PRIVACY POLICY STATEMENT

History of Material Changes

Last revised April 2024

PURPOSE

This privacy policy statement (“Statement”) applies to websites, services, and products of CellTrust Corporation (“CellTrust” or “we,” “our,” and “us”) and explains how CellTrust collects and treats personal information about individuals (also referred to as “Consumers,” “you” or “your”).

CellTrust complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce; however, personal data cannot be received from the United Kingdom and Gibraltar in reliance on the UK Extension to the EU-U.S. DPF before the date that the adequacy regulations implementing the data bridge for the UK Extension to the EU-U.S. DPF enter into force.  CellTrust has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  CellTrust has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

When referencing “personal data” and “personal information” in this Statement, in relation to CellTrust’s DPF commitments, such terms mean data about an identified or identifiable individual that are within the scope of the Directive 95/46/EC (or any subsequent law or regulation implemented by Switzerland or the European Union or the United Kingdom), received by an organization in the United States from the European Union or the United Kingdom, and recorded in any form.

CellTrust is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

THE INFORMATION WE COLLECT

The way CellTrust collects personal data 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”).

2.1.    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. This may include uploading an SL2 user’s contact list information from their phone if the SL2 user gives permission to the SL2 app for this access. Some other 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, information to maintain audit logs for data operations, 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 THEIR APPLICABLE PRIVACY POLICY TERMS. IF YOU CONNECT TO A SERVICE HOSTED AND/OR ADMINISTERED BY ANOTHER PARTY SUCH AS A CELLTRUST CUSTOMER OR STRATEGIC PARTNER, YOU MUST CONTACT SUCH PARTY FOR THE APPLICABLE PRIVACY POLICY. THE CELLTRUST CUSTOMER OR OTHER THIRD PARTY ADMINISTERING YOUR SERVICES IS 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 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 PARTIES SUCH AS TELECOMMUNICATION CARRIERS, WHOSE SERVICES ARE NECESSARY TO SEND THESE MESSAGES. YOU ACKNOWLEDGE THAT INFORMATION SENT THROUGH THE COMMUNICATION NETWORKS WILL BE SUBJECT TO THE PRIVACY AND DATA PROTECTION POLICIES OF THESE THIRD PARTIES AND CELLTRUST CANNOT CONTROL THE INFORMATION WHEN IT IS IN THEIR NETWORKS.

WHEN 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 PARTIES WHOSE SERVICES ARE USED IN CONNECTION WITH THE TRANSMISSION. END USERS ACKNOWLEDGE THAT SUCH ARCHIVING PROVIDERS AND THIRD-PARTY VENDORS ARE OUTSIDE CELLTRUST’S CONTROL AND SUBJECT TO THE TERMS BETWEEN THE CUSTOMER AND THE ARCHIVING SERVICE PROVIDER, 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 (i) to store your contact information within our environment hosted in Microsoft Azure for the End User to continue communications with you and (ii) to fulfill the transmissions of those communications and the archiving of such communications, which will include the disclosure of phone numbers and message content to third parties that are part of the communication networks, such as those in the telecommunication carrier and internet service provider networks, and third parties selected and utilized by the End User’s company for long-term archiving compliance. CellTrust does not use this information for our own purposes.

CellTrust also will share information with third parties as necessary to be compliant with the rules and regulations of the telecommunication carriers, including without limitation, disclosures to The Campaign Registry and the carrier-designated auditors to ensure compliance.

If you provide CellTrust with your contact information by directly communicating with us (e.g. via email or through our website), 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).

Except where restricted by the terms of our agreements with our applicable customers, we may partner with other businesses to assist us in our marketing, communications, and sales efforts, and may share information for these purposes. These partners are not allowed to use your information for any purpose other than doing business with CellTrust. CellTrust does not sell any personal information and does not permit our third-party suppliers, vendors, or contractors to sell any personal information obtained in the course of our business relationship.

Due to the nature of our company and the services CellTrust provides, CellTrust is regularly subject to audits.  Such audits, particularly if they are performed to research potential wrongdoing, may be jeopardized if disclosed prematurely.  Similarly, CellTrust may need to perform, or be the subject of, a “due diligence” review as part of customer requirements, 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 personal information could be transferred to third parties as one of our business assets or for auditing and compliance purposes.  This will often entail the collection and processing of personal data, such as information on senior executives and other key personnel.  Premature disclosure could impede the transaction or even violate applicable securities regulation.  Investment bankers and attorneys engaged in due diligence, or auditors conducting an audit, may process information without knowledge of the individual only to the extent and for the period necessary to meet statutory or public interest requirements and in other circumstances in which the application of these Principles would prejudice the legitimate interests of CellTrust.  These legitimate interests include the monitoring of CellTrust’s compliance with our legal obligations and legitimate accounting activities, and the need for confidentiality connected with possible acquisitions, mergers, joint ventures, or other similar transactions carried out by investment bankers or auditors. Notwithstanding the foregoing, unless required by law or regulation, CellTrust shall not make the personal information of any End User or any individual communicating with an End User available in the course of any audit or due diligence except as to the specific customer with whom the End User and individual are using CellTrust’s SL2 Services to communicate.

2.2.    INFORMATION COLLECTED FROM VISITORS TO CELLTRUST’S WEBSITE

Automatically Collected Information

Some information may be automatically collected from visitors to CellTrust’s websites (“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, GOOGLE ANALYTICS, AND SNAPENGAGE

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 optimize the Visitor’s experience on our website and to better understand how Visitors use our website. CellTrust also uses cookies to collect consent to cookies in compliance with applicable laws with Cookiebot by Usercentrics. 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 regarding cookies and can revoke consent to certain cookies through CellTrust’s Cookie Consent tool. If you choose to reject all or certain cookies, you will be unable to use the services or engage in the activities that require cookies.

The cookies identified on CellTrust’s Cookie Declaration identify the cookies utilized at CellTrust’s website and do not represent what is utilized in SL2. CellTrust does NOT use Google Analytics, SnapEngage, Twitter or YouTube or any similar service within SL2; however, CellTrust does use cookies related to these services on its celltrust.com website to better understand how Visitors use our website and to improve your use of the services, as described below and in our Cookie Declaration.

Google Analytics provides certain information about your online activities on CellTrust’s website over the previous two years, but CellTrust’s use of Google Analytics cannot be used to track a given Visitor or browser across websites that are not a part of CellTrust’s domain. You can find information related to how Google Analytics collects and processes information here: Safeguarding your data – Analytics Help (google.com)., CellTrust also uses AdWords from Google, which may use cookies or other identifiers if an individual clicks on an AdWord link utilized by CellTrust. Times-to-show is a Google cookie that is used on CellTrust’s website to determine when and where certain pop-ups on the website should be presented for the Visitor and remember whether the Visitor has closed these to keep them from showing multiple times.

CellTrust also uses SnapEngage on its website. SnapEngage uses cookies to report the number of visits to our website, to facilitate communications with Visitors (including making the submitted visitor’s name and previous five chat transcripts available), and to record from which URL an individual accessed our website, You can limit the amount of your information utilized by CellTrust’s Snap Engage usage by refraining from using the optional chat feature on our website.

CellTrust also utilizes necessary cookies to distribute traffic to its website on several servers to optimize response times and to preserve a Visitor’s session state across page requests, and CellTrust utilizes the wpEmojiSettingsSupports cookie on its website to enable the conversion of ASCII smilies to real emoji images.

Additionally, with the use of tools from YouTube and Twitter, certain marketing cookies exist on CellTrust’s website to set a unique ID for visitors that allows third party advertisers to target the visitor with relevant advertisements. Remember you can always reject marketing cookies or revoke your consent to marketing cookies at any time.

 

THE DATA PRIVACY FRAMEWORK (DPF) PROGRAM PRINCIPLES

The Data Privacy Framework (DPF) program Principle: Notice

This Privacy Policy Statement serves as CellTrust’s notice to individuals about our participation in the Data Privacy Framework (DPF) Program, as well as other relevant information in relation to CellTrust’s privacy practices. If you would like any clarification on the terms herein or do not understand your rights or CellTrust’s responsibilities and commitments toward your personal information, please contact legal@celltrust.com. We would be happy to provide any clarification and will consider updates to our privacy policy statement language to address the same.

The Data Privacy Framework (DPF) program Principle: Choice

You have the ability to choose to restrict what personal information is sent through CellTrust’s system to third parties by (a) limiting what information you include in the body of messages or voice calls made through CellTrust’s products and services or (b) choosing not to communicate through the CellTrust software. You may also contact the company using CellTrust services to communicate with you to further restrict use of your personal information, or, when available, you may utilize an opt-out keyword to stop messages from being sent to you from a specific phone number. CellTrust never requests any special categories of personal data (such as racial or ethnic origins, information about gender or sexual identity, political, religious or union opinions and activity, etc.) for the use of its products, services, or website. You should only choose to share such information within a message or call if you are consenting to the storage and disclosure of such information through third parties necessary for transmission to the intended recipient and any archiving, mobile device management, or other party utilized by the CellTrust customer through whom you are communicating.

CellTrust will never use your personal information for a purpose materially different from the purpose(s) for which it was originally collected or subsequently authorized.

If you had previously agreed to receive communications directly from CellTrust and wish to discontinue such use, or if you wish to otherwise modify the use of your personal information, you may email legal@celltrust.com to determine what steps may be taken to effectuate desired changes.

We may also be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If CellTrust receives a law enforcement request related to the use of SL2, when permitted, CellTrust will notify the Customer associated with the request. CellTrust requires that all law enforcement requests are sent to its Legal Department for handling, and CellTrust shall confirm the authenticity of the request before any response is provided. Unless otherwise directed by an authorized individual for an applicable Customer, CellTrust will only respond to compulsory law enforcement requests and, to the extent feasible while staying compliant with applicable law, CellTrust will take measures to mitigate any privacy impact with the information it is compelled to disclose to law enforcement.

Please note that there may be some limitations to your choices when it comes to your personal data. For example, adherence to the Principles may be limited: (a) to the extent necessary to comply with a court order or meet public interest, law enforcement, or  national security requirements, including where statute or government regulation create conflicting obligations; (b) by statute, court order, or government regulation that creates explicit authorizations, provided that, in exercising any such authorization, CellTrust can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interest furthered by such authorization; or (c) if the effect of the GDPR is to allow exceptions or derogations, under the conditions set out therein, provided such exceptions or derogations are applied in comparable contexts.   Furthermore, personal information that is gathered for journalistic purposes or other public communication, and the information found in previously published materials from media archives, are not subject to the Data Privacy Framework (DPF) program Principles. Additionally, affirmative express consent for the processing of sensitive data is not required where the processing is:

  1. in the vital interests of you or another person;
  2. necessary for the establishment of legal claims or defenses;
  • required to provide medical care or diagnosis;
  1. carried out in the course of legitimate activities by a foundation, association or any other non-profit body with a political, philosophical, religious or trade-union aim and on condition that the processing relates solely to the members of the body or to the persons who have regular contact with it in connection with its purposes and that the data are not disclosed to a third party without the consent of the data subjects;
  2. necessary to carry out the organization’s obligations in the field of employment law; or
  3. related to data that are manifestly made public by you.

The Data Privacy Framework (DPF) program Principle: Accountability for Onward Transfer

CellTrust ensures that the contracts it has in place with its subcontractors restrict use and processing of personal information to what is necessary to provide the services required. CellTrust does not permit the sale of any personal data processed through its subcontractors or vendors. If CellTrust enters into a contract with a third-party controller, CellTrust shall require that personal data may only be processed for limited and specified purposes consistent with the consent provided by you through the underlying agreements with CellTrust, or as modified thereafter as described above. CellTrust shall further ensure that such third-party controllers provide the same level of protection to your personal data as CellTrust offers in accordance with the Data Privacy Framework (DPF) program Principles, and CellTrust shall require that they notify us in the event they determine they can no longer meet that obligation.  Consistent with the Data Privacy Framework (DPF) program Principles, CellTrust accepts responsibility for such contracted third-party controllers and will take reasonable and appropriate steps to stop and remediate any unauthorized processing.  Internet Service Providers (“ISPs”), telecommunications carriers, and other organizations are not liable under the Data Privacy Framework (DPF) program Principles when they merely transmit, route, switch, or cache information on behalf of CellTrust or a CellTrust customer.  To the extent CellTrust or any other organization is acting as a mere conduit for data transmitted by third parties and does not determine the purposes and means of processing those personal data, they would not be liable.

In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US, UK Extension, and Swiss-US Data Privacy Framework (DPF) program, CellTrust is potentially liable.

The Data Privacy Framework (DPF) program Principle: Security

CellTrust reviews industry best practices to ensure it has taken reasonable and appropriate measures to protect data against loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data.

The Data Privacy Framework (DPF) program Principle: Integrity and Purpose Limitations

CellTrust limits the information it requires for collection to what is relevant for the purposes of processing. CellTrust provides its customers with the means to update contact information to ensure such data is reliable for its intended use, accurate, complete, and current. CellTrust has established mechanisms to log and restrict access to its network and systems to ensure the integrity of records. CellTrust shall adhere to these Principles for as long as it retains personal information.

CellTrust shall only retain information retained in a form identifying or making identifiable, individuals only for as long as it serves a purpose of processing in compliance with our customer agreements, reasonably serves customer relations, compliance and legal considerations, auditing, security and fraud prevention, preserving or defending CellTrust’s legal rights, or other purposes consistent with the expectations of a reasonable person given the context of the collection and these terms.

The Data Privacy Framework (DPF) program Principle: Access

If CellTrust communicates directly with you or maintains your personal information in its own contact system, CellTrust will provide you access to such details and copies of such communications (upon request and authentication that it is you requesting such information), and give you the opportunity to correct, amend or remove your personal information in its contact list. If you believe your personal information is included in the system of a CellTrust customer, it is best that you contact that customer directly to access, correct, amend, or delete such information as CellTrust limits the length of time it maintains customer data and has restricted access to such data. However, CellTrust is willing to cooperate with any individual and such customer to address issues regarding personal information. Under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, individuals must have access to personal information about them that an organization holds and be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

The Data Privacy Framework (DPF) program Principle: Recourse, Enforcement and Liability

CellTrust’s failure to comply with the Data Privacy Framework program Principles is enforceable by the FTC under Section 5 of the Federal Trade Commission (FTC) Act prohibiting unfair or deceptive acts in or affecting commerce (15 U.S.C. § 45) or under other laws or regulations prohibiting such acts. CellTrust shall conduct reviews at least annually to verify that the attestations and assertions made about our privacy practices are true. CellTrust has designated their General Counsel to act as its Privacy Officer who can be contacted at legal@celltrust.com. CellTrust’s Privacy Officer shall be responsible for ensuring CellTrust’s compliance with applicable privacy laws and regulations, including approving the privacy policies and practices and, with the assistance of outside privacy counsel, advising CellTrust on breach reporting requirements.

If you have a complaint regarding your personal information, there are several mechanisms available to you to address the same. In compliance with the Data Privacy Framework (DPF) program Principles, CellTrust commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework (DPF) program.

  • In compliance with the Data Privacy Framework (DPF) program Principles, CellTrust commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework (DPF) program. European Union, the United Kingdom, and Swiss individuals with the Data Privacy Framework (DPF) program inquiries or complaints should first contact CellTrust at: legal@celltrust.com

 

  • European Union, the United Kingdom, and Swiss individuals with the Data Privacy Framework (DPF) program inquiries or complaints should first contact CellTrust by completing the complaint form found here. CellTrust shall investigate and respond to any complaint submitted within 45 days and will work to expeditiously resolve any matter at no cost to any individual submitting a complaint. at: legal@celltrust.com

(3) In compliance with the EU-US Data Privacy Framework Principles, CellTrust commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles.  European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact CellTrust at legal@celltrust.com.

CellTrust has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

CellTrust is committed to respond promptly to inquiries and requests related to compliance investigations and enforcement of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. In the event CellTrust were to become subject to an FTC or court order based on noncompliance, CellTrust shall make public any relevant Data Privacy Framework (DPF) program-related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

Except as to Internet Service Providers (“ISPs”), telecommunications carriers, and other organizations when they merely transmit, route, switch, or cache information on behalf of CellTrust or a CellTrust customer, in the context of an onward transfer, CellTrust has responsibility for the processing of personal information it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. DPF and subsequently transfers to a third party acting as an agent on its behalf.  CellTrust shall remain liable under these Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless CellTrust proves that it is not responsible for the event giving rise to the damage.

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.

ADDITIONAL RIGHTS

There are locations in which individuals have certain rights under the law regarding their information. 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. SL2 Customers will be sent a notification when material changes occur with this Statement. Any individual is also able to utilize the History of Material Changes link at the top of this page for details on when and how this Statement has been materially changed. Users should visit this page regularly, especially prior to providing any personal information.

FICTITIOUS NAMES

EXCEPT AS TO REFERENCES TO CELLTRUST’S CURRENT TEAM MEMBERS, ANY PERSONAL DATA, 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.