PRIVACY NOTICE
Last updated August 26, 2022
This privacy notice for Latence Technologies Inc.
("Company," "we," "us," or
"our"), describes how and why we might collect, store, use,
and/or share ("process") your information when you use our
services ("Services"), such as when you:
▪
Download
and use our mobile application (Latency Measurement), or any other application
of ours that links to this privacy notice
▪
Engage
with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand
your privacy rights and choices. If you do not agree with our policies and
practices, please do not use our Services. If you still have any questions or
concerns, please contact us at support@latencetech.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy
notice, but you can find out more details about any of these topics by clicking
the link following each key point or by using our table of contents below to
find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with Latence
Technologies Inc. and the Services, the choices you make, and the products and
features you use. Click here to learn more.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have
a valid legal reason to do so. Click here to
learn more.
In what situations and with which parties do we share
personal information? We may
share information in specific situations and with specific third parties.
Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify your
information. Click here to learn more.
What are your rights? Depending on where you are located geographically,
the applicable privacy law may mean you have certain rights regarding your
personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling
out our data subject request form available here,
or by contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.
Want to learn more about what Latence Technologies
Inc. does with any information we collect? Click here to
review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us.
We collect personal information that you voluntarily
provide to us when you express an interest in obtaining information about us or
our products and Services, when you participate in activities on the Services,
or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
Application Data. If you use our application(s), we also may collect
the following information if you choose to provide us with access or permission:
▪
Geolocation
Information. We may request
access or permission to track location-based information from your mobile
device, either continuously or while you are using our mobile application(s),
to provide certain location-based services. If you wish to change our access or
permissions, you may do so in your device's settings.
This information is primarily needed to maintain the
security and operation of our application(s), for troubleshooting, and for our
internal analytics and reporting purposes.
All personal information that you provide to us must
be true, complete, and accurate, and you must notify us of any changes to such
personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for
other purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services, including:
▪
To save
or protect an individual's vital interest. We may process your information when necessary to
save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information when we
believe it is necessary and we have a valid legal reason (i.e., legal basis) to
do so under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual obligations,
to protect your rights, or to fulfill our legitimate business interests.
If you
are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK
GDPR require us to explain the valid legal bases we rely on in order to process
your personal information. As such, we may rely on the following legal bases to
process your personal information:
▪
Consent. We may process your information if you have given us
permission (i.e., consent) to use your personal information for a specific
purpose. You can withdraw your consent at any time. Click here to
learn more.
▪
Legal
Obligations. We may process your
information where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or regulatory
agency, exercise or defend our legal rights, or disclose your information as
evidence in litigation in which we are involved.
▪
Vital
Interests. We may process your information where
we believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential threats to
the safety of any person.
If you
are located in Canada, this section applies to you.
We may process your information if you have given us
specific permission (i.e., express consent) to use your personal information
for a specific purpose, or in situations where your permission can be inferred
(i.e., implied consent). You can withdraw your consent at any time. Click here to
learn more.
In some exceptional cases, we may be legally permitted
under applicable law to process your information without your consent,
including, for example:
▪
If
collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
▪
For
investigations and fraud detection and prevention
▪
For
business transactions provided certain conditions are met
▪
If it is
contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
▪
For
identifying injured, ill, or deceased persons and communicating with next of
kin
▪
If we
have reasonable grounds to believe an individual has been, is, or may be victim
of financial abuse
▪
If it is
reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is
reasonable for purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province
▪
If
disclosure is required to comply with a subpoena, warrant, court order, or
rules of the court relating to the production of records
▪
If it was
produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the
information was produced
▪
If the
collection is solely for journalistic, artistic, or literary purposes
▪
If the
information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations
described in this section and/or with the following third parties.
We may need to share your personal information in the
following situations:
▪
Business
Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger, sale of
company assets, financing, or acquisition of all or a portion of our business
to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this privacy notice unless otherwise required
by law.
We will only keep your personal information for as
long as it is necessary for the purposes set out in this privacy notice, unless
a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than 2 years.
When we have no ongoing legitimate business need to
process your personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store
your personal information and isolate it from any further processing until
deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a
system of organizational and technical security measures.
We have implemented appropriate and reasonable
technical and organizational security measures designed to protect the security
of any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the Internet
or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and
from our Services is at your own risk. You should only access the Services
within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market
to children under 18 years of age.
We do not knowingly solicit data from or market to
children under 18 years of age. By using the Services, you represent that you
are at least 18 or that you are the parent or guardian of such a minor and
consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age has been collected,
we will deactivate the account and take reasonable measures to promptly delete
such data from our records. If you become aware of any data we may have collected
from children under age 18, please contact us at support@latencetech.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic
Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you
greater access to and control over your personal information. You may
review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you
have certain rights under applicable data protection laws. These may include
the right (i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing
of your personal information. You can make such a request by contacting us by using
the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in
accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we
are unlawfully processing your personal information, you also have the right to
complain to your local data protection supervisory authority. You can find
their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details
for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your consent: If we
are relying on your consent to process your personal information, which may be
express and/or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw your consent at
any time by contacting us by using the contact details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?" below.
However, please note that this will not affect the
lawfulness of the processing before its withdrawal nor, when applicable law
allows, will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems
and mobile applications include a Do-Not-Track ("DNT") feature or
setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage no
uniform technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser signals or
any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must
follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: Yes, if you are a resident of California, you are
granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as
the "Shine The Light" law, permits our users who are California
residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to
third parties for direct marketing purposes and the names and addresses of all
third parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like to
make such a request, please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of age, reside in
California, and have a registered account with Services, you have the right to
request removal of unwanted data that you publicly post on the Services. To
request removal of such data, please contact us using the contact information
provided below and include the email address associated with your account and a
statement that you reside in California. We will make sure the data is not
publicly displayed on the Services, but please be aware that the data may not be
completely or comprehensively removed from all our systems (e.g., backups,
etc.).
CCPA Privacy Notice
The California Code of Regulations defines a
"resident" as:
(1) every individual who is in the State of California
for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of
California who is outside the State of California for a temporary or transitory
purpose
All other individuals are defined as
"non-residents."
If this definition of "resident" applies to
you, we must adhere to certain rights and obligations regarding your personal
information.
What categories of personal information do we collect?
We have collected the following categories of personal
information in the past twelve (12) months:
Category |
Examples |
Collected |
A. Identifiers |
Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and account name |
NO |
B. Personal information categories listed in the
California Customer Records statute |
Name, contact information, education, employment,
employment history, and financial information |
NO |
C. Protected classification characteristics under
California or federal law |
Gender and date of birth |
NO |
D. Commercial information |
Transaction information, purchase history, financial
details, and payment information |
NO |
E. Biometric information |
Fingerprints and voiceprints |
NO |
F. Internet or other similar network activity |
Browsing history, search history, online behavior,
interest data, and interactions with our and other websites, applications,
systems, and advertisements |
NO |
G. Geolocation data |
Device location |
YES |
H. Audio, electronic, visual, thermal, olfactory, or
similar information |
Images and audio, video or call recordings created
in connection with our business activities |
NO |
I. Professional or employment-related information |
Business contact details in order to provide you our
Services at a business level or job title, work history, and professional
qualifications if you apply for a job with us |
NO |
J. Education Information |
Student records and directory information |
NO |
K. Inferences drawn from other personal information |
Inferences drawn from any of the collected personal
information listed above to create a profile or summary about, for example,
an individual’s preferences and characteristics |
NO |
We may also collect other personal information outside
of these categories through instances where you interact with us in person,
online, or by phone or mail in the context of:
▪
Receiving
help through our customer support channels;
▪
Participation
in customer surveys or contests; and
▪
Facilitation
in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing
practices can be found in this privacy notice.
You may contact us by email
at support@latencetech.com, or by referring to the contact details at the
bottom of this document.
If you are using an authorized agent to exercise your
right to opt out we may deny a request if the authorized agent does not submit
proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our
service providers pursuant to a written contract between us and each service
provider. Each service provider is a for-profit entity that processes the
information on our behalf.
We may use your personal information for our own business
purposes, such as for undertaking internal research for technological
development and demonstration. This is not considered to be "selling"
of your personal information.
Latence Technologies Inc. has not disclosed or
sold any personal information to third parties for a business or commercial
purpose in the preceding twelve (12) months. Latence Technologies
Inc. will not sell personal information in the future belonging to website
visitors, users, and other consumers.
Your rights with respect to your personal data
Right to
request deletion of the data — Request to delete
You can ask for the deletion of your personal
information. If you ask us to delete your personal information, we will respect
your request and delete your personal information, subject to certain
exceptions provided by law, such as (but not limited to) the exercise by
another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to
be informed — Request to know
Depending on the circumstances, you have a right to
know:
▪
whether
we collect and use your personal information;
▪
the
categories of personal information that we collect;
▪
the
purposes for which the collected personal information is used;
▪
whether
we sell your personal information to third parties;
▪
the
categories of personal information that we sold or disclosed for a business
purpose;
▪
the
categories of third parties to whom the personal information was sold or
disclosed for a business purpose; and
▪
the
business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not
obligated to provide or delete consumer information that is de-identified in
response to a consumer request or to re-identify individual data to verify a
consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise
your privacy rights.
Verification
process
Upon receiving your request, we will need to verify
your identity to determine you are the same person about whom we have the
information in our system. These verification efforts require us to ask you to
provide information so that we can match it with information you have
previously provided us. For instance, depending on the type of request you
submit, we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or we may
contact you through a communication method (e.g., phone or email) that you have
previously provided to us. We may also use other verification methods as the
circumstances dictate.
We will only use personal information provided in your
request to verify your identity or authority to make the request. To the extent
possible, we will avoid requesting additional information from you for the
purposes of verification. However, if we cannot verify your identity from the
information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for
security or fraud-prevention purposes. We will delete such additionally
provided information as soon as we finish verifying you.
Other
privacy rights
▪
You may
object to the processing of your personal information.
▪
You may
request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
▪
You can
designate an authorized agent to make a request under the CCPA on your behalf.
We may deny a request from an authorized agent that does not submit proof that
they have been validly authorized to act on your behalf in accordance with the
CCPA.
▪
You may
request to opt out from future selling of your personal information to third
parties. Upon receiving an opt-out request, we will act upon the request as
soon as feasibly possible, but no later than fifteen (15) days from the date of
the request submission.
To exercise these rights, you can contact us by
email at support@latencetech.com, or by referring to the contact details at the
bottom of this document. If you have a complaint about how we handle your data,
we would like to hear from you.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay
compliant with relevant laws.
We may update this privacy notice from time to time.
The updated version will be indicated by an updated "Revised" date
and the updated version will be effective as soon as it is accessible. If we
make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice,
you may email us at support@latencetech.com or by post to:
Latence Technologies Inc.
__________
1000 Rue Saint-Jacques
Montréal, Quebec H3C 1G7
Canada
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
You have the right to request access to the personal
information we collect from you, change that information, or delete it. To
request to review, update, or delete your personal information, please submit a
request form by clicking here.