Last revised September 2023
- Reference to Privacy Shield was modified to reflect the updated Data Privacy Framework and its requirements.
- Section 2.1 was modified to update and clarify the information CellTrust collects, CellTrust’s use of third parties in relation to collected personal information, and the role of personal information with audits that CellTrust is subject to.
- In addition to the updates to reflect the Data Privacy Framework and its current requirements, Section 4 was modified as follows:
- to include the use of opt-out keyword as an option to restrict certain uses of personal information
- to set forth CellTrust’s policy related to law enforcement requests
- to set forth the duration in which CellTrust retains personal information
- to set forth CellTrust’s commitment to annual review of the policy statement to verify its accuracy
- to identify CellTrust’s designated Privacy Officer and contact info
- to clarify the role of communication conduits in relation to the Data Privacy Framework