If this Policy changes in the future, we will post an updated version on our website at www.sandvine.com (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, then to the extent permitted under applicable law, you will be deemed to have accepted such changes.
"Personal Information," as used in this Policy, is information that can be directly or indirectly related to an identified or identifiable individual, such as an individual's name, address, telephone number, or email address. Personal Information also includes information, such as demographic information (e.g., date of birth, gender, geographic area, and preferences) and Product-related information, when any of this information is capable of being linked to Personal Information that identifies that individual.
Personal Information does not include "aggregate" or other non-personally identifiable information. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes at our sole discretion and without notice or liability to you.
Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.
When you use our Products, we collect the following types of information from you:
General usage data: When you use our Products we may also collect information about the actions you take on our Products (e.g., logging in, administering other users of the Products, and approving resource requests), the content, features, and activities that you access and engage with on our Products, the resources you use (e.g., amount of data stored or transferred, time spent on the Product, number of queries run) and, in the case of websites, the referring webpage address and the links you clicked on. Some of our Products collect information from terminal devices connected to networks that are managed by those Products. Those Products also collect information regarding the performance of, and certain other information regarding, such networks. This information includes, for example, MAC address, device type, operating system, geolocation information, and network traffic information (e.g., hostnames, protocols, port numbers, and IP addresses). This information may be made available to administrators of networks managed by our Products through an online interface.
We may also collect information regarding your interaction with email messages from Sandvine, such as whether you opened, clicked on, or forwarded a message.
We may indicate that some Personal Information is required (e.g., for you to register for the account or to create the profile), while some is optional. Where we require Personal Information to comply with legal or contractual obligations, then provision of such information is mandatory; if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us.
Information from Other Sources
In some cases, some of the information listed above will be provided by another person, such as your employer or colleagues when setting up an account for you on our Products; or when your employer or colleagues forward correspondence with/concerning you, or if they provide packet captures, memory dumps, files or equipment (such as hard drives) for support and diagnostic purposes.
We may also receive personal information about you from third parties involved in providing you with the Products you are utilizing or who facilitate the integration of third party hardware, software, applications, tools, scripts, and/or services with our Products.
If we do so, this Policy governs our own use of any combined information that we maintain in a personally identifiable format. However, the third party's own use of your personal information in such cases will be determined by their own policies and with your agreement(s) with them, if any.
If we are asked to provide support or information to law enforcement authorities, courts, regulators, customers or other third parties, they may provide personal information about you as part of their correspondence with us.
To learn more about these practices, and to opt-out from Google’s and other vendors’ use of information collected on the Products through cookies for advertising purposes, you may visit Google’s Ads Preferences Manager or the Network Advertising Initiative opt-out page. Please note that opting-out will not prevent advertisements from being served to you on the internet; it will only result in advertisements that utilize cookies to serve advertisements on the specified advertising networks from which you opt-out no longer being targeted.
We are not responsible for the activities of other parties that may not comply with your opt-out requests, and we generally do not have access to, or control over, the actions of Third-Party Services. Each provider of Third-Party Services uses information that it collects in accordance with its own privacy and security policies.
Information We Generate
We will also collect Personal Information about you that we generate based on the correspondence we send to you, the information you provide, and/or which others provide about you – such as records of messages we sent you, notes of meetings we hold with you, or records of the Products you have inquired about or that we provide to you.
We collect, use and share the personal information we collect about you:
In accordance with this Policy, we may share your personal information:
At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw any consents you previously provided for our use and disclosure of your information; request a description of third parties to which we may have provided your personal information; close your account; and amend your personal information. Depending on jurisdiction, you may have other rights to control the use or Personal Information about you, including to ask us to cease or suspend certain processing of it, to erase it, or to provide a copy of it to you or to another service provider.
You can make such requests by emailing us at firstname.lastname@example.org or writing to us at Sandvine Corporation, 408 Albert Street, Waterloo, Ontario, Canada, N2L 3V3, Attention: Legal Department. In some cases, your employer or another third party may provide and administer your account or other Personal Information processed in connection with the Products; in that case, they should be your first point of contact for any requests of this nature.
You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us. Additionally, if we offer user account functionality on the Products, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.
Please be aware that if you opt-out of receiving commercial email from us, it may take up to 10 business days for us to process your opt-out request, and you may receive commercial email from us during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Products.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information, and this personal information will only be used for this and connected purposes (such as resolving related complaint). If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws.
Generally, you may withdraw at any time your previously-given consents for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. We may however continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.
When you visit the Website, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website, such as the links you click on, and which is active only when you are accessing the Website).
The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We may use third-party web analytics services to help us analyze how visitors use the Website. As discussed under Information from Other Sources above, we may permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.
When you visit our Website, we may allow some third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.
We limit access to your personal information within Sandvine to individuals with a need to know.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Sandvine may post a notice through the Products if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
To receive a free written notice of a security breach, you should notify us at email@example.com.
Your Personal Information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, the European Economic Area and India. Each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region.
To the extent permitted by applicable law, by providing your Personal Information to us through your use of the Service, you agree to that transfer, storage, and processing in these countries.
Where we transfer your Personal Information internationally, we will comply with applicable law in doing so, including by assessing and, where necessary, implementing additional safeguards to maintain continuity of protection. To learn more about those transfers and any safeguards we may have put in place, contact us at firstname.lastname@example.org.
We will retain Personal Information we process on your behalf for as long as needed for the uses detailed above. If hard drives are returned to us by our customers, all drives that are refurbished or decommissioned are securely wiped before re-use or secure destruction (respectively).
The Website and Products are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request by email to email@example.com or write to us at Sandvine Corporation, 408 Albert Street, Waterloo, Ontario, Canada, N2L 3V3, Attention: Legal Department. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by delivery in person, by courier or by mail, to us at Sandvine Corporation, 408 Albert Street, Waterloo, Ontario, Canada, N2L 3V3, Attention: Legal Department, by calling us at +519 880-2400, or by email to firstname.lastname@example.org.
If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (e.g., access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
If you are in the EEA, you also have the right to complain to a data protection supervisory authority. Details of national supervisory authorities in the EU can be obtained here: https://edpb.europa.eu/about-edpb/board/members_en
Effective Date: March 12, 2019