This Privacy Policy describes our privacy practices in relation to personal information that we collect when you use our products, services, and “Digital Channels” operated by us.
Our Digital Channels include:
When we refer to “we”, “us”, “our”, “Soracom” or use similar phrasings, we refer to one of the following entities, all of which acts as the data controller for personal information about our customers depending on the location they register as:
If you wish to know which entity is acting as the data controller for your personal information or for any other reason, please see HOW TO CONTACT US at the bottom of this Privacy Policy.
We are committed to handling all personal information in compliance with applicable data protection laws and will provide additional information about how we collect, process, and use personal information as required in certain jurisdictions.
For California residents, we provide a separate Notice to California Residents in accordance with the California Consumer Privacy Act 2018 (Cal. Civ. Code §1798.100 et seq.), which makes certain disclosures about the collection and processing of their personal information.
For the purposes of this Privacy Policy, personal information refers to information that is reasonably capable of identifying you as an individual and will either be voluntarily provided by you or automatically collected by us.
Voluntarily provided information refers to personal information which you knowingly and actively provide to us upon your use and participation of our products, services, and Digital Channels. This includes the following:
Automatically collected information refers to personal information which is automatically collected by us as you use and access our products, services, and Digital channels. This includes the following:
We collect personal information in a variety of ways, including:
We collect and use your personal information to provide, manage and operate our services. For example, we use your personal information for the following purposes:
Third Party Service Providers: Subject to applicable data protection legislation, we may share your personal information with any affiliate, agents, service providers and/or subcontractors of us for the purposes listed in this Privacy Policy. (e.g. authorised third party companies involved in the processing of payments made on our website, other third parties helping us achieve the purposes listed in this Privacy Policy, including the operation of our websites or hosting our data). Where required by law, our legal basis for such disclosure of personal information may be that it is necessary for our legitimate interests, in order to provide you with our services including in a cost-effective manner.
Legal Obligations: We may disclose your personal information to authorised governmental entities, supervisory agencies, fiscal entities, etc., pursuant to a legal process or enforceable governmental request which we are under an obligation to comply with. Our legal basis for such disclosure of personal information is for us to ensure compliance with a legal obligation to which we are subject.
Business Transfers: In some cases, we may buy or sell assets or businesses and in these types of transactions, user information is typically one of the business assets that is transferred. We may disclose personal information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Our legal basis for such processing of personal information is that it is necessary for our legitimate interests, in order to be able to buy or sell assets or businesses.
Personal information processed by us may be transferred or accessed by entities, including Soracom affiliates, around the world as described in this Privacy Policy. Specifically, we may transfer your personal information between the data controllers specified in this Privacy Policy (SORACOM GLOBAL, INC. and SORACOM CORPORATION, LTD.) as well as to other subsidiaries, affiliates and related companies as specified below.
For the international transfer of any personal information from the European Economic Area, the United Kingdom and Switzerland, we have entered into agreements with each affiliate, which include data protection Model Clauses to contractually protect your personal information.
Please contact us if you have any questions.
Marketing Communication collectively refers to the various tools we use to inform customers about our products and services with a commercial purpose. We may send marketing emails to you if you have specifically consented to receiving such Marketing Communication or if you are an existing customer of similar Soracom products and services. We may also send offers by regular mail, SMS, social media, coupons, or any other communication channel. With your consent, we may use your personal information to provide you with tailored offers, based on your interests and use of Soracom products, services, and Digital Channels. For example, we may assess your personal preferences based on analysing your use of our services, purchase history, participation in promotions or surveys, and other data that has been voluntarily or automatically obtained. You may withdraw your consent at any time by opting-out of receiving marketing emails using the “unsubscribe” link in the marketing emails we send you. For opting-out of receiving tailored offers via other communication channels, please contact us.
Please note that you cannot opt-out of receiving important administrative messages, such as notifications from the User Console and email notifications about your account.
When you use Soracom Social Media Channels, your web browser may be sharing information through an implemented social plug-in (such as a “Like” button) unless you block the use of social plug-ins in your browser settings. Information that may be shared via the social plug-in includes the following:
For more details on how these social media channels collect your information, please refer to the relevant channel’s Privacy Policy. Please note that we have no control over the collection of information on these social media channels.
We have implemented the appropriate organisational, technical, and administrative measures to protect personal information within our organisation, including security controls to prevent unauthorised access to our systems. While we take reasonable steps to secure your personal information, please note that security procedures and protocols cannot be 100% secure. There is always some risk assumed by sharing personal information online. If you have reason to believe that your interaction with us is not secure, please contact us immediately (see How To Contact Us below).
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy. When your personal information is no longer relevant for the purposes for which it has been collected, we will delete it.
As permitted by law, you may have the following rights relating to your personal information:
If you would like to access, correct, remove or limit the use or disclosure of any personal information about you that has been collected and stored by Soracom, please contact us as described in ‘How to Contact Us’ below.
Please note that we may refuse to comply with your request, in which case we will provide you with our reasons. We may also request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you are dissatisfied with our processing of your personal information, you may have the right to lodge a complaint with your local data protection authority. If you wish to know more about this process, please contact us and we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
Our Digital Channels may permit you to link to other websites on the internet through direct links or through applications, and other websites may likewise contain links to our Digital Channels. The privacy practices of such other websites are not governed by this Privacy Policy, and we urge you to refer to the privacy policies of those websites directly.
Soracom may update this Privacy Policy from time to time, for example, to reflect changes to data protection law.
The date shown at the top of this page indicates when this Privacy Policy was last updated.
Any changes to this Privacy Policy will become effective when we publish the revised Privacy Policy. Material changes in our Privacy Policy will be notified 30 days before they are effective.
This Privacy Policy does not apply to the practices of third parties that Soracom does not own or control, or to individuals that Soracom does not employ or manage.
Please note that some Soracom customers may have separate agreements with us that contain further detail regarding the collection, use, and sharing of their data. In the case of conflict between the separate agreement and this Privacy Policy, the terms of the separate agreement will prevail.
When you do not provide personal information which is required by us, we may not be able to provide the products and services under our contract with you. For example, you will be unable to register for a Soracom Account without providing the required account registration information. Additionally, your use of Soracom products and services may be limited if you fail to provide certain personal information, such as a shipping address which will prevent us from fulfilling your purchase order. The same applies if you request for the erasure of your personal information.
Your privacy matters to us. If you have any questions, concerns or complaints regarding the way we collect and handle your information, please go to our Contact Soracom page or send an email to data-request@soracom.io.
Soracom will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.