Privacy Policy
Last updated: November 03, 2023
1. INTRODUCTION
S-Mobile (“Company” or “We”) respects your privacy and is committed to protecting it through this policy and in accordance with appliable law. Please read this policy carefully to understand our practices regarding your information and how we will treat it. If you are in any doubt regarding the applicable standards, or have any comments or questions about this policy, please contact us at the contact details in Section 17 below.
This policy describes how we may collect, use, and disclose the personal information that you provide to us when you interact with our website : https://S-mobile.com/contact-us
(our “Website”), our mobile and desktop software or applications (the “Apps”), and any other service or electronic communication with us (collectively referred to as “Services”). This policy also describes how to exercise your privacy rights under applicable state laws. If you do not agree with our policies and practices, you may choose not to use our website or our Services. By accessing or using this Website or our Services, you agree to this privacy policy.
Finally, this policy may change from time to time (see Changes to Our Privacy Policy in Section 16 below). Your continued use of this Website or our Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
2. CHILDREN UNDER THE AGE OF 13
Our website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.
3. INFORMATION WE COLLECT ABOUT YOU
We may require basic information which identifies you as an individual (“Personal Information”), such as your name, postal address, email address and phone number, to transact business with you, or on behalf of the company you work for, as our customer. We will only use this Personal Information for the purposes of providing information which you have requested, fulfilling business transactions, or for other purposes set out in this policy.
We may also collect Personal Information indirectly from third parties, such as our business partners or third-party providers of marketing lists.
We may collect the following information from consumers:
⦁ Name.
⦁ Postal address.
⦁ E-mail address.
⦁ Telephone number.
⦁ Geolocation.
⦁ Unique device identifier (such as an IMEI or ICCID number).
⦁ Current carrier account number and pin.
⦁ Social media manages basic social media account information when you interact with us through social media.
⦁ Another identifier by which you may be contacted online or offline.
⦁ Information necessary to complete a business transaction, such as your credit card number, payment details, and payment history.
⦁ IT information is required to provide access to systems and networks, such as IP addresses, device IDs, log files and login information and information about your web browser.
⦁ Commercial Information. When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.
4. HOW WE COLLECT YOUR INFORMATION
4.1 Information You Provide to Us
The information we collect on or through our website r from your use of our Services may include:
⦁ Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our Services, use of our Services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, or when you report a problem with our website.
⦁ Records and copies of your correspondence (including email addresses), if you contact us.
⦁ Your responses to surveys that we might ask you to complete for research purposes.
⦁ Details of transactions you carry out through our website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our website.
⦁ Your search queries on the Website.
⦁ Your use of our Service.
4.2 Information from Automatic Data Collection Technologies
As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, devices, browsing actions, and patterns, including:
⦁ Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
⦁ Information about your computer (or other electronic device) and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). This Website does not respond to web browser signals and other similar mechanisms and “do not track” requests.
The information we collect automatically may include personal information, and we may maintain it or associate it with non-personal information we collect in other ways or receive from third parties. This helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:
⦁ Estimate our audience size and usage patterns.
⦁ Store information about your preferences, allowing us to customize our website according to your individual interests.
⦁ Speed up your searches.
⦁ Recognize you when you return to our website.
The technologies we use for this automatic data collection may include:
⦁ Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your electronic device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
⦁ Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
⦁ Web Beacons. Pages of our Website and our e-mails 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 certain website content and verifying system and server integrity).
We may collect personal information automatically, and we may tie this information to non-personal information about you that we collect from other sources, or you provide to us.
4.3 Information from Other Sources
We obtain information from third party sources, which may include:
⦁ Third party data suppliers from which we purchase demographic data to supplement the data we collect.
⦁ Social networks when you reference our Services or grant permission to the Company to access your data on one or more of these services.
⦁ Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities; and
⦁ Publicly available sources such as open government databases or other data in the public domain.
5. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information in Section 9 below.
6. HOW WE USE YOUR INFORMATION
We disclose the Personal Information listed in Section 3 of this policy for our business purposes. We may use and/or disclose the Personal Information we collect for the following business purposes:
Provide Services:
⦁ Establish and administer your customer account, including conducting billing and invoicing, and sending you service messages about your customer account.
⦁ Authenticate access to your customer account. For example, you may provide us with a username and password to get access to the account.
⦁ Perform maintenance and operations, including management of the network and devices supporting the Services and our systems.
⦁ Provide technical support and assure quality of customer service interactions.
⦁ Facilitate hardware and software upgrades for devices and systems.
⦁ Enable your participation in surveys, sweepstakes, contests, and promotions.
⦁ Enable your participation in community forums.
Communicate with You:
⦁ Respond to your inquiries.
⦁ Personalize communications.
⦁ Send you service-related announcements, such as to notify you when we make changes to our agreements or policies, or to contact you about your account.
⦁ Send you information about matters that align with our Mission Statement (including issue alerts, get out the vote notices, issue advocacy, and invitations to special events) newsletters, and special marketing offers.
Make Improvements to Our Services:
⦁ Identify and develop new products and services.
⦁ Identify and integrate new products and services provided through third parties.
⦁ Improve the design of our Services.
⦁ Understand how our Services are used, including by creating measurement and analytics reports.
⦁ We may also collect and use Personal Information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently, for example, for general IT resourcing on a global level and information security/management.
Provide Recommendations and Deliver Relevant Advertising:
⦁ Offer products, programs or services that may be of interest to you, and keep you informed of new happenings at the Company.
⦁ Market our Services.
⦁ Send you promotional communications for the Services and other products and services we think may be of interest to you, including by disclosing contact information to third parties that may want to market products or services to you.
⦁ Deliver more relevant advertising.
Investigate Theft or Other Illegal Activities and Ensure a Secure Online Environment:
⦁ Detect the unauthorized reception, use, or abuse of our Services.
⦁ Protect you and other users from fraudulent, abusive, unlawful use of our Services.
⦁ Protect our rights, our personnel, and our property.
⦁ We also may use your Personal Information where we consider it necessary for complying with applicable laws and regulations, or to exercise or defend the legal rights of the Company.
6.1 Email Policy
We use your e-mail address to communicate with you about your account, the services you are enrolled in, matters that align with our Mission Statement (including issue alerts, get out the vote notices, issue advocacy, and invitations to special events) newsletters, and special marketing offers. You may select the Unsubscribe option in the email to opt out from future non-account related communications.
6.2 Text Messaging/Call Policy
By providing us with your contact information, you give express permission for us to contact you on your device about your account, the services you are enrolled in, matters that align with our Mission Statement (including issue alerts, get-out-the-vote notices, issue advocacy, and invitations to special events), newsletters, and special marketing offers by signing up for the Company’s mobile service or by opting into receiving text messages and/or calls. Message and data rates may apply. Text “stop” to any promotional or list text to opt out of non-account-related text messages from us.
6.3 User-Generated Content
User-Generated Content is any content you create or own, which you post or otherwise provide to us for the purpose of having such content made available through our website, or for the purpose of sharing it publicly through one of our Services or otherwise making such content publicly available. The User-Generated Content you submit on or through our Services may be available to others who use our Services. In addition, we may use User-Generated Content you submit on or through our Services in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the User-Generated Content for such purposes. Therefore, you should have no expectation of privacy with respect to User-Generated Content you submit on or through our Services. You should not submit any User-Generated Content you do not wish to make available to the public, and you must take special care to make sure your submissions comply with our Terms of Use. All applicable terms and conditions of our Terms of Use apply to User-Generated Content submitted on or through our Services. Your submissions must not violate the privacy or other rights of others.
6.4 Location Based and 911 Services
We may use your location information to allow emergency services to locate your general location. We may disclose the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with a court order or subpoena, or if we believe there is an emergency involving risk of death or serious physical harm.
Depending on your device, you may also be able to obtain a wide array of services based on the location of your device (for example, driving directions, enhanced 411 Directory Assistance or search results, etc.). These data services, known as Location Based Services (“LBS”) are made available by us and other entities, usually via applications. These services use various location technologies and acquire location data from various sources. These applications and services use various location technologies (including Global Positioning Satellite (“GPS”), Assisted GPS (“AGPS”), cell ID and enhanced cell ID technologies) to identify the approximate location of a device, which is then used in conjunction with the application to enhance the user’s experience (for example, to provide driving directions, to provide enhanced 411 Directory Assistance or search results, etc.).
LBS may, or may not, involve any interaction with or dependency on our supplier’s network, and location-based services may or may not look to our network to obtain location data. Where our network supplier allows third parties the capability of accessing data about your location that is derived from our supplier’s network, our network supplier requires those third parties to observe specific privacy and security protections consistent with this policy.
It is important that you understand the location capabilities and settings of your device, and that you carefully read and understand the terms under which these services are provided – whether by us or another entity. You should carefully review the privacy policies and other terms of third parties with whom you have authorized the sharing of your location information, and you should consider the risks involved in disclosing your location information to other people. Where we provide a location-based service, you will receive notice of the location features of the service and collection of location data is with your consent. You will be provided with options for managing when and how such information should be shared.
7. DISCLOSURE OF YOUR INFORMATION
We may disclose Personal Information as described in this privacy policy or to fulfill the purpose for which you provide it, for any other purpose disclosed to you when you provide the information, or otherwise with your consent.
We may also disclose your personal information to enforce or apply our Terms and Conditions or other agreements with you, including for billing and collection purposes, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also disclose aggregated information or de-identified data that may include information collected from you without restriction to the extent allowed by applicable law.
7.1 Within the Company
We may transfer information to other Company, subsidiary, or affiliate offices for internal management and administrative purposes or where necessary for the performance or conclusion of our contractual obligations to you or for your benefit. We may combine information from the Services together with other information we obtain from our business records. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.
Employees, contractors, and agents of the Company may be given access to Personal Information which we collect, but their use will be limited to the performance of their duties and the reason for processing. Our employees, contractors and agents who have access to your Personal Information are required to keep that information confidential and are not permitted to use it for any other purposes.
7.2 Sale or Merger of Business
We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
7.3 Service Providers
We may disclose Personal Information to our service providers, which are companies that provide business services to us and process information on our behalf. We require the service providers to treat the information we disclose to them, or that they collect on our behalf, as confidential and to use the information only for the purposes for which they have been engaged. The following is a list of categories of our service providers:
⦁ Subscription management and fulfillment providers.
⦁ Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status.
⦁ Auditing and accounting firms.
⦁ Professional services consultants, such as firms that assist with providing legal services, or supplying project-based resources and assistance.
⦁ Advertising, marketing, and analytics services, including entities that communicate with you on our behalf, facilitate our communications with you, analyze the information we collect from or about you to communicate with and advertise to you.
⦁ Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
⦁ IT vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operation.
⦁ Production vendors, such as pre-press printing service providers.
There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.
Note, some states define “sale” very broadly and include the sharing of Personal Information for anything of value. According to this broad definition, there are limited circumstances where we may sell Personal Information to our service providers to enhance your experience with the service.
7.4 Third Parties
We may disclose certain Personal Information to third parties with whom we have various types of agreements or relationships, including:
⦁ Affiliates: We may disclose or sell certain Personal Information with our various affiliated entities. Those entities may use the information to improve our collective communications and offerings, to share information with you about products or services they believe may be of interest to you, and for other business purposes.
⦁ Advertising, Marketing, and Analytics Partners: We partner with companies that assist us with marketing our Services, including by “remarketing” to you on other websites, apps, or social media platforms. These companies may collect information from you automatically via cookies or other tracking technologies when you use our Services.
⦁ Programs or Services: We may disclose certain information with third party programs or service providers who are integrated with, or with whom we collaborate relative to, our Services, or with whom we otherwise do business including to generate information from products and services offered by such third-party service providers.
⦁ Other External Parties: We may disclose personally identifiable information, including your contact information, to organizations such as marketers, publishers, retailers, and non-profit organizations that want to market products or services to you.
7.5 Authorities
We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
8. THIRD PARTY WEBSITES
Our website may provide links to other third-party websites or offerings where data privacy practices may be different to that of the Company. The inclusion of any link does not imply our endorsement of any other company, its websites, or its products and/or services. These linked websites or offerings have separate and independent privacy policies, which we recommend you read carefully. We have no control over such websites or offerings and therefore have no responsibility or liability the way the organizations that operate such linked websites or offerings may collect, use, disclose, or otherwise treat your Personal Information. If you have any questions about a third party, you should contact the responsible provider directly.
9. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We created mechanisms to provide you with certain controls over your information.
⦁ Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
⦁ Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us at ⦁ [email protected], ⦁ Contact Us – ⦁ S-Mobile
⦁ Promotional Offers from the Company. If you do not wish to have your email address or other contact information used by the Company to promote
our own or third parties’ products or services, and you have received a promotional email, you may follow the unsubscribe instructions included in the email or other message that you receive.
⦁ Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us at ⦁ [email protected], ⦁ Contact Us – ⦁ S-Mobile
⦁ Sales. If you do not wish for us to sell or share the information that we collect from you, you can opt-out by contacting us at ⦁ [email protected], ⦁ Contact Us – ⦁ S-Mobile
⦁ Please note that we do not control a third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
10. ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into Home – S-Mobile and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
11. EXERCISE YOUR RIGHTS UNDER U.S. PRIVACY LAWS
Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:
⦁ Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
⦁ Right to Request Copy: The right to request a copy of the Personal Information we have collected about you in a reasonably available portable format.
⦁ Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
⦁ Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
⦁ Right to Opt-Out of Targeted Advertising: The right to opt-out of the processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
⦁ Right to Opt-Out of the Sale of Personal Information: The right to opt-out of the sale of your Personal information. Please note that in certain circumstances, we may be unable to provide certain services if you opt-out.
⦁ Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
To submit a request to exercise your rights, and as applicable, to appeal a consumer rights action, please contact us via the contact information in Section 17 below. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Please note that to protect your information and the integrity of our products, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.
Under certain U.S. Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information. In most cases, we will facilitate your request through automated tools available through your password protected account.
12. OTHER CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law provides you with additional data protection rights. To learn more about your California privacy rights, please visit our Privacy Notice for California Residents.
13. SENSITIVE PERSONAL INFORMATION
Your Sensitive Personal Information is Personal Information that reveals your:
⦁ Social security, driver’s license, state identification card, or passport number.
⦁ Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
⦁ Precise geolocation.
⦁ Racial or ethnic origin, religious or philosophical beliefs, or union membership.
⦁ Mail, email, or text message content unless the business is the intended recipient of the communication.
⦁ Genetic data.
We only collect and use your Sensitive Personal Information with your consent and when it is necessary to perform or provide certain Services for you. If you want to know more about what information we collect, see Section 3 above or contact us at
+1.888.392.5560 , [email protected], https://airespringwireless.com/
14. DATA SECURITY & RETENTION
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We have put in place appropriate technical, physical and administrative procedures to safeguard and secure the information we collect in order to prevent unauthorized access or disclosure. Personal Information will be retained no longer than necessary in relation to the business purposes for which such Personal Information is provided and to fulfill legal requirements.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or Apps, you are responsible for keeping these passwords confidential. We ask you not to share your passwords with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites or the Apps.
15. CROSS BORDER TRANSFER AND GDPR DATA PROTECTION RIGHTS
15.1 Transfer of Personal Information
We may need to transfer Personal Information to countries other than the ones in which the information was originally collected. By providing your Personal Information to the Company, you are consenting to this transfer and storage of your information across borders. Any data processor used by the Company is required to safeguard Personal Information in accordance with its contractual obligations and data protection legislation applicable to its provision of services. When we export your Personal Information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer Personal Information from the European Union (“EU”) or the European Economic Area (“EEA”) to the United States, we will implement an appropriate data export solution such as entering into EU standard contractual clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law. Your Personal Information will only be transferred if appropriate or suitable safeguards are in place.
15.2 Privacy Rights
If you live in a region that is subject to the General Data Protection Regulation (“GDPR”), the Company would like to inform you that you have additional data protection rights. You can object to processing your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information.
16. CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by placing a notice on the Website. The date the privacy policy was last revised is identified at the top of the page. We encourage you to periodically check back and review this policy so that you are up to date.
17. CONTACT INFORMATION
To ask questions or comment about this privacy policy and our privacy practices, or if you wish to make a complaint about our data handling practices, contact us at:
+1.888.392.5560 ,
Contact Us – S-Mobile
Privacy Notice for California Residents
Last Updated: September 8, 2023
18. INTRODUCTION
The California Consumer Privacy Act (CCPA) provides California residents with additional data protection rights. This Privacy Notice for California Residents (the “Notice”) supplements the information contained in S-Mobile Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to help our California consumers understand and exercise their rights under the CCPA. Any terms defined in the CCPA have the same meaning when used in this Notice.
19. INFORMATION WE COLLECT
We may require information which identifies you as an individual (“Personal Information”), such as your postal address, name, email address, and phone number, in order to transact business with you as our customer, as our employee, or as an agent of your employer. We will only use such Personal Information for the purposes of providing information which you have requested, fulfilling business transactions, or for other purposes set out in our Privacy Policy.
We have collected the following categories of Personal Information in the last 12 months:
⦁ Identifiers: such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, phone number, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties such as social networks and our business partners.
⦁ Internet or Other Electronic Network Activity Information: such as IT information required to provide access to systems and networks, device IDs, log files and login information and information about your web browser, and other information regarding your interaction with our websites and mobile applications, such as the duration you stay on a webpage. This information is collected from you and your devices.
⦁ Geolocation Data: such as the general location of your mobile device. This category of information is collected from you and your devices.
⦁ Commercial Information: such as the goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. This category of information is collected from you, your devices, and third parties such as our business partners.
⦁ Sensitive Personal Information: such as account login information allowing access to an account, financial information to process your payments for services, and identifying numbers or identification to confirm your identity. We only collect and use your Sensitive Personal Information when it is necessary to perform or provide Services for you, or in the course of your employment with us for either establishing or maintaining your employment relationship. Please note we do not collect Sensitive Personal Information for the purpose of inferring characteristics about you.
As more fully described in our Privacy Policy, we obtain Personal Information:
⦁ Directly from you when you provide it to us. For example, from forms you complete or products and services you purchase.
⦁ Indirectly from you. For example, automatically as you navigate through our website, or automatically as mobile devices loaded with our applications are transported by device carriers, providing geolocation about device location and movement as recorded by breadcrumb technologies.
⦁ From third parties, for example, our business partners or other users.
Please see our Privacy Policy to learn more about the types of information we collect and how we collect it.
20. EMPLOYMENT INFORMATION
Applying to work for us: If you apply to work for us, we process Personal Information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.
Employment search engine companies may also send us lists of candidates, which they have generally either pulled your information from public sources or received it from you directly.
Offer of employment or contractor position: Prior to making an offer of employment or a contractor position, we may process Personal Information to conduct professional reference checks in accordance with applicable laws. If we extend an offer of employment or a contractor position to you, we will process personal information about the position to which you have been appointed, your job title, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date.
Employment-Related Background checks: Prior to commencement of your employment with us, we may engage service providers to conduct background checks that require the processing of Personal Information. More details are provided to you in the context of our request to you to complete these checks. We may use service providers to conduct the background screening.
As an employee or contractor with us, we may process Personal Information about your benefits, nationality, residency status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, stock options granted, stock ownership, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with projects and processes.
When your employment ends, we process Personal Information necessary to offboard you, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment.
21. USE OF PERSONAL INFORMATION
As more fully described in our Privacy Policy, we used the Personal Information we collected in the last 12 months, internally, for one or more of the following business purposes:
Provide Services:
⦁ Establish and administer your customer account.
⦁ Authenticate access to your customer account.
⦁ Perform maintenance and operations, including management of the network and devices supporting the services and our systems.
⦁ Provide technical support and assure quality of customer service interactions.
⦁ Facilitate hardware and software upgrades for devices and systems.
⦁ Enable your participation in surveys, sweepstakes, contests, and promotions.
⦁ Enable your participation in community forums.
Communicate with You:
⦁ Respond to your inquiries.
⦁ Personalize communications.
⦁ Send you service-related announcements.
⦁ Send you information about matters that align with our Mission Statement (including issue alerts, get out the vote notices, issue advocacy, and invitations to special events) newsletters, and special marketing offers.
Make Improvements to Our Services:
⦁ Identify and develop new products and services.
⦁ Improve the design of our services.
⦁ Understand how our services are used, including by creating measurement and analytics reports.
⦁ We may also collect and use Personal Information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently.
Provide Recommendations and Deliver Relevant Advertising:
⦁ Offer products, programs or services that may be of interest to you, and keep you informed of new happenings at the company.
⦁ Market our services.
⦁ Send you promotional communications for the services and other products and services we sell that we think may be of interest to you.
⦁ Deliver more relevant advertising.
Investigate Theft or Other Illegal Activities and Ensure a Secure Online Environment:
⦁ Detect the unauthorized reception, use, or abuse of our services.
⦁ Protect you and other users from fraudulent, abusive, unlawful use of our services.
⦁ Protect our rights, our personnel, and our property.
⦁ We may also use your Personal Information where we consider it necessary for complying with applicable laws and regulations, or to exercise or defend the legal rights of the company.
Establish and Manage Our Internal Relationships and Responsibilities:
⦁ Recruit new talent.
⦁ Onboard employees and contractors.
⦁ Grant and ensure appropriate access to systems and facilities.
⦁ Administer payroll and benefits.
⦁ Ensure the security and safety of the workplace.
22. SHARING PERSONAL INFORMATION
As more fully described in our Privacy Policy, we may disclose your Personal Information to a third party for business purposes. We are not in the business of harvesting and selling Personal Information. We only sell or share Personal Information when it is necessary to provide our customers with better products and services. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Personal Information for business purposes to the categories of third parties indicated in the chart below.
Personal Information Category of Third-Party Recipients
Employment Information
Product and services delivery companies
Fraud prevention and authentication/identity verification entities
Internet and other similar
network activity
Product and services delivery companies
Affiliates
Identifiers
Product and services delivery companies
Billing, payment processing and collection companies
Affiliates
Commercial Information
Product and services delivery companies
Affiliates
Note, some states define “sale” very broadly and include the sharing of Personal Information for anything of value. According to this broad definition, in the preceding twelve (12) months, we have sold Personal Information to the categories of third parties indicated in the chart below to facilitate the provision of third-party services to our customers.
Personal Information Category of Third-Party Recipients
Identifiers
Product and services delivery companies
Commercial Information
Product and services delivery companies
We do not sell or disclose Sensitive Personal Information and have not done so within the preceding twelve (12) months. We are not aware of any sale of Personal Information of anyone under 16 years of age.
23. YOUR RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their Personal Information, including:
6.1 Access to Specific Information and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (Section 7, Exercising Your Rights), we will disclose to you:
⦁ The categories of Personal Information we collected about you.
⦁ The categories of sources for the Personal Information we collected about you.
⦁ Our business or commercial purpose is for collecting or selling that Personal Information.
⦁ The categories of third parties with whom we share that Personal Information, if any.
⦁ The specific pieces of Personal Information we collected about you (also called a data portability request).
⦁ If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
⦁ sales, identifying the Personal Information categories that each category of recipient purchased; and
⦁ disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
6.2 Correction
You have the right to request that we correct any inaccurate Personal Information that we have collected from you. Once we receive and confirm your verifiable consumer request (Section 7, Exercising Your Rights), we will use commercially reasonable efforts to correct the inaccurate information, considering the nature of the Personal Information and the purposes for which the Personal Information was requested.
6.3 Deletion
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (Section 7, Exercising Your Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
⦁ Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
⦁ Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
⦁ Debug products to identify and repair errors that impair existing intended functionality.
⦁ Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
⦁ Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
⦁ Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
⦁ Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
⦁ Comply with a legal obligation.
⦁ Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
6.4 Limit the Use of Personal Information
You have the right to opt out of the sale or sharing of your Personal Information. If you wish to opt out of the sharing or selling of your Personal Information, you (or your authorized representative) may submit a verifiable consumer request (Section 7, Exercising Your Rights). Please note that limiting the sharing of your Personal Information may make it impossible for S-Mobile to provide you certain Services.
You also have the right to limit the use or disclosure of your Sensitive Personal Information for the purpose of inferring characteristics about you. However, S-Mobile does not use or disclose Sensitive Personal Information for this purpose.
6.6 Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
⦁ Deny you goods or services.
⦁ Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
⦁ Provide you with a different level or quality of goods or services.
⦁ Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
6.7 Minors
To the extent we have actual knowledge that we collect or maintain Personal Information of a minor under age 16, those minors between the age of 13 and 16 must opt in to any sales of Personal Information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales of Personal Information (as defined under California law); all minors have the right to opt-out later at any time.
Individuals under the age of 18 in California can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through our services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, you can contact us. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through our services.
24. EXERCISING YOUR RIGHTS
To exercise your rights described above, please submit a verifiable consumer request to us by emailing us at: +1.888.392.5560 , [email protected] Contact Us – S-Mobile
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may make a verifiable consumer request on behalf of your minor child. Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
⦁ Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
⦁ Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
25. OTHER CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law (Civil Code Section § 1798.83) permits users of our Websites and Apps that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to
Additionally, California residents under age 18 who are registered users of online sites, services or applications may request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
26. CHANGES TO OUR CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
S-Mobile reserves the right to update this Notice at any time without notice to you. Your continued use of our services, website, or mobile applications following the posting of changes constitutes your acceptance of such changes.
27. CONTACT INFORMATION
If you have any questions or comments about this Notice, the ways in which S-Mobile collects and uses your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
+1.888.392.5560
Contact Us – S-Mobile
Who we are
Suggested text: Our website address is: https://smobileusa.com.
Comments
Suggested text: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
Suggested text: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Suggested text: Visitor comments may be checked through an automated spam detection service.