Last Revised: June 24, 2019
By using our Site and our Services, you agree to this Policy. Please read this Policy carefully. If you disagree with the way we collect, use, disclose, or transfer your personal information, or any other practice described in this Policy, please do not use this Site or our Services.
We collect information, including personal information, about you when you visit our Site and use our Services, including, information that we collect directly from you, information that we collect about you from third parties, and information that we collect automatically as you visit our Site and use our Services.
- Information We Collect Directly From You. We request information directly from you when you interact with our Site and use our Services. Specifically, we request information from you when you register or subscribe to our services, including: your first and last name, contact information (e.g., email and postal/shipping address, mobile and home phone numbers), paypal, credit and debit card and billing information, and demographic information. If you purchase a service from us, then certain of the above-listed information is required, but other information (e.g., demographic) is optional. In certain countries, valid official identification information and proof of ID may be required. From time to time, we may request that you provide us with additional demographic information, such as your birth date, salary, education, marital status, and employment. This information is not necessary for the provisioning of your service, but we may use it to identify other products and services that may be of interest to you and for the purposes described in the section “Use of Your Information We Collect."
- Information We Collect About You From Third Parties. We also may obtain information about you from third parties, such as email app services, social networking sites, and our Refer a Friend Program. We may combine this information with other information that we have collected about you.
- Refer a Friend. If you use our invitation service to tell a friend about our Site and our Services, we will ask you for information to send the invitation, such as your friend's email address, first name and last name. We will send your friend an email inviting him or her to visit the Site or one of our Services, as applicable. FreedomPop stores this information to send this invitation, to register a friend connection if your friend accepts our invitation, and to track the success of our referral program. Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.
CHILDREN UNDER 13
We do not intentionally or knowingly market to, collect information from, or solicit information online from children under the age of 13 without first obtaining parental consent. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, we will immediately delete it from our database.
USE OF YOUR INFORMATION WE COLLECT
We hold this information, including personal, for the legitimate interests of our maintaining a contractual business and compliance relationship with you for the purposes outlined below.
- To Provide Products & Services. We use your information to provide our Services to you and for the purposes described in this Policy, including the following:
- to operate, provide, maintain, develop, and deliver our Services;
- to maintain and administer your FreedomPop account;
- to maintain and display your FreedomPop profile;
- to respond to your comments and questions and to provide customer service;
- to provide you with confirmation of purchases, invoices, support and administrative messages;
- to perform other functions as otherwise described to you at the time of collection; and
- link or combine information about you with other information we obtain from third parties to help understand your needs and provide you with better service.
- Marketing. We use your information to offer you our products and services as well as third party products and services to you that may be of interest to you. This may include passing your information on to a third party. For additional information about how a third party might use your information, please see the section below entitled, "Sharing Information with Third Parties."
- Service Improvement and Development. We use your information to respond to your inquires; operate and improve our Services or emails, improve and create a positive user experience with our Services or emails; and deliver our Services to you. Our Services include the display of personalized products, content, and advertising relating to your experience and interests.
- To administer contests and promotions;
- To send you emails, including about products and services that we believe might be of interest to you; and, with your consent (and depending upon the particular product or service that you have ordered), to send you text messages;
- Where permitted by law, and if you have not opted out, for telemarketing purposes;
- To detect and prevent abusive, fraudulent, malicious or potentially illegal activities, and to protect the rights, safety or property of FreedomPop or our users; and
- To keep you posted on our latest product or service announcements, software updates, security alerts and any technical notices, and products and services that may be of interest to you.
- To maintain contractual and regulatory compliance records
- To Provide Products & Services. We use your information to provide our Services to you and for the purposes described in this Policy, including the following:
We share your information, including personal information, with the following entities and for the purposes described below.
- Affiliates and Third Parties. We share your information with third parties so that they can understand the kinds of visitors to our Site and users of our Services, how those visitors use our Services, and for research purposes. We also share your information with affiliates and third parties for their own marketing purposes. (For California residents, please see our special notice below.)
- Business Transfers/Bankruptcy. We may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, if we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court.
- Legal Process. We disclose information if legally required to do so, or at our discretion pursuant to a request from governmental, administrative, or judicial entities, parties involved in judicial legal matters with us, or any organization that exercises official authority or carries out tasks in the public interest or if we believe in good faith that such action is appropriate to: (a) conform to legal requirements or comply with legal procedures; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
- Service Providers. We may share your information with the third parties listed below who perform various functions on our behalf, such as to process your order and to assist with order provisioning. These service providers also may help us perform technical functions, host our Services, analyze our data, provide marketing assistance, and provide customer service: Sprint, AT&T, Global Touch, Google, Inteliquent, Vindicia, Ingram Micro, MasMovil, Three UK, Consumer Priority Services, Private WiFi, Oracle, Five9, Periscope, Amazon AWS, Braze, Yesmail, Briteverify, Lan Global.
- Joint Venture/Promotional Partners. If we run a promotion or contest, we may share your information with the other sponsors of the contest for marketing and other purposes.
- Aggregate and Anonymized Information. We may share aggregate or anonymized information about you with third parties for marketing, advertising, research or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregate, demographic information with that third party about the users to whom we displayed the advertisements.
In each of these situations, the recipients of your data may potentially be located in any country in the world.
INTERNATIONAL TRANSFERS OF DATA
As required under the General Data Protection Regulations (“GDPR”), applicable in the European Union and United Kingdom, any international transfers of data are conducted for the sole purposes outlined above.
- Data Storage Security: Consumer data is stored within FreedomPop’s global infrastructure on Amazon Cloud and Amazon Web Services (AWS). It has developed a security assurance program that uses best practices for global privacy and data protection to make the best use of the security control environment. These AWS security protections and control processes are independently validated by multiple AWS third-party independent assessments.
- Data Access Security for Call Centers: All FreedomPop web services are securely encrypted and independently logged. Different levels of call controls are implemented for customer support agent organization when accessing consumer data.
Personal data will be retained only as long as necessary for the purpose of processing but will be deleted if the data subject has withdrawn consent to processing.
DATA SUBJECT RIGHTS
You have a number of rights under the GDPR. These rights (which are subject to conditions) include the right of data portability (for us to help move your data to someone else at your request), the right to object to the processing of your personal data, the right to require us to date and correct your data, the right to require erasure of your data, the right to obtain a restriction on processing of your personal data, the right for you to review your personal data we hold and, where applicable, the right to withdraw your consent to the processing of your personal data. You also have the right to lodge a complaint with a data protection supervisory authority in the Member State where you live or work or where you feel a GDPR issue concerning you has arisen.
OTHER STATUTORY OR CONTRACTUAL INFORMATION
As explained above, we hold your personal data for the purposes of fulfilling legal obligations to you and/or to meet our compliance obligations. We would not be able to meet these commitments if we did not hold your personal data.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information. We also use persistent cookies to enable us to recognize whether you have responded to a questionnaire or completed a registration.
- Third Party Cookies. We also engage third parties to track and analyze non-personal and personal information and to serve advertisements. To do so, we may permit third parties to apply cookies to users of our Site, where permitted by law, and, subject to your right to opt-out through the Network Advertising Initiative (as discussed below). We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze site usage. Such third parties may combine the information that we provide about you with other information that they have collected.
- Web Beacons. We also use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs or action tags) that allow us to collect certain information about your visit to these web pages (including the number of users who have visited those pages), measure and improve the effectiveness of advertisements, and deliver services. Web beacons collect information such as a cookie number, time and date of page view and a description of the page on which the web beacon resides. This information may be shared with one or more third parties so that they can understand the kinds of visitors to our Site and our Services, how those visitors use our Site, and the effectiveness of their advertisements. We may also use web beacons in email messages that we send to you, for example, to track whether recipients read our emails. Because web beacons are the same as any other content request, you cannot opt out or refuse them. web beacons can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.
If you do not want to receive marketing or advertising from us via email, you may opt-out by following the instructions contained in the email. You also may exercise your email preferences by logging into your account and following the link to email preferences. It may take up to 10 days to process your request. Please note that we will continue to send you customer service related emails even if you have opted out of receiving marketing communications from us. If you subscribe to services from different affiliates, you may need to unsubscribe from each affiliate's marketing list. Under your email preferences, you also may opt-out of certain third party marketing. If, however, we already have shared your name with a particular third party, then you will need to contact that third party to opt-out of future communications.
UPDATES TO THIS POLICY
We reserve the right to modify this Policy from time to time. If we make any changes that materially affect the use of your personal information, we will endeavor to notify you by changing the "Last Revision" date and posting the updated Policy on this Site.
A California resident has the right to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. California customers may request a list of the entities with which we have shared your information for their direct marketing purposes and the categories of information that we have shared. If you would like to request this information, please provide proof of your California residency and a request via email to: email@example.com. You may make one request per calendar year.
SAFEGUARD AND PROTECTION OF INFORMATION MEASURES
We take measures to protect your information. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through this site is at your own risk.
LINKS TO THIRD PARTY WEBSITES
FreedomPop Services and emails may also post links to other websites over which we have no control. As such, we are not responsible for the privacy policies or practices of other websites when you choose to link from this Site. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
NOTICE TO NON U.S. USERS
Our company is located in the United States. You may be located in a country that has laws that are more restrictive about the collection and use of your personal information. By using this Site and our Services, you agree that your personal information will be transferred to and stored in the United States.
If you have questions about this Policy, please contact us by visiting our Site, calling us at (888) 743-8107, emailing us at firstname.lastname@example.org or by writing to us at: FreedomPop, Inc., Attn: Privacy Matters, 2060D Avenida De Los Arboles Suite 288, Thousand Oaks, CA 91362