Privacy Statement

This privacy statement (“Statement”) applies to websites, services, and products of CellTrust Corporation (“CellTrust” or “we,” “our,” and “us”). Some features discussed below may not apply to all 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.

PURPOSE

CellTrust’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 CellTrust 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.

THE INFORMATION WE COLLECT

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

Information Collected from CellTrust Customers and Customer End Users

CellTrust collects information from its customers and customers’ End Users in the ordinary course of business. CellTrust 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.

FOR END USERS UTILIZING CELLTRUST’S SERVICES, PLEASE NOTE THAT THE INFORMATION SENT MAY BE STORED, ACCESSED, AND USED BY THE CELLTRUST CUSTOMER UNDER THE TERMS OF THE APPLICABLE PRIVACY POLICY OF SUCH CUSTOMER TO WHICH YOU CONNECT FOR SERVICES. IF YOU CONNECT TO A CELLTRUST-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 CELLTRUST CUSTOMER OR VENDOR, YOU MUST CONTACT SUCH PARTY FOR THE APPLICABLE PRIVACY POLICY. THE CELLTRUST 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 CELLTRUST OR THE PARTY THROUGH WHICH YOU ARE ACCESSING THE SERVICES.

FOR USERS UTILIZING A CELLTRUST STANDARD SMS SOLUTION, OR FOR ANY COMMUNICATION THAT INVOLVES A DEVICE WITHOUT A CELLTRUST SECURED APP (OR NOT USING THE SECURED APP), 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.

FOR CONSUMERS UTILIZING CELLTRUST’S SERVICES FOR ARCHIVING, DEPENDING IN PART ON THE CONNECTION AND VENDORS UTILIZED BY THE CUSTOMER, THE TRANSMISSION OF THE INFORMATION BETWEEN CELLTRUST AND THE ARCHIVING SERVICE MAY BE THROUGH STANDARD NETWORKS THAT MAY BE EXPOSED TO THIRD PARTY VENDORS WHOSE SERVICES ARE USED IN CONNECTION WITH THE TRANSMISSION. CONSUMERS ACKNOWLEDGE THAT SUCH ARCHIVING PROVIDERS AND THIRD PARTY VENDORS ARE OUTSIDE CELLTRUST’S CONTROL, AND, AS SUCH, CELLTRUST CANNOT GUARANTEE AND MAKES NO REPRESENTATION ABOUT THE PRIVACY PROTECTION OF THE INFORMATION THAT IS TRANSMITTED IN THIS MANNER.

What do we do with this information?

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:

  • To provide you with information about products, services, news, and events.
  • To allow you to use, purchase, and/or download products and services.
  • To analyze use of our services and products, develop new services and products, and customize our products, services, and other information we make available.
  • To enable our customers to use the services as they deem necessary to conduct their business.

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 CellTrust.

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.

Information Collected from Visitors to CellTrust’s Website

Automatically Collected Information
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.

COOKIES

CellTrust uses cookies on its website. A “cookie” is a tiny text file that is stored on Visitors’ devices to customize your experience and support some necessary functions, either temporarily for that session or more persistently for repeat visits. CellTrust uses cookies to better understand how Visitors use our website. Our cookies collect no PII and are not shared or intentionally revealed to other websites. CellTrust 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.

PERSONALLY IDENTIFIABLE INFORMATION

CellTrust only knowingly collects PII that is voluntarily provided by you. For example, you provide PII when registering for an account on CellTrust’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.

Protecting PII

CellTrust 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, CellTrust 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. CellTrust 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.

CONSENT

By using CellTrust’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.

CHILDREN’S PRIVACY

At CellTrust, we do not intend to collect information from children under the age of 13 (or the applicable legal age in your location). If CellTrust discovers that a child under the age of 13 submits PII to CellTrust, we will delete such information as soon as we become aware of the source of the submission (unless we are required to retain information, and, if so, we will retain only that information that we are required to retain), and we will not use such information for any other purpose. CellTrust 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.

DO NOT CONTACT

CellTrust provides you the opportunity to opt-out of receiving electronic communications from either CellTrust or our customers. If you do not want to receive communications from us, please contact us at legal@celltrust.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.

ADDITIONAL RIGHTS

There are locations in which individuals have certain rights under the law regarding their information. For example, CellTrust does not disclose any person’s PII to any third party for direct marketing purposes; however, if you are a California resident, you may request this information from CellTrust. California is only one example. Individual rights under European data protection rules is another example. If you have additional privacy rights guaranteed to you under your local law or regulations, CellTrust intends to honor those rights. You may contact us at CellTrust Corporation, 20701 N. Scottsdale Road, Suite #107-451 Scottsdale Arizona, 85255, USA. Attn: California Privacy Rights/Marketing, or by sending an email to legal@celltrust.com.

LINKS TO OTHER WEBSITES

When you click on links on CellTrust’s website to third-party websites, you will be subject to such third parties’ privacy policies or statements. CELLTRUST IS NOT BE RESPONSIBLE FOR THIRD-PARTY WEBSITES OR THEIR CONTENT OR ACTIONS. CellTrust 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.

UPDATES

CellTrust 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.

FICTITIOUS NAMES

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

AGREEMENT

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

QUESTIONS

Please direct any questions you might have about this Privacy Statement to legal@celltrust.com or write us at CellTrust Corporation, 20701 N. Scottsdale Road, Suite #107-451 Scottsdale Arizona, 85255, USA. Attn: Privacy.