1. Who We Are
In this policy, references to WLI, or to “we” or “us” are to Wireless Links Inc., A Pennsylvania Registered Company with offices at 1050 Wall Street, suite 340 in Lyndhurst, NJ, USA. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at firstname.lastname@example.org. Our data protection officer is Roye Shayovitch, who may be contacted at our registered address or by emailing email@example.com
2. Your Acknowledge of this Policy (important, please read!)
3. Which Information may we Collect about Users?
We may collect from Users of our Site, two types of data and information:
3.1. Non-personal Information. The first type is non-identifiable and anonymous information. To put it simply, we have no idea the identity of the User from which we have collected the Non-personal Information, unless it is cross-referenced with Personal Information. Non-personal Information, which is being gathered, consists of technical information and behavioural information that does not pertain to a specific individual. For example, technical information may include information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc. Behavioural information may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioural Information”).
3.2. Personal Information. The other type of information we may collect is individually identifiable information. To put it simply, this information may identify an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”). Personal Information which is being gathered consists of any personal details provided voluntarily by the User during the User’s use of the Site, including:
3.2.1. Personal Information which is provided voluntary:
• Communications with WLI: information you provide us as part of any communications with WLI, including by approaching our customer services or during sales calls. We may record such calls for quality assurance purposes and in order to improve our services.
• Contact us forms: information you provide us when filling the “Contact Us” form available on our Site. The “Contact Form” may require you to provide the following details: full name, purpose of your inquiry, e-mail address, phone number, website and company name.
3.2.2. Personal Information collected via technology:
• Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store “geolocation data”, including GPS coordinates and other similar information to determine your location for the purpose of providing a localised version of our Site and for security purposes.
• Technical and behavioural information: to the extent that the Technical and Behavioural Information detailed above will be linked to or associated with a specific individual then such information will be considered as Personal Information.
• Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers.
3.3. Please note:
• We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
4. How do we Collect Information about our Users?
There are two main methods we use to collect information:
4.1. We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we may gather your click-stream.
4.2. We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the “Contact Us” form on our Site. We will inform your prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
5. What are the Purposes of the Collection and Processing of Information?
5.1. Non-personal Information is processed in order to:
• Enhance the User’s experience on the Site;
• Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
• Keep the Site safe and secured and for prevention of fraud.
5.2. Personal Information is processed in order to:
- Enable the operation of the Site;
• Contact you for the purposes of offering you our products and services by email, SMS, phone, through web-browser notification or through the post (having first obtained your consent and subject to your right to opt-out of marketing messages at any time by following the instructions in such message.
• Personalize your experience on the Site (e.g. geolocation data shall be used to provide you with a localised version of the Site (where available));
• Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
• Keep the Site safe and secured and for prevention of fraud and crime;
• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
• Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for WLI to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
• The processing is necessary to comply with a legal obligation – we may process your Personal Information for disclosure of information to authorities; and
• The processing is in our legitimate commercial interests – subject to your interests and fundamental rights, we shall process your Personal Information under this basis with respect all other Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, complying with regulatory requirements, our internal operations, maintaining records and email tracking. We may also use the information contained in cookies and other such files or tags consists based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
6. Sharing Personal Information with Third Parties
6.2. In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:
• WLI Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of WLI for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 5 above). Please note that all WLI personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
6.3. For avoidance of doubt, WLI may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
7. Your Rights
WLI acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: firstname.lastname@example.org and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
• Right to access: you may have the right to request a review of your Personal Information held by WLI.
• Right to erasure: under certain conditions, you may be entitled to require that WLI will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).
• Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity).
• Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
• The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
• Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority.
To exercise these rights, where applicable, please contact us by sending an email to: email@example.com
8. Location of your Data
Note to our Users in the EU:
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
• Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
• Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
• Transferring your Personal Information to organizing that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site is intended for Users over the age of sixteen (16). Therefore, WLI does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.
10. Third Party Service Providers and Third Party Software
10.2. Note, that we collect, hold and/or manage your Personal Information through WLI’s authorized third party’s vendors of certain products or services (such as mapping services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
10.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
10.4. Such third parties service providers include without limitation the following categories of service providers:
• CRM management platforms
• Content management systems
11. Links to Third Party Websites
12. Cookies & Local Storage
12.1. When you access or use the Site, WLI uses industry-standard technologies such as “cookies,” other tracking technologies, other local files and Flash (or similar technologies), which store certain information on the browser or hard drive of your computer and/or your mobile telephone device (“Local Storage”) and which will allow us to distinguish you from other users, enable automatic activation of certain features and improve your User experience and other capabilities.
12.2. Some cookies used by the Site are created per session, do not include any information about you, other than your session key and are removed as your session ends (usually after 24 hours). Other cookies remain saved to your device’s hard drive and/or your mobile telephone device and enable us to recognize your device in the event of a later visit to our website (persistent cookies). Persistent cookies allow us to make our Site more user-friendly, effective and safe.
12.3. It is easy to prohibit the Local Storage. Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option in Flash you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings of Flash, your experience of the Site may be limited. Please note that unless you block the acceptance of cookies, the Site will utilize cookies upon your use of the Site (all unless it is required by applicable law to provide a separate consent to use such cookies, and in which case we will use such cookies only after we receive your separate consent to such use and subject to your right to withdraw such consent at any time).
12.4. Cookies and other Local Storage help WLI personalize the Site, and to:
• track clicks, and online activity to estimate usage pattern and perform other analytics;
• gather information about your approximate geo-location to provide localized content;
• store information about your preferences and the device or browser you are using, and thereby customize and personalize the Site;
• improve the Site; and
• prevent fraud and/or abuse of our services.
13.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
13.2. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on WLI’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.3. WLI will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.5. TO THE EXTENT THAT WLI IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, WLI SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
14. Data Retention
WLI will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.