Who is Lotek?
Our Commitment to Privacy of Personal Information
Personal information is any information that can be used to directly or indirectly distinguish, identify, or contact a specific individual. You may be asked to provide your personal information anytime you are in contact with Lotek.
For example you may have provided us with your personal information as a customer of Lotek, if you have expressed an interest in our products, have participated in an event sponsored or organized by us, signed up for our newsletter, visited our website (‘www.lotek.com’, referred to as our “Website”), provided comments about our products or services, or submitted an application to become an employee of Lotek.
You are not required to provide the personal information that we may request, but, if you chose not to do so, in some cases we will not be able to provide you with our products or services, respond to any queries you may have, or consider you for an employment position at Lotek.
The Information we Collect from You
When you enquire about, or purchase our products and services, or download our software we generally collect, process, and use personal information about you including: contact information such as names, addresses, telephone numbers, e-mail addresses, financial and billing information, and sometimes require proof of identity such as a signature.
We will obtain your consent to collect, use, disclose or otherwise manage your personal information. Depending on the circumstances, your consent may be implied or express. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us. If you wish to withdraw your consent, we will inform you of the implications of withdrawing consent.
How we Use your Information
We may use this information to:
Do we Share your Information?
We also engage service providers that help to operate our business that may require the use of your personal information, for example to run our Website and e-mailing list provider. We also use service providers to deliver products to you, for example when you purchase and activate certain products that require information transmission. Personal information may be stored by us or our service providers in Canada, the United States or other jurisdictions where our service providers are located. Once information has been passed to another organization, it is no longer in the control of Lotek and becomes subject to the privacy practices and procedures of the recipient organization.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Lotek to disclose your personal information. Lotek 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. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Collection and Use of Non-Personal Information
Lotek may also collect data in a form that does not, on its own, permit direct association with any specific individual. This information is not considered personal information. We may collect, use, process, and disclose non-personal information for any purpose.
If we were ever to combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
How we Protect your Personal Information
Lotek makes all commercially reasonable efforts to ensure that personal information collected from you is protected against loss or theft, and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy form. Access to your personal information is restricted to selected employees or representatives of Lotek who are required to respect the confidentiality of that information pursuant to their employment agreement with us.
In addition, we employ generally accepted information security techniques, such as passwords, firewalls and access control procedures, to protect personal information against loss and unauthorized access. Although we use reasonable commercial efforts to protect your information, no method of transmission over the Internet or electronic storage is 100% secure, and therefore Lotek cannot guarantee absolute security of your personal information.
How can you get Access to your Information?
For the personal information that we hold, Lotek will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate, or to delete the data if Lotek is not required to retain it by law or for legitimate business purposes.
We will endeavour to respond to any request you may have as quickly as possible and, in any event, within the legally required time periods. Subject to certain exceptions and limitations prescribed by law, you will be given access to any personal information that we hold about you. Any information provided to you will be provided in a commonly used and machine-readable format.
Lotek may decline to process requests that are frivolous, vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes.
Lotek will retain your personal information as long as it is needed for the purpose for which it was collected and in order to meet legal and regulatory requirements.
Updating your Information or Correcting Errors of your Information
If any of your personal information changes, or you can establish that the information that we hold about you is not accurate, complete, or up to date, please let us know and we will take reasonable steps to change, correct, or eliminate such information as appropriate. We will correct or amend personal information that is shown to be incomplete or inaccurate with your consent and in accordance with applicable law.
At the point where we request information about you, our Website provides you the opportunity to opt-out of receiving communications from us and our partners. If you would like to remove your information from our database, not to receive future communications, or to no longer receive our services, you are able to contact our Privacy Officer directly, or you can fill out our Email Opt-Out Form.
We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited and users of the Website (such as the pages most read, time spent, user preferences and particulars, search terms and other engagement data) in order to segment Website users, advertise, and evaluate and improve the user experience and the convenience of the Website.
We collect the IP addresses of all visitors to our Website including page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, to monitor and improve the Website, and to improve on our products and services available to you.
The Website uses “cookies” – a cookie is a small piece of information that a website can store on your web browser and later retrieve. The cookie cannot be read by any website other than the website that set up the cookies.
You can set your browser not to accept cookies and still access the Website, although as a result certain areas of the Website may be unavailable or difficult to use.
Contact us with your Privacy Questions
Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.
You can contact us at:
Lotek Wireless Inc.
115 Pony Drive
Newmarket, Ontario, Canada
Attention: Privacy Officer
Telephone: (905) 836-6680
Fax: (905) 895-9060