Privacy Policy

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(Last updated 1 April 2020, to incorporate California Consumer Privacy Act transparency requirements)

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Welcome to GigSky!

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Our Privacy Policy applies to visitors and users (“you” or “your”) who visit our website or subscribe to GigSky’s Products or Services. It also covers how GigSky and its affiliated companies (collectively, “we,” “us,” or “our”) collect, use, and share information in connection with your access and use of this website, the GigSky app, and GigSky products and services (collectively, “Services”). Your information is managed as per this Privacy Policy and our Terms of Service.

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CALIFORNIA RESIDENTS

Our California Resident Privacy Notice, below, supplements the information in this Privacy Policy and applies solely to visitors, users, account holders and others who reside in the State of California.

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THIRD PARTY PRIVACY POLICIES

GigSky may provide third-party content or links to third-party websites or apps (or may include features that allow you to connect to your GigSky account via third parties, such as Apple, Microsoft, or Google apps and content). Every company’s privacy practice is different; when you leave our website or interact with third-party features/services, you should read such third party’s privacy policies and terms of service to understand how they may collect, use and share your information.

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INFORMATION WE COLLECT

We collect information from all our Account Holders to provide better GigSky Services. We collect information through:

• Information that you provide to us directly. When you register for an account via this website or the GigSky App and become an account holder, we collect account information, including contact information such as your name, email address, billing information, and country of residence. GigSky collects data from you, through our transactions and interactions with you and through your use of our Services, including when you reach out to our Customer Support and provide us with information related to your use of our Services.
• Information collected automatically from you and others through your use, experience, and interaction with our Services. When you use our Services, we automatically collect information, such as your device/equipment information, SIM card identifier, device model and operating system, server logs related to your usage of our Services, location information, unique user ID numbers.
• Message content. Messages you send and receive via the GigSky app are stored on your device. If a message cannot be sent (for instance, you are off-line), we may keep it on our services for up to 30 days as we try to deliver it but it will be deleted after that period.

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HOW WE USE YOUR INFORMATION

GigSky collects your information only insofar as we need it to provide you with our Services and for other legitimate business purposes. Any of the information GigSky collects from you may be used in the following ways:

• To process transactions and transaction related activities, such as billing.
• When you sign up for our mailing list on this website or through the GigSky app, we use your contact information to keep you posted on GigSky’s latest announcements, software updates, and future events or contests. If you no longer wish to be on our mailing list, feel free to opt out anytime by clicking on the ‘unsubscribe’ link at the bottom of the email.
• To help GigSky create, develop, operate, deliver, and improve GigSky products, services, content and advertising, and to prevent misconduct and for other anti-fraud purposes, such as verification of the account holder’s identity.
• For auditing, data analysis, and research to improve GigSky Services and for customer communications, such as responding to customer inquiries and requests.
• To send periodic emails to notify you of any changes in GigSky Services, including important notices, such as communications about purchases and changes to GigSky’s terms, conditions, and policies. This information is important to servicing the Account Holder, therefore, such communications may not be opted out.
• If you provide personal information in order to participate in GigSky events such as sweepstakes, contests, or similar promotions, the information provided may be used to administer such events.
• We collect your email address in order to send information, respond to inquiries, and/or other requests or questions, process orders and to send information and updates pertaining to orders and to send you additional information related to your product and/or service.

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GigSky only stores your information as long as permitted or required by law. If there is no applicable law or regulation requiring that we store your information, then GigSky will only store your information for a reasonable period to provide our Services or for other legitimate business purposes. Please refer to our Terms of Service (https://www.gigsky.com/terms-of-service/) for further details.

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DISCLOSURE TO THIRD PARTIES

We do not sell or rent your information to anyone. We will not disclose your information to unaffiliated third parties except as provided in this Privacy Policy.

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Trusted Third-Parties Who Are Acting on Our Behalf. GigSky may share your information with third parties who are our agents or service providers and others who assist us in operating the GigSky website, the GigSky App, in providing our Services, conducting our business, or servicing account holders, so long as those parties agree to keep this information confidential. These third parties will need your information in order to perform services that we had requested so that your Services function properly. Additionally, the activities that such agents and service providers may provide could include designing or upgrading our systems, features testing, tracking the performance of our Services, market research, collaboration to improve our Services, feedback management, and other related activities. However, non-personally identifiable information collected when you visit our website may be provided to other parties for marketing, advertising, or other uses.

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Partners Whose Service You Have Requested. Our Services may allow you to interact with our Partners’ products and services. In such cases, we will send you to their site so that you may provide them the information directly. Simply remember to visit their policies regarding privacy and service terms and conditions.

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Your Public Posting. As a part of GigSky community, you may be able to post your comments, reviews, feedbacks, suggestions or other content publicly, which may include your information. What is public is public, including information posted on GigSky’s social media pages, such as Facebook, Instagram, and others.

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Corporate Change. GigSky may disclose and transfer your information, both personal and non-personal, to a third party as a part of or in preparation for corporate change, such as a change in control, restructuring, or the sale/transfer of assets. Under such circumstances, GigSky will notify you either via email (using the email address for those with a GigSky account) or by notification clearly posted on our website.

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Government and Legal Purposes. GigSky may also disclose or release your information when GigSky believes such disclosure or release is appropriate to comply with any court order, law or legal process, including to respond to any government or regulatory request, to enforce our site policies, or to protect ours or others’ rights, property, or safety.

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Outside the EEA and Japan. GigSky is a United States of America business entity, therefore, we may need to transfer your information to other group companies or service providers in countries outside the EEA (European Economic Area) and, for our Japanese customers, outside of Japan. This may happen if our servers or suppliers and service providers are based outside the EEA (or Japan), or if you use our services and products while visiting countries outside your respective area, EEA or Japan. Your information resides in our servers located in the United States.

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With Your Express Consent. Aside from the above, there may be other limited situations where we share specific types of personal information but only with your express consent.

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COOKIES

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

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• Understand and save user’s preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

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You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you would like to know more, please consult the Help section of your browser or take a look at the About Cookies website (allaboutcookies.org) which offers guidance for all modern browsers.

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Not withstanding anything else in this policy, we and/or our partners may place or read use IP and/or cookies to enable you to receive personalized ads or content. These cookies contain zero personally identifiable information. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us on our network, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. Users may also express their choices for display advertising, through the following platforms: Digital Advertising Alliance opt-out platform or the Network Advertising Initiative opt-out platform. We and/or our partners use IP and/or cookies and web beacon technology to associate certain Internet-related information about you, such as your Internet Protocol address and certain online behaviors, such as opening emails or browsing websites or interacting with apps. Such information is used to personalize ads or content and may be shared with our network partners.

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We and/or our network partners may also use IP and/or cookies for delivering personalized advertising emails. These IPs and/or cookies are used to identify the visitors of our advertisers’ websites and for the advertiser to send personalized emails based on the visitors’ browsing experience on the advertiser’s site/app.

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GOOGLE ADWORDS

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en. We use Google AdWords on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

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We have implemented the following:

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• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration

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GigSky along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative (networkadvertising.org) opt out page or permanently using the Google Analytics Opt Out Browser add on (https://tools.google.com/dlpage/gaoptout).

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MINORS

GigSky Products and its Services are intended for those who are legally able to enter into a contract for our Services (generally, those who are 18 years or older). We do not knowingly collect information from children. Our Account Holders are required to have already purchased a GigSky Service to register for an account. Although our website can be visited anonymously, we do not target our website toward children and do not knowingly collect information from minors.

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DO NOT TRACK SIGNALS

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org.

GigSky does not track its account holders or website visitors over time and across third party websites to provide targeted advertising; so, we do not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal on it so that third parties (particularly advertisers) know you do not want to be tracked.

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CALIFORNIA RESIDENT PRIVACY NOTICE

This California Resident Privacy Notice applies to California residents and is adopted to comply with the California Consumer Protection Act of 2018 (“CCPA”).

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• Information We Collect. We collect information that identifies, relates to, describes, is capable of being associate with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (or “personal information,” as defined In the CCPA). We have collected the following categories of information in the past 12 months: Identifiers and personal information, including name, address, email address and similar identifiers, and Internet or similar network activity. As described above, we obtain this Information directly from you or indirectly from the sources and use it for the purposes described in this Privacy Policy. We do not collect other categories of personal information or use the Information we have collected for materially different, unrelated purposes without providing you with notice by posting such changes on this website or by notifying our account holders by email.

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• Your Rights and Choices. The CCPA provides California residents with specific rights concerning their personal information.

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• Access to Specific Information and Data Portability Rights
  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, we will disclose to you:

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• The categories of personal information we collected about you.

• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

• Deletion Request Rights
  You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete, if applicable) 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 providers to:

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• 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, 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 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.

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• Exercising Access, Data Portability, and Deletion Rights
  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by submitting a ticket with our Support. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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• 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.

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• Response Timing and Format. We endeavor to respond to a verifiable consumer request within 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 the registered email associated with the 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.

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• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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• Deny you use of our Services.
• Provide you a different level or quality of Services.

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• Contact Information: If you have any questions or comments about the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via our Support by submitting a ticket.

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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.

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YOU CAN HELP US

You can help ensure that your information is accurate, complete, and up to date by logging in to your account at www.gigsky.com or on your GigSky App. For other personal information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if GigSky is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by opening a ticket with us with our Support (quickest) or email our Compliance desk.

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UPDATES

GigSky reserves the right to change its Privacy Policy from time to time. We will post any updates to this Privacy Policy on GigSky’s website and GigSky App.

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If there are any questions regarding this Privacy Policy, you may visit our website (www.gigsky.com) or contact us by email: compliance@gigsky.com. For quick resolution of all other support and account issues, please visit our Support page and open a ticket.

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Thank you!

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