Absolute Software Corporation (“Absolute”, “we”, “us” or “our”) is committed to respecting and protecting the accuracy, confidentiality and security of your personal information, and wants you to feel secure when visiting our website (the “Website”), downloading our mobile device applications (the “Mobile Apps”), and using our services (the “Services”). This Privacy & Cookie Policy sets out our policies concerning the collection, use, disclosure and protection of personal information we receive from individuals using the Website, the Mobile Apps or the Services, as well as the types of cookies that Absolute uses on our Website.

“Personal information” means all information about an identifiable individual.

Unless otherwise agreed to in writing by Absolute, by using the Website, the Mobile Apps or the Services, you will be deemed to have consented to the terms and conditions set forth in this Privacy & Cookie Policy, including (without limitation), the collection, use and disclosure of your personal information by Absolute.

IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS PRIVACY & COOKIE POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION, USE THE WEBSITE, OR DOWNLOAD THE MOBILE APPS.

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Scope of Privacy Policy

This Privacy & Cookie Policy was drafted with the objective of complying with or exceeding the requirements of Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and British Columbia’s Personal Information Protection Act (“PIPA”), as Absolute’s corporate headquarters are located in Canada and its parent company is incorporated in Canada. However, Absolute also does business in other countries, and non-Canadians also use the Website, the Mobile Apps and the Services. Many of these other countries have their own laws applicable to the protection of personal information, which may or may not conflict with or contain more restrictive legal obligations than PIPEDA and PIPA. It is Absolute’s policy to comply with the privacy legislation within each of these countries. As such, this Privacy & Cookie Policy outlines the minimum standards for Absolute’s treatment of personal information. Where applicable laws contain additional requirements, Absolute will ensure compliance with those laws. Should there be, in any specific case, an inconsistency between this Privacy & Cookie Policy and applicable local privacy laws, this Privacy & Cookie Policy will be interpreted in that case to give effect to and comply with the local privacy laws.

Absolute may update this Privacy & Cookie Policy from time to time. We will notify you about material changes by placing a prominent notice on the Website and the Mobile Apps. As well, a history of material changes will be noted at the end of this Privacy & Cookie Policy, beginning with changes published after April 4, 2014. However, it is your responsibility to review the most current version. If this Privacy & Cookie Policy is updated, your continued use of this Website, the Mobile Apps or the Services and any subsequent submission of personal information by you will be deemed your conclusive acceptance of the most recent version of this Privacy & Cookie Policy.

Accountability

Absolute is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.

In order to oversee overall compliance with this Privacy & Cookie Policy and with applicable personal information protection laws, Absolute has designated a Privacy Officer. Contact information for Absolute’s Privacy Officer can be found at the end of this Privacy & Cookie Policy.

Please note that if you are a corporate customer or any other type of organization, you are responsible for the legal collection and use of personal information of individuals within your organization, in accordance with the principles set out in your privacy policy and the applicable laws in the countries in which you operate or in which you or your customers use the Services or the Mobile Apps. Absolute is not responsible for your privacy practices and policies.

Purposes for Collecting Personal Information

Through the Services, the Website and the Mobile Apps, Absolute collects, uses and discloses to certain third parties personal information for the following primary purposes:

  • to develop, manage and deliver our products and the Services to our customers;
  • to contact our customers, either directly or through one of our resellers, to offer them the option to renew the Services;
  • to contact our customers directly about products and services that may be of interest;
  • to ensure high standards of service to customers;
  • to contact customers with product and service updates, upgrades and enhancements;
  • to meet regulatory requirements; and
  • to verify a customer’s identity.

The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for each of the Services, the Website and the Mobile Apps.

The Services

Absolute’s products and Services help keep assets safe and secure, and our products are designed to help protect your privacy. Using a very small software agent, our products allow your device to call into our confidential and secure monitoring center on a regular basis and transmit to our servers certain information relating to your computer (including IP address, device name, user name, list of hardware and installed software). With your consent and participation, certain of our products may also collect additional asset-related information for certain other purposes designated by you, such as hardware/software inventory, lease management, PC migration and software license compliance, as well as the detection of specific types of data stored in files on your devices.

If the Services you purchase include investigative services, and you report your device as lost or stolen, with your consent we may collect further information from the lost or stolen device in order to determine its location. Once we have gathered sufficient information to determine its location, we may compile such information and deliver it to a law enforcement agency having jurisdiction over the individual in possession of the lost or stolen device.  The law enforcement agency may then use this information to attempt to recover the lost or stolen device.

The terms of your use of the Services will be governed by your agreement with us.

The Website and Use of Cookies

"Cookies" are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and the website faster and easier. They cannot be used to run programs or deliver viruses to your device. In general, cookies do not identify you personally.

The following describes the types of cookies that Absolute currently uses or may in the future use on our Website:

Session Cookies
These are temporary cookies that expire when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your device when you access the Website. Assigning your device a number facilitates the proper functioning of the features of our Website by permitting us to maintain a persistent “state” for your session, including information relating to orders that you may place. We also use session cookies to collect anonymous information (i.e., information that does not identify you personally) about the ways users use the Website, such as which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “click-stream information”) to better understand our user’s interests and needs and to improve the content and functionality of the Website.

Persistent Cookies
Unlike a session cookie, a “persistent cookie” does not expire when you close your browser. It stays on your device until the expiration date set in the cookie (for example, at the end of a calendar month) or until you delete it. Persistent cookies can be used to “tag” your device so that the next time you visit (or someone using your device visits), our server will recognize you, not by name, but by the “tag” on your device. This will enable us to provide you with a personalized experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways people use the Website, for example, how people use the Website on their first visit and how often they return. Using persistent cookies permits us to provide you with a more personalized experience and, in some cases, may save you the trouble of re-entering information already in our database.

Strictly Necessary Cookies
These cookies are essential for the running of our Website. Without these cookies, parts of our Website would not function. They enable you to move around the Website and use its features, such as accessing secure areas. These cookies do not track where you have been on the Internet and do not gather information about you that could be used for marketing purposes.

Performance Cookies
These cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users the Website has. Web analytics services may be designed and operated by third parties on Absolute’s behalf. The information provided by these cookies allows us to analyze patterns of user behaviour, and we use that information to enhance user experience or identify areas of the Website which may require maintenance. These cookies do not collect information that identifies a visitor. All information collected through these cookies is aggregated and therefore anonymous.

Functional Cookies
These cookies allow the Website to remember choices you make (such as your preferences, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

Targeting or Advertising Cookies
These cookies, which may be placed on your device by us or our trusted third party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Although this type of cookies can track your activity around the Internet, they cannot identify you personally. Without these cookies, online advertising you encounter will be less relevant to you and your interests.

Web Beacons
When you visit our Website, your device may receive one or more “web beacons” in order to assist us with delivering cookies, to collect anonymous information about the use of the Website by our users, and to deliver customized or targeted content to you on the Website and through our partners. Web beacons (also referred to as “tracking pixels,” “1x1 gifs,” “single-pixel gifs,” “pixel tags,” or “action tags”) are graphic images, usually no larger than a 1x1 pixel, placed at various locations on the Website. They also help us identify browser types, search terms that bring users to our Website, and the domain names of websites that refer traffic to us. We also utilize web beacons to provide us with more information on any emails we send out. In particular, a web beacon in an email communication will send us information to let us know that you have received, opened, or acted upon an e-mail you have chosen to receive from us.

JavaScript Tags/Pixels
These are used by us to collect anonymous information about the use of the Website by our users, and to deliver customized or targeted content to you on the Website and through our partners. We may use JavaScript tags to anonymously track how visitors interact with our Website, including where they came from and the manner in which they use our Website.

By using our website, you agree that we can place these types of cookies on your device.

Some people find the idea of a website storing information on their device intrusive. If you would prefer to opt out of cookies, it is possible to manage them by changing the cookie settings on your device, in your browser settings. Existing cookies that have already been set can be deleted from your hard drive. You can also block some or all cookies. However, you should be aware that you might lose some features and functionality of our Website if you do so. If you need assistance with your cookie settings, consult the help menu within your Internet browser. For more detailed information about cookies and how to manage and delete them, visit http://www.aboutcookies.org or http://www.allaboutcookies.org.

Absolute’s Website may contain links to third party sites, and we recommend and encourage you to read the privacy policies posted on those third party sites. Absolute is not responsible for the privacy policies or practices of any third party.

The Mobile Apps

For Absolute’s consumer customers (i.e., individuals who purchase our products for their own personal use), our Mobile Apps may collect personal information such as your name, email address, street address, phone number, device make and model, serial number, and device IMEI (International Mobile Equipment Identity) number. In addition, if you choose to agree to Absolute’s geolocation service, Absolute will also collect geolocation data from your device which can be done through IP, wifi or GPS.

Absolute will use this personal information for product registration and installation purposes, as well as for customer verification in the event that you contact our Global Support group for assistance. Some of this personal information may also be used by Absolute in the event that you file a theft report for your device. If you have agreed to Absolute’s geolocation service, Absolute may use your geolocation data to map your device location and display it to you through our Customer Centre.

During the product installation process, you will be asked whether Absolute may share your personal information with third parties for other offers, and if you agree, Absolute may share that personal information. In addition, Absolute may share your contact or product information with its Original Equipment Manufacturer (OEM) partners if you contact Absolute’s Global Support group for assistance and Absolute needs to work with the OEM in order to assist you. Finally, we may share certain personal information with our external service providers to assist us with the delivery of email campaigns, and for product renewal and upgrade purposes.

For Absolute’s non-consumer customers (i.e., businesses, schools, government and other organizations), our Mobile Apps generally do not collect personal information. Rather, they facilitate the collection of information by our customers and utilize information already collected through the use of the Services. These Mobile Apps generally serve as management agents and self-service portals, facilitate the download of non-app software, and perform administrative functions. They may, however, determine the jailbroken status of a device.

Absolute will try to collect personal information directly from the individual concerned unless authorized by that individual to collect it from a third party or as otherwise permitted by law.

If personal information is collected for any other purposes than described above (unless the purpose for collecting personal information is obvious and you provide your personal information for that purposes, or unless otherwise permitted or required by laws), Absolute will communicate the purpose of collecting the personal information to you at the time of collection, either orally or in writing, as well as its use and how it may be disclosed.

If personal information is gathered in writing, the purpose of its collection will be communicated through printed materials, the Website or email. If personal information is gathered orally, Absolute will provide an oral explanation of the purpose for the collection and use.

Consent

As indicated at the top of this Privacy & Cookie Policy, unless otherwise agreed to in writing by Absolute, by using the Website, the Mobile Apps or the services, you will be deemed to have consented to the terms and conditions set forth in this Privacy & Cookie Policy, including (without limitation), the collection, use and disclosure of your personal information by Absolute.

As a general principle, Absolute will obtain your consent before collecting, using or disclosing your personal information for any purpose other than as identified in this Privacy & Cookie Policy. Absolute will make an exception only where legal, medical or security reasons make it impossible or impractical to obtain consent, as discussed further below. We will make reasonable efforts to ensure you understand how your personal information may be used or disclosed. If Absolute plans to use previously-collected personal information for a new use that is incompatible with the original purpose, you will be informed of the new purpose, and we will obtain consent from you prior to this new use.

The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Absolute will be guided by what a reasonable person would consider fair and appropriate in the circumstances.

Your consent may be provided to Absolute orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.

Absolute may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);
  • In an emergency that threatens an individual’s life, health or personal security;
  • When the personal information is available from a public source (e.g. a telephone directory);
  • When we require legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • In connection with criminal justice, taxation or regulatory activities;
  • To protect ourselves from fraud or to protect the rights and property of Absolute;
  • To investigate an anticipated breach of an agreement or a contravention of law; or
  • In the event of a reorganization, merger or sale of Absolute.

Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Absolute, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to Absolute’s Privacy Officer.

If you refuse or withdraw consent, or request that your personal information be removed from our databases and records, Absolute will make you aware of the likely consequences of this action. In some cases, it may prevent Absolute from providing you with the Services.

Limited Collection

Absolute will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Absolute will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.

Absolute will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.

Limited Use, Disclosure and Retention

Absolute will use and disclose personal information only as described in this Privacy & Cookie Policy, or for the purposes for which it was collected, or as agreed by you, or without your consent for the limited circumstances listed above in the section titled “Consent”. We will not use or disclose personal information for any additional purpose that is incompatible with the original purpose unless we obtain consent to do so. We will not sell your personal information to other parties.

Absolute may share personal information with our employees, contractors, consultants, service providers, business partners and other parties who require such information to assist us with providing you with the Services. By providing personal information to Absolute, you will be deemed to have consented to the disclosure of your personal information to such parties.

The use, collection and disclosure of personal information may involve Absolute transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.

Absolute will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous. If you have an account with Absolute, any personal information will be destroyed, deleted or made anonymous once your account has been inactive for two years.

Absolute may use and disclose aggregated and anonymous or de-identified information to third parties, including the general public. For example, we may analyze and publish reports on usage trends or statistics from across our global customer base for information or marketing purposes, but only after we have removed any personal information that would identify or be associated with any particular individual or customer. This type of aggregated and anonymous or de-identified data can help Absolute to improve our products, services and advertising, and it can be used by customers and the public to better understand trends in the industry. We will never sell this aggregated data.

Accuracy

Absolute will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Absolute does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Absolute therefore relies on you to keep your personal information accurate and current.

You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Absolute’s Privacy Officer and must provide sufficient detail to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.

Safeguarding Personal Information

Absolute will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Absolute as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Absolute’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

Absolute will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.

Absolute trains all staff who handle personal information on the importance of and procedure for maintaining confidentiality. All employees, contractors, consultants and service providers of Absolute who are provided access to personal information on behalf of Absolute are required to be familiar with and comply with the provisions of this Privacy & Cookie Policy and applicable laws.

Absolute will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Absolute will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Absolute and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.

Absolute will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Openness

This Privacy & Cookie Policy is available to the public on our Website, so that information about our policies and practices relating to the management of information is readily available to everyone.

Requests for Access

You have the right to access your personal information, subject to limited exceptions under applicable laws such as solicitor-client privilege, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. Absolute’s Privacy Officer will assist you with your request. This includes:

  • Identification of and access to any or all of your personal information under Absolute’s custody or control.
  • An explanation of how that personal information is or has been collected, used or disclosed by Absolute.
  • The names of any individuals and organizations to which your personal information has been disclosed by Absolute.

All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to Absolute’s Privacy Officer. Absolute’s Privacy Officer may require further information defining the request more succinctly.

We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Absolute cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.

A minimal fee may be charged for providing access to personal information, where permitted under applicable law. Where a fee applies, we will inform you of the cost and request further directions from you on whether or not we should proceed with your request.

Complaint Procedure

Complaints, concerns or inquiries about Absolute’s privacy policies and practices, including compliance with this Privacy & Cookie Policy, should be made in writing to:

Privacy Officer
Absolute Software Corporation
Suite 1400, Four Bentall Centre
1055 Dunsmuir Street
Vancouver B.C. V7X 1K8
Canada
Tel: 604 730 9851, ask for the Legal Department
Fax: 604 730 2621
Email: privacy@absolute.com

Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws. If the Absolute Privacy Officer is unable to address your concerns, the issue may be escalated to the office of the CEO or to the relevant Privacy Commissioner or similar regulatory authority for your jurisdiction (for example, in British Columbia, the Information and Privacy Commissioner for British Columbia).

Effective Date and Updates

Absolute’s Privacy & Cookie Policy was initially published effective January 6, 2004 and was updated in April 2014.

A further update to this Privacy & Cookie Policy was made in April 2016. This update included non-material wording changes, as well as the insertion of a notice box at the top of the policy regarding deemed consent.

A further update to this Privacy & Cookie Policy was made in October 2017, when a paragraph regarding the use of aggregated, anonymous or de-identified information was inserted at the end of the section titled “Limited Use, Disclosure and Retention”.