Privacy Policy

Arizona - New Mexico - Colorado

Effective Date: August 28, 2020.

This Policy is incorporated as part of the Terms of Service that apply to your use of CellGap’s services. When you use our services, you acknowledge that you have accepted the Terms of Service and this policy without exception. You also acknowledge that you consent to our privacy practices, including our use and disclosure of your Personal Information.

If you do not consent to the Terms of Service or this Policy, please do not use our services or provide any Personal Information.

Scope of this Privacy Policy

This Policy covers any CellGap-affiliated site, product, or service which links to this Policy and any collection, storage, transfer, sharing, disclosure and handling of your Personal Information when you use our services which we define below.

This Policy does not cover, and we are not responsible for, third-party websites or applications that may be linked from our services; linking to them does not imply an endorsement. We are not responsible for these websites or applications or any information they may collect. You should always review the privacy policy of any third-party website or application that collects your Personal Information.

Personal Information We Collect

When you use our services, we may collect the below types of Personal Information:

Name;
Mailing address;
Email address;
Cell phone number;
Electronic Serial Number (“ESN”) or International Mobile Equipment Identity (“IMEI”) data;
Device serial number and media access control (“MAC”) address;
Records of products or services you have purchased from us;
Any information that you provide as part of filing a claim;
As part of the claim process, CellGap or its affiliates may require you to provide a copy of your driver’s license, passport, or other personal identification card; police reports or other records related to device theft; and
Shipping and billing information, credit card information or other preferred payment means.

We may also draw inferences from the Personal Information we collect from you to potentially offer products or services that we believe would be a good fit for you. At any time you may choose to withdraw your consent to CellGap’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting CellGap at [Insert Contact Information].

Password Management

CellGap may require you to create a password in order to access the Site and our services. CellGap does not maintain a record of your password in clear text format. You are responsible for maintaining the security of your password. If you forget your password or it is otherwise compromised, CellGap may require you to create a new password.

Communications Tools

Our services may allow you to communicate via audio, text, or video with us or another individual (e.g., friend or family member). While doing so, we may collect the content (including any Personal Information) that you share, upload, or provide while using our services to communicate. We may also collect Technical Data (e.g., device model) and Log Information (e.g., date and time of your call) generated from your use of our communications tools.

If a particular communications tool captures images (e.g., video) or enables screen sharing, please be aware that we, or any other individual who is a party to the communication, may be able to view any information that you make available or visible, which may include Personal Information. At any time, you may terminate the video or screen sharing by, for example, closing the tab in your browser or selecting a button to end the session.

Using a Third-Party Account on our Services

If you use a third-party service (such as Google or other social media platform) to create an account, we may receive Personal Information that you allow such third-party service to share with us such as your name, e-mail address, profile picture, or other Personal Information.

Log Information

CellGap may also automatically gather and store certain information about the use of CellGap’s services, including the number of unique visitors, the frequency of visits, how users interact with our services, user experience preferences, and other information that may help CellGap improve the user experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include Personal Information such as: IP address, Unique Device Identifier, CallerID / ANI (Automatic Number Identification) information, content of web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; application usage activity, hardware information, hardware and system settings, browser type, browser language, length of call, participant added to or exited from a call, the date and time of your request or call, or referral URL.

Cookies, Pixel Tags, and Other Tracking Technologies

CellGap may use cookies or similar technologies on our websites to analyze trends, administer the site, track users’ movements around the site, tailor and deliver advertising that may be more relevant or interesting to our users, and gather demographic information about our user base as a whole.

A cookie is a small data file that is managed by your web browser or other application and stored on your local system. CellGap may use session and persistent cookies to, among other things, identify your device during a particular interaction, analyze your behavior during a particular visit, and serve you advertising.

Pixel tags, also known as web beacons, help CellGap better manage user experience and content tracking. They also assist us in serving you advertising, including re-engaging you if you have searched for, viewed, and/or purchased our products or similar products. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by CellGap, an affiliate organization, or non-affiliated companies to assist us in providing, maintaining and operating our marketing. In contrast to cookies, which are stored on a user’s device hard drive, pixel tags are embedded within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but rather minimize distraction. You may opt out of third-party cookies or similar tracking technologies used to serve you targeted advertising based on the Personal Information (e.g., device information) in our cookie banner or, if you are a California consumer, by following the “Sale of Personal Information” instructions contained in the Your California privacy rights section of this Policy.

You can also elect to block all cookies from first parties (such as CellGap) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into your browser software. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via these links from your browser.

Please note, however, that if you do decide to block cookies or similar technologies, some parts of CellGap’s Site may not function correctly

Third-party Data Sources

CellGap may leverage external data sources in order to provide context and background on the users of its services in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

Personal Information We May Collect from Technical Data

When you use certain elements of our services, such as a mobile or web application, browser plug-in, or Alexa skill, we may collect the below types of Technical Data, which may include:

Telephony data, i.e. your network type, network operator name, subscriber identity module (“SIM”) operator name, SIM country;
Carrier name;
Operating system version;
Device model;
Performance and data usage, i.e. data storage amount, Central Processing Unit (“CPU”) and memory consumption;
Battery status and battery usage patterns and power consumptions
Lists of other installed applications;
Listing of types (i.e. Gmail, Yahoo, etc.) of other email accounts configured to your device;
Device information related to your choice of settings for your device such as Wi-Fi, Global Positioning System (“GPS”) settings, and Bluetooth settings;
Geolocation information, if you enable this on your device operating system and are you using a location-based service. You may turn this off at any time within the device settings;
Copies of information that you choose to backup from your phone; and
Aggregated, anonymous non-public Personal Information.

Personal Information We May Collect From Your Wi-Fi network

When scanning a Wi-Fi network, we may collect the below types of Personal Information.

Internet service provider’s name;
Wireless network’s name;
Information about the capabilities of your Wi-Fi network, such as type of internet connection, make and model of your router, and maximum download and upload speed;
Information about the health of your Wi-Fi network, such as measured levels of congestion, packet loss, jitter, latency, and throughput;
IP addresses or any other identifiers of any devices that are connected to the network; and
Information about each device’s internet usage, such as the device’s signal strength from the router and the maximum speed at which your device can operate with respect to your router.

How We Use Your Personal Information

CellGap may use your Personal Information to:

Fulfill a service to you;
Establish and verify your identity;
Handle and resolve billing disputes;
Monitor and maintain the performance and functionality of the device consistent with your choices;
Activate and maintain your account;
Provide technical support and click-to-chat functionality;
Protect and improve our services;
Offer updates, notices and other information about applications and services available from CellGap or its affiliates as permitted by law. At any time you may choose to withdraw your consent to CellGap’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting CellGap;
Respond to your questions, inquiries, comments and instructions;
To enforce the applicable Terms of Service;
Comply with the law and defend our rights;
Track and analyze de-identified data and provide such data to third parties that provide services to CellGap;
Protect against fraud and potential fraud;
Notify you of any known breach of your Personal Information; and
Maintain the security and integrity of CellGap’s systems and services.

How We Share Your Personal Information

We will not use or disclose your Personal Information to non-affiliated third parties except as disclosed in this Policy.

CellGap may transfer or license your Personal Information to:

Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing. These companies are required to comply with the principles set out in this Policy and only use such information for the purposes for which it was provided to them;

A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Policy, or our Services, in the manner described in this Policy. In these circumstances, Personal Information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

CellGap may also disclose your Personal Information to:

Comply with the law and/or legal process in which a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order, or judicial or administrative proceeding);
Defend our rights and/or property or the rights and property of others;
Enforce our Terms of Use and/or this Policy;
Respond to claims that the content(s) of a communication violates the rights of another; or
Detect, prevent or otherwise address fraud, security, or technical issues.

How We Protect Your Personal Information

We use commercially reasonable, industry standard technical, administrative, and physical controls to protect your Personal Information, including data encryption where appropriate; however, since the internet is not a 100% secure environment, we cannot ensure the security of information during its transmission between you and us. Accordingly, you acknowledge that when you transmit such information, you do so at your own risk. We will notify you of any confirmed security breach of your Personal Information to the extent required by and in accordance with state and federal law.

How Long We Keep Your Personal Information

CellGap will retain your Personal Information as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or not prohibited by applicable law.

How You Are Notified If The Policy Changes

We may change this Policy from time to time. If we do, we will post the updated Policy with the last revised date. Your continued use of our services means that you consent to the updates. You should periodically read the Policy to understand our privacy practices.

If we make material changes to this Policy, we will notify you in the site, product, service, or application or by email and seek your affirmative consent where required.

Communicating With You Electronically

By using our services, you agree that we can communicate with you electronically. This includes any required notifications (i.e., legal, technical, regulatory, security, or privacy) relating to your use of the services.

Your Rights Related To Your Personal Information

While we take various steps to ensure the accuracy and completeness of your Personal Information, we rely upon you to provide accurate and complete information when interacting with us.

Upon your request and as allowed or required by law and consistent with our applicable partner agreements, you may request CellGap to take the following actions with your Personal Information: (i) provide you with a copy, (ii) correct, (iii) update, or (iv) delete. To make such a request, or if you have a privacy-related complaint, please contact CellGap.

Children Under 13

Our services are not directed to children under 13. We do not knowingly collect Personal Information from children under 13. If you become aware that your child is accessing the services and providing Personal Information without your consent, please contact us by using the information provided below. We will take steps to remove Personal Information from our storage systems and terminate the account if we determine that a child under 13 has accessed the services.

For Non-U.S. Residents

We may transfer Personal Information that we collect about you outside of the country in which it was collected. If you are visiting from the European Union or other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about yourself, including your Personal Information, to a country and jurisdiction that does not have the same data protection laws in place as the European Union or other region. By doing so, you are consenting to the transfer of information about yourself, including your Personal Information, to the United States, as described in this Policy