Privacy Notice – Wireless Analytics

Effective: January 1, 2020

This Privacy Notice explains how Wireless Analytics, LLC (“Wireless Analytics” or “we”) collects, processes, uses, shares, and handles information about Users of the Wireless Analytics website, mobile app, mobile communications management, and other services (collectively, “Services”).  Users may include employees or contractors of companies that use the Services to manage their employees’ mobile devices or wireless services.  By visiting this Site or using any Wireless Analytics Service, Users accept the practices described in this Privacy Notice and consents to the collection, use and disclosure of information described in this Privacy Notice.

As Wireless Analytics evolves, we may update this Privacy Notice to reflect changes in the manner in which we deal with personal information, whether to comply with then applicable regulations and self-regulatory standards or otherwise. The Privacy Notice posted here will always be current. We encourage you to review this statement regularly. If we make a material change to the Privacy Policy, we will notify you via e-mail at your most recent e-mail address on record and/or post a notice of the change on our website.

This Privacy Notice does not limit collection, use, sharing, or handling by Wireless Analytics of aggregated, de-identified, or anonymized information, provided that the information cannot be associated with an individual.

Information Collected

We may collect your personal information in the following ways:

Information You or Your Employer Provide: We collect information that you or your employer provide to us. If you or your employer refuse to provide any requested information (whether or not required), you may not be able to take full advantage of the Services. The information that we collect from you or your employer includes, but is not limited to:

  • Name
  • Job Title
  • Employee Identification Number
  • Email addresses
  • Phone numbers
  • Home/office addresses

Information from Third Parties: We may also collect information about you from third parties, such as telecommunications service carriers. We may associate or combine the information you provide through the Services with this information collected from third parties. To deliver our Services, we collect information from telecommunications providers including billing and usage details, asset information, and call detail records.

Mobile Device Management details: We may collect asset information from clients’ mobile device management tools.  Asset information includes but is not limited to the make and model of devices and unique identifiers such as make and model, IMEI, ESN, and serial number.

Social Media:  We may use different social media websites and applications to interact with you.

Information Automatically Collected: When you use or your employer use the Services, the server may automatically recognize you by a “cookie” or other tracking technology. These technologies act as unique identifiers and allow us to tailor the Services to your specified interests and keep track of your activity on our Sites. This information may be added to your user profile and used to deliver offers and advertisements that we believe are relevant to your interests.

Furthermore, we may retrieve certain information from your browser (e.g., browser type, referrer URL, date and time of your visit, IP address) and device (e.g., MAC address, device type, screen resolution, and OS version). We use this information to monitor the performance of our Sites or Services, analyze traffic patterns and usage, ensure that the Services and any related transactions function properly, and that they gather demographic information about our user base as a whole. This information also may be appended to your user profile so that we may further tailor the Services to your interests and send you offers based on such information.

Tracking Options and California Do Not Track Disclosures: Certain parts of our Sites require cookies, and we may use them to deliver more relevant advertising and to link data collected across other devices you use. You can adjust your settings to limit tracking or decline cookies, but as a result you may not be able to use certain features of the Services or take full advantage of all of our offerings. Please refer to your device or browser settings for more information on how to delete or decline cookies and control your tracking preferences. The Sites do not respond to do not track signals from most browsers.

Information Use

We may use your information to:

  • Provide you or your employer with Services, such as product and service delivery, customer service, account management, support and training and to provide other services related to an account;
  • For the purpose for which the information was submitted;
  • Email you and your employer a monthly summary of your corporate mobile usage and charges;
  • Respond to inquiries from you or your employer;
  • Provide you or your employer with marketing communications and offers for products and services from us and, in some cases, our partners, including offers based on your interests, business characteristics and location;
  • Administer surveys and other promotional events;
  • Determine if you or your employer are eligible for certain products, services or offers;
  • Provide you or your employer with additional information that may be of interest, such as Wireless Analytics news and announcements and technical service bulletins; and
  • Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance;
  • Provide, maintain and improve customer service;
  • Tailor your experience with services that correspond with your interests;
  • Develop new products and enhance and improve our Services and business; or
  • As otherwise consented to by you.

In addition, we may aggregate your information with our other users’ information and use that information for benchmarking and analysis purposes.

Information Sharing

We may share your information:

  • with any of our parent companies, subsidiaries, joint ventures, or companies under common control with us;
  • with your employer, if they are a company that uses our Services;
  • with telecommunications carriers, who provide information for our mobile management services;
  • with our third-party service providers who provide services like payment processing, IT, advertising of Wireless Analytics services, and data analysis;
  • in the event of a sale, merger, reorganization, asset sale, dissolution transfer of all or part of our business (including in connection with any bankruptcy proceeding), or similar events;
  • to comply with legal process;
  • to respond to lawful requests from authorities, including public and government authorities outside your country of residence, and including to meet national security or law enforcement requirements;
  • to enforce our terms and this Privacy Notice;
  • to protect our business and the rights, privacy, safety, or property of us and others;
  • as otherwise necessary under applicable law, including laws outside your country of residence; or
  • as otherwise consented to by the data subject.


Other Websites

This Site may contain links to third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such third-party websites. These third-party websites have separate privacy practices; we have no responsibility or liability relating to such practices; and such practices govern your use of these websites.

Security

We take commercially reasonable steps to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, and you understand that email or other communications over the Internet are not secure and may be intercepted while being transmitted to and from us over the Internet, by WiFi, or other means. If you have reason to believe that your interaction with us is no longer secure please immediately notify us using the contact information in this policy.

Children

We do not knowingly collect, use, or share the personal information of children under age 16, and our Sites and Services are not directed to individuals under 16. If we are made aware that we have collected personal information from an individual under age 16, we will delete this information as soon as possible.

Marketing Choices

Marketing Emails: To stop receiving marketing e-mails from us, please follow the instructions to unsubscribe. Even if you unsubscribe, we may still send you administrative (i.e., non-marketing) messages. To unsubscribe from a third party’s communications, contact that third party directly or follow the instructions to unsubscribe in the applicable marketing e-mail.

Targeted Advertising: We may participate in targeted advertising of Wireless Analytics products and services. This means that, for example, when you visit our website, we or third-party service providers may use cookies (that they collect or that we provide to them) or other similar technologies to collect information about your use of our website or your online activities over time and across different websites. As you visit our website, cookies will be placed on your computer and information will be collected so that we can understand what you are interested in. Collected information may include the content you view, the date and time that you view this content, the time you spent viewing this content, and the website that referred you to our website. This information may be associated with your unique browser, device identifier, or Internet Protocol address. These practices help our display advertising partners, AdRoll and Google Ads, to tailor advertisements that are relevant and useful to you.  We only use targeted advertising for Wireless Analytics products and services; this information is not used to advertise the products or services of other companies.

You can visit the AdRoll cookie opt-out page and Google Ads personalization page to opt-out of certain targeted advertising. You can also opt-out of targeted advertising by modifying your browser settings or by using a browser plug-in.  For more information about targeted advertising and your choices, visit AdChoices.

Operation of Our Sites and Services

Wireless Analytics is headquartered in the United States and, regardless of where you use our Services or otherwise provide information to us, your information may be transferred to, maintained, and processed by Wireless Analytics and our service providers in the United States or other jurisdictions in which we or they operate. Please note that privacy laws, regulations, and standards in the jurisdictions in which your information may be maintained and processed may not be equivalent to the laws in your country of residence and such information may be subject to lawful access by U.S. or other foreign courts, law enforcement, and governmental authorities.

EU-U.S. Privacy Shield

Wireless Analytics, LLC has certified its compliance with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Wireless Analytics, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Swiss-U.S. Privacy Shield

Wireless Analytics, LLC complies with the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland to the United States. Wireless Analytics, LLC has certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view Wireless Analytics LLC’s certification, please visit: https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Wireless Analytics, LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Notice should first contact Wireless Analytics, LLC at: privacy@wirelessanalytics.com

Wireless Analytics, LLC has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (“AAA”), i.e. International Centre for Dispute Resolution (“ICDR”), a U.S. based alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org for more information or to file a complaint. The services of the American Arbitration Association are provided at no cost to you.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Wireless Analytics, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Wireless Analytics, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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

Your California Privacy Rights

On January 1, 2020, the California Consumer Privacy Act (CCPA) went into effect.  The law requires companies to notify California residents about how their data is collected, used, and shared, and in some cases gives them rights to access and delete that data.  This section provides Wireless Analytics’ disclosures as required by the CCPA.  These disclosures supplement and incorporate the statements in the other portions of the Privacy Notice.  This section applies to all visitors, users, and others who reside in the State of California.

Information We May Collect

Wireless Analytics collects User information from Users and Clients in order to administer and provide Wireless Analytics Services to Wireless Analytics Clients and Users and for the other purposes identified in this Privacy Notice. We may collect the following categories of information, as defined in the CCPA.  The examples listed are only illustrative of potential types of data within each category, and Wireless Analytics does not necessarily collect that data about every individual.

 

Category Examples Collected
Identifiers Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers Yes
Categories of personal information described in Cal. Civ. Code 1798.80(e) Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information Yes
Characteristics of protected classifications under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Yes
Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information No
Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. Yes
Geolocation data Physical location or movements No
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information No
Professional or employment-related information Current or past job history or performance evaluations Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No
Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No

 

Sources of California Personal Information

We obtain the above categories of personal information from the following categories of sources:

  • Directly from you: For instance, you may provide us with information when signing up for an account
  • Indirectly from you: For example, we may observe your interactions on our website
  • From third parties: For example, your employer may provide us with information related to the services that we provide.
  • From publicly available information

Use of California Personal Information

We may use any of the above categories of collected User information to provide services requested from Users or Clients, maintain and improve our services, communicate with Users and Clients about Wireless Analytics Services and affiliated third-party services, market Wireless Analytics Services, prevent potentially illegal activities, protect the rights and property of Wireless Analytics, respond to inquiries of Wireless Analytics Clients and Users, and for any other purpose to which the User has consented. Our use and disclosure of California Personal Information is more fully described above, in the section entitled “How We Use This Information”.

Sharing California Personal Information

We may disclose your personal information to your employer or to another third party, as more fully described in the section above entitled “Sharing Information).  The vast majority of data that Wireless Analytics collects and discloses to its clients is in its capacity as a service provider, as defined by CCPA.  Accordingly, Wireless Analytics does not “sell” CCPA-covered personal information.

In the past 12 months, Wireless Analytics has disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Categories of personal information described in Cal. Civ. Code 1798.80(e)
  • Characteristics of protected classifications under California or federal law
  • Commercial Information
  • Internet or other electronic network activity information

In the past 12 months Wireless Analytics has disclosed personal information to the following categories of third parties:

  • Clients (i.e., the users’ employers)
  • Service providers

Your rights under the CCPA

The vast majority of the personal information that Wireless Analytics collects is related to employees, as part of a service that we provide via their employers.  Most of the rights provided under the CCPA do not currently apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.  The CCPA also currently exempts personal information reflecting a written or verbal business-to-business communication from many of its requirements.

Moreover, Wireless Analytics typically acts as a service provider to its Clients, which are typically employers.  The Clients solely determine the purposes and means of processing Clients’ personal information.  To the extent that Wireless Analytics collects or processes CCPA-covered personal information in its capacity as a service provider, requests for access to CCPA-covered data and deletion must be directed to the Wireless Analytics Client.  For instance, if you want to access or delete data collected via Wireless Analytics, you must contact your employer, which will then work with Wireless Analytics to process your request.

In the rare instance that the CCPA rights apply to the personal information and Wireless Analytics does not collect or process data in its capacity as a service provider, you have the following rights:

  • Access to Personal Information Collected or Sold and Data Portability: 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 (see “Exercising Your Rights” section), we will disclose to you:
    • The categories of personal information we collected about you;
    • The categories of sources for the 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;
    • If we disclosed your personal information for a business purpose, a separate list disclosing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Deletion of Personal Information: You have the right to request deletion of personal information. If you wish to do so, please contact us at any method listed below. The right to deletion is subject to certain exceptions, such as if we need the personal information to provide Services or comply with legal obligation.
  • No Discrimination: You will not be subject to discrimination for exercising any of your privacy rights.

To exercise any applicable access, data portability, and deletion rights, please submit a verifiable consumer request by: sending an email to privacy@wirelessanalytics.com, calling toll-free +1 (866) 618-5646, or sending mail to Wireless Analytics, LLC 230 North Street, Danvers, MA 01923.

Only you, or someone legally authorized 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:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • Your name
    • Address
    • Additional information depending upon the type of request and the sensitivity of the information.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing. 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.

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.

You may designate an authorized agent to make a request under the CCPA on your behalf.

The California Shine the Light Law, Cal. Civ. Code Section 1798.83, requires companies to disclose certain information about information shared with third parties that is used for the third parties’ direct marketing purposes.  These disclosure requirements only apply if Wireless Analytics were to share personal information with third parties for the third parties to market their own services and products directly to consumers.  If you are a California resident, you may request information about the disclosure of your personal information to third parties for the third parties’ direct marketing purposes by sending an email to privacy@wirelessanalytics.com, calling toll-free +1 (866) 618-5646, or sending mail to Wireless Analytics, LLC 230 North Street, Danvers, MA 01923.

Contact Us

If you think that any personal information we have collected from or about you is inaccurate, you may notify us in writing at the address provided below. We will investigate your request and make appropriate changes as needed.

Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice.  You can always reach us online at privacy@wirelessanalytics.com

You can also reach us via mail at:

Wireless Analytics, LLC

230 North Street

Danvers, MA 01923 USA

You can reach us by phone, toll-free, at +1 (866) 618-5646.