MOBILE COMPUTING CORPORATION

PRIVACY POLICY

1. Introduction

Mobile Computing Corporation (“MCC” or “we”) is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable laws. This Privacy Policy is a statement of principles and guidelines for the protection of the personal information of our website visitors, customers, suppliers, service providers, and other individuals (“individuals” or “you”). The objective of this Privacy Policy is to ensure responsible practices in the collection, use and disclosure of personal information, in accordance with laws applicable to MCC. 

2. What personal information do we collect?

Personal information is information about an identifiable individual, as defined in applicable privacy laws. Personal information does not include aggregated information that does not allow an individual to be identified. Generally speaking, an individual’s business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information.  In addition, from time to time, we may ask you to voluntarily provide us with more detailed information regarding your business requirements. For example, we sometimes ask individuals to complete surveys in order to get a better sense of who our customers and prospective customers are, what products and services may be of interest to them and insights into our customer service and account support to MCC customers. 

The types of personal information we may collect includes your name, home telephone number, home and e-mail addresses (if your contact information is personal rather than business based), your method of contact with us and your preferences, delivery instructions and other information incidental to our supply of products and services, feedback and comments you provide to us.  

3. What are our Privacy Principles?

MCC collects, uses and discloses personal information in accordance with the following ten privacy principles which form the basis of this Privacy Policy:

Principle 1 - Accountability
MCC is responsible for personal information under its control and has designated a Privacy Officer to be accountable for MCC’s compliance with this Privacy Policy and applicable laws. Contact information for the MCC Privacy Officer is provided in Section 10 below.

Principle 2 - Identifying Purposes for Collection of Personal Information
MCC identifies the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which MCC collects, uses or discloses of personal information are described in Section 4 below.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
Your knowledge and consent are required for the collection, use, or disclosure of your personal information, except as required or permitted by law. Consent may be express or implied, as permitted by applicable laws. In obtaining consent, MCC uses reasonable efforts to ensure that you are advised of the identified purposes for which your personal information will be used or disclosed. In determining the appropriate form of consent, MCC will take into account the sensitivity of the personal information and your reasonable expectations. You may withdraw consent at any time by contacting our Privacy Officer in writing, subject to legal or contractual restrictions and reasonable notice. MCC will advise you of the implications of such withdrawal.

Principle 4 - Limiting Collection of Personal Information
MCC limits the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by MCC. Personal information is collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is being collected.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
MCC does not use or disclose personal information for purposes other than the identified purposes for which it is collected or as required or permitted by law.  MCC retains personal information only as long as necessary to fulfill the identified purposes.

Principle 6 - Accuracy of Personal Information
Personal information held by MCC is based on the information provided by you and used only for the permitted purposes. MCC does not update personal information, unless provided by you . We rely on you to inform us of any changes to your personal contact information. To update your personal information, please see Section 10.

Principle 7 - Security Safeguards
MCC protects personal information by security safeguards appropriate to the sensitivity of the information. MCC uses reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. MCC protects personal information and does not disclose such information to third parties except for permitted purposes.

Principle 8 - Openness Concerning Policies and Practices
MCC makes readily available to individuals specific information about its policies and practices relating to the management of personal information. MCC makes information about its personal information policies and practices available at www.mobilecom.com and upon request to the Privacy Officer via the contact information provided below.

Principle 9 – Individual Access to Personal Information 
Upon your written request, MCC will inform you of the existence, use, and disclosure of your personal information and, subject to certain exceptions, will give you access to that information. If access is granted, MCC will give you a reasonable opportunity to review the personal information collected by MCC. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost. You are able to challenge the accuracy and completeness of the information and have it amended as appropriate.  If access is lawfully denied, MCC will notify you in writing, give reasons for the denial, and inform you of the recourses open to you.

Principle 10 – Questions on the Privacy Policy
You may address any questions concerning this Privacy Policy or challenge compliance with this Privacy Policy to the MCC  Privacy Officer, whose contact information is set out in Section 10 below.

4. Why do we collect personal information?

MCC, and its affiliates, agents and service providers acting on MCC’s behalf, may collect, use and/or disclose personal information for the following purposes:

(a) to understand and respond to the inquiries, feedback, needs and preferences of our customers, website visitors and other individuals, including to communicate with such individuals;

(b) to conduct research and statistical analysis;

(c) to distribute newsletters, promotional information and other material to individuals, in any format or media, including via third party mailing houses and email service providers;

(d) to develop, enhance, market, advertise, sell or otherwise provide MCC and its affiliates’ products and services;

(e) to manage and develop MCC’s and its affiliates’ businesses and operations, including to apply for and maintain all necessary regulatory licenses and permits;

(g) to update and verify our databases and information provided by third parties;

(h) to establish and maintain commercial relations with customers;

(i) to establish and maintain commercial relations with service providers, suppliers, distributors, investors, insurers, financial institutions, and affiliates, including to provide products and services, administer accounts, facilitate deliveries, evaluate risk and insurance requirements and check references,;

(j) to monitor communications to ensure the quality of the products and services of MCC, its affiliates, suppliers, distributors and other third parties;

(k) to administer the physical and technological security of MCC facilities, and the safety of our customers, visitors, personnel and other individuals, through security surveillance and other security systems and processes, in accordance with MCC’s policies and applicable law;

(m) to comply with MCC’s audit and security requirements, and to audit compliance with MCC’s corporate policies, procedures, contractual obligations and applicable laws;

(o) as permitted by, and to comply with, any legal or regulatory requirements or laws; and

(p) for any other purpose to which an individual consents.

You may have the right to opt-out of some of these identified purposes. In order to specify your privacy preferences, please contact our Privacy Officer.  If you refuse or withdraw your consent to certain purposes, we may not be able to provide you with our products, services and information.

5. To whom do we disclose personal information?

In addition to disclosures identified in the purposes described in Section 4, from time to time MCC may disclose personal information to:

(a) its service providers, including MCC affiliates, retained to perform functions on MCC’s behalf or to provide services to MCC, such as marketing and advertising; and further provided such service provider does not collect, use or disclose the personal information for any purpose other than to perform such functions for MCC or as otherwise required by law;

(b) a person or entity, including MCC affiliates, to whom disclosure is required in order to fulfill one or more of the purposes described in Section 4 of this Privacy Policy;

(c) law enforcement, courts and government agencies, including those in foreign countries, where MCC or its affiliates are required by law, such as in response to a subpoena, warrant, order, demand or request by an agency with jurisdiction to compel the disclosure of personal information; or

(d) any third party with your consent or where disclosure is required or permitted by law.

6. Privacy and our Websites

Website Cookies - When you access the MCC websites, we may use a browser feature called a ‘cookie’ to collect information that is not personally identifiable (such as the type of Internet browser and operating system you use, the domain name of the website from which you came, number of visits, average time spent on our website, and pages viewed). A cookie is a small text file containing a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our websites that uses cookies. Unless you specifically inform us (e.g. by sending us comments or an inquiry from our contact webpage), we will not know who you are. In addition to the identified purposes described in this Privacy Policy, MCC may use this cookie information and share it with our affiliates and other organizations with whom we have a commercial relationship to measure the use of our websites and to improve the functionality and content of the websites. If you wish, you can reset your browser either to notify you when you have received a cookie or refuse to accept cookies. However, if you refuse to accept cookies, you may not be able to use certain features on our websites.

Website Links -Our websites may contain links to other websites which are provided to you as a convenience only. You are advised that other third party websites may have different privacy practices than MCC, and MCC has no responsibility for such third party websites.

7. How can you obtain access to your personal information?

Upon your written request and subject to certain legal exceptions, MCC will inform you of the existence, use and disclosure of your personal information and will give you access to that information. Access requests must be sent in writing to our Privacy Officer at the address set out in Section 10 below.

8. How do we protect personal information?

To help protect the confidentiality of personal information, MCC uses administrative and technological safeguards appropriate to the sensitivity of the personal information. For instance, we operate secure data networks protected by industry standard firewall and password protection systems.  Personal information is stored in secured locations and on servers located either at our offices or at the facilities of our data storage providers and technology service providers. Personal information may be stored in Canada or with our affiliates and service providers in foreign countries, including in the United States.

9. Changes to this Policy

MCC reserves the right to modify or supplement this Privacy Policy at any time. We will post any changes to this Privacy Policy on our website at www.mobilecom.com. However, MCC will seek your consent if we want to collect, use or disclose his or her personal information for purposes other than those to which you have already consented unless otherwise required or permitted by law. Changes to our Privacy Policy will be noted here so that you can be fully informed about our privacy policies and practices.

Date last revised:

Description of Revision:

10. Further Information

For more information about MCC’s privacy practices, to amend or obtain access to your personal information, to opt-out or withdraw your consent, or if you have privacy-related questions or concerns, please contact the MCC Privacy Officer at: 

MCC Privacy Officer

mzanel@mobilecom.com

Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against MCC or any third party or any of their respective directors, officers, employees, agents or representatives (collectively, the “MCC Group”); nor will the existence of this Privacy Policy or its application impose any obligations or liability upon the MCC Group, or add to any such obligation or liability, that the MCC Group does not already otherwise have to any individual or person at law or otherwise.