Privacy Policy

(Last updated: 2024.04.01)

Precision Optical Technologies, Inc. and its subsidiaries in Brazil (FonNet Comercio De Equipamentos De Telecomunicacoes Ltda.), the UK (Precision Optical Technologies, UK Limited), the Netherlands (Precision Optical Transceivers BV i.o.), Canada (Precision Optical Technologies Canada, Inc.), and the US (Opticonx Technologies, Inc.), herby referred to as “Precision” have created this privacy policy (the “Policy”) to explain our privacy practices so you will understand when and how information or data is collected, used, disclosed and protected with respect to our services and web site located at www.precisionot.com (collectively the “Service”). By using the Service, you consent to the privacy practices described in this Policy. We reserve the right to change this Policy at any time. If Precision makes any changes to our Policy, we will post a new policy on our website and update the “last updated” date set forth above.

1. WHAT DATA DOES PRECISION COLLECT?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes full name, gender, company / organization, and title / position.
• Contact Data includes mailing / billing address, email address, telephone number, and delivery address.
• Financial Data includes bank account and payment card information.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased or received from us.
• Technical Data includes internet protocol (IP) address & geolocation, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, products you are interested in, feedback for Precision products, and survey responses.
• Usage Data includes information about how you use and interact with our website, including search terms, pages viewed, links used, videos watched, maps viewed, chat messages, and time spent.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Aggregate data helps Precision understand its user’s needs to best develop new features or otherwise tailor the Service. Precision may share aggregate information about its users with third parties for various purposes, including to better understand and improve the Service and for advertising and marketing purposes.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences about our customers or other business partners.

Precision will never knowingly request personal information from anyone under the age of 16 without receiving parental or guardian consent. If a child under 16 has provided Precision with personal information without parental or guardian consent, the parent or guardian should contact the Precision Privacy Office using the methods below to remove the information and opt-out of the Services provided.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. HOW DOES PRECISION COLLECT YOUR DATA?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:  

• • Register for an account on the Precision website;
  • Submit quote requests or place an order for any Precision products;
  • Complete a customer survey or provide feedback on any Precision message boards;
  • Chat with Precision on the Precision website;
  • Complete a form to receive information about Precision products, including long form content pieces (white papers, e-books, case studies etc);
  • Submit information as part of a promotional company giveaway; or
  • Request newsletters or other marketing information to be sent to you.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.precisionot.com/cookie-policy-eu/ for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  
  • If you have expressed an interest in the types of products or services provided by Precision and have authorised those third parties to share your information.
  • Technical and Usage Data when interacting with Precision websites. This data is collected from the following third parties, which are all based in the US: 

• • • Alphabet
    • Automattic
    • Hubspot
    • LinkedIn
    • NetSuite
    • Salesforce
    • Wistia

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. HOW WILL PRECISION USE YOUR DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the methods listed belwo.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Precision does not rent, sell, or share personal information with other people or non-affiliated companies without prior consent except (i) as necessary to complete a transaction you have requested, (ii) as necessary to perform internal analyses and business functions, (iii) if necessary, in contemplation of a potential business transfer, or (iv) when required by law or where permitted to protect our rights, property, or safety.

Precision does not use automated processing to determine which communications are sent to you. Communications are determined by the products and interests you have indicated as part of feedback, surveys, information requests, and promotional giveaways, along with products that you have purchased or requested quotes for.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.   You will have a choice of newsletters according to your preferences.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. HOW DOES PRECISION SHARE YOUR DATA AND WITH WHOM DOES IT DO SO?

Precision may engage third-parties to perform user engagement analysis of the Service. Precision may share personal information with third-party vendors who assist in performing internal functions necessary to operate our business, such as public relations firms engaged to manage social media platforms or those who assist in processing and completing transactions for products and services that users have requested.

The Service leverages third-party tools that directly collect user personal information such as IP Address and browser information. This information is anonymized unless the user opts into Statistics cookies through the Service’s cookie settings.

In the event that Precision outsources tasks and discloses user personal information to third parties, the use and disclosure of personal information by these third parties is restricted to the performance of those specified tasks. Precision shall endeavor to ensure through contractual terms that all third parties Precision shares user data with shall comply with DPF Principles.

User’s information, including personal information, may be disclosed as part of any merger or acquisition, creation of a separate business to provide the Service or fulfill products, sale or pledge of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.

Precision may share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties as follows: Other companies in the Precision Group acting as joint controllers or processors and who are based in the US, UK, Brazil, Canada, and the Netherlands.

• External Third Parties as follows: 

• • Taxation authorities such as HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Shipping companies that deliver Precision products, marketing materials, gifts, promotional and other gifts, and other goods.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Precision will not share your personal information identification with any third parties, including advertisers, sponsors or partners without your consent unless it has a good faith belief that release is appropriate and necessary to comply with legal process or authority (e.g., a lawful subpoena, warrant or court order), including to meet national security or law enforcement requirements; to enforce or apply its policies; to initiate, render, bill, and collect for amounts owed; to protect its rights, property, or personal safety of Precision, its users, its employees, or the public; or if it reasonably believes that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. HOW DOES PRECISION STORE YOUR DATA?

Precision securely stores your personal information in our Content Relationship Management system (CRM). Information may also be stored in LinkedIn Campaign Manager, Google Ads Manager, Precision’s website administrative portal, Salesforce, NetSuite, HubSpot, or other tools and services depending on where the lead originated.

Precision and third-parties (when consent was provided to share information) will keep user personal information while it may still be used to perform the intended use for which it was obtained, as long as required by regulatory or contractual obligations, or until a request to delete data is obtained from the user.

Upon deletion, personal information will be permanently removed from the Precision CRM system, the systems used to obtain the lead, and from any third-party systems.

Precision will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

6. TRANSFER OF DATA ACROSS INTERNATIONAL BOUNDARIES

Precision is a United States company that sells products worldwide. As products are custom manufactured in the United States, Precision has a legitimate interest in storing your personal information and sales/order information in the United States. If you object to your personal information being transferred or used as described in this Policy, please contact the Precision privacy office using the methods outlined below.

7. WHAT ARE YOUR PERSONAL INFORMATION PROTECTION RIGHTS?

Precision wants to make users are fully aware of your personal information protection rights. Every user is entitled to the following:

• The right to be informed – You have the right to know how Precision and its Services obtain, collect, store, process, and share your personal information. That information is provided by this privacy policy.
• The right to access – You have the right to ask Precision for copies of your personal information. We may charge you a small fee for this service.
• The right to rectification / correction – You have the right to request that Precision correct or complete any personal information you believe is inaccurate or incomplete.
• The right to erasure / be forgotten – You have the right to request that Precision erase or delete your personal information, under certain conditions.
• The right to restrict processing – You have the right to request that Precision restrict the processing of your personal information, including opting opt of sharing your personal information with third parties and Precision using your information for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized, under certain conditions.
• The right to data portability – You have the right to request that Precision transfer the data that it has collected about you to another organization, or directly to you, under certain conditions.
• The right to object to processing – You have the right to object to Precision’s processing of your personal information, including automated decision making, under certain conditions.
• Rights relating to automated decision making and profiling – You may opt out to Precision’s use of automated decision-making (using electronic systems to make decisions without human intervention), under certain conditions. Currently, Precision does not use automated decision making to profile customers.
• The right to withdraw consent at any time – You may withdraw previously provided consent for Precision to process or store your data.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Consent. Precision will not disclose personal information to third parties for their direct marketing purposes without the user’s consent. With consent, Precision may disclose your personal information to third parties so that they may provide the user with the products and services that they have requested.

By subscribing to marketing communications and agreeing to the terms stated within this privacy policy, you consent to receive marketing-related communications from Precision, including but not limited to: product news, event invitations, industry-related content, and resource alerts. You also consent to the storage of your personal information. You may request to unsubscribe from marketing communications using the Unsubscribe link at the bottom of any marketing email or by contacting the Precision privacy office using the methods below.

Children’s Privacy. Precision’s online website is not directed to anyone under the age of 16. Precision does not knowingly collect or solicit information from anyone under the age of 16, or allow anyone under the age of 16 to sign up for Precision services. In the event that Precision learns that it has gathered personal information from anyone under the age of 16 without the consent of a parent or guardian, Precision will delete that information as soon as possible. Collection of personal information for anyone under the age of 16 should be reported to the Precision Privacy Office using the contact information below.

8. WHAT ARE COOKIES AND HOW ARE THEY MANAGED?

Cookies are files placed on your computer when you visit a website that store user settings and preferences and to identify repeat users when the visit the Precision website in the future. The Service uses cookies in a range of ways to improve your experience on our website, including keeping you signed in, tracking users as they navigate between the different pages of the website, retaining your cookie preferences, and to understand how you use the Service.

The Service manages three types of cookies:

• Functional– These cookies are required for the website to function properly. They include keeping the user logged in, maintaining shopping cart contents, retaining user preferences such as cookie settings, and managing CAPTCHAs.
• Statistics– Used for tracking user behavior as they use the service. Part of analytics to improve the user experience.
• Marketing/Tracking– Used to send advertising or other marketing purposes. Also, may be used by third party components of the service to track the user across several websites.

For more information on how Precision uses cookies on this Service, visit the Precision Cookie Policy page at https://www.precisionot.com/cookie-policy-eu/. On this page, users may also manage their cookie preferences, including disabling Statistics & Marketing/Tracking cookies. Functional cookies may not be disabled.

9. THIRD-PARTY WEBSITES

We provide links to third-party websites from the Service as a service to our users and we are not responsible for the content or information collection practices of those sites. Please also note that these websites privacy policies will differ from ours. Therefore, we encourage you to review and understand their privacy practices before providing them with information or visiting their sites.

10. HOW TO CONTACT PRECISION

If you have any questions about this privacy policy, the information that is collected from users of the Service, or if you would like to exercise one of your personal information protection rights, please do not hesitate to contact us at:

Precision OT
Privacy Office
2245 Brighton-Henrietta Townline Road
Rochester, New York 14623
United States
Website: https://www.precisionot.com
Email:  privacy@precisionot.com
Phone number: +1 (585) 500-4090

Cookie Management: https://www.precisionot.com/cookie-policy-eu/

Precision will typically respond to privacy requests within 30 days.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy.  If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the Data Privacy Manager on the email address above.

For EU & UK users, you have the right to make a complaint at any time for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

• EU – Contact their local data protection authorities using the information provided at: https://edpb.europa.eu/about-edpb/about-edpb/members_en
• UK – Make complaints to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues – https://ico.org.uk/

We keep our privacy policy under regular review.  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

11. INFORMATION SECURITY

Precision operates secure data networks protected by industry standard security controls. Precision security and privacy policies are periodically reviewed and enhanced to comply with the latest applicable regulations, best practices, and security frameworks to ensure the confidentiality, integrity, and availability of user data. Only authorized individuals with a need to know have access to user’s personal information.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.