CirrusTel is the data controller in respect to personal data that we collect or that you provide to us. This policy may be amended from time to time and was last updated on September 1, 2019. If you have any questions regarding this policy, please contact CirrusTel through the Contact Us link on this website or see our contact details in the “How to Contact Us” section at the end of this Notice.
This online Privacy Notice is applicable to all information that we collect at this and any/all of CirrusTel’s array of digital websites and platforms including, but not limited to: www.cirrustel.com and any/all of its subdomains, or through other digital communication means such as our own embedded webforms and advertisements placed on 3rd party sites (including job application forms for job opportunities we have listed on 3rd party portals), or through email and social media interactions with you.
1. How We Obtain Information About You
We may collect personal data that you choose to share with us—including, but not limited to, your first and last name, physical address, email address, or telephone number when you:
- Fill out a form, including new account, login, and contact, and contractual forms.
- Sign up to receive direct marketing communications.
- Register online through any of our sites or contract with us.
- Opt-in to receive emails from us.
- Register for or attend an event that we, or one of our affiliates, have organized.
- Communicate with us (for example, on a social-media platform, by sending us an email, by chat, by text/SMS message).
CirrusTel collects personally identifiable information from our users during the initial signup process, as well as during surveys or preference requests, event registrations, and during your normal use of our websites and platforms. We use this information to contact you with offers, newsletters, and special promotions in which you have expressed interest, and to send you necessary business communications pertaining to your ongoing business relationship with us. Additional information, such as dietary preferences, preferred location, events, or group bookings, enable us to provide the best possible service to you in person or digitally based on your needs and communicated interests. You may also be given the opportunity to provide your cell/mobile phone number during various processes, or through a separate email from one of our affiliates. If you provide your cell number and agree/opt-in to receive text (SMS) messages on your cell phone, you will always have the option to “Opt-out” of any future text-based/SMS communication each time you receive an SMS.
We may also collect personal data in other contexts that we will notify you of at the time.
2. Information We Obtain
Information You Provide
Personal data you provide directly to us will be apparent from the context in which you provide it. For example:
- If you fill out a form, you generally will provide your name, contact details, and any other information requested on the form, such as the reason for your inquiry or your product preferences.
- If you sign up to receive electronic marketing communications from us, you generally will provide your name, email address, and other contact information, and your technology preferences.
- If you sign up to a feature on one of our sites, you generally will provide your name, contact information, and any other information necessary to access the feature.
- Each form varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.
- If you participate in web-based contests or surveys, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary, so you have a choice on whether to disclose this information. CirrusTel may use a third-party service provider to conduct these surveys or contests. That company is prohibited from using your personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with any third party unless we give you prior notice.
Information We Collect Automatically
Our web servers may log information such as your operating-system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to one of our sites, and the IP address of the device you use to connect to the internet. They may also log information about your interaction with the sites, such as which pages you visit. To control which web servers, collect information by automated means, we may place tags called web beacons—small files that link web pages to particular web servers and their cookies. We also may collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails—to help us understand and respond to your needs.
Some of our sites include social-media functions, such as the blog, Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on our sites, and the IP address of the device you use to connect to the internet. Any of the widgets may also set cookies to ensure the features are functioning properly. Social- media functions and widgets are hosted either by a third party or directly on our sites. Your interactions with the social-media functions and widgets located on our sites are governed by the privacy policies of the companies that provide them. If you use any of the social-media functions or widgets on our sites, we strongly suggest you review the privacy policies of the companies that provide those functions and features.
Third party web content management system Plug-ins and platform tools
Some of our sites are built on third party content management systems. Each of these sites incorporates functionality from multiple third-party plug-ins which may gather aggregate or general data in order to properly deliver the service or function they provide, such as your IP address and derived geographic location in order to serve you location-specific content, what browser your or using, or your device type in order to alter the layout or function of the plug-in content to best suit your needs.
3. How We Use the Information We Obtain
Information You Provide
We may use personal data you provide to respond to your inquiry—for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights, and freedoms to protect personal data about you. Your email address is used to send email that is designated in our customer database or to send specific content that you subscribed to or requested directly. Your email and relevant content-viewing history may be provided to mutually interested third parties when you demonstrate an interest in their products and/or services on one of our sites (such as reading a blog or attending a CirrusTel sponsored event. CirrusTel is not responsible for the timing, quantity, or quality of the materials which the third party may send to you via your email.)
CirrusTel follows an opt-in, permission-based text-message (SMS) enrollment policy. CirrusTel will NOT rent, sell, trade, or loan our lists to anyone. All emails contain links on how to unsubscribe from the client list, and how to request your data be updated. All SMS messages contain information on how to unsubscribe from our SMS lists. You may leave our lists at any time, for any reason.
In addition to the uses discussed above, we also may use the personal data you provide to:
- Operate, evaluate, and improve our business.
- Develop new products and services.
- Perform market research.
- Advertise and market the products and services we sell.
- Determine the effectiveness of our advertising and marketing.
- Analyze our products, services, and websites.
- Administer the Site.
Your data will be utilized for official CirrusTel business purposes only. We do not sell or provide your data to third parties except as described under “4. Information We Share.” below.
We may also use the information we collect to protect against and prevent fraud, claims, and other liabilities, and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by law that applies to us.
Other Uses of Information
In addition to the uses described above, we may use personal data you provide, or we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data, and our legal basis for doing so.
4. Information We Share
We do not sell or otherwise disclose personal data you provide, or we collect, except as described here. We may share personal data you provide, or we collect with the following parties for the purposes described in this Notice:
- Service providers that perform services on our behalf
- Companies with which we have a contractual business relationship, such as Suppliers/Service Providers
We may share personal data with service providers that perform services on our behalf, such as payment service providers, analytics providers, hosting providers, and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf, or to comply with applicable legal requirements.
We may provide your contact information to interested third parties as described above, only when we have a legitimate business interest in doing so, to third parties with which we have a standing contractual relationship and obligation, and when doing so is to your benefit as well. We do not gain any material benefit from this share of data, and we do not provide data of any person or entity who is not a registered Sales Partner with CirrusTel to any third parties in this process.)
In addition, we may disclose personal data about you: (a) if we are required or permitted to do so by law or legal process—for example, due to a court order or a request from a law enforcement agency; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity; and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
5. Data Transfers
We may transfer the personal data we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data-protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries, we will protect that personal data as described in this Notice. You may request a copy of the safeguards that we have put in place in respect to transfers of personal data by contacting us as described in the How to Contact Us section below.
6. Data Security
We may retain a copy of your information in accordance with law, and only so long as necessary to provide you with high-quality and consistent services, including marketing services and account information.
CirrusTel has put in place certain technological and procedural security functions to protect the personal information it collects, uses, or transfers from loss, misuse, alteration, or destruction. Information collected by our digital properties, or transferred to us from other sources, will be processed in the United States, Europe, or Latin America.
7. How Long We Keep Information
The amount of time for which we keep personal data depends on the purpose for which we collected it. In all cases, we keep it for as long as necessary to fulfill the purposes for which we collected it. We will then delete the personal data—unless we are legally required to retain it, or we need to retain it to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data as follows:
- Personal data you provide us: we keep this personal data for as long as is necessary to maintain our business relationship with you.
- Personal data you provide when you sign up for an account with one or more of our sites or platforms, or to receive direct marketing communications from us, or upon entering into contractual business relationship with us: we keep most of this personal data for the duration of our relationship with you—until you opt out, or we do not have any contact with you for a long period of time.
Certain pages on our sites contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information such as IP address, the URL of the page on which the beacon appears, timestamps, browser type, and the information in cookies set by the third party.
Strictly Necessary Cookies
These cookies are necessary for our Site to operate properly and facilitate your use of its features. Without these cookies, certain services cannot be provided. These cookies help us understand information, such as your session ID and other server authentication information. This category of cookies should not be disabled. If you use your browser settings to block them, we cannot guarantee your security or predict how our website will perform during your visit.
These cookies allow our website to remember choices you make and provide enhanced and more personal features. They capture information such as the pages you have browsed or products you have viewed so that we can improve your browsing experience. They also can be used to remember changes made to parts of our website that you can customize. The information gathered by functional cookies is de-identified, and not linked to information about how visitors use other websites.
Advertising cookies may be used to deliver ads that we believe are relevant to your interests. We may use advertising cookies to customize the advertising and content you receive on the Site and conduct market research. They also can be used to limit the number of times users see an advertisement, as well as help measure the effectiveness of an advertising campaign. They can be placed on a device by us, or by a third party with our consent.
These cookies collect information about how visitors interact with our website, such as what pages you visit and if any errors have occurred. The information is used to improve how our websites function. These cookies do not collect information that identifies you; these cookies generate statistical data about your use of our website.
Analytics Technologies We Use
The service registers a unique ID that is used to generate statistical data on how visitors use our website. More information about how Google Analytics uses the data stored in and obtained from its tracking cookies can be found here: https://www.google.com/policies/privacy/partners/. If you want to opt out of our use of Google Analytics, please click here: https://tools.google.com/dlpage/gaoptout.
We use LinkedIn’s Insight tracking pixel to understand the interactions between our LinkedIn content and the performance of related content on our site. More about our use of LinkedIn’s tracking service can be found here.
We use Facebook’s Insight tracking pixel to understand the interactions between our Facebook content and the performance of related content on our site. More about our use of Facebook’s tracking service can be found here.
Snippets and Custom Objects
We use snippets and custom objects in our HTML-based email campaigns to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt out of these emails, you may change your settings at any time by clicking on the “change your preferences” link at the bottom of the email.
Links to Other Digital Properties
Communication that we send on a 3rd party’s behalf may contain links to other sites or digital properties that are not owned or controlled by CirrusTel. Please be aware that CirrusTel is not responsible for the privacy practices of these other properties and does not exercise authority over such properties. Therefore, CirrusTel assumes no responsibility for the privacy and data-collection policies and procedures of such linked properties, nor for the content or reliability of such properties. If you choose to access a third-party property, you do so at your own risk.
9. Your Rights and Choices
You have the right to access the personal information that we hold about you.
Before providing personal information to you or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us, so we can locate your personal information.
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it by contacting your account management team.
If you would like to exercise any of these rights or lodge a complaint, please contact us using the information set out below.
10. How to Contact Us
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data—or if you would like us to update information we have about you or your preferences—you may contact us at: Phone number: 760-936-4180
US Mail: Cirrus Telecom, LLC., Attn: Legal Dept, 2 Kiel Avenue, Unit #135, Kinnelon, NJ 07405. Opt-Out/Unsubscribe: If you no longer wish to receive our communications, you may opt out of receiving them by following the instructions included in each communication.
Alternatively, you may contact us at: Phone number: 760-936-4180 US Mail: Cirrus Telecom, LLC., Attn: Legal Dept, 2 Kiel Avenue, Unit #135, Kinnelon, NJ 07405.
Changes in Our Privacy Statement: We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will publicize such changes by means of a Notice on our home page by displaying a prominent “NOTICE” above the text of the Privacy Statement.