Last Updated: January 1, 2023
For purposes of this Policy, “you“, “your“, “customer“, “user” and similar terms mean an account holder or user with Flash Mobile. ”Flash Mobile“, “we“, “us“, “our” and similar terms mean ACN Communication Services, LLC and its affiliates doing business as Flash Mobile.
The website includes, but is not limited to, all other sites owned and operated by Flash Mobile that redirect to the website, all subdomains provided through such other sites, and all downloadable applications, features, functionality, content, or information that is made available or provided on the website. The website is made available to you for the purposes of providing you with access to information about Flash Mobile and its product offerings. For your protection, we utilize a Secure Socket Layer (SSL) on all pages that require you to complete personal information.
This Policy also applies to our use of what our industry calls “Customer Proprietary Network Information” (“CPNI“). CPNI relates to the use of Flash Mobile voice services. It includes the length of calls, the phone numbers that customers call and similar information. CPNI does not include information, such as name, telephone number and email address.
This Policy applies to all of our products, services, and websites (“Services“). A few of our Services may be covered by different privacy policies and, in the event of a conflict between the two, the product- or service-specific policy governs. For example, we may have a separate policy or agreement for certain products, services, or brands. We may also give you extra notices about your personal information.
- Information Collected
- Use Of Information Collected
- Customer Proprietary Network Information
- Information We Share
- Information Security
- Information Choices and Changes
- Children and Flash Mobile
- Conditions Of Use, Notices, and Revisions
- Contacting Us
- Updates To This Policy
- California and Other State Consumer Privacy Act Supplemental Notice
We collect personal information about you and CPNI in various ways. We may also obtain information from other sources and may combine it with information we collect about you.
Information you give us.
The personal information we collect includes information you give us such as name, postal address, telephone number, email address, date of birth, Social Security number or other government identification number, demographics, activities, location information, and personal preferences. You may give us information in a variety of ways such as when you sign up for Services, communicate with customer care or register on one of our websites. Personal information does not include information that is not used to identify you, including aggregate or anonymous information. We (or one of our service providers on our behalf) may also collect your payment card information.
Information that we automatically collect.
We automatically receive certain types of information whenever you use our Services. We may collect information about your device, your computer, and online activities. For example, we collect your device’s and computer’s IP address, the date and time of your access and the type of browser you use. We also collect information about your device’s and computer’s operating system, your location, and the website from which you came and subsequently went, and websites you visit on your device. We may link information we automatically collect with personal information, such as information you give us at registration or checkout.
Information we collect when we provide you with Services includes when your wireless device is turned on, how your device is functioning, device signal strength, where it is located, what device you are using, what you have purchased or downloaded with your device (including any applications), how and to what extent you are using it, what sites you visit, and other CPNI.
Regarding your payment card information, we may use third-party providers to automatically update and collect your payment card information. We may also keep records of your communications with us, such as recordings of calls to customer service, emails, text messages, website chat tools, etc.
Use Of Information Collected
We use your personal and payment information for a variety of purposes, including providing you with Services. We use your personal and payment information to do things like the following.
- Contact you or otherwise communicate with you.
- Process your orders.
- Manage your account.
- Check your credit.
- Bill you or collect payment from you.
- Protect our and our customers’ rights and property.
- Respond to legal process and emergencies.
- Develop or inform you of new products and services.
- Anonymize or aggregate personal information for various purposes like market analysis or traffic flow analysis and reporting.
- Customize or personalize your experience with our Services.
- Customize or personalize advertising and communications to bring you information about products and services of Flash Mobile or others that may interest you, including co-branded offers and offers from Flash Mobile’s affiliates. For example, we may customize the ads you see when you are using our Internet-enabled devices. If we use information about your online activities to deliver advertising or communications tailored to your interests, we may share that information with third parties who select tailored advertising.
- Prevent and detect fraud and other credit risks by applying analytics with a goal of protecting your security and that of Flash Mobile.
- Monitor, evaluate and/or improve our Services, systems, or networks.
To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals and customers in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information collected online and offline, including information from third-party sources. We may share anonymized data with third parties for business development purposes. By using the Website and/or the Services, you agree that we are hereby licensed to collect, use, share, and store anonymized (or pseudonymized) aggregated data collected through the Website or your use of the Services for benchmarking, analytics, metrics, research, reporting, machine learning, and other business purposes.
Customer Proprietary Network Information
You have a right, and Flash Mobile has a duty, under applicable law, to ensure the confidentiality of CPNI. CPNI is a subset of the personal information that is generated in connection with the telecommunications services we provide to our customers. CPNI includes, for example, call detail records, call location information, technical configuration, and information about your rate plans and features. Subject to your permission, Flash Mobile may use your CPNI to market additional communications and data products and services similar to the types currently purchased from us. For example, Flash Mobile may market, among other products and services:
- Wireless Internet access;
- New messaging products;
- Interactive service;
- Ringtones, wallpapers, or games;
- Handsets or related equipment; and / or
- Web-based services (e.g., photo sharing on the Net).
Again, subject to your permission, Flash Mobile may contact you to market additional products and services we and our partners sell.
Flash Mobile also discloses your CPNI as required by law (see “Information We Share” below). And, to provide service, we may use and disclose CPNI to our agents and independent contractors, but we restrict their use and limit disclosure of CPNI for purposes of providing service or to market products and services as previously described. We will also prohibit the third party from further disclosing the CPNI except as required by law and will require the third party to implement safeguards to protect the confidentiality of the CPNI.
Information We Share
Related Parties and Service Providers.
Group Account Holders.
We may offer group accounts to business and government customers, family customers and other group account holders (“Group Accounts”). The account holder for Group Accounts is the entity or person that buys the service or product for its employees, family members or other authorized users. You (as the user of a device) may receive service, certain pricing, terms, or other benefits through a Group Account with us. We may share with the Group Account holder customer registration and other information related to your use of our services.
Other Third Parties with Your Consent.
We may share information with other third parties with your consent. For example, you may agree to our sharing your information with other third parties to hear about their products and services. Use of the information you agree to share will be subject to those third parties’ separate privacy policies.
Disclosures to Third-Party Application and Service Providers.
Information may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, information may also be transferred as a business asset.
Protection of Flash Mobile and others.
We may access, monitor, use or disclose your information or communications to:
- Comply with the law or respond to lawful requests or legal process;
- Respond to emergencies;
- Initiate, render, bill, and collect for services; or
- Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement, or determine eligibility for government benefits.
We design our systems with your security and privacy in mind. While no method of processing, transmission, or storage is 100% secure, Flash Mobile has instituted robust security measures to provide protection to your data. Therefore, despite our efforts, we cannot guarantee its absolute security. WE DO NOT WARRANT OR REPRESENT THAT PERSONAL INFORMATION ABOUT YOU WILL BE PROTECTED AGAINST, LOSS, MISUSE, OR ALTERATION BY THIRD PARTIES.
- We work to protect the security of your personal information during transmission by using reasonable encryption protocols and software.
- We and our trusted vendors follow and attest to our compliance with the Payment Card Industry Data Security Standard (PCI DSS) with respect to credit and debit card data.
- We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may ask to verify your identity before we disclose personal information to you.
- It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications. We recommend using a unique password for your Flash Mobile account (should you have one) that is not used for other online accounts. Be sure to sign off when you are finished using a shared computer. Never share your password with anyone and contact us immediately if you believe your password has been compromised.
- Flash Mobile will never request sensitive personal information through email. Do not respond to emails requesting credit information, account numbers, passwords or PINs. Call Flash Mobile to verify the legitimacy of the email.
Information Choices And Changes
Whether you are a visitor to an ACN site or have an account in a self-service portal, you have options as to how your information is used that you can select.
- As described above, you can choose not to provide certain information, but then you may not be able to take advantage of specific services, have fulfilled certain products, or receive support.
- You can add or update certain information on pages within your account profile if you have an account with Flash Mobile.
- You may register a do-not-contact request by calling customer care or sending an email to customer care at the email address specified on our site. If you do not want to receive email or other communications from us, please adjust your preferences in the self-service portal relevant to your relationship status with ACN. You can also opt-out from ACN promotional emails by selecting the unsubscribe link in the footer.
- If you register a do-not-contact request, we may still contact you for non-promotional purposes, such as emails about your accounts or our ongoing business relations.
- If If you want to browse our websites without linking the browsing history to your account, you may do so by logging out of your account and blocking cookies on your browser.
- You will also be able to opt out of certain other types of data usage by updating your settings on the applicable ACN site(s) or application.
- Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.
In addition, to the extent required by applicable law, you may have the right to request access to or delete your personal information. If you wish to do any of these things, please contact the ACN Privacy Officer. Depending on your choices regarding cookies and privacy settings, certain services may be limited or unavailable.
Children and Flash Mobile
Flash Mobile does not sell services or products for purchase by children. This site is not directed to children, and Flash Mobile does not knowingly collect information from children under 13 without verifiable parental consent. If you are under 18, you may use Flash Mobile only with the involvement of a parent or guardian.
Conditions Of Use, Notices, and Revisions
Updates to This Policy
California and Other State Consumer Privacy Act Supplemental Notice
Effective January 1, 2020
Last Updated January 1, 2023
Information We Collect About You
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“Personal Information”). Specifically, our Website has collected one or more data elements listed in the following categories of Personal Information designated with “Yes” in the “Collected” column within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes|
|B. Personal Information Categories.|
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, solutions purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geo-location data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
|L. Equipment information.||Information about your internet connection, the equipment you use to access our Website, and usage details.||Yes|
Personal information does not include:
- Publicly available information from government records.
- Aggregated or deidentified consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), other similar state laws or clinical trial data (only in the case of employees); and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act (DPPA) of 1994.
Flash Mobile will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Our Business Purposes
We use the personal information we may have about you to accomplish our business purposes, including:
- To conduct data analysis (e.g., to improve the efficiency of our services);
- To conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
- To monitor for fraud and security purposes; for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- To develop new products and services;
- To consider ways for enhancing, improving, or modifying our current products and services;
- To identify usage trends; for example, understanding which parts of our services are of most interest to users;
- To determine the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities; for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Your Information
We do not sell, share, trade, or rent User’s Personal Information to others and we have not done so during the preceding twelve (12) months.
- Our subsidiaries and affiliates; Our contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
- A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Flash Mobile’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Flash Mobile about our Website users is among the assets transferred;
- The purpose for which you provide it;
- Any other purpose disclosed by us when you provide the information; and
- Your consent.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Flash Mobile has disclosed the following categories of personal information for a business purpose: (A) Identifiers, (D) Commercial Information, (F) Internet or Other Similar Network Activity.
Right to Know and Data Portability Rights
You have the right to request that Flash Mobile disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable request (see Exercising Right to Know, Data Portability, Correction and Deletion), we will disclose to you:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business purpose for collecting that Personal Information;
- The categories of third parties with whom we share that Personal Information;
- The specific pieces of Personal Information we collected about you (also called a Data Portability request); and
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Right to Correction
You have the right to request that ACN correct inaccurate information that it maintains about you. Once we receive and confirm your verifiable request (see Exercising Right to Know, Data Portability, Correction, and Deletion), we will confirm the correction, if applicable and appropriate. ACN may deny a request to correct if it “determines that the contested personal information is more likely than not accurate based on the totality of the circumstances.”
Deletion Request Rights
You have the right to request that Flash Mobile delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete, and direct our service providers to delete, your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to accomplish any of the following.
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law. .
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) or other similar state laws.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the right to know, data portability, and deletion described above, please submit a verifiable request to us by either:
- Submitting a request at ACN Communication Services, LLC, ATTN: Privacy Officer, 1000 Progress Place, Concord, NC 28025-2449; or
- Sending an email to email@example.com.
Only you, or a person properly authorized to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.
Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
We will not discriminate against you for exercising any of your CCPA or other state privacy rights. Unless permitted by CCPA or other state privacy laws, as applicable, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of services, products, or support; or
- Suggest that you may receive a different price or rate or a different level or quality of services, products, or support.
However, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Right to Appeal
If you believe that ACN has failed to take appropriate action in response to your privacy rights requests or you believe that we have denied your request improperly, you may appeal by contacting our Privacy Officer, 1000 Progress Place, Concord, NC 28025-2449; or firstname.lastname@example.org.
Retention of Your Personal Information
We may retain your personal information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements. We strive to retain your personal information no longer than is reasonably necessary to carry out the purposes listed in this Notice or as required by law.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. To make such a request, please submit a request at email@example.com.
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