SOTI Privacy Policy

Privacy Policy

The SOTI Privacy Policy was updated on February 26, 2015.

At SOTI, Inc. the protection of your personal information is our top priority. SOTI's Privacy Policy regarding the collection, storage, use and disclosure, if any, of personal information is built upon the principles of the Personal

Information Protection and Electronic Documents Act (PIPEDA) established by the Canadian Federal Government.     

Accountability

In the process of collecting personal information, we, SOTI and its affiliates, acknowledge and are responsible for personal information collected under our control and in our possession. SOTI has designated a Privacy Officer who is accountable for SOTI’s compliance with this Policy and all applicable privacy laws.

To maintain consistency and to ensure the upmost security of personal information, all SOTI partners and employees have been made aware of the Privacy Policy and have been advised of the responsibility for day-to-day compliance.

In given circumstances, SOTI uses trusted third parties to act on our behalf to perform functions such as fulfilling orders, delivering packages, processing credit card payments, providing customer service or other services similar in nature.  We would like to confirm with our partners, employees, and clients that prior to any dealings with any third party, SOTI uses contractual or other appropriate means to ensure third parties comply with this Policy and all applicable privacy laws regarding the protection of personal information.

Identifying Purposes

Client Information

When a client purchases product, submits an inquiry (pre or post purchase), downloads software updates, creates a SOTI account, requests delivery or submits payment, SOTI may collect information that may include name, mailing address, phone number, email address, credit card and/or banking information.

The information collected allows SOTI to deliver the high quality of service expected by our clients.  It enables us to keep clientele informed about software upgrades and new product launches, and to also ensure accounts are current and updated.  On occasion SOTI may use this information to send important notifications regarding changes to terms, policies, and prices as well as to develop, customize, improve, and deliver SOTI product, services, and promotional material.

SOTI may also use personal information to generate statistics and aggregate reports for internal use and for sharing with affiliates, subsidiaries, licensees, successors and advertisers.  These statistics and aggregate reports will not contain any information that would personally identify a client.

Employee Information

SOTI collects personal information about our partners and employees in order to pay fees and wages, to comply with laws and regulations, provide employees with benefits, to improve on and manage programs, policies and employee relations and generally to establish, manage or terminate the employment or partnership relationship.

In certain cases, SOTI may also aggregate partner and employee personal information to provide business metrics and evaluate the effectiveness of our HR programs, but this aggregated information will not allow the identification of any one individual.

Consent

SOTI will collect, use or disclose personal information only with your knowledge and consent.  At any time and within reasonable notice you may withdraw your consent to any advertising and/or promotional lists by contacting legal@soti.net . 

SOTI clients always have the option not to provide their consent to the collection, use and distribution of their personal information, or to withdraw their consent at a later stage. Where a client chooses not to provide SOTI with permission to collect, use or disclose personal information, SOTI may not have sufficient information to continue providing the client with services.

Where a partner, employee or candidate for employment chooses not to provide SOTI with permission to collect, use or disclose personal information, SOTI may not be able to employ them, continue to employ them or to provide them with benefits.

 

Consent for the collection of non-personal information, such as employee's, partner’s, or client’s name, title, business address, business email or telephone number, collected in the process of payment fulfillment, delivery, product updates, terms and policy changes, or any other means to allow the supply of SOTI product or service may not be withdrawn.

 

Limiting Collection

Personal information collected by SOTI is limited to information necessary for us to deliver the needs and expectations of our clients, to provide services and operate our business.  For example, you will be asked for personal information when in the process of placing an online purchase.  This information is used to process your order and to allow SOTI to communicate with you to ensure that the transaction has been executed smoothly. 

 

In understanding the sensitivity around the needs to protect our partner’s, employee’s and clientele’s privacy, all personal information will be collected by SOTI using fair and legal methods common in the software corporate realm.  

 

Limiting Use, Disclosure, and Retention

The personal information collected shall only be used and/or disclosed for the purposes it was initially collected for and for reasons outlined within this Policy.  If SOTI intends to use personal information for any purpose not previously identified to the individual, SOTI will obtain their prior consent.

 

However, SOTI may use personal information without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual, or as otherwise permitted by law including for purposes of an investigation. SOTI may also disclose personal information without consent as permitted or required by applicable federal and provincial privacy laws, including:

 

  • to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies 
  • to a government institution that has requested the information, identified its lawful authority, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law 
  • to an investigative body or government institution on SOTI’s initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affairs. 

 

In compliance with professional standards, SOTI will maintain a record of the work performed by SOTI partners and employees. This record may include personal information and will be retained until such records are no longer reasonably required for legal, administrative, audit or regulatory purposes. Records are safeguarded against inappropriate access, as discussed below.

 

SOTI retains personal information about current and past partners and employees in accordance with standard financial auditing practices and employment laws and standards. SOTI will destroy human resource and other files containing partner and employee personal information when such information is no longer reasonably required for legal, administrative, audit or regulatory purposes.

 

Accuracy

SOTI will endeavor with its best efforts to maintain the accuracy of your personal information, and may from time to-time ask clients, partners and employees to update their personal information.  SOTI will keep your personal information as accurate, complete and up-to-date as necessary for the purposes in which it was collected and for reasons outlined in this Policy.  Should you find or believe that the personal information SOTI has collected may be out of date or incorrect please notify your SOTI representative so that we may update records accordingly.

 

Safeguards

SOTI recognizes the sensitivity of your personal information and the importance to take the proper safety measures to protect this information. We take precautions that will protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification or destruction by secure measures appropriate to the sensitivity of the information.  SOTI will protect personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to protect the loss, misuse and alteration of the personal information under our control.  Personal information is stored in secure environments that are not available to the public (e.g., restricted access premises, locked rooms and filing cabinets). To prevent unauthorized electronic access to personal information, any information that is stored in electronic form is protected in a secure electronic and physical environment.

 

We are responsible for all personal information transferred to third parties for processing. SOTI requires third party processors to respect the confidentiality of personal information and all legal requirements under applicable

Canadian federal and provincial privacy legislation, and to agree to contractual requirements that are consistent with this Privacy Policy. These third party processors are prohibited from using personal information, except for the specific purpose(s) for which we supply it to them.

 

In some circumstances, personal information may be processed and stored outside of Canada by SOTI or a third party processor, and such personal information may be subject to disclosure in accordance with the laws applicable in the jurisdiction in which the information is processed or stored. These laws may not provide the same level of protection as Canadian privacy laws.

 

Openness

The most up-to-date version of SOTI’s privacy policy is available in its entirety at www.soti.net or by contacting

SOTI’s Privacy Officer at legal@soti.net 

Should you have any questions or concerns, at any given point, during the process of collecting personal information, please feel free to speak to your SOTI representative to receive clarification about the collection and use of your personal information.

Individual Access

In the event that personal information is collected and kept on record, clients have the right to review and obtain a copy of their personal information on file by contacting their SOTI representative.  Should a request to access your personal information be submitted, SOTI will inform you of the existence, use and disclosure of personal information relating to you and only you, and provide you with access to that relating information.  As the provider of the information, a client has the right to challenge the accuracy and the completeness of the personal information file and make changes as deemed appropriate.

Partners and employees have the right to review and obtain copies of their personal information on record by contacting SOTI HR.

There are certain circumstances, as permitted by law, where information may not be disclosed to you.  These circumstances are when information contains references to other individuals, which cannot be disclosed for legal, security or commercial proprietary reasons, or that is subject to solicitor-client or litigation privilege.

 

Concerns Over Privacy

SOTI will respond to individual complaints, any questions, concerns, and or comments regarding SOTI’s compliance of this Policy.  SOTI will endeavor to investigate and attempt to resolve all complaints. 

 

To challenge compliance with this Policy, individuals should feel free to contact SOTI through letter correspondence at the following address:

 

SOTI Inc.
5770 Hurontario Street
Suite 1100
Mississauga, Ontario
Canada, L5R 3G5

Attn: Legal/Contracts

 

Or via email at: legal@soti.net

Once SOTI has received notice of your communication, a SOTI representative will verify receipt and SOTI’s Privacy

Officer will provide you with a reply within a reasonable time frame.

 

SOTI may update this Policy at any given time.  As this Policy reflects the principles of PIPEDA and/or any other applicable privacy laws the policy will be modified accordingly to comply with current legal standards.  When material changes have been made to this Policy, SOTI will provide notice on our website and update the Privacy

 

SOTI Website Privacy Information

 

This website is owned and operated by SOTI, Inc. in conjunction with its affiliates. 

Security

For the security of transactions, SOTI uses Secure Sockets Layer (SSL) protocol, which encrypts any information sent to SOTI electronically. The encryption process protects information by scrambling it before it is sent to SOTI from your computer. Once the website receives your transmission, SOTI makes commercially reasonable efforts to ensure its security on our system. Unfortunately, no data transmission over the Internet can be guaranteed to be

100% secure. As a result, SOTI cannot warrant the security of any information transmitted to us, and you do so at your own risk.

Unlawful Activities

SOTI may disclose personal information obtained through this website in order to co-operate with local, provincial, national and international authorities investigating improper or unlawful activities or to report improper or unlawful user activities on this website. 

Cookies

Your web browser places cookie files on your computer’s hard drive. This website uses cookies to remember information you give SOTI so that you don’t have to re-enter the information each time you visit the SOTI website.

Cookies also help SOTI to understand which areas of the site are popular by showing how you and others use the site, in aggregate.

 

Information sent to the SOTI Website

Apart from information relating to orders or newsletters, SOTI does not collect or wish to receive any information or other materials from you through this website that may be considered personal, confidential or proprietary.

SOTI will consider any such information and materials that you send to be non-confidential, and you will be deemed to have granted to SOTI an irrevocable license and consent to use, copy, display, and distribute such information and materials for any purpose whatsoever.