Effective date: October 2, 2023
Table of Contents
- Scope and Application
- What is “personal information”?
- What categories of personal information do we collect?
- How do we collect your personal information?
- How do we use your personal information?
- When do we share your personal information with other organizations?
- What are your privacy choices?
- How do we protect your personal information?
- How long do we keep your personal information?
- Cross-Border Transfers of Personal Information
- Accessing and Rectifying Your Personal Information
- EU Notice
- California Notice
- Changes to the Policy
- Contact Us
1. Scope and Application
This Policy applies if you are a customer who purchases or uses our products and services, a user who visits our websites, uses our mobile applications or creates an account through our websites and mobile apps, or a job applicant who applies for a career opportunity with us. This Policy applies to websites and mobile apps managed by Vosker and on which this Policy appears.
In this Policy, we describe our policies and practices with respect to the collection, use and disclosure of personal information and the measures taken to ensure its continued protection. We also describe the rights and choices you have regarding your privacy.
In some cases, at the time of collection of your personal information, we may provide you with additional information regarding the processing of your personal information. We may also, in certain circumstances, obtain your specific consent to the use or sharing of your personal information, including where required by law.
The EU Notice section of the Policy applies specifically to personal information processed by a Vosker entity in the United Kingdom (“UK”) and European Union (“EU”). The California Residents section of the Policy applies to personal information of California residents processed by us and contains additional disclosures, our notice at collection, and a description of your rights.
2. What is “personal information”?
In this Policy, “personal information” generally means information (regardless of its format) about an identifiable individual or natural person. This may include, for example, your name, contact information, home address, email address, birth date and information relating to your account with us (if any). It may also include more technical information, such as your IP address, browser settings, digital footprints and device ID, but only when this information can identify you as an individual. Information that is aggregated or anonymized and cannot be associated with an identifiable individual is not considered to be personal information.
3. What categories of personal information do we collect?
We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected.
Depending on your interaction with us, we may collect your contact information, transactional information, technical information related to your use of our products and services (including our websites and mobile apps), and information provided when applying for an employment opportunity with us. We may also collect content you capture or record using our products and services, such as video and audio recordings, as further explained below. We collect personal information in a variety of ways detailed below under How do we collect your personal information?
We may collect the following personal information about you depending on your interactions with Vosker (for instance, if you are a customer, a website visitor, mobile app user or a job applicant):
- Identifiers, such as your full name, email address, mailing address, telephone number and other information you provide to us when you contact us or create an account (for example, when you make a purchase on our website or create an account to use our mobile application);
- Commercial information, such as your billing and shipping address, details about the products and services you purchase via our websites and mobile apps. Your payment information is collected and processed by our payment processor (acting on our behalf) for the purposes of completing your transaction;
- Technical information about your Vosker device, such as the name and model of your device, its serial number and SIM card number (if applicable);
- Internet or other electronic network activity information (i.e. technical information when you visit our websites or use our mobile applications), including when you log in to use our products and services. This information is collected via automated means, such as cookies, web beacons and similar technologies, and may include your IP address, device ID, browser type, data about the web pages you visited on our websites, your language preferences, email bounce backs and click-throughs. To learn more about how we collect and use this type of information, see How do we use your personal information? below;
- Visual and audio information collected when using our products and services, such as images and sounds captured through our cameras. Note that your use of our products and services may be subject to particular legal requirements, such as privacy and data protection laws and regulations, depending on your jurisdiction. You are solely responsible for complying with these requirements, which includes obtaining all required consents in accordance with applicable laws and displaying a notice to alert individuals that you are using our products and services;
- Professional or employment-related information and other information you submit to us when applying for an employment opportunity, which may include some of the information described above, as well as letters of motivation, your resume, references and any additional information provided by you in the application form;
- Any other information you provide to us, such as when you contact us for customer support or otherwise interact with us online or in-person;
- Inferences drawn from the information identified above, such as your preferences and interests.
4. How do we collect your personal information?
We collect personal information in a variety of ways, including directly from you, from third parties and through our websites and mobile apps.
We may collect personal information from the following general sources:
a. Directly From You
We may collect personal information directly from you, such as when you:
- make a purchase on our website;
- create an account with us;
- subscribe to our newsletter;
- submit forms on our websites and mobile apps (including information provided at the time of registering to use our products and services);
- capture content that contains personal information through your use of our products (for example, if your camera captures your image);
- apply for a career opportunity with us;
- contact us with an inquiry or to report a problem with our websites, mobile apps or Vosker devices; or
- agree to complete a survey.
b. From Third Parties
In certain circumstances, we may receive personal information from third parties, such as business partners with whom we work and/or that use our products, to the extent permitted by law.
c. Through our Websites and Mobile Apps
Vosker collects technical information (e.g. your IP address, browser type and device ID) and information about your device and browser (e.g. page views and clickstream data) when you visit our websites and mobile apps, using technologies, such as cookies, web beacons and analytics engines. Some of these technologies may be operated by third parties. This information supports the functioning of our websites and mobile apps and helps us understand how you use our products and services, improve the content shown on our websites and mobile apps, and ensure that they are working properly.
For more information about the technologies we use to collect information through our websites and mobile apps and how you can manage your choices, see What are your privacy choices? below.
5. How do we use your personal information?
We may use your personal information for the following purposes or otherwise, with your consent or as permitted or required by law:
a. General Business Purposes
We may use your personal information for general business purposes such as providing or delivering a product or service requested, managing our business, including our websites and mobile apps, handling job applications, as well as for purposes relating to information, system or network security.
More specifically, we may use your personal information for the following general business purposes:
Providing or delivering our products and services. We use your personal information for activities that are necessary to provide or deliver our products and services, for instance:
- Creating and managing your account or any other aspect of the products or services we offer;
- Determining your eligibility to receive our products and services;
- Processing your transactions and delivering the products and services requested;
- Providing you with updates about the status of your order;
- Storing the content that you capture using our products and services;
- Verifying your identity;
- Informing you about our products and services which may be of interest to you;
- Responding to your inquiries;
Managing our business operations. We use your personal information for several reasons in connection with our business operations, which include:
- Notifying you of changes to your account or other relevant information related to your use of our products and services;
- Managing and facilitating the use of our websites and mobile apps, which may include using cookies and other similar technology;
- Maintaining the security of the public, our users and our employees;
- Maintaining the safety of our products and services;
- Detecting, investigating and preventing errors, fraud or any other illegal activity;
- Processing your employment application; and
- Meeting our contractual, legal and regulatory obligations.
b. Research and Data Analytics Purposes
We may use personal information to understand and assess your interests and changing needs with a view to improving our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our websites, mobile apps and Vosker devices. When required by law, we will use aggregated or anonymized information for these purposes.
Examples of research and data analytics include:
- Analyzing the images captured by our products to improve our image recognition models and enhance the value of our products for customers. We may also use this information to measure the effectiveness of our marketing campaigns.
- Using third-party web analytics services to analyze how visitors use our websites and mobile apps.
c. Marketing Purposes
We may use your personal information to provide you with personalized content and services, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels.
We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online customer support services) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see What are your privacy choices?
6. When do we share your personal information with other organizations?
We may share your personal information within our corporate group, with our business partners and our service providers (companies that carry out activities on our behalf), and in the context of a sale, or transfer of our business or similar transaction. We may also share your personal information with your consent or in accordance with applicable law.
We may share your personal information as set out below:
Affiliates and Related Entities
Vosker may share personal information with affiliates and related entities for the purposes described in this Policy. This allows each entity to comply with applicable laws, regulations and requirements, and ensures that your information is consistent, accurate and up to date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with Vosker through easier access to your information within the group.
Your personal information may be shared with businesses such as business partners with whom we work and/or that use our products, to the extent permitted by law.
We may share personal information with our agents, vendors or other organizations that provide services on our behalf, for the purposes set out in this Policy. These service providers help us operate and manage our websites and mobile apps, information systems, infrastructure and marketing. They provide services to us, such as processing payments and completing transactions, delivering products and services, sending emails and postal mail, data hosting, survey administration, providing marketing campaign services, and analytics services (e.g. tracking effectiveness of our campaigns and analyzing usage of our websites and mobile applications).
When Vosker shares personal information with our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. Our service providers may be located around the world, as further detailed in the Cross-border transfers of personal information section.
Sale or Transfer of Our Business or Other Transaction
We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction in compliance with applicable laws.
Other permitted reasons
We may share your personal information when permitted or required by applicable law, for instance:
- With governmental authorities, law enforcement and courts when compelled by law; and
- For the purposes of detecting or suppressing fraud or criminal activity, protecting our assets and interests, conducting an internal or external investigation into any actual or suspected illegal activity or managing, defending or settling any actual or potential loss in connection with the foregoing.
7. What are your privacy choices?
You have choices about the way Vosker handles your personal information.
a. Within Your Account
If you have an account with us through our websites and mobile apps, you can update or change your personal information via your account.
b. Changing Your Communication Preferences
You can always choose not to receive marketing or promotional messages from Vosker by email by clicking on “unsubscribe” in any email you receive.
Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with our products and services, in accordance with applicable law (for example, to send you a customer service message, important product information, service notification or recall). In addition, it may take up to ten (10) business days to register a change of preference across all our records.
c. Restricting Collection, Use and Disclosure of Your Personal Information
You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Policy at any time upon reasonable notice to Vosker in writing, subject to legal or contractual restrictions. To withdraw your consent, please contact us in writing using the relevant contact information listed in the Contact Us section below.
The withdrawal of your consent may affect our ability to continue providing you with the products and services that you have or would like to receive where the continued use and disclosure of your personal information is necessary for the provision of such products and services. In certain situations, we may be entitled to retain your personal information in order to comply with applicable legal requirements, to establish, exercise or defend our rights or legal claims, and for other legitimate business purposes described under How do we use your personal information?
8. How do we protect your personal information?
Vosker maintains appropriate policies and practices aimed at safeguarding your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:
- A privacy framework governing the protection of personal information through its lifecycle. This framework defines the roles and responsibilities of Vosker personnel, provides a process for dealing with complaints regarding the protection of the information, and addresses the retention and destruction of personal information;
- Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
- If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, passwords, antivirus software and similar measures;
- A designated Privacy Officer to monitor Vosker’s compliance with applicable privacy laws;
- Employee privacy and data security training.
Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of personal information in our possession. We also use these safeguards when we dispose of or destroy your personal information.
9. How long do we keep your personal information?
We store your personal information for as long as is necessary to provide our services to you, to manage our business operations, and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed or anonymized in accordance with legal requirements.
10. Cross-Border Transfers of Personal Information
Vosker is based in Canada. Some of our service providers may access, process or store your personal information outside of the country where we are located and where you reside, including in Canada and the United States. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction and the jurisdiction where you reside, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
11. Accessing and Rectifying Your Personal Information
You may be entitled to access your personal information and request the rectification information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws. If you have an account or are a registered user with our app, you may access your profile and update your personal information. Depending on the jurisdiction where you reside, you may also be entitled to request the rectification of your personal information if our collection, disclosure or retention of such information is not authorized by law.
To exercise your rights, please contact us in writing using the relevant contact information listed in the Contact Us section below.
Individuals in the UK, EU and California may have additional rights with respect to personal information processed by a Vosker entity in the UK, EU and the U.S. Please review the EU Notice and California Notice below for more information.
12. EU Notice
If you are in the European Union or the United Kingdom, this section applies to Vosker’s processing of your personal information.
a. What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal basis to process your personal information:
- Our processing of your personal information is in our legitimate interest or in the legitimate interest of a third party (such as to protect and enforce our legal rights or the legal rights of other persons, to personalize your experience on our website or to conduct data analytics to improve our product).
- Our processing of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or
- Our processing of your personal information is necessary to comply with a relevant legal or regulatory obligation (for example, where we are required to disclose personal information to a court).
b. Your Rights
You have the following rights with respect to your personal information:
- Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you as well as the following information: (i) the source of your personal information; (ii) the purposes, legal basis and methods of processing; and (iii) the entities or categories of entities to which your personal information may be transferred. You also have the right to request that we delete your personal information. We are not required to comply with a request to delete your personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise or defence of a legal claim.
- Right to restrict the processing of your personal information: You have the right to restrict the processing of your personal information under the following circumstances: (i) you contest the accuracy of the personal information; (ii) the processing is unlawful but you wish to restrict rather than prohibit the processing of your personal information; (iii) the purposes for processing your personal information no longer exist, but you require the personal information for the establishment, exercise, or defence of legal claims; or (iv) you have legitimately objected to the processing of your personal information and the processing is therefore restricted pending the verification of whether the legitimate grounds of the controller override your objection. Please note that we may lawfully continue to process your personal information following a request for restriction to establish, exercise or defend a legal claim; to protect the rights of another person; to comply with applicable laws and/or requests made by law enforcement; or if you have provided your consent.
- Right to data portability: To the extent that we process your personal information (a) based on your consent or under a contract and (b) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
- Right to object to the processing of your personal information: You can object to any processing of your personal information which is based on our legitimate interest (or those of a third party) if you believe your fundamental rights and freedoms outweigh such legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms. We will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election. Our goal is to respond to any verifiable consumer request within thirty (30) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline and require a sixty (60) days extension as permitted by law.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights: If you wish to exercise any of these rights, please use the contact information listed in the Contact us section below.
13. California Notice
This California notice supplements the Policy set forth above with respect to specific rights granted under the California Consumer Privacy Act (“CCPA”) to natural person California residents (“California Resident,” “you,” or “your”) with regards to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose and share your personal information and your potential rights with regards to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used in this California notice have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” for the purposes of this section has the same meaning as in the CCPA. For purposes of this California notice, personal information does not include deidentified information, aggregate consumer information, or publicly available information as those terms are defined in the CCPA.
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section What categories of personal information do we collect?
How We Use Collected Information
We also may use personal information from California Residents for the business or commercial purposes described above in the section How do we use your personal information?
Our Collection, Use, Disclosure, and Sharing of Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section, What categories of personal information do we collect? We may collect personal information from all or some of the categories of sources listed in the section, How do we collect your personal information? We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, How do we use your personal information?
Our Disclosure and Sharing of Personal Information
We do not sell your personal information. We do not knowingly sell the personal information of California residents under 16 years old.
In the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in What categories of personal information do we collect? above, to the following categories of third parties: (i) businesses with whom we offer our products and services jointly, such as authorized retailers when you purchase our products and services from them; (ii) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; (iii) service providers and corporate affiliates (only as necessary or appropriate to perform legitimate business purposes); and (iv) other third parties as may otherwise be permitted by law.
California Residents’ Rights under the CCPA
The CCPA provides California Residents with certain rights related to their personal information. This section explains those rights. If you are a California Resident and would like to exercise any of those rights, please see How to Exercise Your CCPA Rights below for more information on how to submit a request, subject to certain exemptions and other limitations under applicable law.
- Notice: You have the right to be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
- Right to Know: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months.
- Right to Delete: You have the right to request that we delete certain of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with federal, state, local and non-U.S. laws, rules and regulations.
- Right to Non-discrimination: We will not discriminate against you for exercising of any rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
- Opt-Out of Sale: You have the right to opt out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations and law enforcement requests. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA.
How to Exercise Your CCPA Rights
If you are a California Resident and would like to exercise any of the CCPA rights identified above, you may submit a request by writing to email@example.com.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Right to Know or a Right to Delete request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Right to Know or a Right to Delete request on your behalf and have that authorized agent submit the request through the aforementioned methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election. Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline and require a forty-five (45) days extension as permitted by law. Keep in mind that we are not required to provide information in response to Right to Know requests more than twice in a 12-month period and any response to a Request to Know will only cover the 12-month period preceding the verifiable request.
Additional California Privacy Rights
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our sites are not currently set up to respond to those signals.
14. Changes to the Policy
We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our websites or mobile apps. If we make any significant changes to the Policy, we will post a notice on our websites and mobile apps or contact you to inform you when required by law. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand, accept or reject the latest version of the Policy. If you reject the latest version of the Policy, you may withdraw your consent to the processing of your Personal Information by opting out, which may affect our ability to provide you with our services and products. The “Effective Date” at the top of this Policy indicates when it was last updated.
15. Contact Us
If you have any questions or complaints about how we handle your personal information, please contact our Privacy Officer: using the us as indicated below or contact us at the following address:
by email at firstname.lastname@example.org