Effective September 1, 2019
BraveHeart Wireless, Inc. (“BraveHeart”, “we”, “us” or “our”) is committed to protecting the privacy of the users of our products and services (collectively, the “Service”).
We do not share information obtained from users through our Web Sites or Services with third parties except as otherwise provided in this Policy. We do not share, sell, rent or trade personally identifiable information with third parties for their promotional purposes. By purchasing, subscribing to, or using the Services or using BraveHeart Web Sites, you agree to the terms and conditions set forth in this Policy. For other terms and conditions that govern your use of the Services and its website, please review our Terms of Service.
I. Information we collect and use
1. In order to use some of our Services, you will first complete the registration process. During registration you are required to provide personal information (such as, but not limited to, name, third party account passwords, phone numbers, email addresses, and contacts). We use this information to offer Service and to contact you about the Services and other services offered by BraveHeart for which you have expressed interest or that you might be interested in.
2.Certain BraveHeart services store, process and maintain your voicemail messages, recorded voice notes, contact lists and other data related to your account in order to provide the service to you.
3. When you use the Service, the Service’s servers automatically record certain information about your use of the Service. Similar to other web services, the Service records information such as account activity (including storage usage, number of log-ins), data displayed or clicked on (including UI elements, ads, links), other log information (including browser type, IP-address, date and time of access, cookie ID, and referrer URL) and telephony log information (including calling-party number, forwarding numbers, time and date of calls, duration of calls, and types of calls). This information is collected to provide our users with secure communication and to collect statistics to improve service.
A cookie is a small text file stored on the user’s computer tied to information about the user. These files identify your computer and record your preferences and other data about your visit to a website so that when you return to that site, the site operator knows who you are and can personalize and enhance your visit. Usage of a cookie is not linked to any personally identifiable information while on the Web Sites except if you choose to store your user name and password so that you do not have to enter it each time you access your account.
c. Log Files
Like most websites, our servers automatically record information given by browsers and the phone systems, such as Caller ID and IP addresses. These log files are not linked to personally identifiable information.
d. Clear Gifs
Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and we may use them, on some of our Web Sites, to track the online movements of our users. Clear gifs are invisible on the page and are much smaller than cookies, about the size of the period at the end of this sentence. Clear gifs are not tied to users’ personally identifiable information. We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of receiving these emails, please email us at email@example.com.
e. Affiliated Sites
BraveHeart may offer services in connection with other websites or third parties and may link to other websites. To the extent that we receive data from these third parties, BraveHeart will treat that data in accordance with this Policy. The affiliated sites may have different privacy practices that may differ from those of BraveHeart. If you submit personal information on any of these sites, your information is subject to their privacy policies. We encourage you to carefully read the privacy statement of any website you visit.
We may store information that we collect through cookies, log files and clear gifs to create a profile of our users. A profile is stored information that we keep on individual users that detail their Services usage. Third parties may also furnish us with additional information about your preferences. We do not share personally identifiable elements of your profile with third parties.
g. Children’s Privacy
We do not knowingly collect personal information from children under the age of 13. If we learn that we have personal information of a child under the age of 13, we will delete that information from our systems.
For tips on protecting children’s privacy online, please the FTC’s web site(http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm).
h. Customer Surveys
BraveHeart may ask you to participate in our surveys to help us improve our Services. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. Any personal information collected from you will only be used for internal purposes by BraveHeart unless otherwise explained in the instructions.
i. Customer Proprietary Network Information (“CPNI”)
In the normal course of providing telecommunications and interconnected voice-over-Internet-protocol (“interconnected VoIP”) services to its users and customers, BraveHeart collects and maintains certain customer proprietary network information (“CPNI”). Your CPNI includes the types of telecommunications and interconnected VoIP services you currently purchase or subscribe to, how you use those services (for example, your calling records), and billing information related to those services. Your BraveHeart telephone number, name, and address do not constitute CPNI.
BraveHeart does not sell, trade, or otherwise share your CPNI with anyone outside of BraveHeart or with anyone who is not authorized to represent us to offer our services or to perform functions on our behalf except as the law may require or you may authorize.
Federal law generally permits us to use CPNI in our provision of telecommunications and interconnected VoIP services you purchase or subscribe to, including billing and collections for those services. We are permitted to use or disclose CPNI to offer communications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as to respond to a court order, to investigate fraud, to protect our rights or property, to protect against the unlawful use of our services, or to protect other users.
If you choose to restrict access to your CPNI for our own marketing purposes, please contact us. By restricting our use of your CPNI, you will not affect our provision of any service, nor will you necessarily eliminate all types of BraveHeart marketing.
j. Product Updates, Newsletters, Service Announcements
BraveHeart sends out periodic emails informing users of technical service issues, product surveys, new feature announcements and news about BraveHeart products and services. You will not be able to unsubscribe to these mailings, as they are considered a part of the service you have chosen. Receiving these emails is required as part of the service that we offer. If you wish to no longer receive these emails you may deactivate your account by contacting firstname.lastname@example.org.
k. Customer Service
We communicate with users on a regular basis to provide requested Services and regarding issues relating to users’ accounts.
l. Abuse and Spam
BraveHeart has a zero-tolerance policy for abuse. While we cannot be responsible for external communications received through BraveHeart Services, it is our intention to use all legally available means to prevent use of the Services for any illegal purpose. We also specifically restrict users from taking any actions which impose an unreasonable or disproportionately large load on BraveHeart’s resources. We ask that any users who are impacted by illegal use of the Services to please report such activity to BraveHeart at the email address below.
m. Servers and use
BraveHeart processes personal information on our servers in the United States of America and in other countries. In some cases, we may process personal information on a server outside your own country. We may process personal information to provide our own services.
II. Choices for personal information
a. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email@example.com.
b. You may terminate your account by contacting firstname.lastname@example.org. Such deletions or terminations will take immediate effect in your account view. Residual copies of deleted messages and accounts may take up to thirty (30) days to be deleted from our active servers and may remain in our offline backup systems.
III. Information sharing
a. BraveHeart does not release personally identifying information about our customers or monitor, edit or disclose the contents of a user’s private communications through the Services except where BraveHeart in good faith believes that such action is necessary to:
1. Comply with any applicable law, regulation, or enforceable governmental request or where we have a good-faith belief that such disclosure is necessary to comply with a current judicial proceeding, a court order or legal process served on us;
2. Enforce applicable Terms of Service, including investigation of potential violations thereof;
3. Investigate, prevent or take action regarding illegal activity or technical issues;
4. Protect against imminent harm to the rights, property or safety of BraveHeart, its users or the public as required or permitted by law.
b. If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service privacy notices, we will offer you an effective way to opt in or out of the use of personal information for those other purposes.
c. Please contact us at the address below for any additional questions about the management or use of personal data.
d. Third Party Intermediaries; Supplementation of Information. In order for BraveHeart to properly fulfill its obligations to users, it may be necessary for us to use services of third parties, such as credit verification services to obtain credit references of our users. BraveHeart does not release this information except as necessary per our information sharing guidelines in III a above.
e. Business Transfers: Information about our users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of BraveHeart. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or use of your personal information, as well as any choices you may have regarding your personal information.
f. If you use a blog or forum on the Web Sites, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these blogs or forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in the blog or forum. To request removal of your personal information from our blog or community forum, contact us at email@example.com.
IV. Information security
a. We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
b. We restrict access to your personally identifiable information and CPNI to those employees, contractors and agents who need to know that information in order to operate, develop or improve services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We protect the security of your personally identifiable information during transmission via the BraveHeart Web Sites by using Secure Sockets Layer (“SSL”) software, which encrypts information you input, so that no one else can read it as it is transmitted over the Internet. And we use an SSL connection to enable you to view, enter, and change the information in the applicable account setting section securely on our Web Sites. Since no method of transmission over the Internet or electronic storage is 100% secure, we cannot guarantee its absolute security.
c. You can take additional steps on your own to safeguard your personally identifiable information. For example, you should be sure to sign off when finished using a shared computer. And you should always log out of any website, including the BraveHeart Web Sites, after viewing personal account information.
d. Please be advised that BraveHeart has no control over the security of other sites on the Internet you might visit, interact with, or from which you might buy products or services.
V. Data integrity
VI. Personal information changes
When you use BraveHeart Services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We will respond within thirty (30) days of receiving your request at firstname.lastname@example.org.
BraveHeart regularly reviews its compliance with this Policy. Please direct any questions or concerns regarding this Policy or BraveHeart’s treatment of personal information by contacting us at:
c/o BraveHeart Wireless, Inc.
11 Perimeter Road
Nashua NH 03063
When we receive formal written complaints at this address, it is BraveHeart’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including applicable data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between BraveHeart and an individual.
VIII. Changes in this Privacy Statement
If you have any questions, comments or concerns about this Policy, please email us at email@example.com, or write to us at:
c/o BraveHeart Wireless, Inc.
11 Perimeter Road
Nashua NH 03063