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CirrusTel is the data controller in respect to personal data that we collect or that you provide to us. This policy may be amended from time to time and was last updated on September 1, 2019. If you have any questions regarding this policy, please contact CirrusTel through the Contact Us link on this website or see our contact details in the “How to Contact Us” section at the end of this Notice.
This online Privacy Notice is applicable to all information that we collect at this and any/all of CirrusTel’s array of digital websites and platforms including, but not limited to: www.cirrustel.com and any/all of its subdomains, or through other digital communication means such as our own embedded webforms and advertisements placed on 3rd party sites (including job application forms for job opportunities we have listed on 3rd party portals), or through email and social media interactions with you.
1. How We Obtain Information About You
We may collect personal data that you choose to share with us—including, but not limited to, your first and last name, physical address, email address, or telephone number when you:
CirrusTel collects personally identifiable information from our users during the initial signup process, as well as during surveys or preference requests, event registrations, and during your normal use of our websites and platforms. We use this information to contact you with offers, newsletters, and special promotions in which you have expressed interest, and to send you necessary business communications pertaining to your ongoing business relationship with us. Additional information, such as dietary preferences, preferred location, events, or group bookings, enable us to provide the best possible service to you in person or digitally based on your needs and communicated interests. You may also be given the opportunity to provide your cell/mobile phone number during various processes, or through a separate email from one of our affiliates. If you provide your cell number and agree/opt-in to receive text (SMS) messages on your cell phone, you will always have the option to “Opt-out” of any future text-based/SMS communication each time you receive an SMS.
We may also collect personal data in other contexts that we will notify you of at the time.
2. Information We Obtain
Information You Provide
Personal data you provide directly to us will be apparent from the context in which you provide it. For example:
Information We Collect Automatically
Our web servers may log information such as your operating-system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to one of our sites, and the IP address of the device you use to connect to the internet. They may also log information about your interaction with the sites, such as which pages you visit. To control which web servers, collect information by automated means, we may place tags called web beacons—small files that link web pages to particular web servers and their cookies. We also may collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails—to help us understand and respond to your needs.
3. How We Use the Information We Obtain
Information You Provide
We may use personal data you provide to respond to your inquiry—for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights, and freedoms to protect personal data about you. Your email address is used to send email that is designated in our customer database or to send specific content that you subscribed to or requested directly. Your email and relevant content-viewing history may be provided to mutually interested third parties when you demonstrate an interest in their products and/or services on one of our sites (such as reading a blog or attending a CirrusTel sponsored event. CirrusTel is not responsible for the timing, quantity, or quality of the materials which the third party may send to you via your email.)
CirrusTel follows an opt-in, permission-based text-message (SMS) enrollment policy. CirrusTel will NOT rent, sell, trade, or loan our lists to anyone. All emails contain links on how to unsubscribe from the client list, and how to request your data be updated. All SMS messages contain information on how to unsubscribe from our SMS lists. You may leave our lists at any time, for any reason.
In addition to the uses discussed above, we also may use the personal data you provide to:
Your data will be utilized for official CirrusTel business purposes only. We do not sell or provide your data to third parties except as described under “4. Information We Share.” below.
We may also use the information we collect to protect against and prevent fraud, claims, and other liabilities, and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by law that applies to us.
Other Uses of Information
In addition to the uses described above, we may use personal data you provide, or we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data, and our legal basis for doing so.
4. Information We Share
We do not sell or otherwise disclose personal data you provide, or we collect, except as described here. We may share personal data you provide, or we collect with the following parties for the purposes described in this Notice:
We may share personal data with service providers that perform services on our behalf, such as payment service providers, analytics providers, hosting providers, and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf, or to comply with applicable legal requirements.
We may provide your contact information to interested third parties as described above, only when we have a legitimate business interest in doing so, to third parties with which we have a standing contractual relationship and obligation, and when doing so is to your benefit as well. We do not gain any material benefit from this share of data, and we do not provide data of any person or entity who is not a registered Sales Partner with CirrusTel to any third parties in this process.)
In addition, we may disclose personal data about you: (a) if we are required or permitted to do so by law or legal process—for example, due to a court order or a request from a law enforcement agency; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity; and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
5. Data Transfers
We may transfer the personal data we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data-protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries, we will protect that personal data as described in this Notice. You may request a copy of the safeguards that we have put in place in respect to transfers of personal data by contacting us as described in the How to Contact Us section below.
6. Data Security
We may retain a copy of your information in accordance with law, and only so long as necessary to provide you with high-quality and consistent services, including marketing services and account information.
CirrusTel has put in place certain technological and procedural security functions to protect the personal information it collects, uses, or transfers from loss, misuse, alteration, or destruction. Information collected by our digital properties, or transferred to us from other sources, will be processed in the United States, Europe, or Latin America.
7. How Long We Keep Information
The amount of time for which we keep personal data depends on the purpose for which we collected it. In all cases, we keep it for as long as necessary to fulfill the purposes for which we collected it. We will then delete the personal data—unless we are legally required to retain it, or we need to retain it to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data as follows:
Certain pages on our sites contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information such as IP address, the URL of the page on which the beacon appears, timestamps, browser type, and the information in cookies set by the third party.
Analytics Technologies We Use
We use LinkedIn’s Insight tracking pixel to understand the interactions between our LinkedIn content and the performance of related content on our site. More about our use of LinkedIn’s tracking service can be found here.
We use Facebook’s Insight tracking pixel to understand the interactions between our Facebook content and the performance of related content on our site. More about our use of Facebook’s tracking service can be found here.
Snippets and Custom Objects
We use snippets and custom objects in our HTML-based email campaigns to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt out of these emails, you may change your settings at any time by clicking on the “change your preferences” link at the bottom of the email.
Links to Other Digital Properties
Communication that we send on a 3rd party’s behalf may contain links to other sites or digital properties that are not owned or controlled by CirrusTel. Please be aware that CirrusTel is not responsible for the privacy practices of these other properties and does not exercise authority over such properties. Therefore, CirrusTel assumes no responsibility for the privacy and data-collection policies and procedures of such linked properties, nor for the content or reliability of such properties. If you choose to access a third-party property, you do so at your own risk.
9. Your Rights and Choices
You have the right to access the personal information that we hold about you.
Before providing personal information to you or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us, so we can locate your personal information.
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it by contacting your account management team.
If you would like to exercise any of these rights or lodge a complaint, please contact us using the information set out below.
10. How to Contact Us
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data—or if you would like us to update information we have about you or your preferences—you may contact us at: Phone number: 760-936-4180
US Mail: Cirrus Telecom, LLC., Attn: Legal Dept, 2 Kiel Avenue, Unit #135, Kinnelon, NJ 07405. Opt-Out/Unsubscribe: If you no longer wish to receive our communications, you may opt out of receiving them by following the instructions included in each communication.
Alternatively, you may contact us at: Phone number: 760-936-4180 US Mail: Cirrus Telecom, LLC., Attn: Legal Dept, 2 Kiel Avenue, Unit #135, Kinnelon, NJ 07405.
Changes in Our Privacy Statement: We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will publicize such changes by means of a Notice on our home page by displaying a prominent “NOTICE” above the text of the Privacy Statement.