BandwidthX Privacy Policy

Last updated: May 25, 2018

BandwidthX is committed to maintaining your confidence and trust with respect to your privacy. Please read this Privacy Policy carefully to understand our practices about how we collect, use and share your information.

About our Privacy Policy

This Privacy Policy applies when you visit or use our websites or apps that refer or link to this privacy policy (each, a “Service”). This policy may be supplemented by additional privacy statements, terms or notices provided to you. BandwidthX is the primary controller of your personal information provided to, or collected by or for, the Service.

Information we collect about you

We collect certain information in the course of operations. In some instances, this information may include data that could be used to identify a particular individual, otherwise referred to as Personal Information. We collect the following Personal Information:

• Device identifying information, namely your MDN, IMEI, IMSI, ICCCID and IP address
• Location information
• User-submitted datawhen you contact us through a Service or directly about a matter.

We also collect certain data that is not Personal Information. We collect the following non-Personal Information:

• When you use or interact with our website we collect information generated by your activity. We use cookies to better understand and improve the use of our websites. This information is aggregated and anonymous to us.
• When you use our apps we collect certain usage information (“Usage Data”). The Usage Data may consist, among other information, of the amount of data used, the name of a Wi-Fi hotspot (SSID), the status and duration of Wi-Fi session and whether your device is currently connected to a Wi-Fi hotspot. With respect to Wi-Fi use, we also collect certain diagnostic information related to a Wi-Fi connection, such as signal strength and the encoding rate. We also collect certain cellular data information, such as amount of cellular data used and cell tower information. Usage Data is not personally identifying. On the other hand, some Usage Data, either alone or when combined or linked with your Personal Information, may allow your identity to be discovered. In such cases, we treat the combined data as Personal Information.

How we use your Personal Information

We use your Personal Information to operate and best serve you. We use the aforementioned Personal Information as follows:

• Device information is used by our apps. We collect your device’s MDN, IMEI, IMSI, ICCID and IP address. In particular, we may collect and use your MDN (phone number) to be able to provide service. We also get your device’s IP address when you visit our websites. We do not use your IP address in any way other than it is a part of the information used by Google Analytics (see “How do we use cookies” section).
• Location information is used by our apps to identify potential Wi-Fi hotspots to connect to. We also collect anonymous and aggregated location information about where geographically devices are that use our websites.
• User-submitted information is used to respond to your requests, inquiries, comments or concerns.

How may we share your Personal Information

We will not share any Personal Information that we have collected from you except as described below:

• Information shared with service providers.  We may engage third-party service providers, such as cloud-based providers to host our apps and Google Analytics to provide analytics on the websites, to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information only for the purpose of performing services for us and are obligated not to disclose or use your Personal Information.
• Information disclosed as a part of business transaction.  If we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction.
• Information disclosed to comply with legal requests.  It is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties if we have a good faith belief that such disclosure is necessary to (i) meet any applicable law, regulation, legal process or other legal obligation; (ii) detect, investigate and help prevent security, fraud or technical issues; (iii) to prevent or stop activity we consider to be illegal or unethical; and/or (iv) protect the rights, property or safety of BandwidthX, our users, employees or others.
• Information we disclose with your consent or at your request.  If we want to share Personal Information other than as permitted or described in this Privacy Policy, we will provide you with a choice to opt in to such sharing and you may choose to opt in and share the information.

We may disclose Usage Data that is aggregated or de-identified in such a way such that it cannot be used to identify you.

How do we use cookies

Cookies are small text files which are stored on your computer when you visit certain web pages. We use cookies to understand how our websites are used which help us to improve your overall online experience. To find out more about cookies, visit www.aboutcookies.org.

We use the following categories of cookies on our websites:

• Performance.  These cookies are used to collect anonymous information about how you use our websites. We use Google Analytics to collect this information for us which may include recording your use of our websites. By using our websites, you agree that we can place these types of cookies on your device.
• Functionality.  These cookies are used to provide services or remember settings to enhance your visit. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device.

If you'd prefer to restrict, block or delete cookies from us and or any other website, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies, we cannot guarantee the performance of our websites and some features may not work as expected.

How we secure your Personal Information

We take steps, including through contracts, to ensure that Personal Information continues to be protected in a manner consistent with the standards of protection required under applicable law. We use various measures to protect the Personal Information. We regularly test our website, data centers, systems, and other assets for security vulnerabilities. We use commercially reasonable protection technology such as encryption, firewalls and other security procedures to help protect the accuracy and security of your Personal Information and to help prevent unauthorized access or improper use. However, given that no method of transmitting information over the Internet or storing information is completely secure, we cannot guarantee the absolute security of any information.

How long do we retain your Personal Information

We retain your Personal Information for as long as necessary to provide the Services and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

International Transfer of Personal Information

We operate on a global basis. As such, your Personal Information may be transferred to, and maintained on, computer servers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, you should be aware that we may transfer your Personal Information to the United States and process it there. Your consent to this Privacy Policy followed by your submission of any Personal Information represents your agreement to that transfer. We will comply with any applicable regulations regarding any international transfer of your Personal Information.

Links to other websites and services

The Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Linked websites or services may have their own privacy policies or notices, which we strongly suggest you review if you visit those websites. We are not responsible for the content, privacy practices, or use of any websites that are not affiliated with us.

Contact

If you have any questions, comments, complaints or requests regarding this Privacy Policy or our processing of your Personal Information, please contact:

BandwidthX Inc.
Attn: Data Support
5796 Armada Drive, Suite 175
Carlsbad, California 92008
United States
Email: info@bandwidthx.com

Changes to this Privacy Policy

We will keep this Privacy Policy under regular review and we will place any updates here. At the start of this Privacy Policy, we will tell you when it was last updated.