departments, we will collect your contact information and the nature of your complaint, for the purpose of investigating your concerns and responding to you.
• If you provide freelance or other services to us, we may collect your social insurance number for tax reporting purposes and your contact information in order to pay you.
• If you are concerned about cookies, it is possible to turn them off in your web browser preferences. The following link has useful information about how to opt out of cookies that are placed by companies who are members of the Network Advertising Initiative: NAI (Network Advertising Initiative) Opt-Out. However, please be aware that by disabling cookies, you may not be able to use all portions of our websites, particularly pages requiring registration.
• We may place advertising or other links on our websites that originate from outside advertisers. If you view these ads, the advertisers may assign a cookie. Sway Magazine does not control these cookies, nor is it responsible for any marketing or other use of your information by these advertisers.
• Our websites may use Web beacon, gif, or other technologies to better tailor and manage advertising on those sites. These technologies may be in use on a number of pages across web sites. When you access these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These Web beacons usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
• Many of our websites use third-party advertising companies to serve ads when you visit the site. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you. Some ads appearing on our websites are delivered to you by AdTech, which is a web advertising company. These third parties may, from time to time, use information that they collect about your visits to this site, such as the number of times you have viewed an ad (but not your name, address or other personal contact information) to serve additional ads about goods and services that may be of interest to you. If you do not wish to have your information used in this way, please click on the following link: AdTech Opt-Out
• We use IP (internet protocol) addresses, to gather demographic and statistical information about our users, for systems administration and to diagnose problems with our servers, and to administer our websites. We may also use IP addresses to display or allow our third party advertising providers to display more targeted advertising and content.
• We may, from time to time, track and analyze anonymous usage and browsing patterns of visitors to our websites to provide our advertisers with more targeted advertising opportunities and to help users see advertising that is most likely to interest them.
• We generally use your personal information for the purposes of : managing, administering, collecting or otherwise enforcing your accounts; maintaining business records for reasonable periods of time and generally managing and administering our business; and meeting all relevant Canadian and international regulatory, legal, insurance, audit, security and processing requirements.
• Occasionally, we ask our customers to complete market research surveys. If you choose to participate in these surveys and provide your personal information for that purpose, your information will be aggregated as part of the survey results and shared with our advertisers, sponsors and affiliates in a manner that does not identify you.
• Other than as permitted or required by law, if we wish to collect, use or disclose your personal information for purposes that are not contemplated in this Privacy Code, we will identify those purposes at the time of collection. You will be given a reasonable opportunity to opt-out of any such additional purposes.
To whom does Sway Magazine disclose personal information, and why? Sway Magazine may disclose your personal information under the following circumstances:
• To provide you with Marketing Offers, Sway Magazine may disclose your personal contact information to affiliates and selected sponsors and advertisers. If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure below.
• Sway Magazine may transfer your personal information to third party service providers in order to fulfill your order or perform processing and other specialized services (such as credit card processing, prize fulfillment of our contests, collection of overdue accounts, management of customer service requests, and product delivery).
• Sway Magazine may provide your name and credit card information on a confidential basis to a third party (which party may be outside of Canada) for the purpose of updating your credit card information to ensure that your ongoing subscription to Sway Magazine products and services is not interrupted.
• Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Code and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.
• Sway Magazine may disclose your personal information to our affiliates for internal audit, management, billing or administrative purposes.
• Sway Magazine may disclose your contact information on a confidential basis to our advertisers for the sole purpose of newspaper delivery verification.
• Sway Magazine may disclose your personal information to third parties if you have violated our terms of service or conditions of purchase, or if we need to comply with applicable laws and lawful governmental requests, other legal and regulatory authorities and for other legal reasons.
• Sway Magazine may disclose your personal information on a confidential basis to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties.
Consent and opt-out policy. In general, Sway Magazine seeks consent to use your personal information in accordance with our opt-out policy. Except as set out in this section, Sway Magazine obtains your express opt-in consent to use or disclose sensitive personal information.
If you do not wish to receive Marketing Offers, you may opt-out at any time by doing any of the following:
• follow the instructions at the bottom of any email Marketing Offer you receive.
• email Customer Service at firstname.lastname@example.org and request that your personal information not be used for Marketing Offers.
It may take 2-4 weeks to fully process your opt-out request.
Generally, when you provide us with your personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Code, if applicable, or otherwise at the time of collection. We reserve the right to use and disclose your personal information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.
Safeguards: Sway Magazine has technical, contractual, administrative and physical security measures to protect your personal information in a manner that is reasonable and appropriate to the nature of the personal information you provide to Sway Magazine. For example, when you provide credit card information to us, we work to help protect the security of your credit card information by using industry standard secure sockets layer (SSL) encryption technology.
Please be aware that email is not a secure medium, and any personal information you send to us by email could be intercepted. If your communication is very sensitive, or includes information such as your credit card number, you should not send it electronically unless the email is encrypted or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or comment sites are public, not secure and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other internet users. Sway Magazine is not responsible for personal information you choose to post or submit in any online forum on any of its websites.
How to access and correct your personal information. Some of our websites provide you with the means to access, update, edit or delete certain subscriber or registration information by going to the appropriate page on the website and changing or deleting such information as desired. Alternatively, or for other information, you may call Customer Service at 416 933-3412 and we will make the changes upon receipt of appropriate evidence.
We will give you access to the information we retain about you within a reasonable time, upon written request, satisfactory identification and proof of entitlement. In some cases, we may not provide access to personal information in our possession or control. If we deny your request, we will advise you in writing of the reason for the refusal and you may challenge our decision.
How to address concerns regarding your privacy. Sway Magazine encourages you to contact us with any questions or concerns you have about your privacy or this Privacy Code. If you have a question concerning Sway Magazine’s Privacy Code, would like a copy, or if you have any concerns, please contact Customer Service at: 416 933-3412, or email us at email@example.com
Customer Service can successfully deal with many issues. If you prefer, or if after contacting Customer Service your concerns or questions have not been resolved to your satisfaction, you can contact Torstar Corporation’s Chief Privacy Officer in writing as follows:
Chief Privacy Officer
One Yonge Street, 6th floor
Fax: (416) 869-4183
This Privacy Code was last updated on February 7, 2011.