HORSE COMMUNITY JOURNALS INC.
At HORSE COMMUNITY JOURNALS INC, we are committed to providing our clients, customers, and subscribers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers and subscribers, protecting their personal information is one of our highest priorities.
While we have always respected our the privacy of our customers, subscribers, and readers, and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers, subscribers, and readers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting personal information of our customers, subscribers, and readers. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’ and subscribers’ personal information, and allowing our clients, customers and subscribers to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Horse Community Journals Inc. (HCJI) and its subsidiaries. This policy also applies to HCJI collecting, using or disclosing personal information on behalf of its clients and affiliates that exchange information with HCJI from time to time.
Personal Information: means information about an identifiable individual, eg: name, age, home address, home phone number, income. Personal information does not include contact information (described below).
Contact information: means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer: means the individual designated responsibility for ensuring that HCJI complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer, subscriber or reader voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer, subscriber or reader information that is necessary to fulfill the following purposes:
- To verify identity;
- To verify creditworthiness;
- To identify customer, subscriber or reader preferences;
- To understand the advertising, informational and service needs of our customers, subscribers or readers;
- To open and manage an account;
- To deliver requested products and services;
- To process a magazine subscription;
- To contact our customers, subscribers or readers for fundraising;
- To communicate with, and administer prizes to, participants of our contests and surveys;
- To ensure a high standard of service to our customers, subscribers or readers;
- To meet regulatory requirements;
- To collect and process payments for advertising, services or subscriptions;
- To contact our customers, subscribers or readers with offers and information from our partners and affiliates;
- To share with our advertisers, sponsors, and partners, demographic (e.g. age, income), geographic (e.g. location), and other information, only on an aggregate basis, unless consent has been requested from the participant (such as to administer a contest prize).
Policy 2 – Consent
2.1 We will obtain customer, subscriber, or reader consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided, eg: orally, in writing, electronically, through an authorized representative, or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client, customer or subscriber voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer, subscriber, or reader is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer or subscriber does not opt-out.
2.4 Subject to certain exceptions (eg: the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers, subscribers, or readers can withhold or withdraw their consent for HCJI to use their personal information in certain ways. A customers’, subscribers’, or readers’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer, subscriber, or reader in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s, subscriber’s or reader’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security;
- When the personal information is available from a public source (eg: an online directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
- To implement Google Analytics Cookies, to acquire data and reports about the demographics and interests of our visitors. Visitors to our site can opt-out of the Google Analytics Advertising Features used, including through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out).
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer, subscriber, or reader personal information where necessary to fulfill the purposes identified at the time of collection (or for a purpose reasonably related to those purposes) such as:
- To conduct client, customer or subscriber surveys in order to enhance the provision of our services.
- To contact our clients, customers or subscribers directly about products and services that may be of interest;
3.2 We will not use or disclose client, customer or subscriber personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer or subscriber lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use customer, subscriber, or reader personal information to make a decision that directly affects the customer, subscriber, or reader we will retain that personal information for at least one year so that the customer, subscriber, or reader has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer, subscriber, or reader personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer, subscriber, or reader personal information is accurate and complete where it may be used to make a decision about the customer, subscriber, or reader or disclosed to another organization.
5.2 Customers, subscribers, or readers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request to correct personal information should be forwarded to the Privacy Officer or designated individual.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers’, subscribers’, or readers’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer, subscriber, or reader personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer, subscriber, or reader personal information is appropriately protected: physically securing offices where personal information is held by use of alarm system; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (ie: only those that need to know will have access; contractually requiring any service providers to provide comparable security measures).
6.3 We will use appropriate security measures when destroying customers’, subscribers’, or readers’ personal information such as shredding documents, deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers, Subscribers, or Readers Access to Personal Information
7.1 Customers, subscribers, or readers have a right to access their personal information, subject to limited exceptions. Some examples of exceptions include: solicitor-client privilege, where disclosure would reveal personal information about another individual, health and safety concerns.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer or designated individual.
7.3 Upon request, we will also tell customer, subscriber, or reader how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer, subscriber, or reader of the cost and request further direction from the client, customer or subscriber on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer, subscriber, or reader in writing, providing the reasons for refusal and the recourse available to the customer, subscriber, or reader.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Horse Community Journals Inc.’s compliance with this policy and the Personal Information Protection Act.
8.2 Customers, subscribers, or readers should direct any complaints, concerns or questions regarding HCJI’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer, subscriber, or reader may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Horse Community Journal Inc.’s Privacy Officer or designated individual:
Kathy Smith, Publisher