Privacy Policy
Last updated: November 10, 2024
This Privacy Policy describes Our policies and procedures on
the collection, use and disclosure of Your information when You use the Service
and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the
Service. By using the Service, You agree to the collection and use of
information in accordance with this Privacy Policy. This Privacy Policy has
been created with the help of the Privacy
Policy Generator.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have
meanings defined under the following conditions. The following definitions
shall have the same meaning regardless of whether they appear in singular or in
plural.
Definitions
For the purposes of this Privacy Policy:
Account
means a unique account created for You to access our Service or parts of our
Service.
Affiliate
means an entity that controls, is controlled by or is under common control with
a party, where "control" means ownership of 50% or more of the
shares, equity interest or other securities entitled to vote for election of
directors or other managing authority.
Company
(referred to as either "the Company", "We", "Us"
or "Our" in this Agreement) refers to Orogol Insurance Inc., 4815
Jonestown Rd, Ste. 202 Harrisburg, PA 17109.
Cookies
are small files that are placed on Your computer, mobile device or any other
device by a website, containing the details of Your browsing history on that
website among its many uses.
Country
refers to: Pennsylvania, United States
Device
means any device that can access the Service such as a computer, a cellphone or
a digital tablet.
Personal
Data is any information that relates to an identified or identifiable
individual.
Service
refers to the Website.
Service
Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by
the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analyzing how the Service is used.
Usage
Data refers to data collected automatically, either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
Website
refers to Orogol Insurance Inc., accessible from https://orogol.com/
You
means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the
Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with
certain personally identifiable information that can be used to contact or
identify You. Personally identifiable information may include, but is not
limited to:
Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code,
City
Usage Data
Usage Data
Usage Data is collected automatically when using the
Service.
Usage Data may include information such as Your Device's
Internet Protocol address (e.g. IP address), browser type, browser version, the
pages of our Service that You visit, the time and date of Your visit, the time
spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device,
We may collect certain information automatically, including, but not limited
to, the type of mobile device You use, Your mobile device unique ID, the IP
address of Your mobile device, Your mobile operating system, the type of mobile
Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends
whenever You visit our Service or when You access the Service by or through a
mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track
the activity on Our Service and store certain information. Tracking
technologies used are beacons, tags, and scripts to collect and track
information and to improve and analyze Our Service. The technologies We use may
include:
·
Cookies
or Browser Cookies. A cookie is a small file placed on Your Device. You can
instruct Your browser to refuse all Cookies or to indicate when a Cookie is
being sent. However, if You do not accept Cookies, You may not be able to use
some parts of our Service. Unless you have adjusted Your browser setting so
that it will refuse Cookies, our Service may use Cookies.
·
Web
Beacons. Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel
tags, and single-pixel gifs) that permit the Company, for example, to count
users who have visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of a certain section
and verifying system and server integrity).
Cookies can be "Persistent" or "Session"
Cookies. Persistent Cookies remain on Your personal computer or mobile device
when You go offline, while Session Cookies are deleted as soon as You close
Your web browser. You can learn more about cookies on TermsFeed
website article.
We use both Session and Persistent Cookies for the purposes
set out below:
Necessary
/ Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to
provide You with services available through the Website and to enable You to
use some of its features. They help to authenticate users and prevent
fraudulent use of user accounts. Without these Cookies, the services that You
have asked for cannot be provided, and We only use these Cookies to provide You
with those services.
Cookies
Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users
have accepted the use of cookies on the Website.
Functionality
Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember
choices You make when You use the Website, such as remembering your login
details or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter your
preferences every time You use the Website.
For more information about the cookies we use and your
choices regarding cookies, please visit our Cookies Policy or the Cookies
section of our Privacy Policy.
Use of Your Personal Data
SMS Opt-In clause from Phone.com: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
The Company may use Personal Data for the following
purposes:
To
provide and maintain our Service, including to monitor the usage of our
Service.
To
manage Your Account: to manage Your registration as a user of the Service.
The Personal Data You provide can give You access to different functionalities
of the Service that are available to You as a registered user.
For
the performance of a contract: the development, compliance and undertaking
of the purchase contract for the products, items or services You have purchased
or of any other contract with Us through the Service.
To
contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile application's
push notifications regarding updates or informative communications related to
the functionalities, products or contracted services, including the security
updates, when necessary or reasonable for their implementation.
To
provide You with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you
have already purchased or enquired about unless You have opted not to receive
such information.
To
manage Your requests: To attend and manage Your requests to Us.
For
business transfers: We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale
or transfer of some or all of Our assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which Personal Data held
by Us about our Service users is among the assets transferred.
For
other purposes: We may use Your information for other purposes, such as
data analysis, identifying usage trends, determining the effectiveness of our
promotional campaigns and to evaluate and improve our Service, products,
services, marketing and your experience.
We may share Your personal information in the following
situations:
·
With
Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to contact You.
·
For
business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another
company.
·
With
Affiliates: We may share Your information with Our affiliates, in which
case we will require those affiliates to honor this Privacy Policy. Affiliates
include Our parent company and any other subsidiaries, joint venture partners
or other companies that We control or that are under common control with Us.
·
With
business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
·
With
other users: when You share personal information or otherwise interact in
the public areas with other users, such information may be viewed by all users
and may be publicly distributed outside.
·
With Your
consent: We may disclose Your personal information for any other purpose
with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long
as is necessary for the purposes set out in this Privacy Policy. We will retain
and use Your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with
applicable laws), resolve disputes, and enforce our legal agreements and
policies.
The Company will also retain Usage Data for internal
analysis purposes. Usage Data is generally retained for a shorter period of
time, except when this data is used to strengthen the security or to improve
the functionality of Our Service, or We are legally obligated to retain this
data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at
the Company's operating offices and in any other places where the parties
involved in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of Your state,
province, country or other governmental jurisdiction where the data protection
laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your
submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to
ensure that Your data is treated securely and in accordance with this Privacy
Policy and no transfer of Your Personal Data will take place to an organization
or a country unless there are adequate controls in place including the security
of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in
deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain
information about You from within the Service.
You may update, amend, or delete Your information at any
time by signing in to Your Account, if you have one, and visiting the account
settings section that allows you to manage Your personal information. You may
also contact Us to request access to, correct, or delete any personal
information that You have provided to Us.
Please note, however, that We may need to retain certain
information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset
sale, Your Personal Data may be transferred. We will provide notice before Your
Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to
disclose Your Personal Data if required to do so by law or in response to valid
requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good
faith belief that such action is necessary to:
·
Comply with a legal obligation
·
Protect and defend the rights or property of the
Company
·
Prevent or investigate possible wrongdoing in
connection with the Service
·
Protect the personal safety of Users of the
Service or the public
·
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but
remember that no method of transmission over the Internet, or method of
electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee its
absolute security.
Children's Privacy
Our Service does not address anyone under the age of 13. We
do not knowingly collect personally identifiable information from anyone under
the age of 13. If You are a parent or guardian and You are aware that Your
child has provided Us with Personal Data, please contact Us. If We become aware
that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from
Our servers.
If We need to rely on consent as a legal basis for
processing Your information and Your country requires consent from a parent, We
may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not
operated by Us. If You click on a third party link, You will be directed to
that third party's site. We strongly advise You to review the Privacy Policy of
every site You visit.
We have no control over and assume no responsibility for the
content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will
notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on
Our Service, prior to the change becoming effective and update the "Last
updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically
for any changes. Changes to this Privacy Policy are effective when they are
posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can
contact us:
·
By email: info@orogol.com
Phone.com Privacy
Policy – Orogol’s Provider for VOIP Services and SMS Texting
This privacy notice
was updated on 1/28/2023 and is effective immediately.
This website is
located generally at phone.com and is the official website
for Phone.com (the “Site”). This Site is owned and operated
by Phone.com, Inc (“Phone.com”, “the Company”, “we” or “us” ).
Your privacy is very
important to us. Because we gather certain types of personally identifiable
information (“Personal Information”) from users of our Site, subscribers of our
services and for various other operational and business purposes, we feel you
should know how we collect, use, disclose, manage, and store the Personal
Information that you may voluntarily provide us and the Personal Information
that is collected passively through the use of cookies or image tags on our
Site. We collect this information to learn more about who is interested in our
products and services, to improve navigation experience on our pages, and to
provide you with what you request through the web form. This Privacy
Policy is incorporated by reference in the Site’s General Terms of Use, which is binding
on all Site users. This Policy applies only to the Personal Information
collected by Phone.com via the Site and does not govern any such information
collected by its corporate affiliates (“Affiliates”), or any other company or
third party, unless specifically stated.
If you do not agree
with this Privacy Policy, please do not participate in the online or off-line
activities and services that require you to provide your Personal Information.
(The type of Personal Information collected is listed below.) This Policy
provides information regarding your choices to either Opt-out or Opt-in when
your Personal Information is used for various promotional and marketing
purposes by Phone.com, the Site, its corporate affiliates, and/or our
advertisers, service providers, sponsors, or promotional partners
(collectively, “Advertisers”).
YOUR CALIFORNIA
PRIVACY RIGHTS
Residents of the
State of California that have an established business relationship with a
company that conducts business in California, under a new provision of the
California Civil Code, have the right to request from that company a list of
all third parties to which the company has disclosed Personal Information about
the resident for direct marketing purposes during the preceding year.
Alternatively, the law provides that if the company has a privacy policy that
gives either an Opt-out or Opt-in choice for use of Personal Information by
third parties (such as Advertisers or Affiliates) for marketing purposes, the
company may instead provide you with information on how to exercise your
disclosure choice options.
This site qualifies
for the alternative option; it has a comprehensive privacy policy and provides
you with details on how you may Opt-out or Opt-in to the use of your Personal
Information by third parties for direct marketing purposes. Therefore, we are
not required to maintain or disclose a list of the third parties that received
your Personal Information for marketing purposes during the preceding year.
If you are a
California resident and have an established business relationship with us and
want to receive information about how to exercise your third-party disclosure
choices you must send a request to the following address with a preference on
how our response to your request should be sent (email or postal mail). You may
contact us in two ways. Send email to Privacy Administrator at legal@phone.com.
Alternatively, you
may contact Phone.com at:
Phone.com
184 South Livingston Avenue
Suite 9-222
Livingston, NJ 07039
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent
via email, you must put the statement “Your California Privacy Rights” in the
subject field of your email. All requests sent via postal mail must be labeled
“Your California Privacy Rights” on the envelope or post card and clearly stated
on the actual request. For all requests, please include your
name, street address, city, state, and zip code. (Your street address is
optional if you wish to receive a response to your request via email. Please
include your zip code for our own recordkeeping.) We will not accept
requests via the telephone or by facsimile. We are not responsible for
notices that are not labeled or not sent properly, or do not have complete
information.
To all other users
of this Site, if you have other questions about this Privacy Policy, please
contact our Privacy Administrator at the following email address: legal@phone.com or:
Phone.com
184 South Livingston Avenue
Suite 9-222
Livingston, NJ 07039
Attn: Privacy Administrator
GENERAL PRIVACY
GUIDELINES
Unless specified
otherwise on the Site, all subscribers to our Services and users of the Site
must be at least 18 years of age. In the instance where users of the Site
are permitted to be under the age of 18, Phone.com will not knowingly collect
any personal information directly from children under the age of 13. This Site
is governed by and operated in accordance with the laws of the United States.
We make no representation that this Site is operated in accordance with the
laws of other nations. By your participation in our Site activities, you
certify that you are at least 18 years of age. Please be aware that any
Personal Information you transfer to us will be transferred to and processed in
the U.S and subject to U.S. law. By using this Site, participating in any Site
activities, and/or providing us with your Personal Information, you consent to
this transfer of Personal Information to the U.S., and waive any claims that
may arise under your own national laws. All users of the Site are required to
provide true, current, complete and accurate Personal Information when prompted
and we will reject and delete any entry that we believe in good faith to be
false, fraudulent, or inconsistent with this Privacy Policy.
Your continued
participation on this Site indicates your acceptance of this Privacy Policy and
of the collection, use, disclosure, management, processing and storage of your
Personal Information as described below. We may from time to time, transfer or
merge any Personal Information collected off-line to our online databases or
store off-line information in an electronic format. We may also combine
Personal Information we collect online with information available from other
sources, including information received from our corporate affiliates,
Advertisers, or marketing companies. This Privacy Policy covers all such
Personal Information and will remain in full force and effect as long as you
are a user of the Site. We reserve the right to revise this Privacy
Policy at any time by updating this document without advance notice to you.
Such revisions shall be effective to you immediately upon posting. Therefore,
we encourage you to check this Privacy Policy often.
We use your Personal
Information to provide you with the features, services, or goods you request,
to respond to billing and/or other such questions related to Phone.com’s
services offered through the Site and to notify you about updates and new
features that may be of interest to you. (We explain below in the next section
what our policy is for the collection, use and disclosure of Personal
Information to Advertisers.)
We may also use your
information for hiring, operational and business purposes, to find out how we
can improve our services and your use of the Site via surveys or online
tracking mechanisms, and to develop new services and features that may be of
interest to you. We use aggregate Personal Information to help us to evaluate
and modify existing services and features.
We may also use your
information to allow you to connect with other users of Phone.com’s Services.
We will not sell,
exchange, rent, lease or otherwise disclose your Personal Information or
Sensitive Personal Information to third-party marketers that are not associated
with Phone.com as operational service providers or Advertisers unless it is
necessary to: 1) conform to regulatory and legal requirements or to comply with
legal process; 2) to protect the safety and security of our users, employees,
or property; 3) to defend the rights of the Site or Phone.com; or 4) to enforce
the General Terms of Use Agreement.
Notwithstanding the
foregoing, however, we may share your Personal Information with our
subsidiaries, corporate parents, and Affiliates primarily for business,
operational, promotional and marketing purposes.
It is also necessary
that we share your Personal Information and Sensitive Personal Information with
our operational service providers, the specialists that provide us with
internal support for our operations and activities and/or for Site design,
development, hosting and operations including maintenance, management, storage
and/or fulfillment of our services and other activities.
We reserve the right
to collect Personal Information using any new technology yet to be developed
and to use such technology to provide new services and features to you, as well
as for marketing and promotional purposes.
CATEGORIES OF
PERSONAL INFORMATION WE COLLECT AND USE
As used in this
Policy, “personal information” or “personal data” means any information
or data relating to an identified or identifiable natural person or household
that we process in connection with our Websites, Apps, and Services; an
identifiable natural person or household is one who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person or household.
Personal Information
you actively provide to us:
Category of
Personal Data
Examples
Phone.com uses
this personal data to:
Contact and
Account Information
Name, username,
email address, phone number, IP address, and any other identifiers a user
provides when accessing or using the Service
Account holders’
usernames and account numbers
Billing name and
address for paid Services
Phone number for
Phone.com, title
Create a customer
account
Provide Phone.com
Services
Communicate with a
customer
Respond to
requests for support
Market to
potential customers
Information about
use of non-Phone.com services through integrations or otherwise
Social media
account information, single-sign-on service tokens, Google/Apple/Microsoft
sign-in tokens
Create a customer
account
Provide Phone.com
Services
Communicate with a
customer
Respond to
requests for support
Market to
potential customers
Payment
information
Billing name,
address, and credit card or other payment information.
Offering, price
and other information about your purchase.
Bill account
holders who subscribe to paid offerings
Personal Information
we collect automatically when you visit our Website or Apps or use our
Services:
Category of
Personal Data
Examples
Phone.com uses
this personal data to:
Service Usage Data
Internet Protocol
(“IP“) address, MAC address, other device ID (“UDID”), device
type, operating system type and version, client version, type of camera,
microphone or speakers, connection type and other related information
User feedback
ratings, internal feature usage analytics, usage logs, cookie identifiers
Traffic data about
the communications that take place through our platform (such as chat, video
conferencing, SMS), network monitoring data
Call Detail
Records produced by a telephone call or other telecommunications
transactions. The record contains various attributes of the call, such as
time, duration, completion status, source number and destination number;
Fraud data such as
blacklist history and security logs
Metadata such as
session logs and join & leave time of participants
Log data including
IP address, Internet Service Provider (“ISP“), browser type,
referring/exit pages, operating system, date/time stamp, and/or clickstream
data
Publicly available
data from End User accounts
Connect you to and
optimize your experience using our Website, Apps, and Services
Provide customers
dashboards and reports
Respond to
requests for support
Conduct fraud and
threat analysis, and detect and prevent spam or unlawful or abusive activity
or other violations of our Terms of Service
(“ToS”)
Monitor
performance of our data centers and networks
Conduct analytics
to improve Phone.com’s Website, App and Service performance
Personalize your
experience with our Websites, Apps and Services
Comply with
applicable law
SMS messages
Content of blocked
SMS messages that violate our spam rules
Conduct fraud and
threat analysis, and detect and prevent spam or unlawful or abusive activity
or other violations of our ToS
Geolocation
information
Information about
where you are located when using the Service
Provide the
Service
Communicate with
users about the service
Respond to
requests for support
Market Phone.com
products and services to account holders and/or other potential users
Personal Information
you may choose to allow us to access when you use our Apps or services:
We do not upload or
store this information but use it to enhance the user experience. Allowing this
access is optional. This data is not shared with any third parties.
Category of
Personal Data
Examples
Phone.com uses
this personal data to:
End User Contact
List Data
All data for
contacts stored on a device, including contact name, phone number, email
address.
Provide Phone.com
Services to the Phone.com customer on whose behalf we collect or the
information.
Improve the user
experience for incoming calls, messages, and faxes.
End User Files and
Photos
All files and
photos stored on a device.
Phone.com access
files and photos to send them as fax or multimedia messages.
Personal Information
we collect from End Users on behalf of Phone.com customers:
If you are not a
Phone.com customer but you engage in communications powered by Phone.com
(an “End User”), we may collect and store personal information about you on
behalf of a Phone.com customer.
Category of
Personal Data
Examples
Phone.com uses
this personal data to:
End User Personal
Data
Name, username,
email address, phone number, IP address, cookie identifiers and any other
identifiers a user provides when accessing or using the Service
Other forms of
personal information we collect on behalf of the relevant customer such as
title, role, organization, phone number and other related information
Other forms of
personal information we collect as necessary to offer the relevant Website,
App or Service such as IP address, cookie identifiers and other related
information
Provide Phone.com
Services to the Phone.com customer on whose behalf we collect or store the
information
Communicate with a
customer
Respond to
requests for support
Detect and prevent
spam or fraudulent activity, and detect and prevent unlawful or abusive
activity or other violations of our AUP
For other
legitimate business purposes permitted by our agreement with the relevant
Phone.com customer
Certain Phone.com
products and services may also access and store personal information about you
from a customer’s social media accounts or accounts a customer may have with
other third-party services, when the customer chooses to connect its Phone.com
accounts with its other accounts. This personal information may include name,
email, geolocation and any other publicly available information on these
platforms. With respect to social media, only personal information that an End
User has directly provided to the relevant Phone.com customer or that an End
User has designated as publicly accessible will be accessed or stored. We use
this personal information in connection with providing our Services to our
customers.
DISCLOSURE TO
ADVERTISERS
We may also use your
Personal Information for the marketing of events, products or services of our
Advertisers (“Advertiser Promotions”). As we do not currently share Personal
Information with our Advertisers, the way in which users may receive
information about such Advertiser Promotions would be indirectly via
newsletters, email or direct mail from Phone.com. However, depending on the
activity and the Advertiser, we may in the future choose to let our Advertisers
send you marketing information directly. In such event, with respect to any
Personal Information we may collect in connection with a particular Advertiser
Promotion via forms and other methods on the Site, the same will provide you
with notice (which may be via a link to a revised privacy policy or other terms
and conditions) of our intention to share such information with our
Advertisers. With respect to previously collected Personal Information we
choose to share with Advertisers, you will receive an email notice of our
intention to do so. Please be informed that our Advertisers may not have the
same privacy policies that we do. Therefore, you will need to tell us if you
do not want to receive marketing information directly from our
Advertisers. You will need to check the “Opt-out” click boxes that may be
included on the registration area for the particular Advertiser Promotion, in
the email notice, or alternatively, notify the Site’s Privacy Administrator
at legal@phone.com. You will also need
to tell us if you do not wish to receive marketing or promotional materials
from the Site in the same manner.
We also provide you
with an option to “Opt-out” of receiving advertising and promotional email from
us in compliance with federal law by installing an Opt-out mechanism directly
in any such email messages. You must use the designated method in the email message
to notify us of your Opt-out request, as we cannot guarantee that other methods
of notification will be effective or timely. Please be aware that we may
continue to contact you via email for administrative or informational purposes,
including follow-up messages regarding contests you have entered or other
transactions you have undertaken. By law, such messages are not considered to
be commercial email.
COOKIES AND IMAGE
TAGS
The use of cookies
is an industry standard and they are currently used on most websites, including
this Site. We may send “cookies” to your computer primarily to enhance your
online experience. “Cookies” are files that can identify you as a unique customer
and store your personal preferences as well as technical information (including
click through and click stream data). Cookies can either be permanent (i.e.,
they remain on your computer until you delete them) or temporary (i.e.,
they last only until you close your browser). Phone.com uses these cookies,
some of which are essential, to operate the Site. Importantly, cookies do
not personally identify a user, but do recognize the user’s web browser.
Unless you identify yourself by filling out a form on the Site, you remain
anonymous to Phone.com. Some examples of cookies Phone.com uses include:
Preference Cookies –
Phone.com uses these cookies to remember your preferences. When you register at
a Phone.com website, we use cookies to store unique, randomly assigned user IDs
that we generate for administrative purposes. These cookies enable you to enter
the Phone.com sites without having to log on each time.
Advertising Cookies
– These cookies are used to serve you with advertisements that may be relevant
to you and your interests. We use cookies to make advertising more engaging to
users, as well as to assist in reporting on marketing program performance and
analytics
Security Cookies –
These cookies are used for general security purposes and user authentication.
We use security cookies to authenticate users, prevent fraudulent use of login
credentials, and protect user data from access by unauthorized parties.
Image tags work in
conjunction with cookies and are small image files that may be located on
select pages of our Site, or within web-based email newsletters, or marketing
emails that we may send. (Image tags are also called web beacons, web bugs,
clear GIFs or single-pixel GIFs.) Tracking is important because we can better
understand what parts of our website are used the most, when to launch new
services and how to enhance current offerings. We may share the information we
receive from cookies and image tags with third parties and our Advertisers in
aggregate form, which means that such information generally does not contain
specific Personal Information or Sensitive Personal Information about any one
visitor. In short, cookies and image tags collect a user’s Internet protocols
and server information. Such data files allow our Site to remember your web
browser when you visit our Site and are necessary tools for quick and efficient
access to areas of our Site. A cookie will not allow the Site to learn any Personal
Information (such as your real name and email address) or Sensitive Personal
Information that you have not otherwise disclosed.
On their own,
cookies or image tags do not contain or reveal any personally identifiable
information. However, if you choose to furnish the website with personally
identifiable information, this information can be linked to the data stored
using cookies/Web beacons.
By accepting this
Privacy Notice, you specifically agree to our use of cookies and image tags as
described herein. You may adjust your browser to reject cookies from us or from
any other website. If you have a Flash player installed on your computer, your
Flash player may be able to be set to reject or delete Flash cookies. Please
consult the “Help” section of your browser or Flash player for more
information. Additionally, by setting your Web browser to display HTML e-mails
as text only, you may be able to prevent the use of some image tags. However,
certain areas of our websites may only be accessed in conjunction with cookies
or similar devices, and you should be aware that disabling cookies or similar
devices might prevent you from accessing some of our content.
You should be aware
that different rules might apply to the collection, use or disclosure of your
Personal Information by other third parties in connection with their
advertisements, promotions and other websites you encounter on the Internet.
The use of cookies and other technology by these third parties is within their
control and not ours. Even if we have a relationship with the third party, we
do not control those sites or their policies and practices regarding your
Personal Information. This Privacy Policy does not cover any use of
Personal Information that a third party or an Advertiser may collect from
you. We encourage you to investigate and ask questions directly of them in
this regard.
ADVERTISING, OTHER
THIRD-PARTY CONTENT AND HYPERLINKS
This Privacy Policy
does not cover third-party advertising or third-party content that may be
present on the Site. This Site may provide banner and general advertising from
third parties, in addition to other content provided by our Advertisers or
operational service providers. Users may from time to time purchase goods or
services offered through, or otherwise participate in or send messages
concerning such advertising, promotions or third-party content offered through
the Site. Such correspondence, transactions and agreements are solely between
the user and the Advertiser or the third-party content provider and do not
involve the Site. Also, Advertisers and such third-party content providers may
not have the same privacy policies that we do and you are encouraged to read
their privacy policy first. (Also see our section called “Cookies and Image
Tags”)
This Site may
provide links to third-party websites that could be of interest to our users,
including the websites of our Advertisers. Phone.com does not own or control
these websites and therefore, is not responsible for the content, business
practices, nor operations of such websites. Third-party websites linked on this
Site may have different privacy policies and business practices than we
do. The presence of a link to a third-party website does not constitute
or imply our endorsement, recommendation, or sponsorship of the third-party
content, goods, or services available through, or contained on, the Site. By
use of this Site, you have agreed that you will use the hyperlinks to
third-party sites at your own risk.
We also reserve the
right to engage with third parties to track and analyze anonymously
identifiable usage and volume statistical information from users who visit our
Sites. We also may use other third-party cookies to track performance of
our advertisements, and may use anonymized aggregated data from any source for
targeted advertising purposes, including in conjunction with third parties.
SECURITY MEASURES
We conduct the
collection, management, maintenance and storage of website user information in
a secure and commercially reasonable manner using acceptable industry standards
of security technology and practices (such as electronic security systems and
password protections) to protect against the loss, misuse or alteration of
Personal Information. We also request that our operational service providers
take such precautions. The Phone.com website databases are accessible only by
authorized personnel.
However, please note
that when users transmit Personal Information over an unsecured Internet
connection, the Site is not responsible for the security of that information
during the transmission stage as your email or registration could be copied or
intercepted by unknown third parties. We use a secured connection only for the
collection of Sensitive Personal Information, which is necessary for the
purchase of goods or services, but we do not use a secured connection for other
types of activities. Therefore, you understand, acknowledge, and agree that you
transmit certain Personal Information over this Site at your own risk.
HIPAA
Phone.com does not
require or intend to access Customer data in the course of providing services,
including but not limited to any confidential health related information of
Customer’s clients, which may include group health plans, that constitutes
Protected Health Information, as defined in 45 C.F. R. §160.103 under the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA
Rules”). However, Protected Health Information (PHI) may be present in
“data at rest” within Phone.com systems (including the content of voicemail,
call recording, SMS/MMS text messaging, and faxes) but are encrypted with
access and audit controls as also defined by HIPAA and HITECH rules.
CPNI
In the course of
providing Services to you, we collect and maintain certain customer proprietary
network information (“CPNI”). CPNI includes the types of services you currently
purchase, related usage and billing information for those services. Your telephone
number, name and address are not CPNI. We value our relationships with our
customers and are committed to respecting and protecting your CPNI and to
complying with applicable law regarding CPNI. Accordingly, we do not sell,
trade or share your CPNI, including your calling records outside of Phone.com’s
family of companies, including our Affiliates, or with anyone not authorized to
offer our products or services, or to perform functions on our behalf (e.g.
operational service providers) except as authorized by you or required by law.
Generally, we can use your CPNI to offer additional services to you, and for
billing and collections purposes. We can also disclose your CPNI for legal or
regulatory reasons, including in response to subpoenas, court orders and the
like. We can also use CPNI to investigate fraud and to prevent violation of our
policies and agreements with you and unlawful use of our network, services and
other customers.
CHILDREN’S PRIVACY
POLICY
Phone.com does not
sell products or services for purchase by children. Phone.com does not
knowingly solicit or collect Personal Information from children or teenagers
under the age of eighteen. If you believe that a minor has disclosed Personal
Information to Phone.com, please e-mail us at legal@phone.com to report this to us.
REVIEW, UPDATE,
CORRECT, OR DELETE PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION
Generally, you may
review, update or delete your Personal Information or Sensitive Personal
Information collected by the Site. You may also correct factual inaccuracies.
Certain types of Personal Information that are necessary to check eligibility,
such as birth date or age, cannot be deleted, but may be modified with
sufficient verification of the new information. Note that we reserve the right
to terminate or delete any membership or entry if we believe the Personal
Information submitted was knowingly false or fraudulent.
To review, update or
delete your Personal Information or Sensitive Personal Information collected by
the Site, please email the Site’s Privacy Administrator at legal@phone.com . To have access to your
Personal Information or Sensitive Personal Information, you must provide proof
of identification such as full name, street address, city/state and zip code,
user ID and password, and/or information about your recent activity on the
website. We reserve the right to deny access to any user if we believe there is
a question about your identity. And if the burden or expense of providing
access to your Personal Information is disproportionate to the risks to your
privacy, or if the legitimate rights of others would be violated, we may decide
not to provide access to such information. In such cases, we will provide to
you an explanation of why access cannot be provided and a contact person for
further inquiries.
