PRIVACY AND SECURITY STATEMENT
This Privacy and Security Statement (the “Statement”) describes the types of information that Xchange Telecom LLC may collect from you or that you may provide to us when you access and use, including any content, functionality and services offered on or through, www.skywirenetworks.com (the “Website”) whether as a guest visitor or a registered user, and also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. This Statement applies to information we collect: (i) on this Website; (ii) in email, text, and other electronic messages between you and this Website; (iii) through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website; and (iv) when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website. This Statement does not apply to information collected by: (a) us offline or through any other means, including on any other website operated by Skywire or any third party; or (b) any third party, including through any application or content (including advertising) that may link to or be accessible from Website. All references in this Statement to “Skywire Networks”, “Skywire”, “we”, “us”, “our” and all similar terms will mean Xchange Telecom LLC. By using or accessing the Website, you agree to be bound by this Statement. Skywire may modify this Statement at any time and any such modification will be effective upon its publication. You are solely responsible for monitoring this Website for such modifications. If you do not agree to be bound by this Statement, then you must immediately stop using the Website.
INFORMATION YOU PROVIDE TO US
To access and use this Website, you may be required to provided certain personal identifiable information, such as name, postal address, email address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“personal information”). The information we collect on or through our Website may include: (i) information that you provide by filling in forms on our Website; (ii) records and copies of your correspondence (including email addresses), if you contact us; (iii) your responses to surveys that we might ask you to complete for research purposes; (iv) details of transactions you carry out through our Website and of the fulfillment of your orders, including financial information; (v) your search queries on the Website; (vi) that is about you but individually does not identify you; and (vii) from third parties, such as our business partners. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and (ii) information about your computer and internet connection, including your IP address, operating system, browser type, and equipment that you use to access our Website.
The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our Website according to your individual interests; (iii) speed up your searches; and (iv) recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies.Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons.Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Skywire, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information: (i) to present our Website and its contents to you; (ii) to provide you with information, products, or services that you request from us; (iii) to fulfill any other purpose for which you provide it; (iv) to provide you with notices about your account, including expiration and renewal notices; (v) to carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection; (vi) to notify you about changes to our Website or any products or services we offer or provide though it; (vii) to allow you to participate in interactive features on our Website; (viii) in any other way we may describe when you provide the information; and (ix) for any other purpose with your consent. We may also use your information to contact you about our own and third parties’ products and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Statement: (i) to our subsidiaries and affiliates; (ii) to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; (iii) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Skywire’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Skywire about our Website users is among the assets transferred; (iv) to third parties to market their products or services to you if you have consented to these disclosures; (v) to fulfill the purpose for which you provide it; (vi) for any other purpose disclosed by us when you provide the information; and (vii) with your consent.
We may also disclose your personal information: (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (ii) to enforce or apply our contractual rights or other Skywire policies and other agreements, including for billing and collection purposes; and (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Skywire, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We have created mechanisms to provide you with the following control over your personal information:
- Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising.If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data.
- Promotional Offers.If you do not wish to have your contact information used by Skywire to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data. If we have sent you a promotional email, the you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to Skywire as a result of a product purchase, warranty registration, product service experience, or other transactions.
- Targeted Advertising.If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, then you can opt-out by checking the relevant box located on the form on which we collect your data.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at: https://thenai.org/opt-out. California residents may have additional personal information rights and choices. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to the designated address below. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://www.oag.ca.gov/privacy/ccpa. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our app that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address below.
CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, then do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us as detailed below. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.
CPNI POLICY
Customer proprietary network information (“CPNI”) is information that relates to the quantity, technical configuration, types, destination, location, amount of use, and billing information of your telecommunications services with Skywire. Federal law governs our use and sharing of your CPNI, and you can limit the sharing of your CPNI if you do not want us to use it to market services to you that are different than those you are currently receiving. For more information about our CPNI Policy, please contact us at the address below.
DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and CPNI will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website, such as message boards. The information you share in public areas may be viewed by any user of the Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
CONTRACT INFORMATION
Questions, comments or requests about this Statement may be sent to: Skywire Networks, 148 39th Street, Suite A12, Brooklyn, New York 11232 or Legal@Skywirenetworks.com. For active security incidents, please immediately contact Skywire’s Network Operations Center at (844) 759 – 9473 at any time.