St. Joseph Communications’ Privacy Policy has been developed as an extension of our commitment to combine the highest-quality products and services with the highest level of integrity in dealing with our clients. The Policy is designed to assist you in understanding how we collect, use, and safeguard the personal information you provide to us and to assist you in making informed decisions when using our products and services and receiving news and related content through our online properties. It reflects our commitment to protecting the privacy and confidentiality of the personal information entrusted to us by our clients. This Policy will be continuously assessed against new technologies, business practices, and client needs.
The Policy applies to all current and prospective clients of St. Joseph Communications and/or our subsidiaries and/or affiliates (collectively “St. Joseph”), as well as to users of our online properties.
St. Joseph has organized its business into three strategic platforms: Content, Print, and Media. Each of our platforms collects personal information from clients where such information is required for the provision of a particular product or service.
Content and Print Our Content and Print platforms collect personal information that may include an individual’s name, address (postal and/or e-mail), telephone number as well as banking, financial, credit card and/or credit information.
As agents involved in data processing, variable imaging, and direct mailing, we may also obtain personal information from third parties such as our clients, list owners, and other media owners. Typically, the personal information is provided to us with specific instructions on how it is to be used. We make all reasonable efforts to ensure that such personal information is used only for the purposes stipulated and that it is subject to strict terms of confidentiality.
Media Our Media platform may collect personal information through surveys, questionnaires, and other means. In addition to name, address (postal and/or e-mail), telephone number, and transaction information, we may collect demographic information (i.e., age, gender, income, occupation, and education) and opinions of subscribers, or potential subscribers, to our magazines and other print properties. For more details, please visit our Magazine websites.
Modes of Collection St. Joseph collects personal information about clients through various applications and order forms, including credit applications, surveys and questionnaires, face-to-face interactions, and our online properties. For certain transactions, we may obtain personal information about a client from third parties, such as consumer reporting agencies.
USE OF PERSONAL INFORMATION St. Joseph Communications uses the personal information we collect to provide clients with our products and services, manage our business, and comply with regulatory and industry requirements. More specifically, we use personal information to create and maintain client accounts, communicate with our clients, supply clients with our products and services, and provide them with information about existing or new products and services that we believe would be of value to them. We may also use information about client interests and preferences, as well as feedback we receive from surveys, to improve our products and customer service. St. Joseph makes all reasonable efforts to ensure that information is used responsibly, and only for its intended purposes.
DISCLOSURE OF PERSONAL INFORMATION Content, Print and Media Depending on the nature of the products and services our clients require, our Content, Print or Media platforms may disclose personal information to other business platforms or divisions of St. Joseph, financial institutions, credit reporting agencies, and third party service providers such as data processing and marketing companies.
Media In addition to the disclosures outlined in the preceding paragraph, our Media platform may disclose personal information to advertisers, third party service providers including providers of marketing and promotional services, and other organizations that offer products or services that we believe would be of value to our clients.
Other We will request your express consent to the use and disclosure of your personal information for specific types of transactions on the application or other forms used in connection with those transactions. Where it is reasonable to imply your consent to the use and disclosure of your personal information in accordance with this Policy (e.g., in connection with a mailing for the renewal of a subscription), we may do so. Where it is reasonable, we may also imply your consent to the use and disclosure of your personal information in accordance with this Policy from continuing requests for our products and services now that you are knowledgeable about our personal information practices. We will obtain your express consent before using or disclosing your personal information for any purposes not identified in this Policy.
St. Joseph discloses personal information where we are required to do so by law and may disclose personal information to our purchaser or new corporate entity in the event of a sale, merger, or substantial restructuring of our business.
Subject to contractual and other legal obligations, you are entitled to withdraw your consent to our use and disclosure of your personal information. Specifically, if you prefer that we do not use or disclose your personal information for marketing and promotional purposes, please notify our Privacy Officer. Please note that your request may take three to four weeks to implement. We are legally bound to inform you that withdrawing your consent may preclude us from providing you with certain products or services.
In the case of personal information obtained from third parties, we will work with clients, list owners, and other media owners to fulfill the right of clients to know of the existence, use, and disclosure of their personal information and to provide access to that information.
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.
If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
• The specific pieces of personal information we have about you; • The categories of personal information we collected, sold, or disclosed for a business purpose about you within the last 12 months; • The categories of sources from which the personal information was collected; • The purposes for which the information was collected or sold; and • The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to direct your requests to privacyofficer@stjoseph.com.
If you are a California resident, you may submit a verifiable request for us to delete the personal information we have collected about you. The easiest way to submit a request for deletion is to direct your requests to privacyofficer@stjoseph.com.
California residents may opt out of the “sale” of their personal information, as defined by the CCPA. This does not include when:
• You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information; • We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information; • Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and • We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.
In these cases, the disclosure of your personal information would not be considered a “sale” under CCPA. We use and share your information as described in this privacy policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold personal information about you in the last 12 months and currently have no plans to do so in the future. However, we have provided you with a system to record your preference that your data not be sold in the future. You may make this request by directing your requests to privacyofficer@stjoseph.com.
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our owned and/or operated websites.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Similar to other commercial websites, our websites utilize a standard technology called “cookies” and web server logs to collect information about how our websites are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our websites, and the websites visited just before and just after our websites. This information is collected on an aggregate basis. None of this information is associated with you as an individual. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of non-electronic information, such as that received by mail and telephone. Information obtained through our websites is used for internal review, to improve the content of our webpages, and to customize the content and/or layout of our pages for each individual visitor; it is not shared with other organizations for commercial purposes.
St. Joseph will try to ensure that information about you is accurate, complete, and up-to-date. We may update the personal information in our records from time-to-time, where current information is required for the provision of a particular product or service. Please inform us of any change of name, address, or other information. Should you have questions about the accuracy of factual information we have collected about you, you will have access to that information 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.
If you have any questions about the collection, use, or disclosure of your personal information by St. Joseph, or if you simply want to know whether we have any of your personal information on file, you may contact our Privacy Officer by one of the methods outlined below. St. Joseph will respond to your requests for access in accordance with applicable privacy legislation. In the event that we refuse access to you, we will provide you with the reasons for our 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.
To access your personal information, inform us of changes you believe need to be made to that information, request that we investigate a concern you have about our personal information practices, or obtain further information about this Policy and the practices outlined herein, please contact: