COLLECTION, USE, DISCLOSURE, AND SECURITY OF PERSONAL INFORMATION
This policy applies to personally identifiable information (“personal information”), which is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; social security number; call records; wireless device location). Personal information does not include “anonymous” or “aggregate: information – neither of which are associated with a specific person or entity.
Collection of Personal Information
We collect personal information about you when you use our services or otherwise interact with us. Such information includes:
Information you provide. We collect personal information when you sign up for and use our services, and when you e-mail, call, or otherwise communicate with us. For example, we may collect personal contact, billing, and credit information when you sign up for voice or purchase other products or services. We may also collect personal information when you call or e-mail our customer service representatives, enter information on our Web sites, submit survey responses or pay for service. If you provide personal information to us in connection with a co-sponsored Web site, this policy will apply to our use of the information and the co-sponsor’s policy will apply to their use of the information.
Information automatically collected. We automatically collect certain information, some of which may be associated with personal information, whenever you use our services or Web sites. For example, our systems capture details about the type and location of wireless device(s) you use, calls and text messages you send and receive, and other data services you use (for example your ringtone purchases). When your computer Web browser or other communication device (including phone, PDA, etc.) accesses our Web sites or wireless web pages (Odin Mobile Web pages designed for access by wireless device browsers), we automatically receive certain information, such as your IP address, browser type, date and time, and the Web page you visited before visiting our site. If the service is available, our network also automatically captures necessary routing information when you use our services to access the Internet from your wireless device.
Information from other sources. We may also obtain personal information about you from other sources. For example, we may obtain updated address information from our shippers or other vendors. We may also purchase personal information (for example, e-mail lists, postal mail lists, demographic and marketing data) from others.
Use of Personal Information
We use personal information for a variety of business purposes, including for example, to complete transactions and bill for products and services; verify your identity; respond to your requests for service or assistance; anticipate and resolve actual and potential problems with our products and services; create and improve products and services; suggest additional or different products or services; collect for our services; make internal business decisions about current and future offers; provide personalized service and user experiences; protect our rights and property; and contact you about other services offered by Odin Mobile. We may disclose personal information to personnel employed by our parent or affiliated companies in order to further any business purposes, including those described in this policy.
We may contact you by telephone, postal mail, e-mail or other methods. You may opt-out of receiving marketing communications from us at any time as outlined below in the section titled Customer Control.
Disclosure of Personal Information
Other than as described below, we do not sell, rent, or otherwise provide your personal information without your consent, to unaffiliated third-parties to market their services or products to you:
We may disclose personal information about you to third-parties with your consent. We may obtain your consent in several ways, such as in writing; online, through “click-through” agreements; orally, including through interactive voice response; or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.
We may disclose personal information of an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you or your use of the service to them or others at the direction of the account holder. When you are the primary account holder, but you receive special or discounted pricing, terms, or other benefits through another party’s agreement with us (for example, an employee discount), we may provide enough personal information to that party to verify your initial and continuing eligibility for benefits under their agreement with us and to calculate any associated discounts.
We may disclose personal information to third-parties performing services on our behalf (for example, companies who complete transactions and perform credit checks, billing, credit and debit card payment processing, shipping, customer service, and marketing), or that perform transactions on your behalf (for example, verification of your account information at your request to some third-party business, processing of debit/credit card transactions), or transfers related to your service (for example, number portability). Your wireless telephone number, the numbers you dial, and other information about your usage will be available to companies that perform underlying telecommunications services on our behalf to facilitate the origination, transport and termination of your Odin Mobile calls.
Your personal information may be disclosed when the use of our services allow you to take advantage of services and products offered by other companies. For example, if you are roaming on the network of another carrier, your wireless telephone number, the numbers you dial, and other information about your usage will be available to that carrier to facilitate that service.
We may disclose personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information could be transferred to third-parties as a business asset in the transaction.
We may disclose personal information or communications where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (for example, lawful subpoena, court order, E-9-1-1 information); to enforce or apply agreements, the Terms and Conditions of this policy; to initiate, render, bill, and collect for services and products; to protect our rights or property; in connection with claims, disputes, or litigation; to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or if we determine disclosure is necessary in an emergency situation.
ACCESS AND CHOICE
Access to Your Information
You may access and modify your contact information by contacting us at www.Odin Mobile.com or our Customer Service Department. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.
We want to provide you with meaningful choices regarding our marketing communications and you may choose to limit or opt-out of certain communications from Odin Mobile at any time. While you may elect not to receive marketing information from us, if you subscribe to our services or buy our products, you will continue to receive invoices, customer-service and transactional notices, and similar communications. You can stop email marketing messages by “unsubscribing” as instructed in the email. You can stop telemarketing calls by asking that your telephone number be removed from our telemarketing lists when we call you.
Not all marketing communications you receive on your device are sent or authorized by Odin Mobile. When you provide your cell phone number or other contact information to others, you may receive unwanted calls, text messages, or e-mails on your device.
OTHER PRIVACY INFORMATION
When you use Odin Mobile communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill.
Cookies, Web Beacons, and Similar Technologies
Customer Proprietary Network Information (CPNI)
Customer Proprietary Network Information, or “CPNI”, is a form of personal information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted policies and procedures designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under FCC rules, applicable law, or explained in this policy. However, you may designate other “authorized users” (for example, a spouse) to access and manage your account information, including CPNI.
Customer Service Monitoring
We may monitor and record phone calls, e-mails, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests.
We do not publish directories of our customers’ wireless numbers. Nor will we provide or make such numbers available to third-parties for listing in their public directories, without the customer’s prior consent.
Forums and Chat Rooms
If you use or link to a public forum, bulletin board, chat room, or social network on or from a Odin Mobile Web site, be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of personal information you choose to submit or share with others.
Our network may detect your device’s approximate location whenever it is turned on (subject to coverage limitations). This location technology makes the routing of wireless communications possible and is also the basis for providing enhanced emergency 9-1-1 service, which permits us to provide your general location to a public safety answering point, emergency medical service provider, or emergency dispatch provider. We may also use this technology to disclose, without a user’s consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm.
Other Governing Terms
This policy does not modify or alter any applicable agreement you have with Odin Mobile. If you use or subscribe to our products and services, our Odin Mobile Terms and Conditions and certain other terms may apply to your use, purchase, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency.
Wireless Communications Security
We cannot guarantee that your communications using our services or devices will be private or secure. Although it is illegal for unauthorized persons to intercept or access your communications or information, such interceptions or access can occur.
POLICY UPDATES AND CONTACT INFORMATION
Changes to This Policy
We may update this policy if we materially change our practices or if legal or regulatory changes require it. If we decide to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time the personal information was collected, we will notify you by posting notice of the change on our Web site’s home page for at least 30 days before we implement that change. You should refer to this policy often for the latest information and the effective date of any changes.
How to Contact Us
If you have any questions or comments about this policy or about Odin Mobile’s privacy practices, please contact us at 1-855-217-9459. You may also direct your privacy-related comments or questions to the address below:
Attn: Privacy Officer
11426 Rockville Pike, Suite 230
Rockville, MD 20852