This Privacy Notice applies to personal data SOTI Inc and its group of companies, collects through this website (www.soti.net), software products, and mobile applications. Below are highlights of our personal data handling practices.
Privacy Notice Highlights
1. Information We Collect
We collect your information from the following sources:
(i) information you give us when you fill out forms, such as during online purchases, customer service inquiries and surveys;
(ii) information from other sources, such as companies that help us to update our records; and
( iii) information that we collect automatically when you visit our website, such as information about your browser settings and other information collected through cookies.
2. How We Use and Disclose Your Information
(i) We use your information to provide products and services and to manage our business operations. For example, we use your information in order to fill your orders, answer your inquiries, authenticate you when you sign into online services, prevent loss and fraud, and analyze our business operations and website performance.
(ii) We use your information for marketing and promotional purposes, including with our promotional partners.
(iii) We combine all the information we collect other than information relating to your browsing history.
(iv) We share information with our affiliates who may be outside of our headquarters located in Canada and may be subject to laws that are different from those in Canada.
(v) We use third parties to assist us in our operations. We may share your information with these third parties in order to provide services to you such as invoicing.
3. Your Rights
(i) SOTI allows you to change your communication preferences with respect to e-mail newsletters and notifications of special offers and products.
(ii) You may also choose to withdraw your consent from further use of your information by SOTI. We may, however, retain information about your previous transactions for audit purposes, to ensure the integrity of our data and to fulfill legal requirements.
Detailed Privacy Notice
5. About Us
This website (soti.net) is operated by SOTI Inc. We are headquartered at 5770 Hurontario Street, Suite 1100, Mississauga, Ontario, L5R 3G5, Canada.
We have appointed a Data Protection Officer who is accountable for our personal data handling practices. Our Data Protection Officer is Mr. Sidney Rua. If you have a question or complaint about our personal data handling practices, please contact us using our web form using the following link: contact us .
In this Privacy Notice, the terms “we”, “our” and “us” mean SOTI.
6. Effective Date and Scope
This Privacy Notice is effective as of January 1, 2018.
This Privacy Notice governs our practices with respect to personal data we collect through www.soti.net and all affiliated product and international websites and applications.
7. What Personal Information Do We Collect?
Personal information is information that identifies you or could be combined by us or our service providers and affiliates with other information to identify you. This information may include your name and surname, e-mail address, your home address, your telephone number, location data, internet protocol (IP) address, a cookie ID, your image, and may include your age, your income and other similar information when associated with you. Personal information may also be information containing details as to whether you have opened our promotional e-mails or how you have used our website, if we can associate that personal information with you.
We collect personal information from you when you create an account, make a purchase, enter a contest or promotion, communicate with us using our web forms to make a request or ask a question, submit a product review, take a survey or otherwise submit personal information to us with your communication. For example, we will request your full name and other identifying information to process a support ticket when you submit a support request through our website. We will also ask you for contact information in order to either issue out your product or issue to the recipient that you designate.
We receive personal information about you from other sources. For example, we will receive information from shipping companies regarding whether items we shipped were delivered or undeliverable. SOTI may receive information from credit reference agencies which will add to the information we already have about you on order to help us provide, improve, and personalize our service to you. We may also acquire information about you from other promotional or marketing companies with whom you shared your information and whom you have consented and allowed to provide information to us.
If you provide SOTI information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can:
• give consent on their behalf to the processing of their personal data;
• receive on their behalf any data protection notices;
• give consent to the transfer of their personal data abroad; and
• give consent to the processing of their personal data
8. How Do We Use Your Personal Information?
We use your information to provide products and services and to manage our business operations. Some examples include:
(i) to register your account;
(ii) to authenticate you when you log into your account;
(iii) to process and fulfill your requests for products and services;
(iv) to communicate with you about your requests;
(v) to administer contests and promotions that you participate in;
(vi) to recommend or to offer you other products and services based on your inferred interests;
(vii) to post your product reviews;
(viii) customize our websites and its contents to your particular preferences;
(ix) improve our services;
(x) to communicate with you regarding customer service issues and any product recalls or warranty service; and
(xi) to protect the security or integrity of our websites and our business.
We retain your information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.
9. Monitoring and Recording Communications
SOTI may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
When you use SOTI’s website we may gather information about you through Internet access logs, cookies and other technical means. ‘Cookies’ are text files placed on your computer to collect Internet log information and user behaviour information. These are used to track website usage and monitor website activity and for other data processing reasons set out below.
For example, we may monitor how many times you visit the SOTI website or any of SOTI’s affiliated sites, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
11. Personalized Offers and Web Analytics
We also automatically collect information when you visit our website in order to customize your experience. For example, we collect information about what site referred you to our website, your browser type, operating system type and version, language, and your Internet Protocol (“IP”) address. We also collect information about how you browse through our website, including logging the pages you visit and the amount of time you spend on certain pages. We use this information for a number of technical purposes to ensure that our pages load correctly in your browser, as well as to personalize our offers to you. We also use this information to improve our website. For example:
(i) we use IP addresses to correct pages for your geographical location;
(ii) we log the frequency of visits to certain pages on our website and how visitors navigate through our website in order to detect problems, improve our website and learn about what products and services are of interest to our customers;
(iii) we use information about products that you have clicked on to make suggestions about other products or services that you might be interested in viewing; and
(iv) we track whether certain types of promotional e-mails were opened by you and whether you sought information about a particular product or service in order to make inferences about other products and services you might be interested in.
12. Your Ad Choices: Interest-Based Advertising
Our website uses small pixel files (small images) and cookies (small text files) to keep track of your browser so that you will be recognized when you visit other websites where our third-party ad management providers may show you advertisements from us based on your visit to our website. Some of these advertisements may be customized to particular products and services that you viewed or they may be based on inferences about products and services that you might be interested in. This is called “interest-based advertising”.
These pixel files and cookies are generally valid for a limited number of days (usually no more than 90 days) and are provided by our ad management providers. We require our ad management providers to participate in the Digital Advertising Alliance of Canada’s Ad Choices Program. Visit the Digital Advertising Alliance of Canada: Your AdChoices website (http://www.youradchoices.ca) where you can find out more information about digital advertising and how you can opt-out of interest-based advertising. You can also opt-out of interest-based advertising using the link provided in any of our interest-based advertisements. Look for the Ad Choices icon or other link provided.
Please note that if you opt-out of interest-based advertising you may still see advertisements from us on other websites. However, they will not be customized based on your browsing history on our website. In addition, we will continue to customize our offers of products and services to you when you are on our website unless you block cookies from our website. If you block cookies on our website, certain functions, such as the “shopping cart” will not function properly because our website must recognize you as you move through the checkout process.
13. Regarding Children and Minors
Our website and the services offered on our website are not directed to children under the age of 13 years. We will not knowingly collect personal information about a child under the age of 13.
We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions.
14. Do We Disclose Your Personal Information to Others?
We may share your personal information with our service providers and our corporate affiliates that help us with our business operations. For example, we will share information about your shipping address with companies that provide shipping services to us. We share information with service providers and/or our affiliates who provide us with marketing and promotional services. We require our service providers and our affiliates to keep your personal information secure. In addition, our service providers may not use or disclose personal information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.
We may also disclose your personal information if it is necessary for us to collect a debt from you or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so to help prevent unlawful activity.
15. Law Enforcement Requests
We will disclose personal information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information. If we receive a request from a police officer or other law enforcement agency for access to your personal information in the course of an actual or potential investigation, our policy is to require the police officer or law enforcement agency to obtain an order, subpoena or warrant, unless the information is urgently required to prevent serious bodily injury or serious damage to personal property. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your personal information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.
16. Keeping Data Secure
SOTI will use technical and organizational measures to safeguard your personal data.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us.
17. Storage Outside of Canada
Your personal information may be used or stored by us or our service providers and our corporate affiliates outside of Canada. We require that our service providers and our corporate affiliates safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
18. Storage Outside EEA
Your personal information may be used or stored by us or our service providers and our corporate affiliates outside of the European Economic Area for the purposes as described in this Privacy Notice (see ‘How Do We Use Your Personal Information?’ above). We require that our service providers and our corporate affiliates safeguard your personal information. Any transfer of your data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
19. Partner Portal
If you register for an account through SOTI’s Partner Portal, you will have the option to choose what marketing and promotional e-mails and communications you receive from us.
You can modify your information by logging into your account and making the requested changes. If you have consented to receiving such marketing from us or any company within our group, you can opt out at any time.
You may also contact us by one of many means to make a deletion request. Please note that SOTI still maintains information that you provided to us for audit purposes or to comply with our legal obligations. We may also de-identify your information in order to continue to use it for research and analytics purposes to understand our business, to make product improvements and to make available to third parties. We prohibit our employees and third parties from attempting to re-identify information that we have de-identified.
20. Retention of Personal Data
SOTI retains personal data for as long as necessary to provide the products, services, and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly.
21. What Rights Do You Have?
i) Right to Access Your Information
You can request a copy of your information which we hold. If you would like a copy of some or all of your information in a structured, commonly used and machine-readable format, please:
• email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below)
• provide proof of your identity, and
• identify the information you want a copy of, including any account or reference numbers, if you have them
SOTI may charge a small fee for this service where you request the information in a format other than what was provided.
ii) Right to Modify Your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:
• email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below)
• provide us enough information to identify you (e.g. account number, user name, registration details), and
• let us know the information that is incorrect and what it should be replaced with.
iii) Right to be Forgotten
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
• Email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to ten (10) days for this to take place.
• provide proof of your identity;
• let us know the nature of your complaint and how SOTI may be in contact with you, if at all (for example, you may be happy for us to contact you by email but not by telephone).
22. How Do You Access and Modify Your Personal Information or Make a Complaint?
If you have an account, log in to access and to modify the personal information stored with your account. If you have questions or concerns about other personal information collected by us and would like assistance accessing that information, or have any questions about this privacy notice, please contact us here, send an email to our Data Protection Officer at email@example.com or write to us at SOTI Inc., 5770 Hurontario Street, Suite 1100, Mississauga, Ontario, L5R 3G5, Canada.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
23. How Do We Protect Your Personal Information?
We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require our affiliates and any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.
24. Links to Third-Party Websites and Social Network Plug-Ins
You may be able to access third-party websites through links available on our websites. You may also connect to social networks such as Facebook, LinkedIn, Twitter, and YouTube. These links are provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites is at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Notice. Do not transmit personal information using those websites without reading the privacy policies governing those websites.
You may create links between our website and social networking sites. If you do so, we may be able to publish updates about our products and services to your social network account through the links that you establish. You may terminate those links at any time by modifying your social network account.
If you are logged into a social networking site when visiting our page, your visit to our website will be personalized based on your social networking profile.
25. Notice to Persons Outside of Canada
This Privacy Notice is layered so that there is a summary first of basic information that is presented in simple short paragraphs. A more detailed notice follows. Depending on the design and functionality of the website, the Privacy Notice sections could be hyperlinked to allow an individual to “drill down” on areas that are of particular concern to the individual.
26. Changes to the Privacy Notice
We may change this privacy notice from time to time. You should check this notice occasionally to ensure you are aware of the most recent version that will apply each time you access this website.