SATPHONE Privacy Policy

Last updated: December 21, 2019

SATPHONE, LLC further (“SATPHONE” or “we” or “us”) are committed to maintaining your trust by respecting and protecting your privacy. This privacy policy describes how we collect, use, share and protect your personal data. It also explains choices available to you about how we use and share your personal data and how we communicate with you, how you can make requests related to your personal data, and other important considerations.

 

What This Privacy Policy Covers

How We Collect Personal Data About You

How We Use Personal Data About You

When We Share Personal Data About You

How We Protect Personal Data About You

Other Important Information

Your Personal Data Choices

How We Communicate Changes To This Policy

How To Contact Us

 

 

 

What This Privacy Policy Covers

This privacy policy applies to personal data, which we define as data that identifies, relates to, describes, is capable of being associated with, or could reasonably be used to identify an individual. Personal data includes data such as your name, address, email address, phone number, driver’s license number, as well as other data (for example, demographic data, SATPHONE passwords or PINs, payment data, device data, call records and other service data, profile data, and location data) when it is linked to data that identifies you. For purposes of this policy, personal data includes “personal information” and similar terms as defined under applicable privacy laws.

Except as described below, this privacy policy applies to all personal data we collect when you access or use our communications and other services, websites, and apps, (collectively, our “Services”), purchase and use our devices and products (collectively, our “Products”), visit our retail stores, communicate with us (such as by mail, email, phone, chat, social media, or in-person), and otherwise interact with us or our representatives.

This privacy policy does not apply to data that is not personal data, including anonymous, de-identified, or aggregated data, even when such data has been derived from personal data.

By purchasing, accessing or using our Products or Services or otherwise engaging with us, you acknowledge and consent to our collection, use, and sharing of personal data as described in this privacy policy. Accordingly, we encourage you to read this policy carefully and contact us with any questions.

 

 

How We Collect Personal Data About You

We collect personal data about you in three primary ways:

  1. directly from you in person or over the telephone,
  2. automatically from your use of our Products and Services,
  3. by using or combining data to derive additional personal data about you.

The types of personal data we collect depend on your interactions with us and the nature of the Products or Services we provide to you.

Personal Data You Provide Directly to Us

We may collect personal data directly from you in a variety of ways, including when you apply, sign up, or pay for our Products or Services, create or modify an online account, fill out a form or survey, interact with our representatives, or submit information through our Services. The personal data we collect directly from you may include:

  • Account information, such as your name, usernames, passwords and security codes, address, telephone number, email address, Social Security Number, driver’s license information, date of birth, or signature;
  • Demographic information, such as your age, gender, veteran status, or other information you choose to provide;
  • Payment information, such as credit card, debit card, bank account number, or other financial information (see also our Financial Privacy Policy for further information);
  • Preference information, including preferences related to marketing and communications and participation in SATPHONE programs; and
  • Other information you choose to provide, such as when you submit a survey response, enter a contest or promotion, or contact our representatives.

 

Personal Data We Collect Automatically

We automatically collect personal data associated with the use of our network (or other carriers’ networks when you are roaming domestically or internationally), your wireless devices, and our Products and Services. The personal data we collect automatically may include:

  • Customer Proprietary Network Information (“CPNI”) that is generated in connection with your use of our wireless voice communications services. CPNI includes, for example, call details and call location information. Please see the “CPNI” section below for further details about our collection of this information;
  • Usage information related to your use of our Products, Services, and network (or other carriers’ networks when roaming domestically or internationally), including usage of connecting carriers and Internet service providers (“ISPs”), the Internet Protocol (“IP”) address, Mobile Advertising ID, media access control (“MAC”) address associated with service usage, text, and data use history, websites and URLs you visit, mobile apps you install, launch or use or which interact with your device, transmission rates, and delays, time, date and duration of usage, security protocols, and other network analytics and Wi-Fi usage data;
  • One of the analytics providers we use is Google Analytics. To learn more about how Google collects and processes personal data, please visit https://policies.google.com/technologies/partner-sites
  • Device and service performance and diagnostic information, including reports from your device concerning signal strength, data speeds, app and service performance, dropped calls, data failures, geolocation information associated with such events, and device data such as battery strength, serial number, and similar device identifiers, settings, language preferences, and software versions;
  • Data stored in back-ups and cloud services if your device uploads information to SATPHONE network servers to facilitate specific functions (e.g., some devices may back-up your address book, photo album, or diagnostic data). We also collect information such as phone contact lists that you sync to the cloud to enable DIGITS service to work on other devices;
  • Commercial information, such as account and billing information, records of your purchases from us, and purchase history and tendencies;
  • Geolocation data, specifically data that identifies the approximate or precise location of your mobile device. We may also use technology in our retail locations to collect data about the presence of your device;
  • Video data, including video monitoring and recording we deploy in our retail stores and information about viewing habits when you use a SATPHONE video application (e.g., SATPHONE TV) on your device;
  • Audio information, including voice commands you provide to our apps that offer such features, audio recordings of calls between you and our customer service representatives; and
  • Information collected via cookies, web beacons, and other tracking technologies we deploy on our Services, including your browser type and operating system version, language settings, the website that referred you to one of our websites, or that you visit upon leaving one of our websites. For additional details, please review our article on Cookies, Web Beacons, and Analytics Tools in the SATPHONE Privacy Center.

 

Personal Data We Collect from Other Sources

 We may collect personal data about you from other unaffiliated sources. For instance, we may obtain updated address information from our shippers or other vendors, such as the United States Postal Service. We may collect information from credit agencies before or after initiating your Services. We may also purchase or obtain personal data from third parties, such as social media platforms, third-party analytics providers, and consumer data resellers. This information could include contact information, demographic information, geolocation information, and information about your interests, preferences or behaviors.

 

Personal Data We Derive

We may derive personal data or draw inferences about your preferences or characteristics based on the other personal data we collect. For example, we may infer that you are looking to purchase a new device based on your browsing behavior on our Services, or we may use your IP address to estimate your general location.

 

How We Use Personal Data About You

The collection and use of personal data are critical to the operations of most modern organizations – including SATPHONE. Accordingly, we collect and use personal data about you for business and commercial purposes, including to:

 

  • Provide the Products and Services you request or that are reasonably anticipated within the context of our ongoing business relationship, complete transactions, and perform our contractual obligations;
  • Process your orders, payments, and account adjustments and initiate, render, bill, and collect payment for our Products and Services, as well as third-party products and services you charge to your account;
  • Verify your identity and determine your eligibility for accounts and the validity of your payment information;
  • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to local, state, or federal government requirements;
  • Provide you with customer service and technical assistance and respond to your questions related to our Products and Services;
  • Create and manage your accounts with us;
  • Carry out advertising and marketing activities on our behalf and on behalf of others, including communicating with you through various channels such as email or text message;
  • Conduct and administer contests, surveys, and sweepstakes;
  • Create, audit, evaluate, modify, and improve our network, Products, Services, advertising and marketing;
  • Conduct internal research and development and make business decisions about current and future Product and Service offerings;
  • Create analyses and reports about usage patterns and trends, including auditing customer interactions and transactions;
  • Understand your interests and behaviors to customize your experiences, and the experiences of others, including through personalized content, advertisements, and Product and Service offerings and suggestions;
  • Carry out reasonable internal purposes related to our provision of Products and Services or managing our relationship with you;
  • Detect, protect against and prevent security incidents and illegal or unauthorized activities, investigate complaints and claims, and provide other security protections;
  • Protect users of our Services and other carriers or providers from fraudulent, malicious, deceptive, abusive, or unlawful activities of others;
  • Debug and repair errors in our Products and Services and other activities to maintain and improve the quality and safety of our Products and Services;
  • Cooperate with law enforcement and protect the rights (including free speech), interests, safety or property of SATPHONE or our customers, service providers and other third parties;
  • Comply with and enforce applicable legal and regulatory obligations, and respond to governmental requests;
  • Enforce our policies, terms and conditions, or other agreements; and
  • Defend against or pursue claims, disputes, or litigation – in court or elsewhere.

 

When We Share Personal Data About You

We may disclose personal data to third parties as follows:

With Your Consent or at your Direction

We may disclose personal data about you to third parties with your consent, which may be obtained in writing, online, or orally. We may also share your personal data with third parties when you intentionally direct us to do so or when you use our Products or Services to intentionally interact with third parties.

To the Primary Account Holder

We may disclose personal data about an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer and we may provide personal data about you or your use of our Products and Services to them or others at their direction.

To the Authorized Account Holder

We may disclose personal data about an account user to the Authorized account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer and we may provide personal data about you or your use of our Products and Services to them or others at their direction.

To Provide Special Discounts

When you receive special or discounted pricing, terms, or other benefits through another party’s agreement with us (for example, an employee discount), we may provide enough personal data to that party to verify your eligibility for benefits under their agreement with us and to calculate any associated discounts.

To Our Service Providers

We may share personal data with unaffiliated companies or individuals we hire or work with to provide services or perform business functions on our behalf. These service providers need access to the personal data to perform the functions we’ve requested of them. Examples of service providers we engage include print, mail, or email vendors, delivery companies, payment processors, web hosting vendors, cloud service providers, consultants, digital advertising vendors, contest or sweepstakes operators, and social media advertising networks. These service providers are contractually required to treat the personal data we provide as confidential, and to use the personal data only to provide the services we have requested they perform on our behalf.

To Identity Verification and Fraud Prevention Services

To help protect our customers and others from fraud, we may share limited personal data (such as name, address, account status, SIM change history) with trusted partners that provide fraud prevention services to banks and other entities. Personal data is only shared with our identity verification and fraud prevention partners in connection with specific, individual transactions (such as a credit application with a bank). We share only the minimum data required to support the fraud prevention service and take other steps, including mandating strict contractual provisions, to ensure the personal data we share is used solely for those limited purposes. These contractual provisions prohibit partners from sharing the personal data we provide to them with their downstream customers (such as banks). Instead, the fraud prevention partners use the personal data we provide to create and share risk assessments or flags that highlight possible fraudulent activity or other misuse.

Caller ID Providers

We may share your mobile number and associated name with third parties that facilitate Caller ID and similar services across multiple mobile carriers. Please see the “Directories and Caller ID” section below for further details about our sharing of this information;

In a Business Transfer or Transaction

We may disclose or transfer personal data about you as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which case the personal data could be transferred to third parties as a business asset in the transaction – subject to the terms of this privacy policy. We may also share information with banks for purposes of transferring loans in connection with your device financing.

For Legal Process & Protection

We may disclose personal data to third parties involved in the legal process or protection matters, including government authorities, where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary, including:

  • To satisfy any applicable law, regulation, legal process or enforceable governmental request;
  • To enforce or apply agreements, or initiate, render, bill, and collect for services and products (including to collection agencies to obtain payment for our products and services);
  • To protect the rights, interests, property or safety of SATPHONE or others;
  • In connection with claims, disputes, or litigation – in court or elsewhere;
  • To protect users of our Services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services, and other fraudulent activity;
  • To facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; and
  • In an emergency.

 

How We Protect Personal Data About You

We use a variety of administrative, technical, and physical security measures designed to protect your personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use while it is under our control. We maintain authentication procedures when you contact us by phone or in retail locations to help ensure that access is provided only to the primary account holder or authorized users of the account. Online access to your personal data is protected through passwords and other safeguards. For multi-line accounts, the primary account holder (if applicable) is authorized to access information for all the devices and lines on the account. Other users may generally access online account information (including CPNI) related only to assigned line. The primary account holder, however, may designate additional or more limited access rights for other users on the account. Enterprise customer accounts are protected through authentication and access methods that may vary from those used by individual consumers.

Despite our security efforts, we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal data. We maintain security incident response plans to investigate and remediate incidents involving unauthorized access to personal data.

We retain your personal data for as long as we have a business or tax need, or for as long as applicable laws, regulations, or government orders require. When we dispose of personal data, we use reasonable procedures designed to erase or render it unreadable (for example, shredding documents and wiping electronic media).

 

Other Important Information

This section contains additional information about our privacy practices that you may find helpful.

Advertising

You may see SATPHONE and other advertisements on your devices - whether you are connected to our network or using another connection method (e.g., Wi-Fi or wireline connections). In some cases, these ads may be targeted to your device based on information the advertiser has gathered about your prior online or offline behavior, or other data about your interests. These online ads are sometimes called “interest-based” or “targeted” ads.

Like most companies that operate commercial websites or apps, SATPHONE works with third-party advertising networks, which collect certain information about our site and app visitors, serve ads on our behalf, and measure their effectiveness. The advertising networks that provide these ads may place cookies, web beacons, or use similar technologies on their partners’ websites and apps, including SATPHONE’s. This technology allows them to track device activity over time across online properties. Their use of these technologies and of the information collected is subject to their own privacy policies and those of the sites where they operate. To learn more about ad targeting and how to opt-out of interest-based ads, please see http://www.aboutads.info/choices/.

We adhere to the Digital Advertising Alliance's ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. For additional details, please review our article on Online Advertising in the SATPHONE Privacy Center.

Under California law we must disclose how we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals when you use our services and products or interact with our websites or online services.

Children

 

We do not knowingly solicit minors (anyone under the age of 18) to purchase our Products or Services. Generally, if you purchase and then authorize a minor to use our Products or Services by providing them a device or other access associated with your account, any personal data associated with their use will be treated as your personal data under this privacy policy. Where applicable, if you are the primary account holder, you will have the ability to set the marketing and other preferences for any other lines on your account, including those for any minors to whom you provide a device.

Our Products and Services are not directed to children under the age of 13 nor designed to attract them, and we do not intentionally or knowingly collect personal data from anyone known to be under the age of 13. We encourage parents to be involved in online activities (including Internet browsing and app usage) of their children to ensure that no information is collected from a child without parental permission.

CPNI

Some of the information we collect may be Customer Proprietary Network Information – or "CPNI.” CPNI is data generated in connection with the telecommunications services we provide to you, i.e., voice services. CPNI does not include your name, address, or phone number. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted processes and procedures designed to ensure compliance with those rules. For additional details, please review our article on CPNI in the SATPHONE Privacy Center.

Directories and Caller ID

 We do not publish directories of our customers’ wireless numbers or make such numbers available to third parties for listing in their public directories without the customer’s prior consent. We do, however, provide your number and associated name to enable Caller ID and similar services when you make a call. You can request that we exclude your name from Caller ID by calling customer service. See “How to Contact Us” below. You can also block your number from being displayed temporarily for a specific call by entering *67 prior to entering the number you wish to call (including area code). Note that this does not block your number when you call 911 or dial toll-free numbers such as 1-800 numbers.

Geolocation Data

 If your mobile device is turned on, our network is collecting data about the device location. We may use, provide access to, or disclose this network location data without your approval to provide and support our services, including to route wireless communications, operate and improve our network and business, detect and prevent fraud, provide emergency responders information about how to find you when you call 911, or as required by law or emergency.

PushSpring

 SATPHONE is the business owner of PushSpring, a service provider to the online advertising industry. For information on PushSpring’s privacy practices please see https://www.pushspring.com/privacy.html.

Information for California Consumers: Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal data under the “Shine the Light” Law (California Civil Code section 1798.83) and the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq).

Shine the Light

California Civil Code Section 1798.83, known as Shine the Light, requires us to disclose that California customers may request information concerning whether a business has disclosed personal data (as defined in the Shine the Light law) to any third parties for their direct marketing purposes. We do not disclose your personal data (as defined in the Shine the Light law) to non-affiliated companies for their direct marketing purposes without your consent.

California Consumer Privacy Act

Additional Disclosures Related to the Collection, Use, Disclosure and Sale of Personal Data

Categories of Personal Data Collected:

In the preceding 12 months, we have collected the following categories of personal data, as pre-defined by the California Consumer Privacy Act:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers such as signature and physical characteristics;
  • Financial information, such as credit card or other payment information;
  • Characteristics of protected classifications under state or federal law, such as age or gender;
  • Commercial Information, including records of personal property, Products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or electronic network activity information, information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement;
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Professional or employment-related information;
  • Education Information;
  • Inferences are drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

For more specific examples of the personal data we collect, please see “How We Collect Personal Data About You” above.

 

Business or Commercial Purpose for Collecting Personal Data:

We collect personal data for the business and commercial purposes described in “How We Use Personal Data About You” above.

Categories of Sources of Personal Data:

We collect personal data directly from you, automatically from your use of our Products and Services, from unaffiliated parties, and by using or combining personal data to derive additional personal data about you, as described in “How We Collect Information About You” above.

Categories of Third Parties with Whom We Share Personal Data:

We may share your personal data with third parties as described in the “When We Share Personal Data About You” section above.

Categories of Personal Data Disclosed:

In the preceding 12 months, we have disclosed the following categories of personal data for business or commercial purposes, as pre-defined by the California Consumer Privacy Act:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers such as signature and physical characteristics;
  • Financial information, such as credit card or other payment information;
  • Characteristics of protected classifications under state or federal law, such as age or gender;
  • Commercial Information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or electronic network activity information, information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Professional or employment-related information;
  • Education Information; and
  • Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sales of Personal Data:

We are also required by CCPA to disclose that in the preceding 12 months, to facilitate certain advertising activities commonly deployed by online and technology companies, SATPHONE “sold” (as the term “sale” is defined in CCPA) the following categories of personal data: device identifiers and internet and electronic network activity. What this means is a unique, resettable number that identifies your device was linked to online activity and shared with third parties who aggregate that data for advertising purposes. SATPHONE does not knowingly collect, and therefore does not sell, the personal data of minors.

CCPA Consumer Rights:

The CCPA also requires us to communicate information about rights California consumers have to request access to their personal data, to request deletion of their personal data, to request additional details about our information practices, to request to opt-out of the “sale” of their personal data, and the right not to be discriminated against for exercising these rights. For details about how to exercise these rights, please see Your Personal Data Choices. below.

 

Information for Nevada Consumers: Your Nevada Privacy Rights

INSIGHTS Program

Internet of Things

Information for Nevada Consumers: Your Nevada Privacy Rights

Location-Based Services

Technologies in our Retail Stores

Unaffiliated Websites and Mobile Applications

US-Based Organization