Privacy Policy


Toronto, Ontario, Canada


  1. Privacy Statement
  2. ShesConnected’ Commitment: Adhering to the 10 Privacy Principles
  3. Consent
  4. Consent to Share and Disclose Information, Including International Data Transfers
  5. Consent to Electronic Notice If There is a Security Breach
  6. Type of Information We May Collect
  7. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
  8. Children and Data Collection
  9. Our Use of Your Personal Information
  10. Collection and Use of Employee Personal Information
  11. Verifications of Employment
  12. Mobile Information
  13. Forward-to-a-Friend and Refer-a-Friend
  14. Opt-Out of Email and Mobile Updates
  15. Sharing of Personal Information
  16. Security
  17. Phishing
  18. Storage, Retention and Accuracy of Personal Information
  19. Access, Control and Update Information About You
  20. Contact Information
  21. Links to Non-ShesConnected Web Sites and Third Parties
  22. Social Media and Online Engagement
  1. Privacy Statement

Your privacy is very important to us. This privacy policy discloses how ShesConnected Multimedia Inc. (“ShesConnected”) collects, protects, uses and shares personal information gathered about you. Our privacy practices are consistent with:

  • Canada’s federal privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
  • The European Union Data Protection Directive and the U.S. Department of Commerce Safe Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
  • Fair information practices established by the Organization for Economic Co-operation and Development (OECD).
  • The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework.
  • Applicable country, national, state and local data protection laws (some country’s laws require country specific information in a privacy policy.

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. ShesConnected respects your privacy, and that of our employees, job applicants, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

This Privacy Policy explains ShesConnected’ practices regarding the information collected online on behalf of ShesConnected and our clients.

In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies. Please note that this Privacy Policy does not govern the privacy policies and procedures of ShesConnected clients or suppliers.

  1. ShesConnected’s Commitment: Adhering to the 10 Privacy Principles

In Canada, “Fair Information Practices” regarding your personal information are reflected in a series of 10 Privacy Principles developed by the Canadian Standards Association and incorporated into Canadian federal privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

ShesConnected adheres to the 10 Privacy Principles as follows:

Principle 1 — Accountability

ShesConnected is responsible for personal information under its control and has designated a Privacy Officer who is accountable for ShesConnected’ compliance with this Privacy Policy and the applicable privacy legislation for Canada and its provinces.

Principle 2 — Identifying the Purposes for collection of Personal Information

ShesConnected will identify the purposes for which your personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which ShesConnected collects, uses, and discloses your personal information are described below in this Privacy Policy. If we intend to collect, use or disclose your personal information for additional purposes, we will seek your consent.

Principle 3 — Consent for Collection, Use of Disclosure of Personal Information

ShesConnected will obtain your informed consent for the collection, use, or disclosure of your personal information, except as permitted by law.

Principle 4 — Limiting Collection of Personal Information

ShesConnected will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by ShesConnected. ShesConnected will collect your personal information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.

Principle 5 — Limiting Use, Disclosure, and Retention of Personal Information

ShesConnected will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. ShesConnected will retain your personal information only as long as necessary to fulfill the identified purposes.

Principle 6 — Accuracy of Personal Information

ShesConnected will attempt to make sure that your personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 — Security Safeguards

ShesConnected will protect your personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 — Openness Concerning Policies and Practices

ShesConnected will make readily available to you specific information about our policies and practices relating to the management of personal information.

Principle 9 — Individual Access to Personal Information

Upon written request, subject to certain exceptions, ShesConnected will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 — Challenging Compliance

You have the right to address a challenge concerning compliance with this Privacy Policy to ShesConnected’ Privacy Officer.

  1. Consent

This Privacy Policy applies to all information gathered for and on behalf of ShesConnected, whether in writing, verbally or electronically, through any website operated by or on behalf of ShesConnected, including, but not limited to, together with any and all future websites that are operated by or on behalf of ShesConnected. By using, or participating in any program or service managed by ShesConnected, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact the Privacy Officer at


  1. Consent to Share and Disclose Information, Including International Data Transfers

In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to ShesConnected sharing the information that you have provided, as described herein. ShesConnected may share information with its subsidiaries and clients. ShesConnected may also share information with companies that provide support services to it, such as credit card processors, mailing houses, web hosts, technical support providers, fulfillment centers or other service providers or for enforcing or investigating transactions or business operations, because these companies may need information about you in order to perform their functions. These companies are not authorized to use the information ShesConnected shares with them for any other purpose, but ShesConnected does not control these companies. You agree that ShesConnected and those with whom it shares information (the “Recipients”) may disclose and transfer your information worldwide, including in and outside the United States, the European Economic Area, Canada, and other jurisdictions serviced by ShesConnected, for any purpose relating to ShesConnected’ operations and programs.

  1. Consent to Electronic Notice if there is a Security Breach

If ShesConnected or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that ShesConnected, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address ShesConnected or the Recipient has for you, in the good faith discretion of ShesConnected or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

  1. Type of information we may collect

Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Insurance Number (hereinafter “SIN”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: name, home address, home postal code, home telephone number, mobile phone number, email address, Social Insurance Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.

ShesConnected takes measures to maintain the confidentiality of your SIN to protect your SIN from unlawful disclosure, and to limit access to your SIN. ShesConnected will not make your SIN available to the general public, print your SIN on any card, require you to provide your SIN to access any products or services, transmit your SIN over the Internet unless the connection is secure or your SIN has been encrypted, or requires the transmittal of your SIN to access our Website without requiring additional authentication.

Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.

Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.

  1. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information

Cookies – in addition to Personal Information, we use data collection devices such as “cookies” on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you may not have access to many features available on our website.

Web Beacon – Also called a Web bug or a pixel tag or a clear GIF. Used in combination with cookies, a Web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel,that is placed on a Web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values.

Web beacons are typically used by a third-party to monitor the activity of a site. A Web beacon can be detected by viewing the source code of a Web page and looking for any IMG tags that load from a different server than the rest of the site. Turning off the browser’s cookies will prevent Web beacons from tracking the user’s activity. The Web beacon will still account for an anonymous visit, but the user’s unique information will not be recorded.

Internet Protocol (IP) Address – an Internet Protocol (IP) Address is associated with your computer’s connection to the internet. ShesConnected may use your IP address to help diagnose problems with ShesConnected’ server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Website. ShesConnected does not link IP addresses to any Personal Information.

Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that ShesConnected administers, ShesConnected will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, ShesConnected may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although ShesConnected may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

  1. Children and Data Collection

We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at We will use reasonable efforts to promptly delete the child’s information from our servers.

  1. Our Use of Your Information

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

  1. Collection and Use of Employee Personal Information

ShesConnected also collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to ShesConnected and its affiliates facilities and computer networks, employee profiles, employee directories, Human Resource recordkeeping, and other employment related purposes.

It is the policy of ShesConnected to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

  1. To comply with municipal, regional, provincial or federal agency requests;
  2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
  3. Third parties with which ShesConnected has contractual agreements to assist in administration of company sponsored benefits.
  1. Verifications of Employment

Prospective employers, government agencies, financial institutions, and residential property managers routinely contact ShesConnected requesting information on a former or current employee’s work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.

For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee’s signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.

  1. Mobile Information

Mobile: Information We Collect

  • Personally identifiable information (e.g. Name, email address) we collect consists only of what you share with us. For example, certain products may ask for this type of information so that we may contact you by phone or email at your request. You choose what, how, and when you want to share.
  • If you use any location-enabled products, you may be sending us location information. ShesConnected does not store or use this information other than to provide the service you requested. For example, a mobile product may use GPS data to find a nearby restaurant you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.
  • Web-enabled mobile applications may use cookies or web beacons and other methods to customize your browsing experience.
  • Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve consumers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to ShesConnected. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
  • Use of 3rd party services such as social sharing sites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. ShesConnected does not capture or store your login information or other personally identifiable information for these services, however session info or cookies may be stored.

Mobile: How We Use Collected Information

  • We use the information to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.
  • Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.

Mobile: Information sharing

  • ShesConnected does not share any collected information with 3rd parties with the following exceptions:
  • ShesConnected may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
  • All requests are sent through your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policies for additional information.
  • Certain mobile products and services and manufacturers allow you to interact and share your information with others. For example, you may want to Tweet or post to your Facebook page
  • Content from a ShesConnected mobile application. Consult your mobile device manufacturer, or mobile product or application developer’s privacy policies for additional information.
  1. Forward-to-a-Friend and Refer-a-Friend

You may use a referral feature (either on a web page, in an e-mail, from a banner ad or other communication) to inform a friend about a ShesConnected web page or promotion. ShesConnected may use any e-mail address provided when using this referral feature to send both an initial e-mail and a subsequent e-mail to recipients about the particular promotion, product, or service in which you indicated your “friend” may have an interest.

  1. Opt-Out of Email and Mobile Updates

You may have the opportunity to elect to receive email and mobile communications from ShesConnected. ShesConnected will only email you or send you mobile alerts if you elect to receive them. If at any time you decide you would rather not receive these types of communications from ShesConnected, you can opt-out by clicking the unsubscribe link at the bottom of any ShesConnected email and update the contact preferences for your account. For mobile marketing, you may opt-out by following the instructions provided in the text messages you receive, or contact the Privacy Officer at

  1. Sharing of Personal Information

We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, ShesConnected will not share Personal Information with a third party, unless a consumer requests, consents to such disclosure, or disclosure is required or authorized by law. ShesConnected reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. ShesConnected also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of ShesConnected or of any of the business or assets or shares of ShesConnected or a division thereof in order for a user to continue to receive the same products and services from the third party.

  1. Security

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

We safeguard your Personal Information on the Internet by using industry-standard practices. Although “guaranteed security” does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

  1. Phishing

Identity theft and the practice currently known as “phishing” are of great concern to ShesConnected. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or Social Insurance Number in a non-secure or unsolicited e-mail or telephone communication.

  1. Storage, Retention and Accuracy of Personal Information

ShesConnected takes all reasonable steps to ensure that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

ShesConnected will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to ensure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

ShesConnected may store your Personal Information in its databases located in the United States and/or other countries outside of Canada. Additionally, some of our service providers may reside in the United States or other countries outside of Canada and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by ShesConnected.

  1. Access, Control and Update Information About You

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at

  1. Contact Information

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task. If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at 647-969-8763 ; by email at:; or by mail at ShesConnected Multimedia Corp. 1920 Yonge Street, Suite 200 Toronto, Ontario M4S 3E2 Canada. We will address your concern and attempt to resolve any problem.

  1. Links to Non-ShesConnected Web Sites and Third Parties

Please note that websites may contain links to other websites for your convenience and information. ShesConnected does not control those sites or their privacy practices, which may differ from ShesConnected’ privacy policy cannot and does not apply to external websites. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the ShesConnected privacy policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with ShesConnected; that sharing is governed by that third party’s privacy policy.

  1. Social Media and Online Engagement

ShesConnected uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, ShesConnected uses several third-party platforms including, but not limited to, Facebook, Twitter and LinkedIn. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by the SUBWAY® Group. When interacting with the ShesConnected presence on those websites, you may reveal certain personal information to ShesConnected or to third parties. Except when used by ShesConnected employee’s for the purpose of responding to a specific message or request, ShesConnected will not use, share, or retain your personal information.

At this time, ShesConnected has two Social Media Accounts,

Facebook: On the Facebook page, ShesConnected staff posts news and other items of interest to individuals. If you have a Facebook account or ‘Like’ Facebook page, you can post comments or click on the ‘like’ option for individual entries. If you comment or click on the ‘like’ button, personally identifying information will be visible to ShesConnected staff and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. You can completely avoid displaying any personally identifiable information by not creating an account, not posting comments and not clicking on the ‘like’ options in Facebook. ShesConnected does not collect, use or disclose any information about visitors who comment or ‘like’ the ShesConnected site. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to the ShesConnected employees who require this information to perform their duties. The Facebook privacy policy is available at:

Twitter: ShesConnected uses Twitter to send short messages (up to 140 characters) or ‘Tweets’ to share information about ShesConnected with visitors and respond to comments and inquiries sent via Twitter to ShesConnected. While visitors may read the ShesConnected Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) the ShesConnected Twitter feeds must create a Twitter account at To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings at the Web site. ShesConnected staff members monitor the number of subscribers and respond to comments and queries via Twitter, but the staff never takes possession of the personal information belonging to Twitter followers. ShesConnected does not collect, maintain, disclose or share any information about people who follow SUBWAY® on Twitter. The Twitter privacy policy is available at:

LAST UPDATED: 09-29-2015