Last Updated: May 9, 2017
Accipiter Radar Technologies Inc. and its subsidiary companies and affiliates (“Accipiter”) are committed to maintaining the privacy and security of your personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws).
1. Accipiter’s accountability
Accipiter is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on Accipiter’s behalf (i.e. our service providers).
2. Accipiter’s purposes for using your personal information
When Customers use an Accipiter Offering, correspond with Accipiter, or otherwise interact with us, Accipiter may process your personal information for the following purposes:
To understand and meet your needs and preferences, and to provide you with Accipiter Offerings, for example:
- for purposes related to the billing, activation, provision, maintenance, support, troubleshooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of Accipiter Offerings;
- to ensure Accipiter Offerings are technically functioning as intended and to help identify and troubleshoot issues;
- to fulfill or enforce Notices applicable to an Accipiter Offering;
- to manage or respond to your inquiries;
To develop new and enhance existing Accipiter Offerings including to communicate with you about them using various means, for example, to make available or send to you:
- upgrades or updates, or notices of upgrades or updates of Accipiter Offerings or related products, services and software;
- notices of promotions and upcoming events;
To manage and develop our business and operations, for example:
- to detect, monitor, investigate, mitigate or attempt to prevent technical or security issues or to protect Accipiter property;
- to allow for business continuity and disaster recovery operations;
- to enforce Accipiter’s legal rights;
- for statistical purposes;
To meet legal and regulatory requirements and to respond to emergency situations, for example:
- to respond to court orders, warrants or other lawful requests or legal processes;
- to provide emergency assistance in situations that may threaten the life or physical safety of you or others;
For any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
3. Your consent
Individuals can give consent in many ways. Generally, the use of Accipiter Offerings by a Customer constitutes implied consent for us to process personal information for all identified purposes.
a) When obtaining consent is not required
In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, Accipiter may not seek consent:
- in the case of an emergency where the life, health or security of an individual may be threatened;
- when legal, medical, or security reasons make it impossible or impractical to seek consent;
- when disclosure is to a lawyer representing Accipiter;
- to collect a debt;
- to comply with a subpoena, warrant or other court order, lawful request or legal process; or
- as may be otherwise required or permitted by law.
b) Aggregated or anonymous information
Accipiter reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.
4. Types of information processed
The types of information that Accipiter may process can vary. For example:
a) Account and Customer information: Information processed could include your name, postal address, email address, telephone number, Accipiter ID, IP address, communications with Accipiter and any service issues. Accipiter may also process your account credentials, passwords, profile information and other information you provide to facilitate the Accipiter Offerings you use.
b) Applications: In some cases, Accipiter may process information about applications you use including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party) that may be used in conjunction with Accipiter Offerings but are not offered, operated or supported by Accipiter. Also, if you choose to use Third Party Offerings with your Accipiter Offering, certain information may be collected and disclosed to the third party, or from the third party to Accipiter, in order to facilitate or improve the services and functionality provided.
d) Financial information: If you purchase a product, service, software or customer support directly from Accipiter or our service providers, Accipiter may process payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable.
e) General usage data: In some cases, information like technical properties and general usage information of software and hardware utilized in conjunction with an Accipiter Offering might be processed when you use such products, services or software (for example, the type of web browser, referring or exit web pages, operating system version, IP address).
f) Location information: Accipiter may process such information to provide you with or facilitate the provision of information and location-based services. If you choose to use location-based services, you agree that such geographic location information may be processed to provide you with such services. You may be able to manage location functionality or individual settings on your computer or other device.
g) Quality assurance and customer service: Your customer service telephone calls with Accipiter and Accipiter’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to Accipiter Offerings.
5. Accipiter’s processing of your personal information
Accipiter retains personal information as long as necessary for the fulfillment of Accipiter’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for Accipiter’s identified purposes, or required by applicable laws, Accipiter will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, Accipiter continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.
b) International operations and onward transfers
You agree that, to be able to better serve you and facilitate the use or functioning of Accipiter Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of Accipiter in multiple jurisdictions including Canada, the United States, the European Economic Area, Philippines, Singapore and any other country where Accipiter or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of Accipiter.
Given the international nature of our business, Accipiter may also be required to disclose or otherwise provide access to your information under the laws of countries where Accipiter, our service providers, affiliates and data are located. By using Accipiter Offerings, you consent to our compliance with applicable laws including any legal process that Accipiter believes requires that we produce or provide access to your communications data and other information.
c) Marketing communications from Accipiter
Accipiter may communicate with you by a variety of means, such as using an email address that you provide. Accipiter may communicate information, marketing materials, advertisements, surveys, or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with Accipiter. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, or through utilizing aggregated data or data that has been made anonymous. Accipiter may ask you from time to time if you would like to receive from Accipiter or authorized third parties selected by Accipiter additional announcements and news, relating to Accipiter and Accipiter Offerings. Typically, an unsubscribe mechanism is included with every Accipiter marketing or commercial communication. Please visit the section below on “Managing your preferences” for more information on managing marketing or commercial communications from Accipiter.
d) Service-related communications from Accipiter
Accipiter may also send you certain service-related communications. For example, Accipiter may provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of Accipiter Offerings, you may not opt-out of receiving these communications.
e) Information sharing
Accipiter uses contractual or other means to provide a comparable level of protection while the information is being processed by our service providers. It is Accipiter’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from Accipiter. For example, except where Accipiter is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the information in confidence and only use the information for the purposes for which it was provided or to comply with applicable laws.
In the event of the sale of all or a portion of Accipiter’s assets, Accipiter may provide personal information to the third party purchaser.
6. Accuracy of your personal information
Accipiter takes reasonable steps to ensure that personal information is sufficiently accurate and complete for the purposes for which it is to be used, however Accipiter does not routinely update personal information. Personal information is generally updated only as and when necessary to fulfill the identified purposes or upon notification from you to update or correct your personal information.
7. Safeguarding your personal information
Accipiter continues to evolve our physical, organizational and technological measures used to protect your personal information against loss or theft, unauthorized access, alteration or disclosure appropriate to its level of sensitivity. For example, if an Accipiter website requests your name and password, it will have a variety of security measures in place that are designed to protect against the loss, misuse and unauthorized alteration of the personal information submitted to Accipiter. Accipiter employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, to limit access to personal information to those with a need to know it for business reasons, and to take care in its disposal or destruction to prevent unauthorized parties from gaining access to the information.
8. Accipiter’s ongoing efforts to be transparent
9. Accessing your personal information
Upon written request, Accipiter will inform you whether or not it holds personal information about you and provide you with access to your information within a reasonable timeframe and at minimal or no cost, all in accordance with applicable laws.
In certain situations Accipiter may not be able to provide access to all of the personal information that we hold about you. For example, we may not be required to provide access to information if:
- disclosure would reveal Accipiter or third party confidential information or third party personal information;
- the information is protected by solicitor-client privilege;
- the information would prejudice law enforcement activities or our negotiations with you;
- the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law.
If access to personal information cannot be provided, we will provide the reasons for denying access upon request.
Depending on the circumstances and applicable laws, Accipiter may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
In order to safeguard your personal information from unauthorized access, Accipiter may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.
If you identify an inaccuracy or incompleteness in your personal information, Accipiter will respond to your challenge by amending your information and notifying any third parties as required by applicable laws. If our response is not to your satisfaction, we will record the substance of the unresolved challenge in your file. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.
10. Questions or concerns? How to contact us
- by email: email@example.com or
- write to Accipiter Radar Privacy Office c/o Accipiter Radar Technologies Inc. (attention Legal Department), P.O. Box 939, Fonthill, Ontario, Canada, L0S 1E0
a) Managing your preferences
Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about Accipiter or Accipiter® products, services and software by:
- Following the UNSUBSCRIBE instructions at the end of any marketing or commercial communication from Accipiter; or
- Writing to Accipiter Radar Privacy Office c/o Accipiter Radar Technologies Inc. (attention Legal Department), P.O. Box 939, Fonthill, Ontario, Canada, L0S 1E0 and advising what particular types of marketing or commercial communications you no longer wish to receive.
- Remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Accipiter Offerings as they may not work well or at all with Cookies disabled.