Gabb Wireless Privacy Policy

About This Privacy Policy

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Unless otherwise stated, changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice via the Sites or communication (e.g., email) at least 30 days before using your Personal Information in the new way.

Information We Collect

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Services to you. Note that this section is applicable only to the use of the sites and services intended for use by parents and adult members of the general population. See the section below titled “Children’s Privacy” for details of information collection for products and services intended for use by children. Some of the information we collect may personally identify, relate to, describe, or be capable of being associated with you (“Personal Information”), including:

• Personal identifiers and contact information such as name, mailing address, email addresses, phone numbers;
• Sensitive personal identifiers such as gender, age;
• Banking/financial information such as credit/debit card numbers and expiration date, checking account numbers;
• Commercial information such the type(s) of service subscribed to, service dates, customer type, account balance and status;
• Internet and network information such as IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system;
• Browsing and search history within the Gabb Sites;
• Geolocation data such as geographic location indicators from mobile devices, websites and customer addresses;
• Audio/visual information such as call recordings, and chat transcripts;
• Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The types of Personal Information we collect about you may vary based on how you use our Sites or Services, and your relationship with us, and may or may not include some of the categories identified above.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.

Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, your IP address, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us online or offline, including events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as consumer reporting agencies, marketing agencies and partners, analytics firms, and government agencies.

Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of our Sites may not work if you delete or disable cookies.

We use the following types of cookies:

• Session Cookies:

  Session cookies keep track of you or your information as you move from page to page within our Sites and are typically deleted once you close your browser.

• Persistent or Preference Cookies:

  Persistent or Preference cookies reside on your system and allow us to customize your experience if you leave and later return to our Sites. For example, persistent cookies may allow us to remember your preferences.

• Advertising Cookies:

  Advertising cookies are used to learn more about you and advertise products/services that might interest you.

• Analytics Cookies:

  Analytics cookies help us understand how our Sites are working and who is visiting our Sites. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.

We employ software technology that enables us to track certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses “tracking pixels.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed.

If you arrive at our Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to our Sites, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Marketing and Advertising Partners

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via our Sites or on third-party websites. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (DAA) Consumer Choice Page. The DAA website allows you to opt-out of one or more interest-based advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA’s Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising.

Information from Advertisements

If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

Social Media Widgets

The Sites may include social media features, such as Facebook, YouTube, Pinterest, LinkedIn, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.

Third Parties That Collect Information on Our Sites

Third parties, including Advertisers, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as cookies and tracking pixels. These third parties’ collection, use, and disclosure of Personal Information and/or Usage Data is governed by their data policies.

How We Use and Share Information

Generally

We use Personal Information for business purposes, such as:

Account creation, fulfillment, servicing and customer support: to create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their services, respond to questions and address customers concerns, deliver upgrade, updates and product improvement information;

Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;

Collection and credit reporting: to collect on outstanding balances, update credit reporting agencies;

Surveys, promotional events, contests: to administer surveys, polls, sweepstakes, contests, loyalty programs and other promotional events and contests;

Other company communications: to provide consumers with information that may be of interest such as company newsletters, announcements, reminders and service bulletins;

Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data (such as email and IP addresses);

Eligibility and pricing: to determine if consumers are eligible for certain products, services or offers and the pricing related to such offers;

Product and services research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;

Business operations: to evaluate, develop, and improve business operations, products and services offered, perform business administration and other normal business activities;

Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and

Information security and fraud prevention: to operate information security and anti-fraud programs.

Reviews and Testimonials

If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Service Providers

We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:

Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and perform payment processing services;

Payment processors, which help us to accept and process the payments for our products/services to you;

Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys and other outreach campaigns;

Research and development vendors, which help us develop and improve our products and services;

Data and business analytics vendors, which help us collect, analyze and improve the accuracy of our data (including Personal Information);

IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;

Professional service firms, which provide accounting, legal and other professional services; and

General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information that we provide to them other than as specified by us.

In the past twelve months, we have shared the following categories of Personal Information with at least one Service Provider: personal identifiers and contact information; sensitive personal identifiers; other demographic information; banking/financial information; commercial information; internet & network information; geolocation data; audio/visual information; professional/employment information; education information; and inferences drawn from other Personal Information or data.

Aggregate and De-Identified Information

We do not sell your information, but we may share anonymized or de-identified information about you or your use of Gabb’s products and services with third parties, as well as aggregated and anonymous information, for any number of purposes, including without limitation the improvement of the products and services we provide. Except as noted in this Privacy Policy, we will not share personally identifying information about you without your consent.

Miscellaneous

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to: respond to legal requests (including court orders, investigative demands and subpoenas); protect the safety, property, or rights of ourselves, consumers, or any other third party; prevent or stop any illegal, unethical, or legally actionable activity; or comply with laws.

Links

The Sites may contain links to third party websites including social media platforms. Please be aware that if you access these links, you will be leaving our site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. A reasonable effort will be made to provide you notice via the Sites or communication (e.g., email) at least 30 days before any such transaction occurs, as allowed by law and regulatory requirements.

Children’s Privacy

We are committed to protecting the privacy of children who use Gabb Devices and Apps. This section explains our information collection, use, and disclosure practices with respect to children under the age of 13 in compliance with the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect Personal Information from children under the age of 13 without parental or guardian consent. If you learn that a child has provided us with Personal Information, you may contact us at legal@gabb.com.

In general, Gabb Sites are not designed or intended for use by children. Children are the primary users of Gabb Devices and the included Apps, and may make use of support Services.

Parental Consent

Prior to collecting any information from children using a Gabb Device, we obtain verifiable consent directly from the child’s parent or legal guardian. Before a child may use a Gabb Device and embedded Apps, the child’s parent/guardian is required to review notice of our practices regarding the collection, use, and disclosure of children’s Personal Information.

After reviewing this notice, the parent/guardian must create a GabbID for the child. A GabbID is required to access a Gabb Device and its features, including Apps. To create a GabbID, the parent/guardian must provide a verification code sent to their registered email address. Once verification is complete, the parent/guardian will be prompted to provide certain information for the child’s Gabb ID, including the child’s full name, gender, and age.

If a parent/guardian does not consent to the collection of the child’s Personal Information, the child will not be able to use the Gabb Device.

Information Collection

Gabb collects only the Personal Information reasonably needed to provide the Gabb Device and its functionalities and features. Once a parent/guardian has activated the Gabb Device, then we may collect the following information from your child:

• Subscription information such the Apps approved and/or installed, Services subscribed to, usage statistics, and service dates;
• Photographs and videos that the child creates using the Gabb Device;
• Message content from text messages sent by the child through the Gabb Device;
• Voice recordings from videos and voice notes;
• Presets and other Gabb Device content, such as calendar entries, notes, music preferences, emojis, and assigned tasks.

Gabb Devices will also automatically collect Personal Information from children as they use the Gabb Device and Apps, including:

• Location information, including IP address and device precise location;
• Device identifiers, such as the device serial number and UDID;
• Usage habits.

Where Gabb collects persistent identifiers, such as a device serial number, we implement technical and organizational safeguards to ensure the information we collect from children is not used to contact children directly, deliver behavioral or targeted advertising, create a profile on children, or for any other purpose incompatible with the purposes described in this section or COPPA.

Additionally, when children utilize support Services, we may collect:

• Recordings of calls and text conversations with support staff;
• Feedback such as ratings, reviews, recommendations provided by the user through Apps.

Information Use

We use information collected from children to:

• Provide access to and use of the Gabb Device and Apps;
• Personalize and customize their experience on the Gabb Device and Apps;
• Operate, maintain, analyze, and improve the Gabb Device and Apps;
• Maintain the safety, security, and integrity of the Gabb Device and Apps;
• Comply with applicable legal requirements and enforce our rights and the rights of others;
• Customer support such as responding to questions and address customers concerns and delivering upgrade, update and product improvement information;
• Feedback to understand user needs.

Information Sharing

We limit disclosure of a child’s Personal Information to:

• Service providers and business partners to perform functions in connection with providing Services on Gabb Devices and Apps. We may share personal information with these providers and partners as necessary to enable them to provide services. Third parties are prohibited from using personal information for any unrelated purpose. These third parties include Verizon, Telispire, Smartcom, ZTE, Samsung and Tuned Global.
• Situations permitted by law or required by law (e.g. in response to a court order, subpoena, or law enforcement request), to establish, protect, or exercise our legal rights, or to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats.

Gabb Wireless does not sell or rent your child’s Personal Information to any third party for any purpose – including for advertising or marketing purposes.

Retention

We maintain a data retention policy that identifies the purposes for which we collect children’s Personal Information, documents our business need for retaining such information, and establishes timeframes for deletion of such information when it is no longer needed for these purposes.

In any instance, Personal Information collected from children is only retained as long as necessary to allow the child to use the Gabb Device, allow for a grace reactivation period for the Gabb Device, ensure the security of users and the Services, or as required by law. The specific timeframe for deletion will depend on the purposes for which the information is being retained.

Third-party Apps

Third-party apps that have been enabled on Gabb devices (at parents’ discretion) are subject to each app’s data privacy policy and practices, which may include the collection of a child’s personal data. These apps may collect and transmit personal data to advertisers, including children’s general location, IP addresses, and other personal data. You acknowledge that Gabb Wireless cannot control that access, and that by enabling these apps, you agree to each app’s terms and conditions. Gabb Wireless does not benefit from or have access to the data collected by third-party apps.

Parental Choices

Parents have the right to review, correct, or have deleted their child’s Personal Information and/or have the right to refuse further collection or use of a child’s Personal Information. Please note such a request may impact our ability to continue to provide the Gabb Device and Apps to your child.

If you have questions about the collection and use of children’s information or wish to make a request about your child’s Personal Information, or to withdraw consent for information collection, please contact us at legal@gabb.com.

Your California Privacy Rights

Under California Civil Code Section 1798.83, California residents may request certain information from us regarding our disclosure of personal information to third parties for their direct marketing purposes. Please see the California Privacy Notice below for more information on your rights as a California resident.

Privacy Practices Related to Employees and Job Applicants

If you apply for or accept an offer of employment, we may collect:

Personal identifiers and contact information such as name, address, social security number, driver’s license number, alien registration number, passport number;

Educational information such as educational institutions attended, degrees received, college transcripts;

Professional/employment information such as resumes, CVs, positions held, tenure, references, skill assessments;

Internet & network information browsing/search history, data collected by cookies;

Characteristics of protected classifications such as age, race, disabilities, citizenship;

Medical information such as drug test results, doctors’ notes, leave of absence forms, workers compensation forms;

Banking, financial and insurance information such as checking account and routing numbers for direct deposits, 401(k) account information, loans, mortgage documents and garnishment information, insurance policies and coverages;

Geolocation information from mobile applications and vehicles or vehicle equipment;

Beneficiary/Dependent information such as the names, social security numbers and gender of your beneficiaries/dependents;

Inferences drawn from the above categories of Personal Information that relate to your characteristics, behavior, attitudes, intelligence, abilities and aptitudes, including criminal background information and driving history.

We may use this information to evaluate candidates for initial and continued employment; conduct background checks and drug screening; communicate with you; provide training and mentoring; provide benefits, services, and accommodations; maintain company security; facilitate company policies; comply with legal and contractual obligations; and otherwise operate our business. We may disclose Personal Information to Service Providers to facilitate any of the above uses. We do not sell applicant or employee Personal Information to Third Parties.

How to contact Gabb with questions

If you have questions about this policy, please contact Gabb at:

Archived August 12, 2019 Privacy Policy