Privacy Policy

This Privacy Policy is effective as of June 1st, 2017.

SECROM LLC ("SECROM") has adopted this Privacy Policy ("Policy") to establish and maintain an adequate level of personal data privacy protection. SECROM has designated the legal department to oversee its practices concerning privacy of personal data, including its compliance with data privacy and security programs where SECROM participates. Any questions, concerns, or comments regarding this Policy may be directed to: legal@secrom.com.

SECROM DOES NOT DISCLOSE INFORMATION TO UNAFFILIATED THIRD PARTIES WITHOUT YOUR CONSENT OR AS OTHERWISE PROVIDED IN THIS POLICY. THE USE OF INFORMATION COLLECTED THROUGH OUR SERVICES SHALL BE LIMITED TO THE PURPOSE OF PROVIDING THE SERVICES OFFERED BY OR THROUGH SECROM.

Our customers should know what information SECROM may collect, as well as understand how we use, disclose, and protect that information. You should be able to communicate with us regarding any limitation of disclosure of your personally identifiable information, where attainable, and to address any questions or concerns that you may have.

 

INFORMATION WE COLLECT

We collect a variety of personally identifiable information (“personal data”) about users of our services and visitors to our websites to provide seamless user experience. Personally identifiable information means information that is directly associated with, or could be used to identify, a specific person (e.g., a name, address, telephone number, e-mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person). Personally identifiable information excludes “aggregate information.” Aggregate information means data we collect about a group or category of services or users or customers and from which individual user or customer identities have been removed (e.g., a report on how many customers have visited our website). Such aggregate information allows SECROM to consider new products and services or tailor existing services to customer preferences. I addition, personally identifiable information does not include an Internet protocol (“IP”) address and any network-related information that you used to access our services or websites.

We may collect the following types of personally identifiable information through your use of our websites, products, services, and telephone calls to SECROM’s or its agent’s customer service:

Information You Provide: We collect information that you provide (e.g., your personal and your organization’s name billing address, telephone number, e-mail address, credit card or bank account information, identification documents, tax ID, social security number, and other information that is required in order for us to provide you products and/or services or that you may participate in a promotion, survey, or register on our websites, or participate in other activities offered by SECROM or our affiliates.

Information We Collect: We automatically collect certain types of information whenever you interact with us or access our services or websites depending on the device and type of communication channel you use. SECROM, where possible, may collect your phone number, the type of device you use, including its operating system, browser-related data, device model, device identifiers, network data, communication session data, application identifiers, and other information for the purpose of providing you better and safer services, as well as to comply with laws and regulations. If you are placing an emergency call, such as 911, SECROM may access and collect, where possible, your location information to assist the emergency services. When you visit our websites, we may collect any search terms you use on or to get to our websites, and any clickstream data generated by your use of our websites. Any information that we collect, we may store in log files or other types of records, which may be linked to personally identifiable information. When you visit our websites, or third-party websites, and click on SECROM’s or third-party’s advertisement that is linked to SECROM’s website, we automatically collect information about the website you were visiting, including without limitation, the IP address of the website and the date and time that you clicked on the SECROM’s advertisement.

Personal Information Transmitted: SECROM may not have direct relationship with individuals and/or organizations whose information is transmitted via products, services, and/or websites provided by or through SECROM. Our customers may transmit, receive, and/or store personal information of individuals and/or organizations whom they contact by means of our products, services, and/or websites. If you are an individual or a representative of organization who is being contacted by one of our customers or an entity authorized by one of our customers through the products, services, and/or websites that we offer and would no longer like to be contacted by such customer or entity through such services, please contact the customer directly.

We may transfer and store personal information and its derivative information, regardless of how it is obtained, that is contained within the communications sent, received, and/or stored by our customers or their authorized entities using our products, services, and/or websites to third parties that help us provide or supply to us such products, services, and/or websites.

Any individual or organization whose personal information is included in the communications sent, received, and/or stored by one of our customers or its authorized entities through the products, services, and/or websites that we offer who seeks access to, or who seeks to correct, amend, or delete any such inaccurate data should direct the request to the customer directly. Customer is the one who controls such data—therefore, customer may choose to provide such access to such data or may choose to perform any correction, amendment, or deletion thereof.

SECROM retains, where possible and required, the communications that we transmit or store on behalf of our customers for as long as necessary or as obligated according to the service terms, and as required to comply with our legal obligations, resolve disputes, and enforce our agreements.

CERTAIN COMMUNICATIONS ARE TECHNOLOGICALLY NOT POSSIBLE FOR SECROM TO RETAIN AND STORE, AND THEREFORE SECROM IS UNABLE AND DOES NOT RETAIN OR STORE SUCH COMMUNICATIONS (E.G., COMMUNICATIONS ENCRYPTED USING CERTAIN ENCRYPTION TECHNOLOGIES, OR BYPASS OR PASS-THROUGH COMMUNICATIONS). 

Information We Obtain: SECROM may obtain information about you and/or your organization from third party sources and associate it with your personally identifiable information. Such information may include but is not limited to credit information, commercially available demographic and marketing information, social websites, and other information commercially or publicly available on the Internet or from third parties.

SECROM does not knowingly collect—either actively or passively, or stores any information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of thirteen. If you are a parent or guardian of a child under the age of thirteen and believe that your child has disclosed personally identifiable information to us, please notify us to request the specific information collected from your child. A parent or a guardian of a child under the age of thirteen may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.

 

USE OF PERSONALLY IDENTIFIABLE INFORMATION

Internal Use: SECROM uses personally identifiable information to serve its customers and to enhance our customer relationships. We use personally identifiable information for billing purposes, to provide services or complete transactions you have requested, to anticipate and resolve problems with products and services, to protect our websites, products and services, to protect our other customers, to create and inform you of products and services, or to better meet your needs, and to comply with laws and regulations.

Subject to your consent, SECROM may use e-mail, telemarketing, direct mail, and other marketing methods to inform you about our and our affiliates’ products and services. If you do not wish to receive these types of communications you can choose at any time not to continue receiving them by contacting SECROM or, where possible, opting out from receiving such communications.

We may use communication device information to conduct anonymous analytics so we can assess how you interact with your communication device. Certain products or services that SECROM provides may require capturing, transferring and/or processing your picture, fingerprint, or other biometric or location information. Therefore, SECROM-provided software may access video camera, microphone, GPS, radio, memory card, or other sensors and modules of your communication device, or you may be required to provide such information. SECROM does not use this information for any purposes except for the designed use as mentioned herein in connection with providing you such services.

We may send you push notifications, Short Message System (SMS) notifications and/or other notifications and alerts. SECROM-provided software may need to access and send SMS, email, and other notification and messages from your communication device, access phone services and place calls, use wireless and other networks, including near filed networks, consume data services provided by your telecommunication provider, and access and use other services and applications available on or through your communication device in connection with providing you the services you requested. We are not responsible for telecommunication and all other charges that you may incur as a result of using or not using our products and services.

While you may choose not to receive marketing information from us or our affiliates, you will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. You may not opt out from service or product-related notifications. You will also continue to receive communications directly related to each service or product you purchase or subscribe to.

Customer Surveys: Periodically, you may be able to participate in our surveys or promotional campaigns. Any personally identifiable information that we may collect from you in a survey or a campaign, such as, but not limited to a testimonial, will be used internally by SECROM and its affiliates, notwithstanding anything to the contrary contained in any agreement between you and SECROM, or unless otherwise explained in the instructions for a customer survey or a campaign.

 

DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

SECROM seeks to protect and keep customer’s information confidential, and therefore SECROM does not share personally identifiable information with unaffiliated third parties, nor it sells such information to third parties, unless permitted to do so in accordance with this Policy or other agreements between you and SECROM.

Disclosure to None-Affiliates: We may disclose your personally identifiable information and any sensitive or confidential information to an unaffiliated entity, only if: (i) you consent to such disclosure, or (ii) we are required to do so by law, such as to comply with a lawful government request (e.g., lawful subpoena or court order), or (iii) we can do so in accordance with an agreement between you and SECROM.

In addition, we may disclose your personally identifiable information and any sensitive information to an unaffiliated entity if SECROM, in its sole discretion, believes it is absolutely necessary in order to: (i) enforce its agreements and policies, including this Policy, (ii) bill and collect for products and/or services, (iii) protect and defend its websites, products and services, its legal rights and property, the interests of customers and the rights of third parties (e.g., to address allegations about fraudulent or unlawful activity), (iv) protect health and safety of general public, and (v) in case of an emergency, including, but not limited to assisting emergency services, (vi) complete a transaction or perform a service that you have requested, or to support the technical operation and maintenance of our products, services, and websites.

We may also share personally identifiable information with or to our agents, outside vendors or service providers to perform functions on our behalf. For example, we use third party service providers to perform functions such as analyzing data, providing marketing assistance, providing customer service and processing orders, providing computing infrastructure, etc. When the unaffiliated third party acts solely on our behalf, SECROM requires that party to follow our privacy practices.

We may obtain your consent for a disclosure in several ways, including: (i) in writing, whether such consent is signed and/or transmitted electronically or delivered by a postal service or a courier; and notwithstanding anything to the contrary contained in any agreement between you and SECROM as follows: (ii) verbally, (iii) online, by clicking on a link or button, or (iv) using a dialing string or buttons on a telephone pad.

Disclosure to Affiliates:  We may share your personal and payment information with: (i) our subsidiaries and business affiliates where it is necessary to support or enhance our products and services, (ii) with payment providers and fraud prevention services in order to verify payment methods and prevent fraud, (iii) with credit reporting agencies in order to perform a credit inquiry, and such inquiry may be noted on your credit record, (iv) with government agencies and other authorities to verify your compliance with the law and our terms and conditions. We may use automated decision-making systems to verify payment methods, assess creditworthiness, or prevent fraud, and we may contact you requesting additional information when needed.

For European Economic Area (“EEA”) customers, this may mean that the personally identifiable information (i.e., personal data) you provide us may be transferred to countries outside the EEA. By way of example, this may happen if any of our subsidiaries or affiliates are located in a country outside the EEA, such as SECROM that is located in the United States. These countries may not have similar data protection laws to the EEA. Nonetheless, if we transfer information outside the EEA in this way, we will take steps to ensure your privacy rights continue to be respected.

Business Transfers: Information about our users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of SECROM or its subsidiaries.

Emergency Calls: If you dial for emergency services (e.g., 911 in the U.S.), we may provide personally identifiable information and location information to: (i) a public safety answering point, (ii) emergency service provider or dispatch provider, (iii) public safety, fire service, or law enforcement official, (iv) hospital emergency or other medical care facility, (v) or other emergency service or a service provider that acts of behalf or in connection with an emergency response.

 

CUSTOMER PROPRIETARY NETWORK INFORMATION

In the normal course of providing telecommunications and interconnected voice-over-Internet-protocol (“interconnected VoIP”), email, SMS and other services to its users and customers, SECROM collects and maintains certain customer proprietary network information (“CPNI”). Your CPNI includes the types of telecommunications and interconnected VoIP services, you currently purchase or subscribe to, how you use those services (for example, your calling, SMS, and email records), and billing information related to those services—except your SECOM telephone numbers, name, and address that do not constitute CPNI.

SECROM may share your CPNI with our subsidiaries, affiliates, and authorized agents in order to offer you additional products and services that may fit your needs. SECROM does not sell, trade, or otherwise share your CPNI with anyone who is not authorized to represent us, or to offer our products or services, or to perform functions on our behalf, except as the law may require or you may authorize.

In the United States, Federal law permits us to use your CPNI to provide the telecommunications and interconnected VoIP services you purchase or subscribe to, and to bill and collect for those services. We may also use or disclose your CPNI for legal or regulatory reasons such as to respond to a court order, to investigate fraud, to protect our rights or property, to protect against the unlawful use of our products, services or websites, or to protect other users. You have a right and we have a duty under the federal law to protect the confidentiality of your CPNI. In order to opt out and restrict access to your CPNI for our marketing purposes, please contact us within 30 days of this notice. Restricting our use of your CPNI will not affect our provision of any service or product to which you currently subscribe, nor will you necessarily eliminate all types of SECROM’s or its affiliates’ marketing.

 

SECURITY AND DATA INTEGRITY

We maintain a variety of physical, electronic, and procedural safeguards to guard your personally identifiable information and CPNI. Specifically, we use commercially accepted procedures and reasonable security systems to protect against unauthorized access to our systems. We restrict access to your personally identifiable information and CPNI to those employees and contractors—all of whom are covered by this Policy—who need to know that information to provide products or services to you or otherwise assist you for a legitimate business reason. We protect the security of your personally identifiable information during transmission via our websites by using Secure Sockets Layer (“SSL”) software, which encrypts information you input.

Please be advised that SECROM has no control over or responsibility for the security or privacy policies or practices of other websites or services on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links on one of our websites.

 

USE OF COOKIES

SECROM may use tracking technologies such as “cookies”, tags, and scripts to enhance your use of our websites. “Cookies” are small text files placed on your computer’s hard drive by a website when you visit that website. These files identify your computer and record your preferences and other data about your visit to a website so that when you return to that website, the site operator knows who you are and can personalize your visit. For example, cookies enable a website shopping cart to function so that you only have to check out once.

Consequently, cookies are often tied to the use of personally identifiable information while using our websites. If you choose not to accept the use of cookies or choose to block or delete cookies, your use of our websites may be impaired. Cookies allow us to do the following: (i) complete transactions you have requested, (ii) collect information to determine which services and sections of our websites are most and least popular, (iii) personalize our websites and services, such as make recommendations to you based on the services you have used in the past, and (iv) improve the ease of use of our websites, sometimes in conjunction with web beacons, (v) and perform other functions for yours and our convenience.

We do not use cookies to store credit card information, but we may use cookies to store login information for customers who choose the option of storing such information on their computers. We also use session-based cookies to maintain continuity of navigation for you when viewing our websites. We may also use cookies that are not linked to your personally identifiable information. We also use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity use LSOs such as HTML 5 and Flash to collect and store information. SECROM may also not use technologies that recognize browser “Do Not Track”’ signals or other mechanisms that provide you with a choice regarding the collection of data related to your online activities over time and across third party websites. You can block cookies from your computer using your web browser’s settings (see below). For more information on how to disable and manage cookies and tracking devices see: www.ftc.gov/ftc/cookies.shtm.

 

USE OF WEB BEACONS

SECROM may use web beacons on its websites. A web beacon is a small and usually invisible graphic image displayed in a webpage, web-based document, or e-mail message. When the user’s web browser reads the HTML code for the web beacon to retrieve the image, it can pass along the IP address of the user’s computer, the time the web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to “cookies” and any personally identifiable information that may be stored in them.

SECROM may use web beacons to gather aggregate information, as described herein. We do not permit unaffiliated third parties to place web beacons in advertisements on our websites. We may use third parties, such as Google, to analyze use of our websites.

 

USE OF BANNER ADS

We may use third-party advertising companies to place advertisements about our products and services on other websites. These advertising companies may use cookies, web beacons, or other technologies to measure the effectiveness of our ads. The advertising companies may use anonymous information about your visits to our and other websites in order to measure advertising effectiveness and offer selective ad content. Normally, such advertisement companies do not link to or collect any personally identifying information. The use of such cookies, web beacons, and other technologies is subject to the advertising companies’ privacy policies, not the SECROM’s privacy policy. SECROM does not control and is not responsible for how third party sites handle personal information of users. If you wish to not have this information used for the purpose of serving you targeted ads, you may be able to opt out from such services or follow the instructions above to block cookies using your web browser settings. Please note that this does not opt you out of being served advertisement. You will continue to receive generic ads.

 

CHECKING INFORMATION FOR ACCURACY

SECROM customers may be able to review and change their information that is related to the products and services they are using. See the product or service instructions on how to review and change, where applicable, such information. We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or want to request that we no longer use your information, please see the instructions for the product or service you would like to cancel.

 

SOCIAL MEDIA

Our websites may include social media features. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the third party company providing them. SECROM does not control and is not responsible for how third party social media companies handle personal information of users.

 

REFERRALS AND INVITATIONS

If you choose to use our referral programs or services that involve a referral or invitation, and you choose to refer or invite someone to use our products or services, or to visit our websites, or otherwise to contact us, we may ask you for the intended recipient’s name, email address, phone number, and other information. SECROM may store and use this information to communicate with such individual or entity as it deems appropriate, and use this information for any of its business purposes. By agreeing to the terms in this Policy you acknowledge that you have received any referral recipient’s or invitees consent to provide its information to us. Your referral or invitee may contact us here to request that we remove this information from our database.

 

BLOGS AND FORUMS

Our websites may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blogs or community forums your should contact us at info@secrom.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. SECROM is not liable for the distribution of personal information posted on a public forum. We encourage all users to exercise caution when providing personal information in blogs and community forums.

 

TESTIMONIALS

With your input and your consent, or as otherwise specified in an agreement between you and SECROM, we may post our customers’ testimonials on our websites and on other resources as we deem appropriate, which may include your name, industry, company, title, or other identifying information. If you want your testimonial removed or wish to give or withdraw a consent, where possible, please contact us at legal@secrom.com.

 

PRIVACY SHIELD COMPLIANCE

For the information regarding SECROM and the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce’s International Trade Administration (ITA) regarding the collection, use and retention of personal information from European Union member countries and Switzerland, please see SECROM’s website for additional information if available.

 

ENFORCEMENT

SECROM regularly reviews its compliance with this Policy. Please contact us with any questions or concerns regarding this Policy or SECROM’s treatment of personal information. When we receive formal written complaints, it is SECROM’s practice, where possible, to contact the complaining customer regarding the concerns.

 

UPDATING THE POLICY

SECROM will revise or update this Policy if our practices significantly change or as we deem appropriate. If we make any material changes, we will notify you by email, where feasible, and/or by updating this Policy on our website prior to the change becoming effective. You should refer to the SECROM’s website at www.secrom.com for the latest information and the effective date of any changes.

 

CONTACT US

If you have any questions, comments or concerns about this Policy, please e-mail us at legal@secrom.com. We are committed to the statements set forth in this Policy.

 

ACKNOWLEDGMENT

By purchasing, subscribing to, or using any of the SECROM’s products and/or services or using any of our websites or any other product or service provided by or through SECROM, you agree to the terms and conditions of this Policy.

 

 

Secure Communication Solutions

Customers must be qualified to use SECROM. Certain products and services are only available to U.S. Persons, as defined in the International Traffic in Arms Regulations. Qualifications are subject to change without notice. Other limitations apply. All product names, logos, and brands are property of their respective owners. All company, product and service names used in this website are for identification purposes only. Use of these names, logos, and brands does not imply endorsement.

Copyright © 2016 SECROM. All Rights Reserved.

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