Privacy Policy

Effective Date: February 17, 2026

Wakey Communications Inc. ("Wakey Communications", "Company", "we", "us", "our") is committed to protecting the privacy and security of personal information entrusted to us by our customers, website visitors, and business contacts. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information in connection with our telecommunications services, our website at wakeycommunications.com, and our business operations.

This Privacy Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), the British Columbia Personal Information Protection Act (PIPA), and other applicable Canadian privacy legislation. By using our Services or website, you consent to the collection, use, and disclosure of your personal information as described in this Policy.

1. Scope

This Privacy Policy applies to:

• Individuals and businesses that subscribe to or use Wakey Communications' telecommunications services, including SIP trunking, hosted PBX, unified communications, and related products;
• Visitors to our website at wakeycommunications.com;
• Individuals who communicate with us through our contact forms, email, telephone, or in person;
• Business contacts, prospective clients, and partners with whom we engage in the ordinary course of our operations.

This Policy does not apply to the content of communications transmitted over our network by our customers. Wakey Communications acts as a carrier and does not monitor, intercept, or access the content of customer communications except as required by law or as described in our Terms of Service.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including:

Category	Examples	Purpose
Account Information	Business name, contact person name, job title, email address, phone number, mailing address	Account creation, billing, communications
Billing Information	Credit card number, bank account details, billing address, tax identification number (GST/HST number)	Payment processing, invoicing, tax compliance
Service Configuration	SIP credentials, IP addresses, PBX settings, call routing preferences, DID assignments	Service provisioning and management
Support Information	Support ticket content, chat transcripts, email correspondence, phone call notes	Technical support, service improvement
Identity Verification	Government-issued ID (for number porting), business registration documents, Letters of Authorization	Regulatory compliance, fraud prevention

2.2 Information Collected Automatically

When you use our Services or visit our website, we automatically collect certain technical and usage information:

• Call Detail Records (CDRs): For each call processed through our network, we record the originating number, destination number, call start and end times, call duration, codec used, and call disposition (answered, busy, failed). CDRs do not include the content of your conversations.
• Network and Performance Data: IP addresses of SIP endpoints, registration events, jitter and latency measurements, packet loss statistics, Mean Opinion Score (MOS), and other quality-of-service metrics.
• Website Analytics: IP address, browser type and version, operating system, referring URL, pages visited, time spent on each page, and click patterns. We collect this data using first-party analytics tools and do not use third-party tracking pixels or advertising cookies.
• Device Information: Screen resolution, device type, and language preferences when accessing our website or customer portal.

2.3 Information from Third Parties

We may receive personal information from third parties in limited circumstances:

• Number Porting: When processing port-in or port-out requests, we exchange subscriber information with other telecommunications carriers as required by CRTC regulations;
• Credit and Payment Processing: Our payment processor may provide us with transaction confirmations, declined payment notifications, and fraud alerts;
• Regulatory and Law Enforcement: We may receive information through lawful intercept orders, court orders, or regulatory requests from the CRTC or law enforcement agencies.

3. How We Use Your Information

We use personal information for the following purposes:

3.1 Service Delivery

• Provisioning, activating, and managing your telecommunications services;
• Processing and routing voice calls, signaling, and media traffic;
• Monitoring network performance and optimizing call quality;
• Troubleshooting service issues and providing technical support;
• Managing your account, including authentication, authorization, and access control.

3.2 Billing and Payments

• Generating invoices and processing payments;
• Calculating usage-based charges from Call Detail Records;
• Managing collections and resolving billing disputes;
• Complying with tax reporting obligations.

3.3 Communications

• Sending service-related notifications, including maintenance windows, outage alerts, and security advisories;
• Responding to your inquiries and support requests;
• Sending invoices and payment confirmations;
• With your consent, sending marketing communications about new services, promotions, or industry insights. You may opt out of marketing communications at any time.

3.4 Security and Fraud Prevention

• Detecting and preventing fraud, toll fraud, traffic pumping, and other forms of network abuse;
• Monitoring for unauthorized access to your account or our network infrastructure;
• Implementing and enforcing our Acceptable Use Policy;
• Investigating security incidents and responding to data breaches.

3.5 Legal and Regulatory Compliance

• Complying with CRTC regulations, PIPEDA, tax laws, and other applicable legislation;
• Responding to lawful access requests from law enforcement and regulatory authorities;
• Maintaining records as required by telecommunications regulations;
• Exercising or defending legal claims.

3.6 Business Operations

• Analyzing aggregate usage data to plan network capacity and infrastructure investments;
• Improving our services, website, and customer experience;
• Conducting internal audits and quality assurance;
• Training staff on service delivery and support procedures (using anonymized or de-identified data where possible).

4. Legal Basis for Processing

Under PIPEDA, we process your personal information based on one or more of the following grounds:

• Consent: You have provided express or implied consent to the collection, use, and disclosure of your personal information for the purposes described in this Policy. Implied consent applies where the purpose would be obvious to a reasonable person (e.g., collecting your phone number to provide you with telephone services).
• Contractual Necessity: Processing is necessary for the performance of our contract with you (the Terms of Service and Service Order).
• Legal Obligation: Processing is necessary to comply with applicable laws, regulations, or lawful requests.
• Legitimate Interest: Processing is necessary for our legitimate business interests, such as fraud prevention, network security, and service improvement, provided those interests are not overridden by your privacy rights.

5. Disclosure of Personal Information

We may disclose your personal information to the following categories of recipients:

5.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our business, including:

• Upstream carriers and interconnection partners: Call routing data necessary to complete calls across carrier networks;
• Payment processors: Billing information necessary to process payments securely;
• Cloud infrastructure providers: Data stored on servers within Canadian data centres operated by our infrastructure partners;
• Professional advisors: Legal counsel, accountants, and auditors as necessary for our business operations.

All service providers are bound by data processing agreements that require them to protect your information and use it only for the purposes for which it was disclosed.

5.2 Regulatory and Law Enforcement

We may disclose personal information when required or permitted by law, including:

• In response to a valid court order, subpoena, search warrant, or other lawful process;
• To comply with lawful intercept obligations under the Criminal Code of Canada;
• In response to requests from the CRTC or other regulatory authorities;
• To report suspected criminal activity, including fraud, to law enforcement;
• To protect the rights, property, or safety of Wakey Communications, our customers, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, personal information may be transferred to the successor entity. We will provide notice to affected customers in such circumstances, and the successor entity will be bound by the terms of this Privacy Policy with respect to previously collected information.

5.4 With Your Consent

We may disclose your personal information to other parties with your express consent for purposes not otherwise described in this Policy.

6. Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. Our specific retention periods are:

Data Type	Retention Period	Basis
Account information	Duration of account + 2 years	Business records, dispute resolution
Billing records and invoices	7 years from date of transaction	CRA tax record requirements
Call Detail Records	18 months from call date	Billing verification, regulatory compliance
Network performance data	12 months	Capacity planning, troubleshooting
Support tickets and correspondence	Duration of account + 1 year	Service continuity, quality assurance
Website analytics data	24 months	Website improvement, usage trends
Number porting records (LOAs)	7 years	CRTC LNP compliance
Call recordings (if applicable)	90 days, unless extended by customer	Quality assurance, dispute resolution

When personal information is no longer required, it is securely destroyed using industry-standard methods (cryptographic erasure for digital records, cross-cut shredding for physical documents).

7. Data Security

Wakey Communications implements comprehensive technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction:

7.1 Technical Safeguards

• Encryption in transit: All SIP signaling is encrypted using TLS 1.2 or higher. Voice media is encrypted using SRTP with AES-128 or AES-256 encryption. All web traffic uses HTTPS with TLS 1.2+ and HSTS.
• Encryption at rest: All databases and file storage systems use AES-256 encryption. Encryption keys are managed through a dedicated key management system with automatic rotation.
• Network security: Enterprise-grade firewalls, intrusion detection and prevention systems (IDS/IPS), DDoS mitigation, and network segmentation between customer-facing and internal systems.
• Access controls: Role-based access control (RBAC), multi-factor authentication for administrative access, and principle of least privilege for all staff accounts.
• Monitoring: 24/7 security monitoring, centralized log management and analysis, and automated alerting for suspicious activity.

7.2 Organizational Safeguards

• All employees and contractors are required to sign confidentiality agreements;
• Regular security awareness training for all staff;
• Background checks for employees with access to customer data;
• Documented incident response procedures with regular testing;
• Annual third-party security audits and penetration testing;
• SOC 2 Type II compliance maintained and verified annually.

8. Data Location and Cross-Border Transfers

Wakey Communications stores and processes all customer data exclusively within Canada. Our primary data centre facilities are located in Montreal, Quebec, and Vancouver, British Columbia.

We do not transfer personal information outside of Canada as a matter of standard practice. In the limited circumstances where cross-border transfer may be necessary (e.g., routing international calls through foreign carrier networks), only the minimum information necessary to complete the communication is shared, and such transfers are governed by contractual safeguards that provide a comparable level of protection to Canadian privacy law.

Call Detail Records for international calls necessarily include the originating and destination numbers, which may be disclosed to foreign carriers for call completion and billing purposes. This is an inherent aspect of international telecommunications and is consistent with standard industry practices.

9. Cookies and Tracking Technologies

Our website uses a limited number of cookies and similar technologies:

9.1 Essential Cookies

These cookies are strictly necessary for the operation of our website and customer portal. They enable core functionality such as session management, authentication, and security features. Essential cookies cannot be disabled.

9.2 Analytics Cookies

We use first-party analytics to understand how visitors interact with our website, including pages visited, time spent, and navigation patterns. We do not use Google Analytics, Facebook Pixel, or any third-party advertising trackers. Analytics data is aggregated and cannot be used to identify individual visitors.

9.3 Preference Cookies

These cookies remember your preferences, such as language selection and display settings, to provide a more personalized experience on return visits.

We do not use cookies for targeted advertising, cross-site tracking, or behavioral profiling. We do not sell cookie data or share it with third-party advertisers.

10. Your Privacy Rights

Under PIPEDA and applicable provincial privacy legislation, you have the following rights with respect to your personal information:

10.1 Right of Access

You have the right to request access to the personal information we hold about you. Upon receiving a written request and verifying your identity, we will provide you with a copy of your personal information within thirty (30) days. We may charge a reasonable fee for access requests that are manifestly unfounded or excessive.

10.2 Right of Correction

You have the right to request correction of any inaccurate or incomplete personal information we hold about you. We will update the information and, where appropriate, notify any third parties to whom the information was disclosed.

10.3 Right to Withdraw Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Please note that withdrawing consent for information that is necessary for the provision of our Services may result in service limitations or termination. For example, we cannot provide SIP trunking services without processing your SIP credentials and call routing data.

10.4 Right to Complain

If you believe that we have not handled your personal information in accordance with this Policy or applicable privacy law, you have the right to file a complaint with:

• Our Privacy Officer (contact details below);
• The Office of the Privacy Commissioner of Canada (www.priv.gc.ca);
• The applicable provincial privacy commissioner (e.g., the Office of the Information and Privacy Commissioner for British Columbia).

10.5 Exercising Your Rights

To exercise any of these rights, please contact our Privacy Officer using the information provided in Section 14. We will respond to all requests within thirty (30) days and will not charge a fee for routine requests.

11. Children's Privacy

Our Services are designed for business use and are not directed at individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take immediate steps to delete such information from our systems.

12. Third-Party Links

Our website may contain links to third-party websites, services, or resources that are not operated by Wakey Communications. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party websites you visit. Wakey Communications is not responsible for the privacy practices of third-party websites.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Post the revised Privacy Policy on our website with a new "Last updated" date;
• Notify active customers by email at least thirty (30) days before the changes take effect;
• Where required by law, obtain your consent to the revised terms before they take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer:

Privacy Officer
Wakey Communications Inc.
970 Burrard St, Suite 112
Vancouver, BC V6Z 2R4, Canada
Email: privacy@wakeycommunications.com
Phone: (343) 369-5118

For general inquiries, you may also reach us at info@wakeycommunications.com.

This Privacy Policy was last reviewed and updated on February 17, 2026. Previous versions are available upon request.