Effective Date: October 12, 2017

This Privacy Policy governs the manner in which 3Cinteractive Corp. and PrimeMessage by 3Cinteractive Corp. (hereinafter, “3Cinteractive”) at www.3c.com and http://sms.celltrust.com (collectively, the “Websites”) and our service at http://sb2.3cinteractive.com , 1tel.com, 2fon.net, txtcollect.com / textcollect.com, 3cinteractive.com, collect2phone.com, 4mvm.net / mobilevoicemessaging.com (the “Service”) collects, uses, maintains and discloses information collected from its customers, its client’s customers and users of its Website and the Service (each, a “User”). The purpose of this Privacy Policy is to inform you about what kinds of information we, at 3Cinteractive, may gather about you, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of the information.  Some features discussed below may not apply to all services products or in all locations. In general, individuals (also referred to as “you” or “your”) may visit our website without telling us who they are or disclosing information to us.

1.0 PURPOSE.

3Cinteractive’s business is in mobile communications. In the course of its business, we collect, transmit, record, store, and otherwise handle information about individuals (personally identifiable information or “PII”). We take these activities seriously and provide appropriate procedures for the handling of PII. This Statement provides information to our website visitors, customers, and individuals communicating with or through our customers (collectively “Consumers”) about how information is collected, transmitted, stored, or otherwise handled. Any information provided by Consumers or collected from individuals who use 3Cinteractive services/products is not sold or shared with unauthorized third parties, except in certain cases described below. Our customers may provide your PII to us for conducting their business and their use of your information is governed under their privacy policies/statements.

This Privacy Policy does not apply to the practices of companies that 3Cinteractive does not own or control, or to people that 3Cinteractive does not employ or manage. This includes any companies from whom you may have ordered services or products that are transmitted over 3Cinteractive’s mobile and/or other platforms, and any companies from whom you may be purchasing other services.

2.0 INFORMATION WE COLLECT.

3Cinteractive may collect various types of personal information including name, address, telephone number, billing information, email address, and other information that, either alone or in combination with other kinds of information, may personally identify Users. 3Cinteractive may collect personal information from Users in a variety of ways, including through online forms for ordering products and Services, and other instances where Users are invited to volunteer such information.

3Cinteractive only knowingly collects PII that is voluntarily provided by you. For example, you provide PII when registering for an account on 3Cinteractive’s website. PII provided by customers may include email addresses, phone numbers, payment card numbers, first and last name, and addresses. PLEASE NOTE THAT GIVEN THE STATE OF THE TECHNOLOGY, A TELEPHONE NUMBER USED IN THE PROVISION OF OUR SERVICES WITHOUT ANY ADDITIONAL IDENTIFYING INFORMATION IS NOT CONSIDERED PROTECTED PII.

The way we collect PII depends on our relationship with you. 3Cinteractive collects information from its customers as they use 3Cinteractive’s products and services and from individuals communicating with or through 3Cinteractive’s customers (“End Users”). 3Cinteractive also collects information from people who visit our websites (“Visitors”).

3.0 PASSIVE COLLECTION.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

While not all of the information that we collect from Users is personally identifiable, it may be associated with personal information that Users provide to us through our Website.

3Cinteractive is dedicated to protecting the PII it knowingly receives from End Users in a confidential and secure environment. When authorized third parties need to access PII, 3Cinteractive will provide the minimum amount of information required to complete the requested service or transaction.

If you register for an account on our website, your security relies on the strength and confidentiality of your password to your account. 3Cinteractive will never request that you send a password to us via email, but you will be required to enter your password when using certain products or services.

4.0 COLLECTED INFORMATION.

3Cinteractive collects information from its customers and customers’ End Users in the ordinary course of business. 3Cinteractive only collects information that customers and their End Users voluntarily disclose or provide to us and may include information that is made available from their devices as they use our products or services. Some of this information may include information in emails sent between us and customers or End Users, content of unsecured messages and voice communications sent through our services, secure messages and voice communications if hosted at our data center and provided with access permissions to such information, information related to support issues, information about customer devices (such as phone numbers, carriers, or device types), financial information provided by customers, and other information sent in the course of business.

Most of the personal information we collect is what you tell us about yourself. For example, certain of our products and services allow you to interact and share personal information and data with others. Except as otherwise set forth herein, you choose what you want to share and how you want to share it.

Sometimes, we record your phone number. We record your phone number when you send it to us; ask us to remember it; or make a call or send a text message or Short Message Service (SMS) to or from 3Cinteractive. If you ask us to remember your phone number, we will associate your phone number with your account identification number based on your device and hardware identification numbers; so if you change your device or hardware, you will have to re-associate this new device or hardware with your account before we can authenticate you.

Most of the other information we collect for mobile, such as your device and hardware identification numbers and device type, the request type, your carrier, your carrier user identification number, the content of your request, and basic usage stats about your device and use of 3Cinteractive’s products and services does not by itself identify you to 3Cinteractive, though it may be unique or consist of or contain information that you consider personal.

Some information may be automatically collected from Visitors, such as the name of the domain and host used to access the Internet, including the Internet Protocol (IP) address; the date and time you access the website, the length of stay and the specific pages, images or forms accessed when visiting the website; the Internet Address of the website from which you linked directly to our website, and, if applicable, the search engine that referred you; any search strings or phrases that you entered into that search engine; demographic information concerning the country of origin of your computer and the language(s) used. We use this information to monitor usage of our website, assess its performance, ensure technological compatibility with the computer used, and to understand the importance of the information provided on our website. We may also conduct statistical analyses on your usage patterns and other aggregated data.

If you use location-enabled products and services (or Location-Based Services, also known as LBS), you may be sending us location information. This information may reveal your actual location, such as Global Positioning Satellite (GPS) data, or it may not, such as when you submit a partial address to look at a map of the area.

When you use your mobile browser or enable other data services, we collect your location information. We use that information to provide you with any Location-Based Services that you have requested. We may also use your location information to create aggregate data from which your personal information has been removed or obscured.

We retain location information for no longer than one (1) year. Except as otherwise set forth herein or as legally required, we will not disclose your location information to third parties without your consent. You should carefully review the privacy policies of third parties with whom you have authorized the sharing of your location information, and you should understand the risks involved in disclosing your location information to friends or other people you may not know.

Certain of our products and services allow you to download and/or personalize the content you receive from us. For these products and services, we will record information about your downloads and preferences, along with any information you provide yourself.

For products and services with voice recognition capabilities (such as Interactive Voice Response, or IVR), we collect and store a copy of the voice commands you make to the product or service. To improve processing of your voice commands, we may also continuously record in temporary memory a few seconds of ambient background noise. This recording stays only temporarily on the device and is not sent to 3Cinteractive.

FOR END USERS UTILIZING 3CINTERACTIVE’S SERVICES, PLEASE NOTE THAT THE INFORMATION SENT MAY BE STORED, ACCESSED, AND USED BY THE 3CINTERACTIVE CUSTOMER UNDER THE TERMS OF THE APPLICABLE PRIVACY POLICY OF SUCH CUSTOMER TO WHICH YOU CONNECT FOR SERVICES. IF YOU CONNECT TO A 3CINTERACTIVE HOSTED AND ADMINISTERED SERVER AND UNLESS OTHERWISE PROVIDED FOR UNDER A SEPARATE WRITTEN PRIVACY POLICY, THE TERMS OF THIS STATEMENT WILL GOVERN; PLEASE CONTACT THE PARTY THROUGH WHICH YOU USE THE SERVICES FOR INFORMATION ON THE APPLICABLE PRIVACY POLICY TERMS. IF YOU CONNECT TO A SERVICE HOSTED AND/OR ADMINISTERED BY ANOTHER PARTY SUCH AS A 3CINTERACTIVE CUSTOMER OR VENDOR, YOU MUST CONTACT SUCH PARTY FOR THE APPLICABLE PRIVACY POLICY. THE 3CINTERACTIVE CUSTOMER OR OTHER THIRD PARTY ADMINISTERING YOUR SERVICES IS SOLELY RESPONSIBLE FOR ALL REQUIRED COMPLIANCY AND NOTICE REQUIREMENTS RELATED TO PRIVACY RECORDS AND AUDIT PRACTICES FOR YOUR USE. IF FURTHER GUIDANCE IS NEEDED AS TO THE PRIVACY POLICY APPLICABLE TO YOUR USE, PLEASE CONTACT 3CINTERACTIVE OR THE PARTY THROUGH WHICH YOU ARE ACCESSING THE SERVICES.

FOR USERS UTILIZING THE 3CINTERACTIVE SWITCHBLADE PLATFORM OR A STANDARD SMS SOLUTION, PLEASE NOTE THAT WHEN SUCH MESSAGES ARE TRANSMITTED, THEY ARE EXPOSED TO THIRD PARTY VENDORS SUCH AS CARRIERS, WHOSE SERVICES ARE NECESSARY TO SEND THESE MESSAGES. YOU ACKNOWLEDGE THAT THESE THIRD PARTY VENDORS ARE NOT WITHIN OUR CONTROL, AND, AS SUCH, THERE MAY BE LIMITED (IF ANY) PRIVACY WITH THESE MESSAGES.

5.0 MINORS PRIVACY.

At 3Cinteractive, we do not intend to collect information from children under the age of 13 (or the applicable legal age in your location). If 3Cinteractive discovers that a child under the age of 13 submits PII to 3Cinteractive, we will delete such information and we will not use such information for any other purpose. 3Cinteractive encourages parents to take an active role in their children’s use of the Internet and cellular telephones and to inform them of the dangers of providing Information about themselves on the Internet or through cellular telephones.  3Cinteractive is committed to safeguarding the information Users entrust to 3Cinteractive. This Website is not directed at children under thirteen (13) years of age. Accepting party should be at least thirteen (13) years of age.

6.0 CALL RECORDS.

Calls are recorded and may be monitored in accordance with company policy and required laws. Except as otherwise set forth herein, 3Cinteractive does not sell or share information with external parties for the purposes of marketing.

7.0 TRACKING TECHNOLOGIES.

3Cinteractive and our partners use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

A “cookie” is a tiny text file that is stored on Users’s devices to customize your experience and support some necessary functions, either temporarily for that session or more persistently for repeat visits. 3Cinteractive uses cookies to better understand how Users use our website. Our cookies collect no PII and are not shared or intentionally revealed to other websites. 3Cinteractive does not look for or at other websites’ cookies on a Visitor’s computer. You have choices with respect to cookies. Visitors can modify their browser preferences, to accept all cookies, be notified when a cookie is set, or reject all cookies. If you choose to reject all cookies, you will be unable to use the services or engage in the activities that require cookies. Accepting a cookie does not give us access to your computer or PII other than the personal data you choose to share with us.

We also may from time to time engage third parties to track and analyze statistical information from visitors to our Website to help us administer our Website and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual Website visitors to any personal information. Except as otherwise set forth herein, all data collected by such third parties on our behalf is used only to provide us with information on Website usage and is not shared with any other third parties.

We partner with a third party(ies) to either display advertising on our Website or to manage our advertising on other sites. Our third party partner(s) may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt-out of interest-based advertising click http://preferences-mgr.truste.com/ (or if located in the European Union click http://www.youronlinechoices.eu/). Please note you will continue to receive generic ads.

8.0 HOW WE USE INFORMATION.

3Cinteractive may use personal information collected through our Website or other means to contact Users regarding products and services offered by 3Cinteractive and its trusted affiliates, independent contractors, business partners and clients, and otherwise to enhance Users’ experience with 3Cinteractive and such affiliates, independent contractors, business partners and clients. 3Cinteractive may also use information collected through our Website or other means for research regarding the effectiveness of the Website and the marketing, advertising and sales efforts of 3Cinteractive, its trusted affiliates, independent contractors, business partners and clients. Because 3Cinteractive is a global company, we may share your information with other 3Cinteractive affiliates, business units, clients or contractors in other parts of the world, who will maintain the privacy of your information in accordance with this Privacy Policy.

3Cinteractive may also use information for fulfillment of User requests, to contact Users or for reporting purposes. We limit access to your personal information to employees, clients and contractors who we believe need access in order to provide services to you or to do their jobs. You should know that your personal information may be transferred from your home country to employees, clients and contractors in other areas of the world, who may communicate with you regarding your inquiry.

We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no computer system is completely secure, we believe the measures implemented by our Website reduce the likelihood of security problems to a level appropriate to the type of data involved.

9.0 INFORMATION COLLECTED FOR OUR CUSTOMERS.

This “Information Collected for Our Customers” section shall apply solely to the extent your information collected by 3Cinteractive is not collected pursuant to the “User Access and Choice” section immediately below.

Except as otherwise set forth herein, the use of information collected through our service shall be limited to the purpose of providing the service for which 3Cinteractive’s clients have engaged us.  3Cinteractive collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes. 3Cinteractive works with its clients to help them provide notice to their customers concerning the purpose for which personal information is collected.

We collect information for our clients; if you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly. If you are a client and would like to update your account please contact our Customer Support at info@3c.com or by telephone or postal mail at the contact information listed below.

3Cinteractive may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Privacy Policy regarding notice and choice and the service agreements with our clients.

3Cinteractive acknowledges that you have the right to access your personal information. 3Cinteractive has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to 3Cinteractive’s client (the data controller). If the client requests 3Cinteractive to remove the data, we will respond to their request within a reasonable timeframe.

3Cinteractive will retain and use personal data we process on behalf of our clients for as long as needed to provide services to our client. 3Cinteractive will also retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

10.0 CONSENT

By using 3Cinteractive’s website and services, you understand and consent to the collection, processing, and use of information for the purposes and in the manner set forth under this Statement.

11.0 USER ACCESS AND CHOICE.

This “User Access and Choice” section shall apply solely to the extent your information collected by 3Cinteractive is not collected pursuant to the “Information Collected for Our Customers” section above.

Upon request, 3Cinteractive will provide you with information whether we hold any of your personal information. If your personal information changes, or if you no longer desire our service, you may correct, update, amend or ask to have it removed by emailing our Customer Support at info@3c.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within a reasonable timeframe.

We will retain and use your information for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may sign-up to receive email or newsletter or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at info@3C.com.

12.0 DO NOT CONTACT.

3Cinteractive provides you the opportunity to opt-out of receiving electronic communications from either 3Cinteractive or our customers. If you do not want to receive communications from us, please contact us at info@3c.com, or if you are being contacted through a customer, please follow the instructions in the communication itself or contact the customer directly. You may also use the convenient opt-out feature included with emails.

Keep in mind, this opt-out does not apply to necessary communications, such as responding to an inquiry, and may be revoked if you later request information from us. Additionally, if you have various contact options that are not linked to your PII or account, we may not be able to identify which options link to you. Please provide the information necessary to honor your request as fully as possible. 

13.0 DISCLOSURE OF INFORMATION.

3Cinteractive may disclose information collected from Users to trusted affiliates, independent contractors, business partners and clients who will use the information for the purposes outlined above. We may also disclose aggregate data based on information collected from Users to investors, potential partners and clients.

We may also disclose personal information about you if we believe that doing so is legally required or is necessary to protect our property or other legal rights (including but not limited to enforcement of our agreements or the rights of property of others).

Subject to the terms of our agreements with customers, we may partner with other businesses to assist us in our marketing, communications, and sales efforts, and may share information about you for these purposes. These partners are not allowed to use your information for any purpose other than doing business with 3Cinteractive.

In addition, subject to the terms of our agreements with customers, PII may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy or receivership in which PII could be transferred to third parties as one of our business assets.

Further, what we do with information gathered from and about you depends on your relationship with us. In general, if we obtain your information solely because an End User communicates information about you within the Services, then our sole uses for your information are to fulfill the customer’s purposes. We do not use this information for our own purposes. However, unless limited by law or contract, we may use your information:

  • 13.1 To provide you with information about products, services, news, and events;
  • 13.2 To allow you to use, purchase, and/or download products and services;
  • 13.3 To analyze use of our services and products, develop new services and products, and customize our products, services, and other information we make available;
  • 13.4 We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us. We will share your personal information with third parties only in the ways that are described in this Privacy Policy;
  • 13.5 As required by law, such as to comply with a subpoena, bankruptcy proceedings or similar legal process;
  • 13.6 When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • 13.7 If 3Cinteractive is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information; and
  • 13.8 To any other third party with your prior consent to do so.

14.0 SECURITY

The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

15.0 ADDITIONAL PRIVACY INFORMATION.

15.1 Links to 3rd Party Websites.

Our Website includes links to other websites whose privacy practices may differ from those of 3Cinteractive. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

When you click on links on 3Cinteractive’s website to third-party websites, you will be subject to such third parties’ privacy policies or statements. 3CINTERACTIVE IS NOT BE RESPONSIBLE FOR THIRD-PARTY WEBSITES OR THEIR CONTENT OR ACTIONS. 3Cinteractive encourages you to read the posted privacy statement or policy of any and every website visited.

Also, you may have the opportunity to share your information through other websites, such as social media sites. We may provide a convenient link to let you do this easily, but we cannot control their website or your posts/sharing

15.2 Changes To This Privacy Policy.

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this Website for the latest information on our privacy practices.

15.3 3Cinteractive Blog.

Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@3c.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.

15.4 Social Media Widgets.

Our Website includes social media widgets, such as the share this button or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets 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 company providing it.

16.0 EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD.

3Cinteractive participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. 3Cinteractive is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

3Cinteractive is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. 3Cinteractive complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, 3Cinteractive is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and/or the U.S. Department of Transportation, as applicable. In certain situations, 3Cinteractive may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

17.0 UPDATES

3Cinteractive may in its sole discretion, update this Statement at any time and will post any amended Statement on its website. Users should visit this page regularly, especially prior to providing any PII.

18.0 FICTITIOUS NAMES.

EXCEPT AS TO REFERENCES TO 3CINTERACTIVE’S CURRENT TEAM MEMBERS, ANY PII, INCLUDING NAMES AND PHONE NUMBERS AND PHOTOS, DISPLAYED ON 3CINTERACTIVE’S WEBSITE ARE FICTITIOUS AND MERELY FOR ILLUSTRATIVE PURPOSES. ANY RESEMBLANCE OR SIMILARITY TO AN ACTUAL INDIVIDUAL IS MERELY COINCIDENTAL.

19.0 LINKS TO OTHER WEBSITES.

When you click on links on 3Cinteractive’s website to third-party websites, you will be subject to such third parties’ privacy policies or statements. 3CINTERACTIVE IS NOT BE RESPONSIBLE FOR THIRD-PARTY WEBSITES OR THEIR CONTENT OR ACTIONS. 3Cinteractive encourages you to read the posted privacy statement or policy of any and every website visited.

Also, you may have the opportunity to share your information through other websites, such as social media sites. We may provide a convenient link to let you do this easily, but we cannot control their website or your posts/sharing.

20.0 AGREEMENT

By using our website and services, you agree to be bound the terms and conditions of this Statement.

21.0 CONTACT US.

If you have questions or concerns about our policies concerning privacy, data collection, data processing or data transmission, please email us at info@3c.com or call us at (561) 443-5505 or mail us at 750 Park of Commerce Boulevard, Suite 400, Boca Raton, FL 33487.

 

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