CSI WEBSITE PRIVACY POLICY
CMRRA-SODRAC Inc. (“CSI” or “we”) respects your privacy and has instituted the policies and practices described below to ensure that your personal information is handled in a responsible manner. This online privacy policy describes the types of personal information we may collect from you when you visit our website, which includes the Claims Website, how we use this information, and when we share it with third parties or our affiliated companies. The information on this website is subject to change from time to time. Any changes to the privacy policy will be reflected on this page so that you can be aware of what information we collect and how we are using and/or disclosing it.
By submitting your personal information to CSI through this website, you consent to the collection, use and disclosure of your personal information as set out in this privacy policy and you agree that such consent has been made on an informed, manifest, free and enlightened basis.
Your Privacy Rights
In Canada, organizations engaged in the collection of personal information in the course of commercial activities must comply with the Personal Information Protection and Electronic Documents Act (the “Act”).
CSI is responsible for the personal information it collects, uses, maintains and discloses. To ensure this accountability, CSI has developed this policy, and trained our staff about our policies and practices.
What is “Personal Information?”
Personal information is any information that identifies you, or by which your identity could be deduced. It does not include your name, business address, business title, professional designation(s) or business telephone number.
Automatic information is information that we collect automatically whenever you interact with this website such as your IP address, the type of computer you use, and the web browser you use. An IP address is a number assigned to your computer when you connect to the Internet. Each time you visit this site, our web server may automatically recognize and collect this information. Automatic information also includes “cookies” and “web beacons”. A “cookie” is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Among other things, cookies provide a means for us to keep track of your online patterns and preferences. By understanding which areas of the site you visit, cookies allow us to present information, products and services that are of personal interest. A cookie will not allow us to learn any personal information (such as your birth date and address) that you have not otherwise disclosed. Most browsers are initially set up to accept cookies. You can change your browser so that it will not automatically accept cookies. However, if you do so, it is possible that some portions of the site may not function as intended. “Web beacons”, also known as clear GIFs or single-pixel GIFs, are small image files that we may place on web pages and within web-based email newsletters that we send. Working in conjunction with cookies, web beacons allow us to accurately count the number of unique users who have visited a specific page and the number of times those pages are displayed.
Location of Personal Information
All records of your personal information will be kept in Canada.
Collection and Use of Your Information
We will use your personal information to communicate with you and in connection with the development and maintenance of accurate records of the ownership and administration of copyright in musical works. Where applicable, we may also use it to verify and/or process claims submitted by users for unpaid royalties for the use of musical works in relation to the Pending List Class Action and pursuant to the Order (each as defined below).
Disclosure of your Personal Information
CSI may disclose your personal information as follows:
- when disclosure is required by law – for example, in connection with a proceeding before the Copyright Board of Canada or if a court issues a subpoena;
- to its affiliates, including Canadian Musical Reproduction Rights Agency Ltd. (“CMRRA”), Society for Reproduction Rights of Authors, Composers and Publishers (SODRAC) Inc. and SODRAC 2003 Inc. (together, “SODRAC”), their respective affiliates;
- to legal, financial and other professional advisors of CSI, CMRRA and SODRAC;
- prospective parties, ultimate parties and their respective legal, financial and other professional advisors, in connection with any transaction or prospective transaction consisting of the purchase, sale lease, merger or amalgamation or any other type of acquisition or disposal of, or the taking of a security interest in respect of, CSI, CMRRA, SODRAC, or a portion thereof, or any strategic alliance or joint venture involving any of CSI, CMRRA or SODRAC or their respective affiliates; and
- in any other circumstances where you have consented to the disclosure.
Part of this website is used for the submission of claims by rightsholders for compensation pursuant to the Order of the Ontario Superior Court of Justice (the “Court”) dated May 30, 2011 in relation to Northey v. Sony Music Entertainment Canada Inc. et al. (the “Pending List Class Action”), certifying the class action for settlement purposes and approving the settlement of the action (the “Order”). In addition to the permitted disclosure already set out above, CSI may disclose the personal information it collects through this process of claims submission to class counsel, to the Court, or to Sony Music Entertainment Canada Inc. (formerly Sony BMG Music (Canada) Inc.), EMI Group Canada Inc., Universal Music Canada Inc. or Warner Music Canada Co.
CSI will not disclose your personal information to any third party to enable them to market their products and services.
Use of Third Party Service Providers
If we engage third party agents, mandataries or service providers, including but not limited to consultants and data processors (collectively, “Service Providers”), to provide services to us (including, without limitation, hosting services, computer back-up services and archival file storage), we will transfer personal information to these Service Providers as necessary for them to process this information for us. All Service Providers handling personal information on behalf of CSI will be required to maintain the confidentiality of the information, comply with this privacy policy and follow reasonable security precautions in relation to the personal information that is sent to them for processing;
Updating Your Information
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If any of your information changes or if you believe it is inaccurate, please inform us so that we can make any necessary changes.
Security
CSI takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
- premises security;
- restricted file access to personal information;
- deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access; and
- internal password and security measures.
Access to Your Personal Information
You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
Denying Access to Your Personal Information
Your rights to access your personal information are not absolute. CSI may deny access when denial of access is required or authorized by law, including the following situations:
- information is protected by solicitor/client privilege;
- providing access would reveal confidential commercial information;
- granting access could threaten the life or security of another individual;
- the information was generated in the course of a formal dispute resolution process; or
- information was collected without the consent of the individual and collection with the knowledge of consent of the individual would have compromised the availability or the accuracy of the information and the collection was reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
Communicating with Us
You should be aware that email is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.
Request for Access
If you have any questions, or wish to access your personal information, please write to our Privacy Officer at privacy@cmrrasodrac.ca.
Website
Our website contains links to other sites, which are not governed by this privacy policy.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. In some instances, we may employ third-party software or services (e.g., Google Analytics) to do so. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.