Evanov Communications

PRIVACY AND CONFIDENTIALITY POLICY

(this/the “Policy”)

Dated April 2024

INTRODUCTION

This is the privacy and confidentiality policy of Evanov Communications Inc., https://evanov.ca/, Dufferin communications Inc. (“Dufferin”), CKDX Radio Limited (“CKDX”), and Ottawa Media Inc. (“OMI”), doing business as Evanov Communications, and the radio stations owned and operated by Dufferin, CIDC-FM Z 103.5, CHLO AM530 Multilingual, CFWC-FM Hot Country 93.9 FM, CKPC-FM Lite 92.1 FM, CJGB-FM Lite 99.3 FM, CHWE-FM Energy 106, CFJL-FM Hot 100.5, CKJS-FM 92.7 Multilingual, CKDX-FM Hot Country 88.5, owned and operated by CKDX, and the radio stations owned and operated by OMI, CJWL-FM Lite 98.5, and CKHK-FM Hot Country 107.7 FM (the “Stations”), and the Stations’ websites:

• https://z1035.com/;
• https://am530.ca/;
• https://hotcountry939.com/;
• https://lite92.ca/;
• https://lite993.ca/;
• https://www.energy106.ca/;
• https://hot1005fm.com/;
• https://ckjs.com/;
• https://hotcountry885.ca/;
• https://lite985.ca/; and
• https://hotcountry1077.ca/,

(the “Website(s)”)(collectively, “Evanov”, “we”, “us” and “our”).

This Policy applies to the personal information of individuals (“you” and “your”) who engage with us in the manners mentioned immediately below and which we collect, hold, use, transfer, share and/or communicate to third parties when you:

• provide us with feedback;
• submit questions, or comments;
• enter our contests;
• interact with us on social media;
• inquire about, or purchase, our advertising services or airtime;
• use our Websites;
• stream our Stations; or
• apply for jobs or internships with us.

Personal information means any information relating to an individual that directly, or, indirectly (e.g., when combined with other information), permits the individual to be identified. For example, personal information could include someone’s name, their contact information, their name and birth date, or their name and certain facts about them. If an individual applies for a position with us, their personal information may include information listed on their application, such as their work history and education or training. If an individual becomes an employee of the company, a separate Employee Privacy Policy applies.

Personal information does not include:

• information that is anonymized or de-identified such that you cannot be identified directly or indirectly;
• your name and contact details (job or professional title, professional duties,    address, email address, and telephone number) when provided to us in the context of engaging in enterprise, or working in a professional capacity, such as professional or business contact information; or
• journalistic or historical information that we hold, use or communicate to the public for informational purposes.

Your privacy and the protection of your personal information is important to us. We want you to know what information we collect from you, why we collect it, how we use it, how we protect it, and what rights you may have in relation to personal information we hold about you.

If, after you read this Policy, you do not agree with the personal information that we are collecting from you, our reasons for collecting it, how we are using it, or how we are protecting it, please do not engage with us in ways where your personal information will, or must, be shared with us.

If after reading this Policy, you continue sharing your personal information with us, we take that as your agreement with this Policy and that we have your consent to collect, use, share, transfer and retain your personal information as set out below.

PRIVACY OFFICER

If you have questions or concerns about this Policy, or our collection, use, disclosure or protection of your personal information, you can reach out to our General Counsel by email at privacy@evanov.ca, or by mail at Evanov Communications C/O General Counsel, 5312 Dundas Street West, Toronto, Ontario M9B 1B3.

SERVICE PROVIDERS AND AFFILIATES

This Policy only covers our own collecting and handling of data, and that of our Service Providers and Affiliates or other partners whose privacy policies align with ours and with which we share your personal information.

Our Service Providers include cloud storage providers, online email and corporate communications platforms, payment processors, website hosting services providers, web analytics, and customer relationship management platforms. We selected these Service Providers in part because they subscribe to acceptable security, data protection and data privacy standards, and thus align with our own standards under this Policy.

We also share information with our Affiliates, including Evanov Communications Inc. and Evanov Radio Group Inc./Groupe Radio Evanov. These Affiliates’ data security, protection and privacy standards also align with ours.

THIRD-PARTY WEBSITES

Our Websites may also link to external or third-party websites that are not operated by us and are not within our custody or control. Please be aware that we have no control over the content and policies of those sites, and thus we cannot accept responsibility or liability for their respective privacy practices.

To that end, we encourage you to read the privacy policies of any third-party websites to determine whether you agree to and accept those policies and their privacy practices before sharing your personal information with them.

SOCIAL MEDIA AND APPLICATIONS

If you interact with us through Facebook, Instagram, Twitter, or any other social media platform, you should read the privacy policies of those platforms before sharing your personal information with and through them. We do not control these platforms, or their handling of personal information, and are not responsible for any personal information that these platforms may collect, use, disclose, or retain about you. However, we may collect personal information that you provide to us through these platforms, depending on the circumstances in which you provide the information. For more information on what types of personal information we may collect through our social media platforms, please see below under Purposes for Collection of Personal Information and Types of Information Collected.

COOKIES

Please refer to our Cookie Policy. In general, as you browse our website, advertising cookies will be placed on your computer so that we can understand your interests. Our display advertising partner enables us to present you with retargeting advertising on other sites based on your previous interaction with this site. The techniques our service providers employ do not collect personal information such as your name, email address, postal address, or telephone number. However, the information we collect through our website does include your IP address, browser type, and content viewed.

COLLECTION AND USE OF YOUR PERSONAL INFORMATION

In the following paragraphs we will tell you:

• how we collect your information;
• what types of information we collect, and our purposes for collecting it;
• how we use your information;
• who we share your information with;
• how we protect it; and
• how long we keep it.

How We Collect Your Personal Information

We collect your personal information when you provide it to us directly. We do not collect your personal information from third parties unless you provided your consent to that third party for this method of collection, or where:

• the collection of the personal information from a third party is in your interests, and we are unable to collect it from you within the required time; or
• it is necessary to collect the personal information from a third party to ensure the accuracy of the personal information; or
• where otherwise permitted by law.

Collection Through Website Analytics

Information may also be provided to us, or to one of our web analytics Service Providers, automatically when you use our Websites, or stream our Stations through our Websites, or through other third-party applications.  

The information collected through web analytics does not identify you, but, during the process of collection, may identify the IP address associated with your device – a unique number assigned to your device that your device uses to communicate with our Websites and third-party streaming applications.

The following information may be collected by web analytics when individuals access our Websites: webpages traveled from; geographical location (city, province, country); time spent; webpages visited; gender; whether this is first time your device has accessed one of our Websites; language; browser type; device model; interests; and age.

We may also collect the amount of time a device spent streaming our Stations; and whether this is the first time the device has streamed our Stations using that particular third-party streaming application.

Information provided through web analytics is collected by using Cookies (small text files that are stored on your computer, mobile phone, or other devices you use when accessing our Websites, or streaming our Stations). Please refer to our Cookie Policy.

You can generally manage the information that is shared with us through Cookies in your browser or device settings, including by disabling Cookies altogether. Note that if you choose to disable Cookies, some features of our Websites or the third-party applications that stream our Stations may not work properly.

One of our third-party web analytics service providers is Google Analytics. To find out more about how Google Analytics and how you can control the information shared by your device with Google Analytics when you access our Websites, visit How Google uses information from sites or apps that use our services – Privacy & Terms – Google.

Purposes for Collection of Personal Information and Types of Information Collected

In general, we collect personal information to deliver products or services that you may request, including access to the content of our website, which do not require your specific consent. However, since your assent to this Policy and continued interaction with us imply consent, following is a specific listing of the information we collect and the purposes for which we collect it:

Purpose	Types of Personal Information Collected
To Engage with you as a Radio Broadcaster. We collect the personal information of individuals who provide us with feedback, or submit comments, or questions to us, to communicate with you.       We collect the personal information of individuals who enter our contests, to administer our contests, determine contest eligibility, and award our contest prizes.	Name and contact information, which may include, telephone number, email address, or mailing address (“Contact Information”). If you provide us with feedback, or submit comments or questions to us via one of our social media pages, we may collect such information from your applicable social media profile as is necessary to communicate with you. Name and Contact Information, and other personal information that may be required to administer the contest and determine eligibility, such as age or birthdate, personal information included on government-issued photo identification necessary to verify an individual’s identity, previous contest entries, and submissions that may contain personal information such as an individual’s likeness or voice recording.   If one of our contests includes an entry mechanism through social media, we may collect such information from your applicable social media profile as is necessary to determine your eligibility for the contest and that you have met the entry requirements.   Contest entrants will be informed of the specific personal information collected at, or before, the time of entry into the contest.
For Promotional/Marketing Purposes.   We may collect the personal information of individuals who enter our contests or win our contest prizes, or send us content or submissions, to promote and market our Stations and, where applicable, those of our third-party advertisers, on our Websites, on-air, and through our social media platforms.	Name and Contact Information, and personal information that may be included in any content, or submissions provided to us, including an individual’s likeness and voice recordings.
To Provide Advertising Services or Airtime Opportunities We may collect personal information from individuals interested in advertising with us or purchasing our airtime, to communicate with them about our advertising services.	Name and Contact Information and any personal information included in the communications between us, including experience, skills or training. Credit information is normally collected from corporate entities, but in rare instances we may collect credit card information from individuals to pay for advertising or airtime opportunities.
To Hire Employees. We collect personal information individuals provide as part of any application to work with us to determine whether to move forward with the individual in the hiring process, including for the purposes of ranking them against others who have applied for the same position.	Name and Contact Information and any personal information forming part of the application, including, but not limited to, employment history, education, skills, and/or training.   If an individual is hired, any personal information submitted as part of their application may become part of their employee file and be governed by our internal employee privacy policies.
To Provide Internships. We collect personal information individuals provide as part of any inquiry about internships with us to determine whether to move forward with their application for an internship, including for the purposes of ranking them against others who have applied for the same internship.	Name and Contact Information and any personal information forming part of the application, including, but not limited to, employment history, education, skills, and/or training. If an individual is accepted for an internship, any personal information submitted as part of their application may become a part of their internal file and be governed by our internal intern privacy policies.

 

We may also collect your personal information for other purposes than those identified above, upon notifying you of such purposes at, or before, the time of collection.

How we use your Personal Information

We use your information in accordance with the purposes for which it was collected, as set out above. However, we may also use your information:

• for purposes consistent with the purposes for which it was collected;
• where it is clearly for your benefit;
• if necessary to prevent fraud, or to assess or improve our security and protection measures;
• to provide or deliver a service or product that you have requested from us;
• to conduct research, or to produce statistics, where that information has been de-identified;
• in accordance with other purposes and for which we have obtained your consent at, or before, the time of collection; or
• where otherwise permitted by law.

Disclosure of Your Personal Information

We may disclose the personal information that we collect, or you provide, where necessary in accordance with the purposes for which it was collected, with your consent, upon court order or where otherwise permitted by law.

Our employees and/or agents may have access to the personal information we collect or you provide, but only to the extent required for them to perform their duties. Our employees understand the need to keep personal information confidential and to not access, or permit another employee to access, personal information unless it is required to fulfill their employment obligations.  

Transfer of Personal Information

We may transfer the personal information we collect from you to contractors, Service Providers, and other third parties we use to support our business, who are obligated to keep the personal information confidential, and to use it only for the purposes for which we disclose it to them.

We may transfer the personal information we collect from you to other jurisdictions, including to other Canadian provinces, territories and foreign countries. Be advised that other countries or provinces may not have the same standards for protection of consumer data as that provided in your current jurisdiction. However, if we transfer your personal information to another jurisdiction, we will require any receiving entity to adhere to appropriate privacy and security standards.

Protection of Personal Information

The security of your personal information is important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss, and from unauthorized access, use, alteration, and disclosure.  

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of the personal information that you transmit to us through our Websites, social media platforms, or the internet, generally. Any transmission of personal information by you is at your own risk.

Retention of Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. If we use your personal information to make a decision about you, we will keep that information for at least one year following our decision.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you directly or indirectly. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

RIGHT TO ACCESS, CORRECTION, AND TO WITHDRAW CONSENT

We want your information to be accurate and up-to-date. You have the right to request access to and to correct the personal information that we hold about you.

To access, verify, or correct your information please send a request in writing to our general counsel by email at privacy@evanov.ca, or by mail at Evanov Communications C/O General Counsel, 5312 Dundas Street West, Toronto, Ontario M9B 1B3.

We may refuse to change personal information if we believe such change would violate any law or legal requirement or cause the information to be incorrect.

We may charge you a fee for copying, transcribing, or transmitting your personal information to you. We will notify you of any such fee in advance.

When you make a request for access or to verify or correct your information we will require specific information from you to confirm your identity, your right to access the information, and to provide you with the personal information we hold about you or make your requested changes. Where permitted by law, we may refuse to provide you with access to some or all of the personal information we hold about you. If we cannot provide you with access to your personal information, we will tell you the reasons why, subject to any legal or regulatory restrictions.

Withdrawing Consent

You may have the right to withdraw your consent to our processing of your personal information, if our processing is based on your specific consent.

However, note that where you withdraw your consent to the collection, use, sharing, or retention of your personal information, you may not be able to engage with us in the same ways intended for those who provide the requisite information.

To withdraw your consent to our processing of your personal information please send a request in writing to our general counsel by email at privacy@evanov.ca, or by mail at Evanov Communications C/O General Counsel, 5312 Dundas Street West, Toronto, Ontario M9B 1B3.

CHILDREN UNDER 13

We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact our General Counsel by telephone at 416-213-1035, or email at privacy@evanov.ca.

CHANGES TO OUR PRIVACY POLICY

We regularly review this Policy and amend it from time-to-time in accordance with our business or operational needs, or changes to the applicable privacy laws or regulations.

The date at the top of this webpage is the latest revision date for this Policy. You are responsible for periodically reviewing this Policy to check for any changes.