Privacy Policy

Cue Digital Media is committed to providing its clients and others in the advertising industry with innovative advertising products, services and other resources, including this Website and blog, and to protecting the privacy of individuals in the process. This Privacy Policy describes Cue Digital Media’s commitment to privacy.

In this Privacy Policy, “personal information” generally means information about an identifiable individual and may include the individual’s name, personal email address and website and User Submissions used or posted in connection with the Website and blog, and Cue Digital Media’s other advertising products, services and resources and other identifying information such as web statistics and traffic data. Personal information does not include an individual’s name or business title, address, telephone number, email address or website as an employee of an organization, where collected, used or disclosed in connection with his or her employment.

“Cue Digital Media” means Cue Digital Media Inc. and its affiliates engaged in the provision of advertising products, services and resources, and includes any service providers acting on behalf of such organizations. You can obtain a current list of Cue Digital Media’s affiliates and/or service providers upon request, where appropriate.
If you have any questions about this Privacy Policy, or Cue Digital Media’s policies and practices, please contact Cue Digital Media at:

Cue Digital Media Inc.
250 The Esplanade
Berkeley Castle
Courtyard
Suite 127
Toronto, ON
M5A 1J2

Attention: Tony Mutch, Chief Privacy Officer
Tel: 416 583-2581
Fax: 416-214-1571
Email: info@cuedigitalmedia.com

Privacy law is a relatively new and rapidly evolving area. This Privacy Policy is subject to periodic review to maintain its accuracy and compliance with applicable law. This Privacy Policy is current as of the date identified above. Any updates to this Privacy Policy will be posted on the Website.

CUE DIGITAL MEDIA’S COMMITMENT TO PRIVACY

Commitment #1: Accountability
Cue Digital Media is responsible for all personal information in its possession or control, including any personal information transferred to third parties for processing. Cue Digital Media has established policies and practices to give effect to this Privacy Policy and has designated a Chief Privacy Officer, whose contact information is set out above, to be accountable within the organization for Cue Digital Media’s compliance with this Privacy Policy.

Commitment #2: Identifying Purposes for Collecting Personal Information
Cue Digital Media will, either directly or through a client, identify to an individual the purposes for which it collects, uses and discloses personal information (the “Purposes”), before or at the time the information is collected, or where the information is to be used or disclosed for a new purpose, before that use or disclosure. The Purposes may include:
(a) understanding, developing and administering the Website and Blog and other products, services and resources that meet individuals’ and clients’ advertising-related needs, including by operating, maintaining and improving the features and functionality of the Website and Blog; processing any User Submissions, ombudsman inquiries or other communications individuals send via the Website or Blog; and distributing such Blog feeds or weekly updates as may be requested by individuals;
(b) communicating with individuals in connection with the purposes in (a);
(c) offering individuals and/or their organizations new advertising-related products, services and resources that may be of interest to them (provided that such individuals have not opted out of receiving, or having their organizations receive, such offers); and
(d) monitoring overall traffic on the Website and Blog and composing and analysing aggregate traffic data and statistics, in each case, on an anonymized basis.

Commitment #3: Obtaining Consent
Cue Digital Media will make a reasonable effort, either directly or through a client, to advise an individual as to how personal information will be used or disclosed by Cue Digital Media. Generally, Cue Digital Media or a client, on behalf of Cue Digital Media, will obtain the individual’s consent to the collection, use and disclosure of personal information for the Purposes before or at the time it collects the information. An individual’s consent may be express or implied, depending on the sensitivity of the information.
An individual may withdraw or vary his or her consent on reasonable notice to Cue Digital Media, subject to legal or contractual restrictions. Cue Digital Media will generally be able to give effect to such withdrawal or variation on thirty (30) days’ notice, and will, if it has not already done so, advise the individual of the implications of his or her withdrawal or variation.

Commitment #4: Limits on the Collection of Personal Information
Cue Digital Media will limit the personal information it collects to information necessary for the Purposes. Cue Digital Media will only collect personal information by fair and lawful means. Cue Digital Media will not collect personal information from any third party (other than a client acting on behalf of Cue Digital Media) without an individual’s consent unless the collection is clearly in the individual’s interest and Cue Digital Media is unable to obtain consent in a timely way, or as otherwise permitted by law.

Cue Digital Media will not, as a condition of supplying a product, service or resource, require an individual’s consent to the collection, use or disclosure of his or her personal information beyond that reasonably required to supply the product, service or resource, to comply with its obligations under applicable law or for related internal business or management or legal purposes.

Commitment #5: Limits on the Use, Disclosure and Retention of Personal Information
Cue Digital Media will only use, disclose and retain personal information for the Purposes. Cue Digital Media will identify any third parties to whom personal information will be disclosed at the time of collection and obtain individuals’ consent to such disclosure. For example, Cue Digital Media may:
(a) disclose personal information to an individual’s organization for the purposes of understanding and administering products, services and resources that meet the organization’s advertising needs, and communicating with the organization for that purpose, and/or offering the organization new products, services and resources that may be of interest to it (provided that the individual has not opted out of having his or her organization receive such offers);
(b) make some information about an individual available to other users of the Website and Blog. This may include an individual’s name, website and User Submissions, for instance, when the individual engages in certain activities such as posting or submitting comments or other information or materials using Blog. An individual’s email address will not generally be made available to other users; or
(c) transfer personal information to third parties for processing (e.g., data processing or hosting), pursuant to contractual agreements that provide a level of protection for the personal information comparable to that provided by Cue Digital Media, as well as assurances that such third parties will not use or disclose the personal information for any purpose other than processing.

Under certain statutory exceptions, Cue Digital Media may have a legal duty or right to disclose personal information without individuals’ consent. Examples of permitted disclosures of personal information to non-affiliated third parties may include disclosures required to comply with a subpoena or warrant, made pursuant to a request by a government institution, made to an investigative body or government institution where Cue Digital Media has reasonable grounds to believe that the information relates to a breach of an agreement or law or disclosures otherwise required by law.

Cue Digital Media may also disclose personal information to a prospective purchaser of its business, or any material part of its business, for the purpose of evaluating the purchase, and/or to a purchaser of its business, or any material part of its business, who agrees to be bound by this Privacy Policy or a substantially similar privacy statement, to the extent reasonably required for the Purposes.

Cue Digital Media will use, disclose and retain personal information only for as long as is necessary to fulfil the Purposes or as otherwise permitted or required by law. User Submissions will be archived on Blog only so long as the relevant Cue Digital Media post is archived. Cue Digital Media has established minimum and maximum retention periods and procedures for retaining and destroying personal information.

Commitment #6: Accuracy of Personal Information
Cue Digital Media will use reasonable efforts to keep personal information as accurate, complete and up-to-date as necessary for the Purposes. That said, Cue Digital Media will not routinely update personal information unless necessary. Cue Digital Media expects individuals, from time to time, to inform Cue Digital Media of any updates that may be required by contacting Cue Digital Media using the contact information above.

Commitment #7: Safeguarding Personal Information
Cue Digital Media is committed to protecting the security of personal information. Cue Digital Media uses security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and limiting access on a “need to know” basis and technological measures, such as the use of passwords, encryption and other secure methods by which to verify the identity of individuals.

Cue Digital Media’s staff are made aware, through orientation and refresher training programs, of the importance of maintaining the confidentiality of personal information. Cue Digital Media conducts periodic internal and independent audits of its security safeguards and any breach of Cue Digital Media’s security safeguards is a disciplinary matter. Cue Digital Media’s security safeguards extend to the destruction of personal information.
Cue Digital Media remains responsible for all personal information transferred to third parties for processing. As such, Cue Digital Media ensures that all third parties engaged to perform services on Cue Digital Media’s behalf are required to provide a level of protection for personal information comparable to the level of protection provided by Cue Digital Media, and that such third parties are prohibited from using or disclosing personal information for any purpose other than processing.

Commitment #8: Availability of Information about Cue Digital Media’s Policies and Practices
Cue Digital Media is open about the policies and practices it uses to manage personal information. This Privacy Policy is intended to provide individuals with specific information about such policies and practices; however, Cue Digital Media will provide individuals with additional information upon request.

Commitment #9: Access to Personal Information
Upon written request, Cue Digital Media will generally tell an individual what personal information it has, what it is being used for and to whom it has been disclosed and will grant the individual access to the information. Cue Digital Media will make such information available to an individual in a form that is generally understandable, including by explaining any abbreviations or codes or by employing an alternative format, if required. Written requests, including the individual’s name and contact information, should be sent to Cue Digital Media’s Chief Privacy Officer using the contact information above. Cue Digital Media will make every reasonable effort to respond to written requests within thirty (30) days of receipt and will advise individuals in writing if for any reason this time limit cannot be met.

Cue Digital Media may request individuals who submit written requests to provide sufficient information to enable Cue Digital Media to verify their identity. Any such information will be used only for the purpose of identification.
Cue Digital Media will not assess any costs to individuals for accessing their personal information without first providing individuals with an estimate of such costs, which will be minimal, if any. Individuals are asked to confirm their wish to proceed in writing within the thirty (30) day notice period set out in any estimate. If an individual does not notify Cue Digital Media in writing of his or her wish to proceed within such notice period, then Cue Digital Media will deem the individual to have withdrawn his or her request for access and will provide him or her with a written notice to that effect.

An individual may challenge the accuracy and completeness of personal information and request that it be amended. Cue Digital Media will, if appropriate, amend the information and advise third parties to whom the information as been disclosed of the amendment.

Commitment #10: Handling Complaints and Questions
An individual may challenge Cue Digital Media’s compliance with this Privacy Policy. All complaints or inquiries should be in writing, include the individual’s name, contact information and a brief description of the complaint, and be directed to Cue Digital Media’s Chief Privacy Officer using the contact information above. Cue Digital Media’s Chief Privacy Officer will investigate the complaint and will generally respond within thirty (30) days of receipt with the action proposed to be taken by Cue Digital Media, including any changes to its privacy policies or practices.

Prior to making a complaint to the Chief Privacy Officer, or if a complaint is not resolved to the individual’s satisfaction, the individual may also make a complaint to the applicable Privacy Commissioner.