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PRIVACY POLICY

Last Updated: May 23rd, 2023
 1. INTRODUCTION

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:

 * Soracom Websites:
   * Soracom Homepage (https://soracom.io)
   * Soracom UK Site (https://www.soracom.co.uk/)
   * Developers Site (https://developers.soracom.io/)
   * Soracom Partner Space (https://sps.soracom.io)
   * Soracom User Console (https://console.soracom.io)
   * Soracom Mobile (https://soracommobile.com)
   * Soracom Blog (https://blog.soracom.io)
 * Soracom Social Media Channels:
   * LinkedIn
   * Facebook
   * Twitter
   * Youtube

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:

 * SORACOM GLOBAL, INC., having its registered office at 10400 NE 4th St, 5th
   Floor, Bellevue, WA 98004, USA; and 

 * SORACOM CORPORATION, LTD., having its registered office at 16 Great Queen
   Street, Covent Garden, London, WC2B 5AH, United Kingdom.

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.

 2. COMPLIANCE WITH APPLICABLE LAWS

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. 

 3. THE DATA SORACOM COLLECTS AND PROCESSES

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:

 * Registration Information: We will collect information you directly provide
   such as your name, title, company name, job role, expertise, postal address,
   telephone number, SNS account, and email address.
 * Demographic Information: We may collect demographic information such as your
   age, gender, and race.
 * Payment and Billing Information: We collect credit card or debit card
   numbers, bank account information, and other payment details when you make a
   purchase or other similar financial transaction.

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:

 * Transaction Information: We collect details relating to your purchases such
   as the date, time, and amount charged.
 * Cookies: We collect other types of information through cookies like browser
   information, time of visit, referring site, etc. For more information, please
   read our Cookie Policy.
 * Usage Information: Through your use of our products and services, we will
   also collect certain communications traffic data including details on a data
   communication’s origin, destination, route, time, date, size, duration, or
   type of underlying service (collectively “Traffic Data”).
   * We process Traffic Data as a data controller or equivalent term: (i) to
     provide and maintain the products and services; (ii) to calculate any
     charges and fees payable by you, and to bill and invoice you accordingly;
     (iii) to identify, investigate and protect against fraud, threats and
     unlawful or wrongful use of the products and services; (iv) for internal
     use for development and improvement of products and services; and / or (v)
     as may be required by applicable law.
 * Device Information: We may collect information about your device, such as
   device type and ID, device model, operating system and application version.
 * Geolocation Information: We collect geolocation information through IP
   addresses or other location information obtained through the use of our
   products and services or through the use of positioning technologies.

 4. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information in a variety of ways, including:

 * Through Digital Channels: We collect personal information through our Digital
   Channels, both voluntarily (e.g., when you subscribe to a newsletter,
   register for a webinar, complete our contact us form, download content such
   as whitepapers, sign up to use a service, or place an order requiring a
   physical delivery address) and automatically (e.g., when you use a mobile
   device or web browser to access our Digital Channels).
 * Through your use of our products and services: We automatically collect
   personal information and other Traffic Data when you use our products and
   services.
 * Offline: We may collect personal information from you offline, such as when
   you attend one of our events, meet in person, talk with a sales
   representative on a phone call, or when you contact customer service or
   support.
 * Information from other sources: To enhance our ability to provide relevant
   marketing, offers, and services to you, we may obtain information about you
   from other sources, such as public databases, joint marketing partners,
   social media platforms, as well as from other third parties.

 5. WHY WE COLLECT YOUR PERSONAL INFORMATION

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:

 * Provide Soracom Products and Services: We use your personal information to
   provide and deliver Soracom products and services in accordance with our
   contractual obligations or the legal basis of legitimate interest. 
 * Comply with Legal Obligations: We may use your personal information to
   fulfill our legal obligations that require us to collect, use or retain
   certain personal information or to respond to a request by the government or
   law enforcement authorities.
 * For Customer Support: We use your personal information to respond to your
   inquiries and provide customer support services in order to improve your
   experience of our products and services.
 * For the Improvement of our Products and Services: We may use your personal
   information in our efforts to improve and develop our offerings to customers,
   such as by analysing your use of and assessing the performance of Soracom
   products and services.
 * For Marketing Purposes: We may, subject to your consent, use your personal
   information to provide marketing that is tailored to your use of our products
   and services. This is discussed in more detail in Section 8.
 * To Prevent Fraud and Abuse: We may use your personal information to
   investigate, identify, assess, and prevent unlawful acts such as fraud and
   abuse on our Digital Channels.

 6. SHARING YOUR PERSONAL INFORMATION

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.

 7. INTERNATIONAL TRANSFERS

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. 

 * Soracom Inc. (4-5-6-3F Tamagawa Setagaya Tokyo, Japan 158-0094) is our
   affiliated company which may have access to personal information because of
   common data systems and access is required to operate and provide services.
   Soracom Inc. is ISO27001 certified and we have model clauses to help protect
   your personal information and privacy.

Please contact us if you have any questions.

 8. MARKETING COMMUNICATIONS AND OPTING OUT

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.

 9. SOCIAL MEDIA

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:

 * Date and time of your visit
 * The internet address or URL for the address you are temporarily visiting
 * Your IP address
 * The browser you are using
 * The operating system you are using
 * If registered as a user of the social media channel, your account and login
   information
 * The information for which you have used this specific plug-in

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. 

 10. HOW DOES SORACOM SECURE PERSONAL INFORMATION?

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).

 11. HOW LONG WILL WE RETAIN YOUR DATA?

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.

 12. HOW CAN YOU ACCESS, CORRECT OR REMOVE DATA?

As permitted by law, you may have the following rights relating to your personal
information:

 * Request access to your personal information;
 * Request rectification or erasure of your personal information;
 * Request restriction of the processing of your personal information;
 * Object or withdraw consent to any processing of your personal information.
 * Request transfer or receive a copy of your personal information in a usable
   and portable format.

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. 

 13. THIRD PARTY SITES

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.

 14. CHANGES TO THIS POLICY

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.

 15. WHEN THIS POLICY DOES NOT APPLY

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.

 16. CONSEQUENCES OF ERASING OR NOT PROVIDING PERSONAL INFORMATION

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.

 17. HOW TO CONTACT US

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 .

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.

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