VECIMA WEBSITE PRIVACY POLICY

Effective as of August 23, 2022

Vecima Networks Inc. takes your privacy seriously. This privacy notice (“Privacy Notice”) describes the types of information that are identifiable to a particular person (“personal data”) that Vecima Networks Inc. (“Vecima”, “we”, “us”, and “our”) collects from you or about you when you use or access our website (http://vecima.com/) (the “Site”) and any customer platform (the “Platform”) (collectively, “Services”) for our customer relationship and databases. This Privacy Notice also describes our practices for using, sharing, and protecting that information. Please read this Privacy Notice to ensure you are fully informed. Your use of this Site or the Platform constitutes your acceptance of and agreement to this Privacy Notice.

Vecima reserves the right to change this Privacy Notice at any time. If we decide to change the Privacy Notice, we will post the changes on the Site and the Platform so that you are aware of the changed Privacy Notice. We encourage you to check the Site and Platform for revisions to the Privacy Notice. To stay current on our practices, please update your email address with us if it changes.
We are a personal data Processor with respect to information related to our business partners and clients.

This Privacy Notice is considered part of the Terms and Conditions of Use (the “Terms”) at http://vecima.com/terms-of-service/. This Privacy Notice does not apply to any activity on third-party websites and mobile applications that may link to the Site. We do not control third-party websites and applications and are not responsible for their actions or privacy practices.
Services offered by Vecima are not directed to individuals under the age of thirteen (13). Vecima does not knowingly collect personal data (as defined below) from individuals under thirteen (13) years of age. No information should be submitted to or posted to the Vecima website by visitors younger than 13 years of age.

Types of Personal Data We Process

  1. Information Provided By You. We may collect and retain personal data, from you or your devices provided to us when you visit the Site or the Platform, such as your name, phone number, email address, mailing address, and company name, when you voluntarily submit service or other requests to us, purchase our services or products, subscribe to email alerts or newsletters, or communicate with us, such as to provide feedback (i.e., surveys), request company information or support, or seek additional information. You are not required to provide your information at any time while visiting the Site or the Platform; however, you may be required to provide your information for us to process your request. You warrant that, when you submit the personal data of a third party, you have obtained consent from that third party to provide such information to us.
  2. Automatically Collected Information. The Site and Platform may automatically track traffic data, such as Internet Protocol (IP) addresses. Examples: domain server, type of computer or device, user settings, cookie identifiers, mobile carrier, browser or device information, location information (including approximate location derived from IP address), IDFA (identifier for advertisers) and other unique identifiers, and Internet service provider. This traffic data may include the frequency and duration of your visits to the Site and Platform, what pages you visit and the features you use, and other information about how you use the Site and Platform. Additional details about how we use cookies, browser information and tracking technology is provided under “Cookies and Tracking Technologies” below.
  3. Personal Data Obtained From Third Party Sources. We may receive personal data about you from third party sources where we are performing customer service for our business-to-business clients, you have provided consent or as otherwise legally permitted or required under applicable law.

Purposes For Processing

As a processor, we manufacture equipment that processes your personal data on behalf of our clients in order to provide you with telecommunication services. Our clients own and manage the equipment we create once it is installed in their networks.
As a controller, we process your personal data in order to provide you the business services and equipment you request from us in a personalized and efficient way.

We and others acting on our behalf may use and retain the information that we gather for a variety of business purposes. For example, we may use the information that we gather to contact you, provide you products or services you requested, send you information you have requested, provide customer service, or to diagnose or address technical problems in the operation of our Site or Platform. We may also use the information that we gather in order to technically evaluate and improve our Site, Platform and Services or to develop new products or services. We may use third party analytics tools on our Site and Platform, such as Google Analytics, in order to better understand our website visitors and their interests. To learn more about Google Analytics, see www.google.com/policies/privacy/partners/. In addition, we may use the information we collect or receive to:

  1. Send you relevant communications, promotions and offerings about our new products and Services;
  2. Assist in the re-targeting or distribution of future campaigns;
  3. Deliver highly targeted or personalized offers based on past activity or attributes;
  4. Communicate with you through telephone, email, direct mail or using other contact information we may have about you, as permitted by law;
  5. Comply with legal obligations or legal process;
  6. Monitor for and protect against or prevent fraud or other unauthorized or illegal activity;
  7. Protect the security and integrity of our business, brand, customers, and service providers; and/or
  8. Other purposes where we have individual consent.

We may also combine or aggregate any of the information we collect through our Services or obtain about you from our affiliates and other third parties for any of these purposes.

Third Parties

You understand that if you use our Site or Platform, your personal data is also processed by third parties that process your data on our behalf in order to provide you our tools and services and to improve them. For example, we rely on third parties for certain activities, such as payments, storage of data, and website analytics. Moreover, we rely on third parties to follow certain of your actions on our Site or Platform in order to better understand how Vecima is used.

We share information to support the purposes for which the information was acquired or as described or permitted by this Privacy Notice. For example, we may share information with our third party service providers who help us operate our Site and Platform (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site or Platform), or who otherwise support our business. Our service providers may include development, maintenance, and support of the Services, hosting, data management, storage, payment processing, delivery of the services, the distribution of email and mobile messages, promotions, advertising services, and market research and analysis. Parties with whom we may share personal data are contractually required to use and disclose such information only for the permitted purposes set forth in the contract in accordance with this Privacy Notice as well as use reasonable security measures to protect personal data from unauthorized access and use.

We may also share information, including personal data, under the following circumstances:

  1. Vecima may sell transactional data with third parties for cross-contextual behavioral advertising purposes;
  2. As may be necessary to protect the rights and interests of Vecima, our affiliates, third party business partners and service providers, and our and their respective employees, customers, users, or any other person or entity;
  3. To enforce any applicable terms and conditions and/or other agreements;
  4. In aggregated or other non-personally identifiable form to build predictive models that use anonymized data to improve future targeted promotions and advertising;
  5. In the event of a corporate transaction, including a merger, acquisition, financing, dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of Vecima’s business or assets. In the event of an insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset of Vecima. If another third party acquires Vecima or any of its business operations, whether through stock or asset purchase, such third party will possess the Information, including personal data, collected by us and will assume the rights and obligations with respect thereto as described in this Privacy Notice;
  6. To comply with law, a court order, or other legal process, or in connection with a legal investigation; and/or
  7. In accordance with your consent.

Please note that other parties may collect personally identifiable information about your online activities over time and across different websites when you use our Site and Platform.

What Choices Do I Have About My Personal Data?

Vecima values your privacy and strives to provide you with choices regarding the handling of all personal data you choose to provide to us. You may choose not to provide us with your personal data if you don’t agree with our practices, as set forth in our Privacy Notice. Where we are the controller of your personal data, the following applies:

  1. You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us.
  2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge.
  3. If you have consented to the processing of your personal data, you have the right to withdraw that consent at any time.
  4. You have the right to request that your personal data be deleted if they are no longer required in light of the purposes outlined above or if you withdraw your consent. This request will be evaluated by Vecima against:
    1. Overriding interests of the Vecima or any other third party;
    2. Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
  5. Instead of deletion you can also ask that Vecima limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed above but you need them to defend yourself in judicial proceedings.
  6. You have the right to object to the processing on grounds relating to your particular situation. However, you can always object to processing for direct marketing purposes free of charge and without justification.
  7. When we process your personal data based on your consent or in order to perform a contract, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller.
  8. You have the right not to be subject to a decision solely based on automated processing, which produces legal effects concerning you or when this decision similarly significantly affects you, unless these decisions are made as a consequence of our agreement in order to provide you with the services requested by you or when we asked your explicit consent for this.
  9. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@vecima.com. This e-mail in which you request to exercise a data subject right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and, if required, the reasons or proof for it. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity.

We will promptly inform you of having received this request. If the request proves valid, we will honour it as soon as reasonably possible and at the latest one month after we received your request.

If you are unhappy with any aspect of our handling of your personal data you, you may always contact us at privacy@vecima.com. If you remain unsatisfied with our response, you are free to file a complaint with the competent supervisory authority.

Security of personal data

We use administrative, technical, and physical security measures that are designed to safeguard your personal data under our control. While Vecima protects your personal data, the confidentiality and security of any communication or material transmitted to or from the Site cannot be guaranteed to be 100% secure at any time. Any transmission of your information is at your own risk. We strongly encourage all users to be careful and responsible about what you choose to provide online.

If you have any reason to believe that your interaction with Vecima through this Site is no longer secure, please immediately notify us using the Contact Us section below.

Quality Assurance

We will keep your information only for as long as we believe that we need it for the purpose we have collected it (as described above) or to meet legal obligations, resolve disputes, maintain security, prevent fraud and abuse, enforce our agreements with you, or fulfill your request to unsubscribe from further messages from us.

Data Transfer

Vecima has operations in Canada, the United States, China, Japan, and the Netherlands. When you engage with our Site or Platform, you may be sending personal data into the United States which may have different data protection rules than those of your country. We process data both inside and outside of the United States. Where we receive your personal data in the context of our services provided to our clients, the transfer of your personal data outside the EEA is based on standard contractual clauses adopted by the European Commission.

Our Legal Bases

We will collect, use and share your personal data only where we have a legal right to do so. This section explains our legal bases for processing personal data, including under GDPR.

  1. Consent. Where possible, we rely on your consent in order to collect your personal data.
  2. Legitimate Interests. For the purposes outlined above, the data processing is necessary so that we can pursue our legitimate interests or those of third parties. When we process your personal data for these purposes, we have carefully assessed our company’s or the third party’s legitimate interests against your data protection rights. You can obtain further information about this assessment by contacting us at privacy@vecima.com.

Where we rely on consent, you have the right to revoke your consent and where we rely on legitimate interests, you have the right to object by emailing us at privacy@vecima.com. If you have any questions about the lawful bases on which we collect and use your personal data, please contact us at privacy@vecima.com.

Cookies and Analytics

We may collect information from you when you visit our Site and Platform to enhance your user experience. A “cookie” is a small data file that is placed on your computer or other device when you visit a website. To learn more about cookies, please visit http://allaboutcookies.org/. If you are concerned about having cookies on your computer or other device, you can set or amend your web browser controls to accept or refuse cookies. Although most web browsers are initially set up to accept cookies, if you prefer, you may decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. However, if you choose to block or delete cookies, your access to some functionality and areas of our website may not operate correctly.

Some of the advertising networks and other vendors we work with may offer you with the opportunity to “opt-out” from interest-based advertising. To exercise this opt-out, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Please note that opting out through these mechanisms does not mean you will no longer be served advertising. You will still receive online advertising, but it may not be tailored to your interests, and the websites you visit may still collect information about your visits.
We may allow third parties to use tracking technologies on our Site (such as Google Analytics). Thus, when using our Site, third parties may collect personally identifiable information about your activities over time and across different websites. The information collected by these tracking technologies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by tracking technologies may be used on our Site and Platform or on other websites or services, including those that may not be operated by us.

Contact Us

Vecima welcomes your questions and comments about this Privacy Notice or the use of your personal data. Please email us at privacy@vecima.com with any questions or comments.