Effective date: May 27, 2024

Pathway Communications, its subsidiaries, affiliates, successors and assigns (“Pathway”, “We”, or “Us”), does not collect personal information about individual users (“You”, “you”, or “Client”) except when such personal information is provided to us on a voluntary basis. Your privacy is important to Pathway and we are committed to protecting and safeguarding your personal information. Personal information may be gathered from the registration process for subscription or products and services and in connection with content submissions, a contest or sweepstakes registration, postings in discussion areas or other public areas, suggestions, voting/polling activities and transactional areas. We may request personal information from time to time in order to enable you to participate in and enjoy various Pathway product and service offerings. This statement and the Privacy Code disclose Pathway’s privacy practices and policies. By using Pathway’s products and services, you agree to be bound by this Privacy Policy.

1. Personal information

1.1. Personal information is information about an identifiable individual. This includes information about your product and service subscriptions, usage, billing records, credit information and any recorded complaints. Please note that, pursuant to federal privacy legislation, publicly available information – including a directory listing of your name, address, telephone number and electronic address – may be collected, used and disclosed without your consent. The client’s contact information may be used to contact the visitor when necessary and may be shared with other affiliated companies within Pathway who may want to contact our visitors. Only Pathway has access to your personal information.

2. Collection and use of information

2.1. We collect and use personal information about you and your use of our products and services and our web sites (the “Information”) for the following purposes:

• 2.1.1. To consider initiating and to establish, maintain and develop a responsible commercial relationship with you in connection with our offering and servicing of products and services;
• 2.1.2. To administer billing and accounting services and security measures in relation to your business with us;
• 2.1.3. To monitor your client history, evaluate your credit standing, to share or exchange credit reports and information with credit reporting agencies and credit bureaus and to collect any unpaid amounts owing to us;
• 2.1.4. To promote and to market additional products, goods and services offered by us, including by means of direct marketing;
• 2.1.5. To provide you with newsletters via email;
• 2.1.6. To provide personalized features and services;
• 2.1.7. To analyze traffic and use of the Pathway web sites in order to determine which features and services people like and don’t like so that we can improve what we do;
• 2.1.8. To prepare aggregated user statistics or information summaries in order to describe our services to third parties such as prospective business partners and advertisers and for other lawful purposes;
• 2.1.9. To present web page advertisements that we hope will be of particular interest to you;
• 2.1.10. To contact you to fulfill distribution of prizes if you win a promotion or contest;
• 2.1.11. To comply with any legal and regulatory requirements, including requirements;
• 2.1.12. To manage and develop our business and operations, including personnel and employment matters;
• 2.1.13. Requests of government agencies or pursuant to a subpoena or other legal proceeding.

2.2. If you choose not to provide the requested information, Pathway may not be able to offer you some of the personalized products and services that depend on this type of information to function. We may request you to provide additional personal information such as your date of birth, SIN number, health card number or drivers license number. This information is obtained solely for security purposes such as identifying you when you call us with respect to your account and services. You do not have to provide it to us, but if you do, it will help us to ensure that we take instructions with respect to your account only from you.

2.3. You consent to our collection from, verification with and communication to, any third party and our use of, the Information for the above purposes.

2.4. You also authorize these parties to give us the Information. In addition, you agree that we may disclose Information to:

• 2.4.1. any person who, in our reasonable judgment, is seeking the Information as your agent or
• 2.4.2. a person involved directly or indirectly in supplying the product or service to you, including, without limitation, our sales and marketing agents, to the extent the Information is required and used only for such purposes, including the efficient supply of products and services to you, and provided that such person is required to keep the Information confidential; or
• 2.4.3. a person retained by us to collect amounts which you owe us or to enforce our rights under our terms of service, if the Information is required for, and is to be used only for that purpose and that person is required to keep such Information confidential.

2.5. We may also use Information in our records for as long as it is needed for the purposes described above and your consent remains valid after the termination of our relationship with you.

2.6. We reserve the right to conduct statistical analyses of your behavior and characteristics in order to measure interest in and use of Pathway’s products and services, Pathway’s proposed products and services, the Pathway web sites and the Internet and to provide advertisers with information such as the number of users that have been exposed to or clicked on their advertising banners.

2.7. We will provide only aggregated data from these analyses to third parties. Also, you are advised that we may permit third parties to offer subscription and/or registration-based services through the Pathway web sites. We are not responsible for any actions or policies of such third parties and you should check the applicable privacy policy of each such third party when providing personal information. We are also not responsible for any actions of any third party sites that you access through the Pathway web sites and the Internet and you are responsible for checking the applicable privacy policy of such third party sites.

3. Use of “Cookies”

3.1. “Cookies” are parcels of text sent by a server to a web browser and then sent back unchanged by the browser each time it accesses that server. Cookies are used for authenticating, tracking, and maintaining specific information about users. We use cookies so that we may: Estimate our audience size. Your browser is given a unique cookie that helps us determine whether yours is a repeat visit or a first visit. Compile aggregate data that will permit content improvements and targeted advertising. Cookies cannot extract information from your hard disk. You should be aware that we cannot control or prevent the use of cookies or any information obtained through such cookies by advertisers or third party content providers. If you do not want information collected through the use of cookies, most browsers permit you to disable the cookie feature. However, you are advised that cookies may be required for the use of certain features on the Pathway web sites.

4. Access to information

4.1. Occasionally, we may or any of our advertisers or partners may host a contest or promotion where it will be your option to enter and your option to provide the requested information. Data collected during a promotion or contest is typically shared with the sponsor or co-sponsor. If you do not want your data to be shared, you can choose not to participate in the promotion or contest. Children under the age of majority must get parental or legal guardian permission before providing any information for contests or promotions.

4.2. Pathway may disclose, on a confidential basis, to any third party with whom we have business relations, certain relevant information relating to your dealings with us and our products and services. Pathway does not sell or redistribute your Information.

4.3. Pathway may enter into third party agreements from time to time for the purposes of providing you with goods and services we think may interest you and may share your Information with these third parties solely for these purposes. We may share Information with potential business partners of, or investors in, Pathway. All such disclosure is made solely under a confidentiality agreement with the third party who is required not to disclose or use the Information for any other purpose other than is necessary to fulfill the agreement with Pathway.

4.4. Please note that Pathway’s web sites contain links to other sites and occasionally allow other sites to be co-branded with Pathway. We cannot represent or guarantee that other sites’ privacy policies conform to our own, so please note that sites linked from Pathway’s web sites may have privacy policies which differ from those of Pathway.

4.5. Pathway’s privacy policy does not cover third party data collection and Pathway does not assume any responsibility for the actions of any third parties. You should make every effort to read the individual privacy policies of the partners, advertisers or co-sponsors. You may opt out of sharing your information with such partners, advertisers or co-sponsors by choosing not to use their service or content.

4.6. Any submissions to Internet discussion areas or other public Internet areas on the Pathway web sites are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions on the Internet.

5. Mailing lists

5.1. We reserve the right to contact you regarding account status, billing notifications, account renewal, changes to any Pathway product and service offerings, and other matters relevant to the underlying service and/or the personal information collected. When your Internet account is established with us, your primary email address and subsequent email addresses created by you are automatically subscribed to the following mailing lists:

• 5.1.1. Emergency systems status notifications, network alerts and virus warnings from Technical Support and Customer Services
• 5.1.2. Special offers, product upgrades, new service or product offerings and marketing newsletters from Pathway

6. Security measures

6.1. Pathway has reasonable security measures in place to protect against loss, misuse and interception by third parties. While Pathway cannot guarantee that loss, misuse or alteration to data will not occur, we make every effort to prevent such occurrences.

6.2. Pathway assumes no liability for interception, alteration or misuse of information transmitted over the Internet. We will keep your Information in secure data storage in order to safeguard it from unauthorized access. We will keep your Information for as long as it remains necessary or relevant for the identified purposes or as required by law.

6.3. You are responsible for the security of your Internet Username and Password. At the time of signing up for new Internet services, Pathway may provide new clients with a standard password that is required to activate the service. Pathway strongly recommends that you do not divulge your Username and/or Password to anyone. You should log out of your browser at the end of each computer session to ensure that others cannot access your personal information and correspondence, especially if you share a computer or are using a computer in a public place. You should also be aware that when personal information is voluntarily disclosed (i.e. Username, e-mail address, etc.) in the discussion areas or other public areas of the Pathway web sites and the Internet, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control.

6.4. Pathway cannot ensure and/or warrant the security of any Information transmitted online. You are advised that conveying personal information online is done at your own risk and you remain solely responsible for maintaining the secrecy of Usernames, Passwords and/or any account and/or credit information.

6.5 We reserve the right to change this Privacy Policy at any time and you are advised to check this page periodically for any changes. Your continued use of Pathway’s products and services, the Pathway web sites and the Internet will constitute your acceptance of such changes.

7. Summary of privacy principles

7.1. In compliance with the Personal Information Protection and Electronic Documents Act that came into effect on January 1, 2001, Pathway has adopted for the management of personal information of its clients and employees that we collect, use or disclose. These principles are in accordance with the Personal Information Protection and Electronic Documents Act and the ten principles of Canadian Standards Association Model Code for the Protection of Personal Information (the “Privacy Principles”).

7.2. Principle 1 – Accountability

• 7.2.1 Pathway is responsible for personal information under their control and shall designate one or more persons who are accountable for compliance with the following principles.

7.3. Principle 2 – Identifying Purposes

• 7.3.1 The purposes for which personal information is collected shall be identified by Pathway at or before the time the information is collected.

7.4. Principle 3 – Obtaining consent

• 7.4.1 The knowledge and consent of a clients or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

7.5. Principle 4 – Limiting Collection

• 7.5.1 The collection of personal information shall be limited to that which is necessary for the purposes identified by Pathway. Pathway shall collect personal information by fair and lawful means.

7.6. Principle 5 – Limiting use, disclosure and retention of personal information

• 7.6.1 Pathway shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as necessary for fulfilment of those purposes.

7.7. Principle 6 – Accuracy of personal information

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

7.8. Principle 7 – Security safeguards

• 7.8.1 Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

7.9. Principle 8 – Openness concerning policies and Practices

• 7.9.1 Pathway shall make readily available to clients and employees specific information about its policies and practices relating to the management of personal information.

7.10. Principle 9 – Client and employee access to personal information

• 7.10.1 Pathway shall inform a client or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.

7.11. Principle 10 – Challenging compliance

• 7.11.1 A client or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the Pathway’s compliance with the Code.