Rev. 2.1 Dated: 02/02/2022
Privacy Policy of Gotek Telecom LTD
Owner and Data Controller
Your privacy matters. Gotek Telecom LTD is committed to providing secure, reliable global connectivity using its products and services. We value your privacy and as part of our commitment, we want to be transparent about the data we collect and how it is used.
This Privacy Policy applies when you purchase a Gotek Telecom LTD product and/or use Gotek Telecom LTD Services. This includes the use of products and services of Gotek IoT & Gotek Cloud.
Owner contact email: info@gotektelecom.com / info@gotekiot.com / info@gotekcloud.gotektelecom.com
Address: GOTEK TELECOM LTD., 3107 Avenue des Hôtels, Quebec City, Québec G1W 4W5, Canada.
Types of Data collected
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Gotek Telecom products and services.
Unless specified otherwise, all Data requested by Gotek Telecom LTD is mandatory and failure to provide this Data may make it impossible for Gotek Telecom LTD to provide its services. In cases where Gotek Telecom LTD specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Gotek Telecom LTD or by the owners of third-party services used by Gotek Telecom LTD serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Gotek Telecom LTD and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and Place of Processing the Data
Methods of Processing
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Gotek Telecom LTD (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal Basis of Processing
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention Time
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Purpose of Processing
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Analytics
Google Analytics (Google Inc.)
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Data transfer outside the EU
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (Gotek Telecom LTD)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data collected: various types of Data.
Data transfer abroad based on standard contractual clauses (Gotek Telecom LTD)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data collected: various types of Data.
Handling Payments
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Managing Support & Contact Requests
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g., email address, account information).
Platform Services & Hosting
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host Gotek Telecom LTD.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Further Information about Personal Data
Service use, Device & Location
The Owner (Gotek Telecom LTD) or third-party services employed by the Owner collects information automatically when the User uses or engages with Gotek Telecom LTD Products & Services, such as the Gotek Telecom LTD website, mobile app, and web platform technology. The information collected includes the User usage data, purchases made, app installation and updates, and how the User engages with service content. Gotek Telecom LTD uses login information, user data, cookies, device information, and internet protocol (“IP”) addresses in order to identify Users, log API calls, and provide User support.
Information is collected automatically (or manually by the user) about User’s services usage, these services include the usage of specific Gotek IoT products, such as Healthcare data, Vehicle Tracking data, etc. The information collected includes, but is not limited to, user and device location, health data, vehicle data, personnel data, login status, user & device tracking and positioning, length of data sessions, amount of data used in a session, and network connectivity status. This information is required in order for Gotek Telecom LTD to be able to provide access to, and billing for, use of Gotek Telecom LTD services to the User. Gotek Telecom LTD stores this data as long as the user account is running and active, as stated in the retention period, data will be deleted after a specific time, if the user account is inactive / deleted / subscription is not paid / retention period is over.
Gotek Telecom LTD Customer Support accesses User data to troubleshoot and resolve User complaints and service issues. Additional information may be requested from the User to investigate further. User data may be shared with third party vendors (if any) in order to address service issues beyond Gotek Telecom LTD ’s control.
Device and location
In order to offer services, Gotek Telecom LTD automatically collects User information pertaining to device & user location, operating system, IP address, device identifier, ISP and/or mobile carrier connection, cell id, and Gotek Telecom LTD app version.
Communications
Personal Data collected: email address, first name, last name, country, and phone number.
Advertising
Personal Data collected: amount of data used, home country, countries visited (e.g. Vehicle tracking location), cookies, pixels and ad tags.
The Rights of Users
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data (this may result in limited support or account closure since some services rely on some specific user data).
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data. Users have the right to receive their Data in a structured, commonly used and machine-readable format.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Cookie Policy
Gotek Telecom LTD uses Cookies or other Identifiers to carry out activities that are strictly necessary for the operation or delivery of the Service and, therefore, do not require Users to consent. Users can disable such Identifiers by modifying their browser or device settings as described in more detail within this document, but this may affect core operational functions or result in the unavailability of the Service.
How to provide or withdraw consent
Users can provide or withdraw consent to the use of Cookies and other Identifiers by setting their preferences within the cookie notice or by updating such preferences via the relevant consent-preferences widget accordingly, if available.
Additionally, Users can manage preferences regarding Identifiers directly from within their own device settings and prevent – for example – the storing of third-party Identifiers. It is also possible, via relevant browser or device features, to delete previously stored Identifiers, including those used to remember the User’s initial consent. Users can, for example, find information about how to manage Identifiers in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
Notwithstanding the above, Users are hereby informed that they may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
Additional information about data collection and processing
Legal action
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
Information not contained in this policy
How “Do Not Track” requests are handled
To determine whether any of the third-party services (if any) it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Usage Data
User
Data Subject
Data Processor (or Data Supervisor)
Data Controller (or Owner)
Service
European Union (or EU)
Cookies
Legal information
This privacy policy relates solely to Gotek Telecom LTD, if not stated otherwise within this document.