Following are terms you will see in our policy.
Aggregate Information: Information that we combine into anonymous groups of customers or users. These groups are large enough to reasonably prevent individuals from being identified.
Anonymous Information: Information that doesn’t directly identify and can’t reasonably be used to identify an individual customer or user.
Customer: Anyone who purchases or uses our products or services. When a customer purchases retail products or services for use by others, for instance family members, those family members also are customers.
Mobile Application: A software application that runs on smartphones, tablet computers or other mobile devices and that allows users to access a variety of services and information.
Personal Information: Information that directly identifies or reasonably can be used to figure out the identity of a customer or user, such as your name, address, phone number and e-mail address. Personal Information does not include published listing information.
Relevant Advertising: Uses aggregate information about groups of people (like age, ethnicity, income range, where those groups live and work, and their interests) to develop advertising that is more likely to be useful to that group. It does not use individual data about what a specific person might like.
User: Anyone who visits our website or uses our mobile applications.
Website: And other terms like “Internet site,” “site” and “web page” all mean the same thing, namely any page or location on the Internet, no matter what device (cell phone, tablet, laptop, PC, etc.) or protocol (http, WAP, ftp or other) is used to access the page or location. Our website is www.MySpareOne.com.
SCOPE OF THIS POLICY
Information not covered by this Policy includes any information you give to companies other than SpareOne. Some examples are:
- When you subscribe to a cellular service in order to use your SpareOne device.
- When you go to a non-SpareOne website from our website or applications (by clicking on a link or an advertisement, for example);
- Information about your location, usage and the numbers you dial available to your cellular network provider, including when you are out and about and roaming on the network of another company;
THE INFORMATION WE COLLECT, HOW WE COLLECT IT AND HOW WE USE IT
We may collect different types of information based on your use of our products and services and on our business relationship with you.
- Contact Information that allows us to communicate with you. We get this information when you order or register for our services. This would include information like your name, address, telephone number and e-mail address.
- Billing Information related to any financial relationship with us, such as the services we provide to you, the telephone numbers you call and text, your payment history, your credit history, your credit card numbers, Social Security number, security codes and your service history.
- Technical & Usage Information related to the services we provide to you, including information about how you use our network, services, products or website.
- Location Information includes your ZIP-code and street address, as well as the whereabouts of your wireless device. Location information is generated when your device communicates with cell towers and/or with other technologies, including the satellites that comprise the Global Positioning System.
We collect information in three basic ways:
- You Give It To Us when you set up an account with us or when you make a purchase from us;
- We May Also Obtain Information from Outside Sources like credit reports, marketing mailing lists, and commercially available geographic and demographic information.
We use your information to improve your experience and to make our business stronger. Examples might include:
- Providing and managing your services, responding to your questions and addressing problems;
- Delivering customized content, Relevant Advertising and personalized offers for products and services that may be of interest to you;
- Communicating service updates, offers and promotions;
- Conducting research and analysis for maintaining, protecting and developing our services;
- Investigating violations of our Terms of Service, Acceptable Use Policies, or other service conditions or restrictions; and
- Protecting the safety of any person.
We do not give listing information for wireless numbers to phone book publishers or directory assistance services without your permission.
We share your Personal Information internally within our affiliated companies. Our products and services are developed, managed, marketed and sold by a variety of affiliated companies. Sharing this information helps us offer you the high quality, seamless and innovative range of products you have come to expect from us.
We will only share your Personal Information with other companies for them to use for the marketing of their own products and services when we have your consent.
We share your Personal Information with companies that perform services for us. Because we take our responsibility to safeguard your Personal Information seriously, we do not allow those companies to use it for any purpose other than to perform those services, and we require them to protect it in a way consistent with this Policy.
Companies that perform these services may be located outside the United States or the jurisdiction where you reside. If your Personal Information is shared with these companies, it could be accessible to government authorities according to the laws that govern those jurisdictions.
There are also occasions when we provide Personal Information to other companies or other entities, such as government agencies, credit bureaus and collection agencies, without your consent. Some examples include sharing to:
- Comply with court orders, subpoenas, lawful discovery requests and other legal or regulatory requirements, and to enforce our legal rights or defend against legal claims;
- Obtain payment or make refunds for products and services that appear on applicable SpareOne billing statements, including the transfer or sale of delinquent accounts or refund obligations to third parties for collection or payment;
- Enforce our agreements and protect our rights or property,
- Assist with identity verification and e-mail address validation;
- Notify, respond or provide information (including location information) to a responsible governmental entity in emergency or exigent circumstances or in situations involving immediate danger of death or serious physical injury; and
INFORMATION & ADVERTISING
We may use information like the preferences you have expressed and interests you have demonstrated on our website and through use of our products and services to provide you with marketing information and advertisements for SpareOne products and services. Those ads may be delivered on our website and mobile applications. This is called “first party” advertising. It is part of our service relationship and you are not able to opt-out from this type of advertising.
Our advertising affiliates and advertising partners may also use anonymous information gathered through cookies and similar technologies, as well as other anonymous and aggregate information that either of us may have to help us tailor advertising.
SpareOne may also use information we get through your use of our products and services, from our advertising partners, and information like your age and gender to deliver Relevant Advertising.
We are careful to create Relevant Advertising with aggregate audience segments that are large enough that you can’t be identified individually.
SpareOne may use information about the locations you visit in order to create combined wireless location interest characteristics that can be used to provide Relevant Advertising to you and others like you.
Location information includes your ZIP-code and street address, as well as the whereabouts of your wireless device.
Location information is used in various ways, including:
- Location Based Services (LBS): Your device can be used to access services based on location. We’ll give you prior notice and ask for your consent when your location is used or shared. The form of consent may vary, but will be appropriate for the type of SpareOne LBS you use.
- LBS from other providers: With your consent (to us or the other company) we also may enable LBS from other companies by providing location information to their developers or location service providers.
- Advertising. As described in above section “Information and Advertising” we may utilize anonymous location information.
The accuracy of wireless location information can vary considerably depending upon the technology utilized and the actual location. For example, we can locate your device based on the cell tower that’s serving you. The range could be up to 1,000 meters in any direction from the tower in urban areas, and up to 10,000 meters in rural areas.
Other companies may also be able to locate your device. For example, cellular network providers may be able to locate your device.
AGGREGATE AND ANONYMOUS INFORMATION
Sometimes we’ll collect information about how you use our products using cookies and other similar technologies. This information doesn’t include your Personal Information and is considered anonymous.
When we collect information that identifies you personally, we may anonymize it for certain purposes. We remove data fields (such as name, address and telephone number) that can reasonably be used to identify you. Anonymizing information is one of the tools we use to protect your privacy.
We may share aggregate and anonymous information with other companies and entities for specific uses, which may include:
- Universities, laboratories, think tanks and other entities that conduct networking, social, behavioral, environmental and other types of scientific research, for the purpose of creating fundamental new knowledge;
- Municipalities, government or other entities that may use this data for purposes such as municipal and transportation planning, and emergency and disaster response coordination.
We may also share this information in external reports.
We do not knowingly collect personally identifying information from anyone under the age of 13 unless we first obtain permission from the child’s parent or legal guardian.
Internet and wireless devices and services purchased for family use may be used by children without our knowledge. When that happens, information collected may appear to us to be associated with the adult customer who subscribes to our services and will be treated as the adult’s information under this Policy.
DATA PROTECTION AND SECURITY
We do not sell your Personal Information to anyone, for any purpose.
We keep your Personal Information as long as we need for business, tax or legal purposes. After that, we destroy it by making it unreadable or undecipherable.
We’ve established electronic and administrative safeguards designed to make the information we collect secure. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of your Personal Information. Some examples are:
- Maintaining and protecting the security of computer storage and network equipment, and our security procedures require employee user names and passwords to access sensitive data;
- Applying encryption or other appropriate security controls to protect Personal Information when stored or transmitted by us;
- Limiting access to Personal Information to only those with jobs requiring such access; and
- Requiring caller/online authentication before providing Account Information so that only you or someone who knows your Account Information will be able to access or change the information.
- Although we strive to keep your Personal Information secure, no security measures are perfect, and we cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Policy).
We will make reasonable attempts to notify you if we determine that we have experienced a security breach and there is a reasonably likely risk of identity theft, or where otherwise required by law.
We are happy to help you review and correct the Personal Information we have associated with your account and billing records. Please contact us.
Information about our customers and users, including Personal Information, may be shared and transferred as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which customer and user records would be transferred to another entity as a result of such a proceeding.
YOUR CHOICES & CONTROLS
Because first party advertising is part of the service you receive when you visit our website and use our mobile applications, we don’t offer an opt-out for first party advertising.
We realize that unwanted marketing contacts can be a hassle and we’ve worked hard to meet the expectations of customers and potential customers who have expressed a desire to limit certain types of solicitation communications from us.
E-Mail: Every marketing e-mail we send contains instructions and a link that will allow you to stop additional marketing e-mails for that product or service type. By unsubscribing once we will eliminate you from all of our company e-mail marketing.
Text Messages: Opt-out of SpareOne marketing text message contacts by replying “stop” to any message.
SpareOne Consumer Telemarketing: Ask to be removed from our consumer telemarketing lists by contacting us through the contact form on www.MySpareOne.com. You also can ask the SpareOne representative to remove you from our telemarketing lists when you receive a marketing or promotional call from us.
Federal Do Not Call: The FTC maintains a National Do Not Call Registry at donotcall.gov, and your state may maintain its own Do Not Call Registry. Putting your number on these Registries also may limit our SpareOne telemarketing calls to that number.
All of our practices are designed to satisfy state and federal legal requirements limiting marketing contacts. Those laws and regulations - such as the requirements governing the state and federal “Do Not Call” lists - generally permit companies to contact their own current and, in some cases, former customers, even when those customers are listed on the federal and state “Do Not Call” lists.
HOW TO CONTACT US ABOUT THIS POLICY
- E-mail us at email@example.com.
- Write to us at SpareOne 1621 Alton Parkway, Suite 150, Irvine CA92606
- SpareOne is a DBA of XPAL Power, Inc.
- You also have the option of filing a complaint with the FTC Bureau of Consumer Protection, using an online form, or by calling toll-free 877.FTC.HELP (877.328.4357; TTY: 866.653.4261). Other rights and remedies also may be available to you under federal or other applicable laws.
The effective date of this policy is: March 12, 2015.