Wittaya Aqua International Inc. (“Wittaya”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our Website and in the course of providing our services, including but not limited to our AquaOp Feed and AquaOp Farm software-as-a-service platforms (the “Platforms”), as further described in our Terms of Service (together with our Platforms, the “Services”).

The privacy of our users is of great importance to us. By visiting our website located at https://wittaya-aqua.ca/, including subpages, (collectively, the “Website”), or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”). Personal Information may be collected about users and visitors to the Website, as well as our customers and their end users who use the Services.

This Privacy Policy covers the activities of Wittaya as well as our affiliates. This Privacy Policy does not apply to the practices of companies that we do not own or control, including third parties that may use or resell Wittaya services. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.

3.1 Account Information. Companies, organizations or individuals who have entered into a subscription agreement to use our Services (“Licensees”) and all of their authorized end-users (“End-Users”) will be required to have a valid Wittaya account to log in to the Services (“Account”). When you register for the Services or create an Account, Wittaya collects certain information from you (collectively, “Account Information”).

• When Licensees register for the Services or make a purchase, Wittaya collects your name, email address, business phone number, business address, payment information and any other Personal Information you may wish to share via the message box on our Website. We use this Personal Information to process your service orders, provide sales services, account support and provide you access to the Services. We may also use this Personal Information for advertising, business intelligence and other analytics.
• When End-Users register for the Services or make a purchase, Wittaya collects your name, email address, business address and payment information. We use this Personal Information to process your service orders, business intelligence purposes and to provide you access to the Services.

3.2 Services Information. When Users create an Account and log in, Wittaya keeps track of login attempts, IP Address, date and time of last login, as well as date and time of Account creation. When Users use the Platform, Wittaya will also track farm production data (for AquaOp Farm) or feed data, such as prices, volume, chemical composition (for AquaOp Feed).

When our users utilize the Services to make purchases, Wittaya collects your purchase and transaction information. Purchase information such as your billing address is used to process your purchases. Wittaya may also store your upcoming and past purchases in connection with your Account. Wittaya also collects your IP address while you are using the Website in order to screen for fraudulent activity and optimize your use of our Services.

3.3 Prospective Customers. Wittaya also collects Personal Information about individuals who may be prospective customers. Wittaya collects this Personal Information from individuals directly or publicly available directories. In particular, we may collect name, email, business contact information, farm information such as species cultivated (e.g. Atlantic Salmon), preferred method of contact, as well as any other information that they may share via a “message” box on our Website. In order to manage our customer relationships and conducted targeted marketing, Wittaya may collect logs of all emails to/from the prospective customer, logs of meeting date/time with the prospective customer, records of the individual’s visits to the Website and receipt of email, as well as the referral source.

3.3 Use of Personal Information. In addition to the purposes listed above, Wittaya uses the Account Information and Services Information to:

• authenticate access to the Account and provide access to the Services;
• provide, operate, maintain and improve the Services;
• send technical notices, updates, security alerts and support and administrative messages;
• provide and deliver the Services and features you request, process and complete transactions, and send you related information, including confirmations and invoices;
• respond to comments, questions, and requests and provide customer service and support;
• communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;
• investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
• personalize and improve the Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Services;
• monitor and analyze trends, usage, and activities in connection with the Services showcasing user behaviors and preferences and for marketing, advertising and other business intelligence purposes;
• link or combine with other information we receive from third parties to help understand your needs and provide you with better service; and
• for other purposes which we will notify you about and seek your consent.

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, operating system, flash version, javacript support, screen resolution and colour processing ability, network location IP address, time zone, referral source and some of the cookies that are installed on your device.

Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, time of visit, and information about how you interact with the Website. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

The Website uses "cookies" to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity.

We may use "persistent cookies" to save your registration ID and login password for future logins to our service. We may use "session cookies" to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. We also use session cookies to verify your age, keep track of items you have viewed and store such items in your cart while you are browsing.

The Website may also use technologies such as beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies. We may also use third-party ad companies to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising.

You can opt out of certain third-party targeted advertising by using the links below:

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Wittaya processes and stores its data, including Personal Information, on servers located in Canada and the United States. Wittaya also transfers data to the following third-party service providers described on our Sub-Processors webpage, available here: (“Sub-Processors”). By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

6.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.

6.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

6.3 With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

6.4 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and
• detect, prevent, or otherwise address fraud, security or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

If you are visiting the Website or using the Services from outside of Canada, please note that you are agreeing to the transfer of your information to Canada and the United States and for it to be processed globally by our third-party Sub-Processors. By providing your information you consent to any transfer and processing in accordance with this Policy.

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

10. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

Questions regarding this Privacy Policy or Wittaya’s privacy practices should be directed to our Privacy Officer:

Wittaya Aqua International Inc.
Re: Privacy Compliance Officers
1 University Ave, Suite 300, Toronto, ON, M5J 2P1
Tom McDonell (tom.mcdonell@wittaya-aqua.ca)
Evan Hall (evan.hall@wittaya-aqua.ca)

Effective Date: January 21st, 2021

To support Wittaya in delivering the Services, Wittaya engages third-party service providers as sub-processors.

This page identifies our sub-processors, describes where they are located, lists what services they provide to us and identifies the type of personal information processed.

Our business needs may change from time to time and Wittaya will periodically update this page to provide notice of additions and removals to our list of sub-processors.