Privacy Policy for Optical Pathways

Collection of Personal Information

When you use our Services, we may collect or receive Personal Information about you to provide our services and operate our business. The types of Personal Information that we may collect about you are:

• Information You Provide to Us Directly: You may provide your Personal Information to us when you use our Services, including when you create an account on the Website (“Account”), use the Website, contact us with inquiries, or otherwise access our Services. This information may include:
• User Profile: We collect Personal Information associated with your Account. This includes information such as name and email address.
• Purchase or Order Details: When you make a purchase through our Services, we collect information related to that purchase. This may include information such as date and time of purchase and total price.

Information Received From You as Part of Your Communications

When you use our Services (for example, on our Website), complete electronic forms, communicate with us, or contact us by email or phone, we may automatically collect and store certain information about you and the activity you engaged in. This may include:

• your name and contact information;
• your purchase details;
• information that you voluntarily provide to us;
• the nature of your communication;
• the purpose of the interaction; and
• the action we took in response to your inquiry or request.

Information Collected Automatically

We may receive and store certain information about you and your device(s) automatically when you access or use our Website and Services. This information may include:

• Technical Information: We collect technical information associated with your activity on our Website. This may include information related to your browser and operating system, IP address (the internet address of your computer), unique device identifiers, and other information such as your device type. We use such information for diagnostic and statistical purposes and to administer our Services.
• Site Usage Information: We collect information to better understand customer traffic patterns and Website usage. This may include the webpage that you were visiting before accessing our Website or mobile application, the pages or features of our Website or mobile application you browsed, to inform us which part of our Website app and Services you visit and how much time you spend there. This information is used to analyze and improve our Website and to provide our customers with a better user experience.
• Site Preferences: We collect information about your preferences to make your use of the Website more productive through the use of cookies.

Personal Information from Publicly Available Sources and Third Parties

We may collect or receive Personal Information about you from publicly available sources, social network providers, marketing partners, and/or third parties. This may include:

• Social Network Information: We may receive information about you from other services. For example, we may receive certain information from social media influencers that we retain when you interact with their content.

Use of Cookies and Other Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to collect information and personalize your experience with our Services.

Cookies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.

• How We Use Cookies: We use first-party and third-party cookies for the following purposes:
• to make our Services function properly;
• to improve our Services;
• to recognize you when you return to the Website (or one of our other Services) and to remember information you have already provided;
• to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and
• to provide a secure browsing experience during your use of our Services.

How to Manage Cookies

You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies, you may not be able to fully experience the interactive features of our Services. For more information on cookies and how to disable cookies, visit www.ftc.gov/ftc/cookies.shtm or https://www.usa.gov/optout_instructions.shtml.

Web Beacons

Web beacons, also known as web bugs, pixel tags, or clear GIFs, are tiny graphics with a unique identifier that may be included on our Website to deliver or communicate with cookies in order to track and measure the performance of our Website and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or in an email).

Online Analytics and Advertising Technologies

We and our third-party vendors may use automated technologies (including cookie identifiers on our Website) along with other collected information to tailor ads or deliver content when you are on our Services or on other devices, apps, or websites.

Interest-Based Advertising

We (or our service providers) may use the information we collect, for instance, IP addresses and unique mobile device identifiers to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt-out of cross-device tracking for purposes of interest-based advertising, you may do so through your device settings. We may also use cross-device targeting to help identify our users and serve advertising. This type of advertising is often called “interest-based” or “personalized” advertising—and when it occurs on mobile apps “cross-app” advertising.

You can learn more about interest-based advertising and how to opt-out of receiving tailored advertising by visiting:

• (i) the Network Advertising Initiative’s Consumer Opt-Out link; or
• (ii) the Digital Advertising Alliance’s Consumer Opt-Out link. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

Please note that even if you opt-out, you may still receive advertisements from us. However, in that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.

Mobile Applications

Depending on your permissions, we may receive your Personal Information from your Internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Learn more about your choices for mobile devices by visiting http://www.aboutads.info/appchoices. Each operating system (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You should view your device or system “Settings” to determine how you can opt-out of use of your device ID for “cross-app” personalized advertising.

Use of Your Personal Information

We may use the information we collect or receive about you for various purposes, including:

• To provide you with our Services. For example, we use credit card information to complete a transaction or an address to fulfill your purchase order. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable Personal Information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers (such as the post office, credit card companies, and payment processing companies) that are contractually obligated to protect your information as disclosed in this Policy.
• To maintain, improve, and personalize the Services. We use your information for our everyday business operations such as auditing, administration of the Services, forum management, fulfillment, and analytics. Your information may also be used to improve the content and/or functionality of the Services. For example, it may be used to help us improve our offerings. We also use your information to personalize your experience. For example, we may personalize the content and features you see when visiting our Services. In addition, we may personalize advertisements, marketing communications, and recommendations to make them more tailored to your interests.
• To communicate with you. We use your information to communicate with you. We may contact you with promotional offerings or other communications that may be of interest to you. If we send you marketing emails about services that may interest you, each email will contain instructions permitting you to “unsubscribe” from receiving future marketing or other communications within 10 days.
• To maintain legal and regulatory compliance. Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your information to fulfill our business obligations or as necessary to manage risk as required under applicable law.
• To enforce compliance with our Terms and Conditions and Policies. When you access or use our Services, you are bound to our Terms and Conditions and this Policy. To ensure you comply with them, we process your Personal Information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit, or illegal activities on our Services. We also process your Personal Information to investigate, prevent, or mitigate violations of our internal terms, agreements, or policies and to enforce our agreements with third parties and business partners.
• To protect you, others, and our business. We use your information to protect you, others, and our business, including without limitation using information for fraud prevention, for enforcement of our Terms and Conditions, to comply with the law, and to protect against security risks.
• For our business purposes. We may use your information for any other purpose disclosed to you at the time we collect or receive the information or otherwise with your consent.

Sharing of Personal Information with Third Parties

Your Personal Information is not shared with third parties without your permission except as described below.

• Service Providers: We may share your information with our third-party service providers for certain business purposes. This information is provided in order for them to provide us services such as payment processing, hosting services, security services, data services, advertising services, marketing partners, and other services. These third-party service providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
• When Required by Law: We recognize that information related to your orders could contain private information. However, we may be required to disclose your information to third parties, including law enforcement agencies, when required to protect and defend our legal rights, protect the security of users of our Services, prevent fraud, comply with the law, respond to legal process, or a request for cooperation by a government entity.
• Corporate Transactions: In the event of sale, transfer, merger, reorganization, dissolution, or similar event, we may transfer your information to one or more third parties as part of that transaction.
• With Your Consent: We also may share or disclose your information with your consent or at your direction.

Security

Company has implemented administrative, technical, and physical security controls that are designed to safeguard Personal Information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Information is absolutely secure. Please keep this in mind when disclosing any information to Company.

Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the internet or when you communicate with us and with others through the internet.

Data Retention

We will retain your Personal Information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Third-Party Sites

Some of the functionality may be provided by third parties, and the Services may link to other third-party websites that are not controlled by Company. These third parties are not under our control, and Company is not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.

Your Choices

We provide our customers and their authorized agents with the ability to access and delete certain Personal Information. In order to exercise these rights, you must log in to your account to confirm your identity, which helps us ensure that Personal Information is only made accessible to appropriate parties. Customers will not receive discriminatory treatment for exercising their rights and can return to the service after deleting their information.

Your Rights

This section lists the privacy-related rights (“Rights”) we extend to all of our customers. Your right to know and right to deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us, or the security of our systems.

• Right to Know: You have the right to know the Personal Information we collect, use, and disclose about you.
• Right to Deletion: You have the right to request that we delete any Personal Information we have collected from you or maintain about you. We may save Personal Information when permitted by applicable law, including without limitation when the information is needed for a legal purpose.
• Right to Rectification: If you have an Account, you may modify your Personal Information by contacting us at the address provided at Section 11 of this Policy.
• Right to Opt-Out of the Sale of Your Personal Information: Company does not sell or rent Personal Information to third parties.
• Right to Non-Discrimination: We do not discriminate against those who exercise their Rights. Specifically, if you exercise your Rights, we will not deny you goods or Services, charge you different prices or rates for goods or Services, or provide you a different level or quality of goods or Services.

Asserting Your Rights

You may exercise your right to know or your right to deletion by contacting us at privacy@opticalpathways.com. We may ask you to verify your identity if you are contacting us through online chat, email, or phone. You may also designate an authorized agent to make a request to know or a request to delete. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.

For Personal Information that we have collected that is not accessible through the Account, you can request in writing that we correct an error or omission to your Personal Information or delete your Personal Information. We will respond to written requests within 30 days or alternatively the timeframe prescribed by the relevant legislation.

International Users

Company is based in Canada, and regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in Canada. Any information we obtain about you will be stored in accordance with Canadian privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in Canada.

Contact Us

If you have any questions or concerns relating to this Policy or our privacy practices, please contact us at: privacy@opticalpathways.com