Privacy Policy

CUSTOMER PRIVACY STATEMENT
Effective January 1, 2004

The Personal Information Protection and Electronic Documents Act (PIPEDA) applies to all business and organizations in Canada. This legislation was enacted in response to public concerns about personal privacy issues, especially since the advent of the Internet, e-commerce and advance data mining of information about individuals. The Act applies to the privacy of individuals, not corporations.

"Personal information" is defined as any information about an "identifiable individual" including your name, residential address, email address, subscription information, product and service usage, credit information, billing records, and recorded complaints.

Personal information is collected by The Essex Free Press only when you specifically and knowingly choose to provide it to us, such as when you subscribe to the newspaper, enter an Essex Free Press promotion, or choose to receive information, products or services from The Essex Free Press. We may also receive personal information from our business partners and other third parties, provided that such third parties confirm to us that they have obtained your consent to the disclosure of your personal information.

Publicly available information is not considered personal information. Business contact information and certain publicly available information, such as names, addresses and telephone numbers (as published in telephone directories) are not considered personal information. Where an individual uses his or her home contact information as business contact information, the contact information provided is regarded as business contact information and is not subject to protection as personal information.

Collection and Use of Personal Information

The Essex Free Press collects and uses your personal information primarily for the purpose of providing you with the products and services you have requested from us, including the delivery of news and related content through publications of The Essex Free Press

Your personal information is used to communicate with you about your account and to provide you with information related to other Essex Free Press publications and services. You always have the option, however, to inform us that you do not wish to share your personal information with other companies or to exclude you from offers for other products and services.

If you enter a contest or other promotion offered by The Essex Free Press, your personal information will be used to administer the promotion, including the use of your name and selected information for the purposes of contacting, announcing and promoting the winners of the promotion.

The Essex Free Press may also contact you from time to time to conduct market research and surveys in an effort to continually improve our product and service offerings.

Unless you specifically authorize us to release your personal information or release is required or permitted by law, The Essex Free Press will not sell, lease or trade your personal information to other third parties.

The Essex Free Press only asks for information about you that we need and will only ask for it when we need it. When we ask you for the information, we will explain to you why we need it and what we are going to do with it.

The Essex Free Press has an obligation to obtain the appropriate consent from its customers in the collection, use and disclosure of personal information. The company's Privacy Officer shall be the Publisher.Disclosure

To enable us to more efficiently provide the products and services you have requested from us, The Essex Free Press may share your personal information with other selected third parties who are acting on our behalf as our agents, suppliers or service providers. Such third party service providers are provided only with such information as is necessary in the circumstances. Information provided to third parties may be used only the purpose stipulated and is subject to strict terms of confidentiality.

Accuracy

The Essex Free Press will try to ensure that information about you is accurate, complete and up-to-date. However, please inform us of any change of name, address or other information, In the event you have questions about the accuracy of factual information we have collected about you, you will have access to that information in order to verify and update it. If we have disclosed inaccurate information about you to a third party, we will be pleased to contact the third party in order to correct the information.
Security

The Essex Free Press is committed to protecting your privacy. Security measures, such as restricted access and the use of passwords have been adopted to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all times and those employees with access to your personal information shall use it strictly in accordance with The Essex Free Press Policy and the laws applicable to the business.

Access

If you have any questions about the collection, use or disclosure of your personal information by The Essex Free Press, or if you simply want to know whether we have any of your personal information on file, you may contact our Privacy Officer. Except in limited circumstances, as specifically provided by applicable privacy legislation, The Essex Free Press can tell you whether we hold personal information about you. We can tell you the source of the information, allow you access to your personal information, and find an account of the use that has been made or is being made of the information and the third parties to which it has been disclosed.

If The Essex Free Press refuses access to you, we will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. The Essex Free Press will respond to your requests for access in accordance with applicable privacy legislation.

Questions or Concerns

If you have any questions or concerns about the personal information about you held by The Essex Free Press or about our compliance with this Privacy Policy, please contact our Privacy Officer.

If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information , please contact the federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.

TEN PRINCIPLES OF FAIR INFORMATION PRACTICES

PRINCIPLE 1 - ACCOUNTABILITY
The Essex Free Press is responsible for the personal information under its control and shall designate one or more individuals who shall be accountable for the company's compliance with the procedures and principles set out in the Privacy Policy.

PRINCIPLE 2 - IDENTIFYING PURPOSE
The Essex Free Press will identify the purpose for which personal information is collected at or before the time the information is collected. The purposes for which information is collected, used or disclosed by The Essex Free Press must be those that a reasonable person would consider are appropriate in the circumstances.

PRINCIPLE 3 - CONSENT
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where consent is not required by privacy legislation as, for example, where the collection, use or disclosure of personal information is solely for journalistic, artistic or literary purposes.

The Journalistic Exemption:
Newspapers use personal information in every edition of their publication. PIPEDA exempts journalistic enterprises in order to protect the ability of the media to continue their practices of gathering information for journalistic purposes and handling such information as they see fit in the circumstances. Newspapers do NOT need to tell people that they are holding information about them and are considering using it in the newspaper at some point in the future. The Act protects the traditional ability of a journalistic enterprise to decide which information that it has gathered will become public, how it will be stored, and what will not be published. The journalistic exemption applies to personal information that is collected, use or disclosed for journalistic purposes and NOT personal information it collects, uses of discloses for any other purpose.

PRINCIPLE 4 - LIMITING COLLECTION
The Essex Free Press shall limit the collection of personal information to that which is necessary for the purposes identified by the company. Personal information shall be collected by fair and lawful means.

PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of the purposes for which it was collected.

PRINCIPLE 6 - ACCURACY
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

PRINCIPLE 7 SAFEGUARDS
Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information.

PRINCIPLE 8 - OPENNESS
The Essex Free Press shall make readily available to its customers and employees specific information about its policies and practices relating to the management of personal information.

PRINCIPLE 9 - INDIVIDUAL ACCESS
Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information except where The Essex Free Press is permitted or required by law not to disclose personal information to the individual customer or employee. An individual customer or employee shall be able to challenge the accuracy and completeness of the information disclosed to him or her and have it amended as appropriate.

PRINCIPLE 10 - CHALLENGING COMPLIANCE
An individual customer or employee shall be able to address a challenge concerning compliance with the principles in the Essex Free Press Privacy Policy to the designated Privacy Officer.