Privacy Statement

Last Updated: 09 January 2024

Important Information and Who We Are

Incident Management Group, Inc. (IMG) respects our clients’ and users’ privacy and is committed to protecting their personal data. This Privacy Policy has been updated to reflect the new and additional requirements of the General Data Protection Regulation (“GDPR”).

This Privacy Policy sets out how we safeguard personal data whenever that information is provided to us when you use our websites, products and services. This Privacy Policy provides details about how your personal information is collected and used by us.

Personal information is any information that identifies you or would enable someone to contact you, which may include your name, email address, phone number and other non-public information that is associated with such information. It does not include aggregate information, anonymous information or any other non-personally identifiable information.

This Privacy Policy applies to IMG websites, www.TheIMG.com and www.TheIMG.com/blog/, www.GlobalSecur.com and www.GlobalSecur.com/blog/, www.FoneTrac-go.com and www.IMGsecurity.net (“Websites”).

Incident Management Group, Inc. and IMG GlobalSecur, Inc. are headquartered in the United States of America. And located at 10097 Cleary Boulevard, Suite 700, Plantation, FL 33324 USA. For the purposes of European Directive 95/46/EC and applicable national implementing laws in your jurisdiction, with respect to your data, we are a data controller and with respect to your contacts’ information, we are a data processor.

This policy should be read along with our applicable Terms and Conditions of website use.

The Data We Collect About You

This privacy notice provides information on how IMG collects and processes client and other personal data, including any data you may provide through our websites. Personal information is any information that identifies you or would enable someone to contact you, which may include your name, email address, phone number and other non-public information that is associated with such information.

We are the sole owner of information collected on the Websites (including any metadata), except for information that you provide to us in connection with your use of our products and services. We collect information only as necessary to fulfill the purposes set forth in this Privacy Policy and we will only use this information as described in this Privacy Policy.

We do not share personal information with others except as necessary to fulfill a requested assignment or obtain requested information for an existing or potential client. In these circumstances, personal data may be provided to a primary business partner who has enacted stringent data protection and compliance measures.

We may communicate with you regarding your use of our existing services, to provide technical assistance, or to inform you of other services that may be of interest. We may aggregate and anonymize information received to produce reports on trends and statistics.

We do not record telephone conversations with clients or others, except with the agreement of participants that a conversation will be recorded. We will only use or share a username and/or password to enable service, or for the purpose of assisting in site or service use or resolving a technical issue. User names and passwords will not be shared with others, except under the aforementioned circumstances.

When you register, browse, become a subscriber or submit a contact form on one of the aforementioned Websites, you are invited to provide us with your personal data or personal information (any information about an individual from which that person can be identified). This does not include data where the identity has been removed (anonymous data). This includes when you request services or information from us, contact us (or we contact you), purchase products or services from us, use our websites or connect with us via social media, or link to or from our websites.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes billing address, home address, email address and telephone numbers.
• Location Data includes your geographic location. As part of our travel security services, we will be made aware of your exact geographic location. We do not have access to your location on a continuous basis, but only when you instigate contact with us using one of the of the communication features provided as part of your service. As a result of actions by you that indicate an emergency situation, we will continue to monitor your current location and instigate appropriate communications until the situation is resolved.
• Financial Data includes payment, credit or debit card details.
• Transaction Data includes details about products and services you have bought from us, and details about your purchase history, including payments received, and when you have requested information or raised queries, subscription history, including personal data about the emergency contact(s) you specified when subscribing.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website/or any apps.
• Profile Data includes your username and password, products and services bought by you, queries, feedback and survey responses.
• Usage Data includes information as to how you use our Websites.
• Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

If You Do Not Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a contract you have with us, but we will notify you if this is the case at the time.

How is Your Personal Data Collected?

We collect data from and about you in different ways, including through:

Your direct dealings with us

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via one of our Websites, apps or otherwise.

This includes personal data you provide when you:

• subscribe to our Daily Intelligence Briefing (DIB) and/or other publications;
• request promotional or marketing materials to be sent to you;
• register as a subscriber on one of our Websites;
• buy products and/or services via one of our Websites;
• ask us for help and give us feedback.

Automated technologies or interactions

As you interact with our Websites, we may collect Profile and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see below for some further details.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Websites and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Websites.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Websites.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Websites.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Comments

If visitors are able to leave comments on the Websites and do leave comments, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website. In addition, if you upload a photo or image to be used as your Avatar, this photo may be publicly visible to anyone.

Site Cookies

If you leave a comment on our Websites you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to one of our Websites, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on one of our Websites may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These other websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

reCAPTCHA Data

The reCAPTCHA SPAM protection feature analyzes traffic, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM. Google reCAPTCHA is a SPAM protection service provided by Google Inc. The use of reCAPTCHA is subject to the Google privacy policy and terms of use. You acknowledge and understand that the reCAPTCHA API works by collecting hardware and software information, such as device and application data, and sending these data to Google for analysis. The information collected in connection with your use of the Websites (such as cookies and usage data) will be used for improving reCAPTCHA and for general security purposes. It will not be used for personalized advertising by Google.

YouTube

We have embedded YouTube videos on some of our Websites, which allow you to view content hosted on external platforms directly from the pages of the Websites and interact with them. The embedded videos might still collect web traffic data for the pages where they are installed, even when users do not use it. YouTube is a video content visualization service provided by Google Inc. that allows our Websites to incorporate content of this kind on its pages. The personal Data collected includes cookies and usage data and the place of processing is in the United States. Please see Google’s Privacy Policy for more information.

Zoho

We use Zoho and associated plugins to collect user-submitted data and pass it to our CRM. By submitting a form on our site, you agree to allow us to collect your information. In addition, we use a LiveChat feature on our site for user convenience. Your IP address is one of the pieces of data collected as part of this feature as well as any information submitted. You can learn more about Zoho’s LiveChat here.

Yoast SEO Data

The Yoast SEO plugin we use on some of our Websites only collects information regarding a site’s environment, PHP version, and installed plugins.

Wordfence Data

We use the Wordfence plugin on some of our Websites to help with site security. To help you understand which cookies the Wordfence plugin sets, when in use on our Websites, please click below. Wordfence currently sets three cookies and the below explains what each cookie does, who will have the cookie set, and why the cookie helps secure our Websites. You can read Wordfence’s privacy policy here.

wfwaf-authcookie-(hash)

What it does: This cookie is used by the Wordfence firewall to perform a capability check of the current user before one of our Websites has been loaded.
Who gets this cookie: This is only set for users that are able to log into our Websites.
How this cookie helps: This cookie allows the Wordfence firewall to detect logged in users and allow them increased access. It also allows Wordfence to detect non-logged in users and restrict their access to secure areas. The cookie also lets the firewall know what level of access a visitor has to help the firewall make smart decisions about who to allow and who to block.

wf_loginalerted_(hash)

What it does: This cookie is used to notify the Wordfence admin when an administrator logs in from a new device or location.
Who gets this cookie: This is only set for administrators.
How this cookie helps: This cookie helps site owners know whether there has been an admin login from a new device or location.

wfCBLBypass

What it does: Wordfence offers a feature for a site visitor to bypass country blocking by accessing a hidden URL. This cookie helps track who should be allowed to bypass country blocking.
Who gets this cookie: When a hidden URL defined by the site admin is visited, this cookie is set to verify the user can access the site from a country restricted through country blocking. This will be set for anyone who knows the URL that allows bypass of standard country blocking. This cookie is not set for anyone who does not know the hidden URL to bypass country blocking.
How this cookie helps: This cookie gives site owners a way to allow certain users from blocked countries, even though their country has been blocked.

Site Backups – UpdraftPlus

We use the UpdraftPlus plugin on some of our Websites as one of the ways we perform site backups. We will not delete information out of our website backups, because this becomes technically difficult to accomplish. However, our backups are stored in a safe place, including Google Drive. Please see this page for more information specifically on this. These links also offer additional information on the Google Privacy Policy and on UpdraftPlus.

Site Backups – Hosting Provider

Our hosting provider also provides us with backup functionalities for some of our Websites.

WooCommerce

We collect information about you during the checkout process on our store.

What we collect and store

While you visit our www.FoneTrac-Go.com site, we’ll track:

• Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
• Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
• We’ll also use cookies to keep track of cart contents while you’re browsing this site.

When you purchase from us, we’ll ask you to provide information including your name, billing address and country, email addresses, phone numbers, emergency contact name and phone numbers, credit card/payment details and account information like username and password. We’ll use this information for purposes as detailed in “How We Use Your Personal Data” below.

If you create an account, we will store the contact information you’ve submitted, which will be used to provide the services you have purchased. We generally store information about you for as long as we need the information for the purposes for which we collect and use it. We may also store comments or reviews, if you choose to leave them.

Who on our team has access

IMG team members have access to the information you provide us. For example, both Administrators and Shop Managers can access:

• Order information like the services that were purchased and when they were purchased, and
• Customer information like your name, email address, company or other organization and emergency contacts.

Our team members have access to this information to help manage the purchased services and support you.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Websites.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. We anonymize this data to monitor the use of our Websites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Websites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/.

Behavioral Remarketing

We do not use remarketing services to advertise on third party websites to you after you visited our Websites.

Google AdWords

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/.

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.

Third Parties

Certain functions on our Websites may permit interactions between our Websites and a third-party website or interactive service (“Social Features”). If you choose to use Social Features (e.g., the “like button, share this card on Facebook”), certain information, which may include your personal information, may be publicly displayed, and the third-party website or interactive service used in connection with the Social Features (and its users) may have access to information about you and your use of our Websites.

Our Websites may also contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you. You have the right to withdraw consent at any time by contacting us.

• By phone number: (954) 458-5500
• By mail: 10097 Cleary Boulevard, Suite 700, Plantation, FL 33324 USA
• By email: [email protected]

Purposes for Which We Will Use Your Personal Data

We have set out below a description of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

In the course of your use of our products or services or visit to the Websites, we may also obtain the following information about you:

• Information about you will only be gathered as a result of your request to us for service information. We will use this information to respond to your request.
• Information that you provide during any voluntary or mandatory registration process (such as first and last name, company name, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services;
• Payment information that you provide to us (on our websites or otherwise) when you purchase some of our products and services, including credit card data;
• Data relating to your service activity purchased from us (such as your geographic location that will be necessary for us to provide you with the purchased services).
• The information that we obtain in places within our infrastructure and in the cloud environment. These platforms include secure platforms such as Microsoft Azure, Office 365, and Dynamics 365.

We may use any of this information to offer and improve our products and services, to provide you with requested information or technical support, to facilitate your movement through the Websites or your use of our products and services, to do a better job of advertising and marketing our products and services, to diagnose problems with our servers or our products and services, in connection with our security and compliance programs, to administer our Websites, to communicate with you, to target prospective customers with our products or services, to assist us in offering you a personalized experience or otherwise tailor our Websites, product and service offerings to you, or as otherwise described in this Privacy Policy.

We may aggregate and anonymize information received to produce reports on trends and statistics, such as search trends, or the number of users that have been exposed to, or clicked on, our Websites. Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services. We will only use the username, password and other contact information provided to us to enable the correct functioning of the services that you purchase from us.

When we refer to legitimate interests, we mean the interest of our business in conducting and managing our business to enable us to give you the best service and products. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Disclosures of Your Personal Data

We may have to share your personal data with the categories of parties set out below:

• Credit card companies and other payment processors;
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Analytics (like Google Analytics) and search engine providers that assist us in the improvement and optimization of our services and Websites;
• Professional advisers, including lawyers, banks, auditors and insurers;
• Governmental organizations, regulators and other authorities.

Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. Some of the third parties mentioned above (like professional advisers and payment processers), are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own Privacy Policies setting out how they deal with personal data.

We may share your information with others within your organization (including any affiliates or any other individuals designated as users by you).

With your consent, we may obtain and post testimonials or reviews for inclusion on our Websites or elsewhere. Your posts may remain even after you suspend or cancel your account. Reviews and contributions to any of our social accounts or public communities are considered public and non-confidential by us and are not treated as proprietary information or personal information covered by this Privacy Policy. To request removal of your personal information on the public portions of our Websites, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Lastly, we may disclose your personal information to courts, law enforcement authorities and other relevant third parties, such as internet service providers, when such disclosure is necessary or advisable, in our sole discretion, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be: violating our terms and conditions of use; causing injury or other harm to, or otherwise violating our property or other legal rights, or those of other users or third parties; or violating federal, state, local, or other applicable law. This disclosure may include transferring information to parties outside the U.S. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.

International Transfers

We are headquartered in the United States of America. Personal information may be accessed by us or transferred to us in the United States or to our affiliates (including other members of the Incident Management Group, Inc. and IMG GlobalSecur, Inc. family), partners, or service providers elsewhere in the world. By providing us with personal information, you consent to this transfer. We will protect the privacy and security of personal information according to this Privacy Policy, regardless of where it is processed or stored, however you acknowledge and consent to the fact that personal information stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your personal information. Any third-party controllers/processors we use, like United Healthcare Global, will have their own privacy policies and you may want to review their documentation for more information on how your personal data will be used by them.

For the purposes of European Directive 95/46/EC and applicable national implementing laws in your jurisdiction, with respect to your data, we are a data controller.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Processors we appoint will only process your personal data on our instructions and they are subject to a duty of confidentiality.

You should be aware, however, that transmission of information via the internet is not completely secure.

If any suspected personal data breach is discovered, we will notify you and any applicable regulator of a breach where we are legally required to do so.

Security and Privacy

We employ reasonable technical, administrative and physical safeguards to protect the confidentiality and security of your personal information. We use industry-recognized technical safeguards and have confidence that the methods of data usage and storage capabilities and the implemented security procedures on the platforms mentioned above will protect your information from loss, misuse or unauthorized alteration. When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.

Notwithstanding our own efforts and those of our service providers, we cannot guarantee absolute or unqualified protection of this information given the open nature and resulting instability of the Internet and World Wide Web, and we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches or any failure in the security of your computer equipment, your internet service provider or other networks and communications providers.

Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different types of your personal data are available by request from us by contacting us. In some circumstances you can ask us to delete your data by following the “Request Erasure” right as outlined below.

For users that register for our services on a secure website, we store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time. Website administrators can also see and edit that information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

You have rights under data protection laws in relation to your personal data, including:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. If we are not be able to comply with your request for erasure for specific legal reasons, we will tell you at the time of your request. In addition, we will be unable to erase personal data collected about you that’s part of our email records or stored in website backup files.
• Object to processing of your personal data where we are relying on our legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.

We will try to respond to all legitimate requests within one month.

California Residents – Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request from us certain information regarding the disclosure of certain categories of personal information to third parties for their direct marketing purposes within the immediately preceding calendar year. A company may also comply with the law by disclosing in its Privacy Policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes (as we do), and information on how to exercise that choice.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You might include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

If you are a California resident under the age of 18, and a registered user of one of the Websites, California Business and Professions Code Section 22581 permits you to request and obtain removal of content that you have publicly posted. To make such a request, please contact us with a detailed description of the specific content. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information that you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

Marketing Communications / Opt-Out

You have a choice about how we use your personal information to communicate with you, and you may opt out at any time by unsubscribing or changing your preferences. You always have the opportunity to opt-out of our marketing communications with you or change preferences by emailing us at [email protected].

Some communications (for example, important account notifications and billing information) are considered transactional and are necessary for all of our subscribers. You must cancel your account, as applicable, to unsubscribe from these communications. To cancel your account, please send us an email to [email protected] with a request about canceling your account / subscription. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

How To Update Your Information

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

You can review and update some of your account information on our www.FoneTrac-go.com site by logging into your account through the link at https://www.fonetrac-go.com/my-account/ with your username and password. If you have any questions, please send us an email at [email protected].

If you would like to suspend or cancel your account, request that we no longer use your account data or obtain further information about or access to your personal information, you can do so by contacting us.

Children

Registration on these Websites are not intended for children, and we do not knowingly collect information from persons younger than the age of thirteen (13). We would ask parents please to ensure that their children under the age of 13 do not provide us with personal information without your permission. If we learn that we have inadvertently collected information from a person younger than the age of 13, we will seek to delete that information from our databases.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via a prominent notice on our Websites and update the “last updated” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. In all cases, your continued use of any of our Websites or our products and services constitute consideration and your binding acceptance to any such changes.

Contacting Us

Questions, comments and requests regarding this Privacy Policy are welcomed and you can contact us in the following ways:

• By phone number: (954) 458-5500
• By mail: 10097 Cleary Boulevard, Suite 700, Plantation, FL 33324 USA
• By email: [email protected]