Privacy Policy

Wenco International Mining Systems Ltd. and our corporate affiliates (the “Company”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you.  This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) your personal information and how you may correct, update and access your personal information that you provide as a user or visitor of: (a) the website(s) found at https://www.wencomine.com/ and the associated domain https://www.wencomine.com/ operated by us from time to time (collectively, the “Website”); (b) Wenco social media pages including LinkedIn, Facebook, Instagram and X (collectively, the “Social Media Pages”); (c) our products  and services, including documentation made available or provided by us from time to time  through an application distribution platform such as the Apple App Store or the Google Play Store (collectively, the “Application”), or the Website or any other means., excluding all third party software, websites, or services that may interact with the Application or our Services generally (“Third-Party Services); and (c)  our other related products and services (collectively with the Website, Social Media Pages and the Application, and excluding any Third-Party Services, the “Service”) or any business relationship.
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‍PLEASE READ THIS PRIVACY POLICY CAREFULLY.  By accessing or using our Service, or otherwise by choosing to provide us with your personal information, you acknowledge  that you have read, understood, and agree  to the processing of your personal information in accordance with this Policy.
This Policy is current as of the “updated” date which appears at the top of this page.  We reserve the right to amend this Policy as necessary to ensure compliance with applicable laws, align with best practices, or meet the requirements outlined in other agreements or policies. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. Your continued use of our Services after any such changes are posted constitutes your acceptance of the revised Policy. We recommend that you periodically review this Policy to stay informed about how we handle your personal information.
If you do not agree with the terms of this Policy, please do not use our Services or provide us with any personal information.

1. Personal Information We Collect

For the purposes of this Policy, “personal information” means any identifiable information about an individual or any information that can be used, either alone or in combination with other information, to identify an individual, including but not limited to an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by applicable privacy laws.

The categories of personal information we collect may include:

• Information collected through the Use of the Service. After registration, you may create data or information as part of your use of the Service (collectively, “User Data”). User Data and any information contained in the User Data, including personal information you may have included, is stored and collected as part of the Service. User Data may include:
• • contact information such as name, email address, mailing address, and phone number;
  • professional information such as occupation, employee id number and vehicle name;
    
  • location information such as city, province, state, territory, country, latitude, longitude and altitude;
  • interpretation of biometric information, such as fatigue level or status; and
  • data insights associated with physical and operational parameters; and unique identifiers such as username, account number, device serial number and password
• Information from third parties. As part of our Services, we collect and analyze data about you related to your work activity and we share our data and analysis with you and the company, entity, or organization managing your account with us (such as your employer) (“Your Organization”), including other members of Your Organization.
• Information Collected for Business Relationship Purposes. We may collect personal information directly from you or from third parties, which may include:
  
• • Contact Information: Full name, job position, address, telephone number, mobile phone number, fax number, and email address.
  • Biographical Information: Social media presence, education, professional experience, skills, and other relevant details you provide on our recruitment platforms.
  • Payment Data: Information required for processing payments, including credit/debit card numbers, security codes, and billing information.
  • Content Information: Content information about you or provided by you, including from support requests or comments.
  • Transaction and Usage Data: Further information related to the business relationship, such as personal information related to orders placed, payments made, requests, interests, and usage patterns of our products and services.
  • Publicly Available Data: Information gathered from publicly available sources, such as databases and credit agencies.
• Inquiries and Feedback.  If you contact us, we will collect the information that you provide us, such as your contact information and the contents of your communication with us.
• Information we collect automatically.  We, and our third-party partners, also automatically collect information about you and any computer or device you use to access the Service, read our emails, or otherwise engage with us. Some of the information we collect, and ways we collect it, include:
• • Cookies.  When you use or visit the Service, we may send one or more cookies - small text files containing in a string of alphanumeric characters – to your computer or device that allows us to uniquely identify your browser, computer or device. A cookie may also convey other information to us, such as: your Internet Protocol (IP) address; unique device identifiers; your browser settings and specifications; and information about how you use the Service (e.g., the pages you view, the links you click, features and functionalities you utilize, how frequently you access the Services, and other actions you take on the Services). Cookies also allow us to track your usage of the Service over time. You have control over your cookie preferences. When you visit our Website, you will be presented with the option to accept or reject cookies through our cookie consent banner. The processing of personal information collected through cookies is based on your consent, where required by applicable laws.
  • Log Files.  We may record log file information each time you access the Services. This information may include information such as: your IP address; browser type; unique device identifiers; information about your computer or device; number of clicks; how you interact with links, features or functionalities on the Service; and other such information.
  • Usage Data.  We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our Service, the pages you visit, the links you click on, how frequently you access the Service, whether you open emails of click the links contained in emails, whether you access the Service from multiple devices, last login time, and other actions you take on the Service. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices.
• Social Media Pages. You may interact with us on various Social Media Pages. Unless otherwise stated, the platform provider is responsible for processing your personal information when you visit our company Social Media Page. For more information, please review their data privacy statements.

We only collect personal information that we need.  We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Collection from Third Parties
We do not knowingly collect your personal information from third parties unless it is stated in this Policy, you provide consent or we are otherwise exempted, required or permitted by applicable laws to do so.  
If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.

Links to Other Sites
Our Service may contain links to Third-Party Services or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services, we have no responsibility or liability for, or control over, those Third-Party Services or their collection, use and disclosure of your personal information.  We encourage you to read the privacy policies of those Third-Party Services to learn how they collect and use your personal information.

Information about Minors
The Service is intended solely for users who are at least the age of majority in their jurisdiction of residence.
We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian as it relates to such minor, should submit such minor’s personal information to us through the Service for any reason and under any circumstances.

2.  Purposes for Which Personal Information is Processed

We may process your personal information for the followingpurposes (the “Purposes”):

• To verify and authenticate your identity;
• To establish, manage, and terminate contractual relationships with you or your organization, including fulfilling our obligations under such agreements;
• To analyze user behavior and optimize the performance, functionality, and user experience of our services to ensure they are effective and beneficial for you;
• To operate, maintain and provide to you the Service, including sending awareness data to Your Organization and all other features and functionality of the Application;
• To process your payment in respect of the Service;
• To communicate with you to provide you Services, contacts, materials and recommendations for your needs as identified by you through phone, email, or the Service;
• To communicate updates, collect feedback, and use customer insights for marketing and improvement.
• To protect the security and integrity of our systems and Services, including through the detection, prevention, and mitigation of unauthorized access, cybersecurity threats, and other unlawful or malicious activities.
• To ensure compliance with legal, regulatory, and contractual obligations, including documentation retention, export control assessments, due diligence processes, and adherence to internal policies and industry standards. To safeguard and uphold our legal rights, including intellectual property rights, and to initiate or respond to legal proceedings or claims as necessary.
• To share your personal information with our employees and contractors, consultants and other third party service providers such as application hosting providers, (“Third-Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Service for your use and benefit. Please note that we may change or add Third-Party Processors at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference this Policy from time-to-time, to obtain updated information.  All such sharing will be conducted in accordance with applicable data protection laws.

3. Legal Basis for Processing Your Personal Information

We process your personal information in accordance with applicable data protection laws, based on the following legal grounds:

• Consent: We may process your personal information where we have obtained your consent, in a manner consistent with applicable laws. For example, if you voluntarily submit personal information through our Website, Social Media Pages, or Application, we rely on your consent to process that information.
• Contractual Necessity: We process personal information when it is necessary to fulfill a contract or provide the products or services you request. This includes processing information necessary for the provision and functionality of our products and services, such as the Wencomine FMS, Wencolite FMS, SmartCap and other applications.
• Legitimate Interests: We may process personal information based on our legitimate business interests, provided such interests are not overridden by your privacy rights.  This includes improving our products and services, enhancing user experience, securing our platforms, and communicating with you about relevant updates, promotions, or support matters.
• Compliance with Legal Obligations: We may process personal information where required to comply with applicable legal, regulatory, or statutory obligations. This may include obligations relating to taxation, accounting, law enforcement requests, or other legal processes.
• Vital Interests: In exceptional circumstances, we may process personal information where necessary to protect your vital interests or those of another individual, such as during a health or safety emergency.
• Public Task: Where applicable, we may process personal information in the performance of a task carried out in the public interest or under official authority vested in us by law.

You can withdraw your consent at any time by contacting us directly through the contact details provided in this Policy.

4. Security of Personal Information

The security of your personal information is important to us. Wenco declares its certification as ISO 27001 compliant, attesting to the company's commitment to maintaining a high standard of information security management. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

5. Transfer of Personal Information

Your personal data may be shared with the following categories of recipients:

• Our corporate affiliates and other third parties, on a need-to-know basis, who provide services within the scope of your business relationship.
• Service providers, when necessary to deliver their services (such as cloud or system service providers).
• Law enforcement authorities, regulators, legal advisors, and consultants, when required to fulfill legal obligations or to establish, exercise, or defend legal claims or rights.
• Content you share on our Website and Social Media Pages may be visible to other registered users globally.

Due to the nature of cloud services, your personal information may be stored in locations outside of Canada, including jurisdictions outside of your home country. Where we transfer, including making available, your personal information outside of your home country, the transfer will comply with the applicable laws.

6. Requests for Access to and Correction of Personal Information

Applicable privacy laws allow individuals the right to access, correct or request the deletion of personal information that is in our custody or under our control. You may request access to your personal information and receive a copy of the information we hold. If you believe any of your personal information is inaccurate or incomplete, you have the right to request corrections. In some cases, you may also request that we delete your personal information; however, we may need to retain certain information to comply with legal obligations or for legitimate business purposes. Please be aware that limiting or deleting personal information may affect our ability to provide services or fulfill commitments to you. We will carefully assess each request and notify you of our decision and the reasons for it. If you have provided consent for us to process your personal information, you may withdraw that consent at any time without providing a reason. Upon withdrawal of your consent, we may keep a limited amount of personal information strictly required for legal or operational purposes.

7. Retention of Your Personal Information

We retain personal information as long as necessary to fulfill the purposes for which it was collected or for other legitimate and authorized purposes, including compliance with applicable privacy laws. When personal information is no longer required for these purposes, or when retention is no longer legally mandated, we take appropriate steps to securely delete, destroy, anonymize, or aggregate the information. We adhere to established industry best practices and maintain documented retention schedules, controls, and procedures to ensure the responsible, secure, and lawful management, retention, and disposal of personal information in accordance with all applicable privacy requirements.

8. Contact Information for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing privacy@wencomine.com.