SUMMARY – POLICY OVERVIEW
2. What Categories of Information We May Process
This Policy explains how we may Process your information. This Policy may be amended
updated from time to
time, so please check it regularly for updates.
Telecom Technology Services Incorporated, its other affiliates and its subsidiaries (collectively,
” or “we
”), owns, operates, or provides access to, several interactive
websites, mobile and
applications, and other online interactive features and services, including, but not limited to, emails,
newsletters, chat areas, forums, and communities (collectively “Services
information collected about you by TTS Inc through and in relation to the Services, regardless of how it is
collected or stored, and describes, among other things, the types of information collected about you when
interact with the Services, how your information may be used, when your information may be disclosed, how
can control the use and disclosure of your information, and how your information is protected.
Data Protection Regulation (“GDPR”)) and the Brazilian General Data Protection Law
means that we decide how and why the information you provide to us is processed. Please contact us using
DSAR Portal. This Policy may be amended or updated from time to
time to reflect changes in our practices
respect to the Processing of your information, or changes in applicable law. We encourage you to read
Policy carefully, and to regularly check this page to review any changes we might make.
SUMMARY – CATEGORIES OF INFORMATION WE MAY PROCESS
3. Sensitive Personal Information
We may Process: your personal details (e.g., your name); your contact details (e.g.,
your email address);
records of your consents; details of your employer (where relevant); information about your
our content; and any views or opinions you provide to us.
We may also Process information about you from your use of our Services (e.g., the type of device
the internet service provider, etc.), including your interactions with content on the Services.
” means information that is about any individual, or from which any individual
or indirectly identifiable.
” or “Processed
” means anything that is done with any Personal
Information, whether or
by automated means, such as collection, recording, organization, structuring, storage, adaptation or
retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available,
or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:
- Personal details: your name; username or login details;
or topics of interest; and
(if you or another user posts a photo on the Service).
- Demographic information: salutation; job title, company
- Contact details:postal address; telephone and/or mobile number;
- Consent records: records of any consents you may have given,
with the date and time, means of
and any related information (e.g., the subject matter of the consent).
- Location information: location data that describes the precise
geographic location of your device
- Employer details: where you interact with us in your capacity as
employee, the contact information
employer (including name, address, telephone number and email address) to the extent relevant.
- Views and opinions: any views and opinions that you or other
choose to send to us, including but
limited to feedback on third party services, or publicly post about us on social media platforms or
Services, including on forums.
We also collect other kinds of information from you or other sources, which we refer to as “Other
in this Policy, which may include but is not limited to:
- Information about your use of the Services, such as usage data and
statistical information, which may be
- Browsing history including the websites or other services you visited
before and after interacting with
- Searches for and interactions with e-commerce opportunities, such as
merchants and offers contained in the
- Non-precise information about the approximate physical location (for
example, at the city or zip code
of a user’s computer or device derived from the IP address of such computer or device (“GeoIP
- Device identification (“ID”), which is a distinctive number
with a smartphone or similar
device but is different than a hardware serial number.
- Internet Protocol (“IP”) address, which is a unique string of
automatically assigned to your
whenever you access the Internet.
- Internet connection means, such as internet service provider
mobile network operator, WiFi
connection, service set identifier (“SSID”), International Mobile Subscriber Identity
Mobile Equipment Identity (“IMEI”).
pixel tags, device ID tracking,
identifiers and other technologies, including information collected using such methods and
(i) your visits to, and interaction and engagement with, the Services, applications, platforms and
channels (“Channels”), and (ii) your interaction with emails including the content therein
- Device type, settings and software used.
- Log files, which may include IP addresses, browser type, serving mobile
operator, operating system,
stamps and/or clickstream data, network serving cells, network performance checks taken, and general
network performance data.
- Web Beacons, which are electronic files that allow a website to count
users who have visited that page or
access certain cookies.
- Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web
bugs, which are a method for passing
information from the user’s computer to a third-party website.
- Local Shared Objects, such as Flash cookies, and Local Storage, such as
- Mobile analytics to understand the functionality of our mobile
applications and software on your phone.
Under certain circumstances and depending on applicable law, some of this Other Information may
Personal Information. Personal Information together with Other Information is hereinafter referred
SUMMARY – SENSITIVE PERSONAL INFORMATION
4. How We Collect or Create Information
We do not seek to collect or otherwise Process your Sensitive Personal Information.
Where we need to Process
your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable
Services are not intended for use by children.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions,
religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any
or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under
GDPR or LGPD (collectively, “Sensitive Personal Information
”) in the ordinary course of our business.
becomes necessary to Process Sensitive Personal Information under GDPR or LGPD, we would rely on one of the
following legal bases:
Compliance with applicable law: We may Process your Sensitive Personal Information where
required or permitted by applicable law;
Detection and prevention of crime: We may Process your Sensitive Personal Information
necessary for the detection or prevention of crime (including the prevention of fraud);
Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal
the Processing is necessary for the establishment, exercise or defense of legal rights; or
Consent: We may Process your Sensitive Personal Information where we have, in accordance
obtained your prior, express consent prior to Processing your Sensitive Personal Information.
The Services are not intended for use by children, especially those under 13. No one under
13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under
age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the
Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your
children disclose information about themselves in our public discussion areas, consequences may occur that
not intended for children (for example, they may receive unsolicited messages from other parties). If it is
discovered that we have collected Personal Information from someone under 13, we will delete that
SUMMARY – COLLECTION AND CREATION OF INFORMATION
5. Purposes for Which We May Process Your Information
Collection of User Information:
We may collect or obtain User Information about you: directly from you (e.g., where
you contact us); in the
course of our relationship with you (e.g., if you make a purchase); when you make your Personal
public (e.g., if you make a public post about us on social media); when you download, install, or
use any of our
Services; when you visit our Services; or when you register to use any part of the Services. We may
User Information about you from third parties (e.g., social network sites). We may also create User
about you, such as records of your interactions with us. TTS Inc is not responsible for Personal
volunteer about yourself in public areas of the Services. This Policy does not cover the practices
parties who may provide information about you to TTS Inc.
We may collect User Information about you from the following sources:
Data you provide: We may obtain your Personal Information when you provide it to us across
where you sign up for emails, newsletters, bulletins, webinars or white papers; register for
site membership or
create a profile or account on any part of the Services; enter a sweepstakes, contest,
competition or prize
draw; receive promotional information by SMS text message; participate in surveys; perform
through the Services; contact us via email, telephone or by any other means; purchase a
license or product; or when you provide us with your business card, etc.).
Relationship data: We may collect or obtain your Personal Information in the ordinary
relationship with you (e.g., if you purchase a service from us).
Data you make public: We may collect or obtain your Personal Information that you clearly
public, including via social media (e.g., we may collect information from your social media
profile(s) if you
make a public post about us) or through our chats, forums or communities on the Services.
Service data: We may collect or obtain your Personal Information when you visit, download,
use any part of our Service.
Mobile Trace by TTS Inc: When conducting a test and uploading to the web portal on any
collect: (a) the test results; (b) non-precise information about the approximate physical
location of your
computer or device-derived from GeoIP Data and/or Precise Location Data (if your mobile device
it); and (c) Other Information, including, but not limited to, the IP address, the ISP, college
that operates the network you test, and network, hardware and device identifiers such as your
SSID or IMEI (if
the test is conducted on a smartphone). If you install Mobile Trace on your smartphone or other
TTS Inc may collect your Precise Location Data, both while you are running a test and when the
not actively in use but is running in the background on your device.
Third-party information: We may collect or obtain your Personal Information from third
who provide it
to us. This may include offline channels such as through telephone or direct mail efforts; from
vendors, suppliers, third parties, commercially available or publicly available sources (e.g.,
data aggregators, public databases, etc.); third party affiliate network operators; referral
network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party
log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership
or profile on
any part of the Services, access our content or forward our content to another person, platform
or service, we
may also receive your username or email address for those third party services or other
about you or collected from you on those services.
Please note that TTS Inc is not responsible for the information you volunteer about yourself in the
in any public areas of the Services, such as comments sections, forums, blogs, wikis, chat rooms, private
messages, message boards or other publicly accessible interaction, or information that you choose to make
in any user profile of yours or other areas of the Services that allow users to upload or post content. We
discourage users from posting such Personal Information in this fashion. You can change your publicly
information at any time via your profile page. To request removal of your Personal Information from these
please contact us via email: firstname.lastname@example.org
. In some
cases, we may not be able to remove your
Information, in which case we will let you know we are unable to do so and why.
to TTS Inc.
Creation of User Information
. We may also create User Information about you, such as records of your
interactions with us and details of your purchase history, for internal administrative purposes and
may also combine data you have provided to us with data obtained from third parties such as social networks
other data collection entities.
SUMMARY – PURPOSES FOR WHICH WE MAY PROCESS YOUR INFORMATION
6. Direct Marketing
We may Process User Information for the following purposes: providing the Services to
you; communicating with
you; analyzing engagement with our audience; observing user engagement and purchase activity across
and Channels; offering business-to-business lead generation services; offering Mobile Trace to test
network connectivity offering TechInsights to manage workflow delivery; marketing our services and
current and prospective customers; managing our IT systems; financial management; conducting
the security of our systems; conducting investigations where necessary; compliance with applicable
improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:
Provision of the Services to You: providing the Services to you from TTS Inc or its partners
chat areas, forums and communities, (ii) posting of your personal testimonial alongside other
(iii) display of your personal reviews of products or services, (iv) allowing you to search for
members using information you may already know about that member such as username, full name or
and identify users matching that criteria, (v) management of your account, and (vi) customer
Offering and Improving the Services: operating and managing the Services for you;
content to you; communicating and interacting with you via the Services; identifying issues with
and planning improvements to or creating new Services; and notifying you of changes to any of
Surveys: engaging with you for the purposes of obtaining your views on our Services.
Communications: communicating with you via any means (including via email, telephone, text
media, post or in person) regarding news items and other information in which you may be
interested, subject to
ensuring that such communications are provided to you in compliance with applicable law;
updating your contact information where appropriate; and obtaining your prior, opt-in consent
where required. We
may provide direct marketing to you as set out in Section 6 below.
Audience Engagement: identification and development of audience engagement, and
various platforms and channels, both within the Service and on Channels.
User Engagement: tracking activity across the Service and on Channels, including review of
history (if available); provision of analytics and measurement of cost of traffic against money
Lead Generation: business-to-business lead generation in the provision of leads to
customer’s target marketing campaigns and services through different strategies. This includes
through phone calls and email newsletter marketing to drive you to content, such as white papers
offered by TTS Inc, whereupon your contact information will be shared with our customer.
Mobile Trace Offerings: Mobile Trace by TTS Inc are offered on multiple devices, products
as an extension on your web browser or as applications in certain products such as routers. It
enables you to
test the network coverage, performance, speed, latency and other primary network characteristics
of your mobile
network connections and be provided with the results. Your Mobile Trace results may be used by
TTS Inc to
conduct analyses and prepare product enhancements, as well as to prepare market reports. TTS Inc
Mobile Trace results, including any feedback you submit in connection therewith, to its business
Inc also licenses the Mobile Trace applications to business customers who wish to have their end
their own networks’ internet connectivity or, in the case of Mobile Trace to test an end user’s
between a product and a network of servers.
TechInsights: TechInsights is offered on multiple devices, products, and platforms.
on outages of third-party services, including anonymous reporting of outages directly to
on TechInsights, social media posts regarding outages, and Other Information. TechInsights
enables users to view
the status of the third-party services it tracks. TTS Inc licenses TechInsights data to its
Marketing to Customers: We may market to current and prospective customers and their
indicated an interest in doing business with, or have previously conducted business with, TTS
Inc in order to
further generate and promote our business. Such efforts include sending marketing emails or
calls to drive the purchase of additional Services, Mobile Trace and TechInsights licensing,
lead generation and
other business services offered by TTS Inc.
IT Administration: administration of TTS Inc’s information technology systems; network and
administration; network and device security; implementing data security and information systems
compliance audits in relation to internal policies; identification and mitigation of fraudulent
compliance with legal requirements.
Security: electronic security measures (including monitoring of login records and access
mitigate the risk of and provide the ability to identify and rectify a security incident.
Financial Management: general business and financial management purposes, including
administrative management; planning and reporting; personnel development; sales; accounting;
audit; and compliance with legal requirements
Investigations: detecting, investigating, and preventing breaches of policy, and criminal
accordance with applicable law.
Legal Proceedings: establishing, exercising, and defending legal rights.
Legal Compliance: Subject to applicable law, we reserve the right to release information
concerning any user
guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal
activity, and to release
information in response to court and governmental orders, other requests from government
subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We
also may release
information about users when we believe in good faith that such release is in the interest of
rights, property, safety or security of TTS Inc, any of our users or the public, or to respond
to an emergency.
SUMMARY – DIRECT MARKETING
7. Cookies and Similar Technologies
We may Process your User Information to contact you with information regarding
services that may be of interest
to you. You may unsubscribe for free or opt out of SMS messages at any time.
We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods
communication to provide you with information regarding the Services that may be of interest to you. We may
information to you regarding the Services, upcoming promotions and other information that may be of interest
you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included
every email we send. We will not send you any emails from a list you have selected to be unsubscribed from,
we may continue to contact you to the extent necessary for the purposes of any other Services you have
or for additional emails you have signed up for.
SUMMARY – COOKIES AND SIMILAR TECHNOLOGIES
8. What is the Lawful Basis for Processing Personal Information
We may Process your User Information by placing or reading Cookies and similar
technologies on the Services and
us to assign
a unique identifier to you and relate information about your use of the Services to Other
Information about you,
including your User Information for the purposes of learning more about you so we can provide you
content. We and our partners also use these technologies to analyze trends; administer the Services;
store information such as user settings, anonymous browser identifiers and video viewing history;
our server logs and other methods of traffic and response measurement; track users’ location and
around the Services; gather demographic information about our user base; and to improve our
traffic on the Services, visitor behavior, and responses to promotional campaigns.
track users’ movements around the Services and on third party sites, devices and applications, and to gather
but if you choose to disable cookies, it may limit your use of certain features or functions on the
the different types of cookies used on the Services, and how to change or delete them.
Tracking technologies on the Services may be deployed by TTS Inc and/or by our service providers or
Certain tracking technologies enable us to assign a unique identifier to you and relate information about
use of the Services to other information about you, including your User Information. We may match
collected from you through different means or at different times and use such information along with offline
online information obtained from other sources (including from third parties), including, but not limited
demographic information and updated contact information, for the purposes of learning more about you so we
provide you with relevant content and Services.
When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs
similar technologies to determine whether the email has been opened and which links you click in order to
provide you with more focused email communications or other information, and/or to aggregate that
We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers)
may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash
cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user
settings, anonymous browser identifiers and video viewing history; supplement our server logs and other
of traffic and response measurement; track users’ location and movements around the Services; gather
information about our user base; and to improve our understanding of traffic on the Services, visitor
and responses to promotional campaigns. We may receive reports based on the use of these technologies by
third-party companies on an individual and aggregated basis. For example, we may connect information about
IP address to known corporate or User Information and use the associated information related to aggregate
content preferences to assist in our efforts to market services to you or the originating corporation(s).
Various browsers may offer their own management tools for removing Local Storage. To manage Flash Local
Objects please click here.
We may use mobile analytics software to collect data and to better understand the functionality of our
software, devices and applications on your phone and other devices. This software may record information
how often you use the application, the events that occur within the application, aggregated usage,
data, and where the application was downloaded from. We may link this information to User Information.
SUMMARY – LAWFUL BASIS FOR PROCESSING USER INFORMATION
9. What Information We Disclose to Third Parties
We may Process your User Information where: you have given your consent; the Processing is necessary
contract between you and us; the Processing is required by applicable law; the Processing is
protect the vital interests of any individual; or where we have a valid legitimate interest in the
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on
or more of the following legal bases, depending on the circumstances:
- Consent: We may Process your User Information where we have
your prior, express consent to the
Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it
for Processing that is necessary or obligatory in any way);
- Contractual necessity: We may Process your User Information where
Processing is necessary in
with any contract that you may enter into with us;
- Compliance with applicable law: We may Process your User
where the Processing is required by
- Vital interests: We may Process your User Information where the
Processing is necessary to protect the
interests of any individual; or
- Legitimate interests: We may Process your User Information where
a legitimate interest in carrying
the Processing for the purposes of managing, operating, improving or promoting our business, and
interest is not overridden by your interests, fundamental rights, or freedoms.
As described above, we have identified legitimate interest as the basis for processing in connection with
Mobile Trace offerings by TTS Inc and how we market our business to our current and prospective customers.
For Mobile Trace and TechInsights, TTS Inc has a legitimate interest in sharing your submitted log results
mobile network operators, hardware manufacturers and industry regulators to help them understand and create
better and faster mobile network experience.
SUMMARY – DISCLOSURE OF USER INFORMATION TO THIRD PARTIES
10. International Transfers of Information
We may disclose your User Information to: legal and regulatory authorities; our
external advisors; parties who
Process User Information on our behalf (“Processors”); any party as necessary in connection with
proceedings; any party as necessary for investigating, detecting or preventing criminal offences;
of our business; and any third party plugins or content used on the Services.
We may disclose your User Information to other entities within the Company group, for legitimate business
purposes (including operating the Services, and providing services to you), in accordance with applicable
In addition, we may disclose your User Information to:
- legal and regulatory authorities, upon request, or for the purposes of
reporting any actual or suspected
breach of applicable law or regulation;
- outside professional advisors (such as accountants, auditors, or
lawyers), subject to binding contractual
obligations of confidentiality;
- third party Processors (such as analytic providers; data centers; etc.),
located anywhere in the world,
subject to the requirements noted below in this Section 9;
- any relevant party, law enforcement agency or court, to the extent
necessary for the establishment, exercise
or defense of legal rights;
- any relevant party for the purposes of prevention, investigation,
detection or prosecution of criminal
offences or the execution of criminal penalties, including safeguarding against and the prevention
of threats to
- any relevant third-party acquirer(s), in the event that we sell or
transfer all or any relevant portion of our
business or assets (including in the event of a reorganization, dissolution or liquidation);
- any sponsors of contests, competitions, sweepstakes and prize draws, or
white papers, webcasts or other
downloads, the registration data for such events is to be used by us as part of User Information,
and may be
your information with third party vendors involved in the administration of such events. For
competitions, sweepstakes and prize draws, please read the official rules or terms and conditions
before you submit your information; and
(e.g., third party providers of goods
and services, marketing and advertising companies and agencies, content publishers and retailers).
For some of our Services, we may make some information, such as the name of our users, their mailing
phone number, email address—and in certain circumstances their employer’s name, company size and other
data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for
example, when such information is provided in connection with webcasts, white papers or other sponsored
When you use a co-branded service (a service operated with a partner of TTS Inc), or register or otherwise
provide information on a co-branded site, you grant us permission to pass the collected information back to
partner, which may include third-party service providers whose services are embedded into and/or appear
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the
they take the survey. Otherwise, we will disclose only aggregate information regarding its users’ responses
surveys to other participants in the survey. Where surveys allow users to submit written comments, and where
Inc advises users of the possibility of such disclosure at the time they take the survey, TTS Inc reserves
right to disclose any information provided by users, provided that no user Information identifying a
user is disclosed.
We may also sell or transfer Online Data to certain third parties such as mobile network operators who will
this data for network evaluation purposes. Some of these third parties may combine the Online Data with
own data about you to form a more detailed picture.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data
the providers are required to maintain the confidentiality of this information. These third-party providers
collect User Information from our Services for their own purposes, including but not limited to monitoring
around the web.
We may also engage third parties for the purpose of recognizing our users and delivering interest-based
to them. We may share your User Information with our partners such as your name, postal address, email, or
identifier. Our partners may also: (i) collect information directly from your device, such as your IP
device ID, advertising ID, and information about your browser or operating system; (ii) combine User
about you received from TTS Inc with information about you from other sites or services; and (iii) place or
recognize a unique cookie on your browser.
Except as otherwise described herein, the information we gather from all tests and services run through TTS
is collected anonymously and then aggregated to provide performance data to users on the TTS Inc websites,
including its Mobile Trace and TechInsights server hosts, and/or to third parties to whom we license the
information. The only Mobile Trace results we license to third parties are those test results from instances
Mobile Trace which are made available pursuant to a user belonging to a specified third-party within their
Information collected through Mobile Trace may not be anonymous as follows: for some ISPs and mobile
TTS Inc will provide full IP addresses and/or network, hardware or device identifiers for such ISP or mobile
carrier’s customers upon request. TTS Inc may also provide full IP addresses and/or network, hardware and
identifiers, to equipment manufacturers and core network, or wholesale providers on a case-by-case basis for
network research purposes. TTS Inc may also collect GeoIP Data and/or Precise Location Data, and such data
also be licensed and/or transferred to third-parties.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to
contractual obligations to: (i) only Process the User Information in accordance with our prior written
instructions; and (ii) use measures to protect the confidentiality and security of the User Information;
together with any additional requirements under applicable law.
The Services contain links to other sites or partners whose information practices may be different from
SUMMARY – INTERNATIONAL TRANSFERS OF INFORMATION
11. Data Security
We may transfer your Personal Information to recipients in other countries. Where we
transfer User Information
from the European Economic Area (“EEA”) to a recipient outside the EEA that is not in an adequate
we do so on the basis of standard contractual clauses.
Because of the international nature of our business, we may need to transfer your User Information within
TTS Inc group of companies, and to third parties as noted in Section 9 above, in connection with the
set out in this Policy. For this reason, we may transfer your User Information to other countries that may
different laws and data protection compliance requirements to those that apply in the country in which you
Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not
jurisdiction that has been formally designated by the European Commission as providing an adequate level of
protection for Personal Information, we do so on the basis of standard contractual clauses. You may request
copy of the relevant standard contractual clauses via email at email@example.com
Please note that when you transfer any Personal Information directly to a Company entity established outside
EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process
Personal Information, from the point at which we receive the data, in accordance with the provisions of this
”) Cross Border Privacy Rules System. To learn more about this program, please click here
Please note that we may use data collected by a third-party operator/licensee of localized versions or
SUMMARY – DATA SECURITY
12. Data Accuracy
We implement appropriate technical and organizational security measures to protect
your User Information. Please
ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User
Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure,
access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In
instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a
readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are
responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely
secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the
security of your data transmitted to us using the internet. Any such transmission is at your own risk, and
are responsible for ensuring that any Personal Information that you send to us are sent securely.
SUMMARY – DATA ACCURACY
13. Data Minimization
We take every reasonable step to ensure that your User Information is kept accurate
and up-to-date and are
erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that your User Information that we Process is accurate and, where
necessary, kept up to date, and any of your User Information that we Process that you inform us is
(having regard to the purposes for which they are Processed) is erased or rectified.
SUMMARY – DATA MINIMIZATION
14. Data Retention
We take every reasonable step to limit the volume of your User Information that we
Process to what is necessary.
We take every reasonable step to ensure that your User Information that we Process is limited to the User
Information reasonably necessary in connection with the purposes set out in this Policy or as required to
provide you services or access to the Services.
SUMMARY – DATA RETENTION
15. What Can I Do to Control My Information?
We take every reasonable step to ensure that your User Information is only retained
for as long as they are
needed. Online Data related to OBA is kept by TTS Inc for not more than 365 days after which it will
subject to certain conditions.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period
necessary for the purposes set out in this Policy. The criteria for determining the duration for which we
keep your User Information are as follows: we will retain copies of your User Information in a form that
identification only for as long as is necessary in connection with the purposes set out in this Policy,
applicable law requires a longer retention period. Unless there is a specific legal requirement for us to
the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
Inc retains historical Mobile Trace data in connection with the following purposes identified in Section 5
above: conducting analyses and preparing product enhancements, preparing market reports, and licensing the
Mobile Trace results and to its business customers. TTS Inc may also retain historical Mobile Trace data for
archiving purposes in the public interest, scientific or historical research purposes or statistical
more than 365 days after which it shall expire. However, the 365 day period may commence again if the same
subsequently visits or interacts with an email, the Services or a Channel.
SUMMARY – WHAT CAN I DO TO CONTROL MY INFORMATION?
You can directly take steps to change your preferences for newsletters and online
content as outlined in this
If you are an EU resident, you may have certain rights including: the right not to provide your
Information to us; the right of access to your Personal Information; the right to request
inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal
right to object to the Processing of your Personal Information; the right to have your Personal
transferred to another controller; the right to withdraw consent; and the right to lodge complaints
supervisory authorities. We may require proof of or need to verify your identity before we can give
You may directly take steps to change your preferences as follows:
Access to Your Personal Information. Upon request TTS Inc will provide you with information about whether we
hold any of your personal information. You may access, correct, or request deletion of your personal
by logging into your account or contacting us via email at firstname.lastname@example.org
. We will respond to your
request within a reasonable timeframe.
Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list
any time by following the instructions at the end of the newsletters or emails you receive. Please allow
ten business days for changes to take effect. On some Services, member service-related communications are an
integral part of such Services to which you subscribe, and you may continue to receive emails as part of
particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or
email list. If you have provided more than one email address to us, you may continue to be contacted unless
request to unsubscribe each email address you have provided.
Cookies and Pixel Tags
. You may stop or restrict cookies and pixel tags on your computer or purge
your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable
pixel tags, although you may still use the Services, you may not be able to use all of the features,
or services available on the Services.
Location Based Services
. You may opt-out of having your Precise Location Data collected by TTS Inc at
by editing the appropriate setting on your mobile device (which is usually located in the Settings area of
Mobile Trace App
. To turn off the automated log upload feature of the Mobile Trace application, go to
settings features within the Mobile Trace application and switch the automatic log upload feature to “Off.”
Please note if your smartphone or mobile device settings do not allow transmittal of Precise Location Data,
certain features may not be available, or their functions may be limited.
. In accordance with the California Online Privacy Protection Act, we may collect
Information about your online activities when you use the Services. While we give our users many avenues to
out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals.
“Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to
periodically request and obtain certain information about any Personal Information disclosed to third
for direct marketing purposes. If you are a California resident and wish to make such a request or if you
for us to refrain from gathering your Personal Information, please submit your request in writing to the
details set out in Section 17 below.
. GDPR provides certain rights for EU residents. You may decline to share certain
us, in which case we may not be able to provide some of the features and functionality of the Services.
rights include, in accordance with applicable law, the right to object to or request the restriction of
processing of your information, and to request access to, rectification, erasure and portability of your own
information. Where we process your information on the basis of your consent, you have the right to withdraw
consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the
date on which we receive notice of such withdrawal and does not prevent the Processing of your Personal
Information in reliance upon any other available legal bases). Requests should be submitted by contacting us
. If you are an EU resident and
have any unresolved privacy concern that we
not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU
Authority and lodge a complaint.
. LGPD provides certain rights for Brazilian residents. You may decline to share
information with us, in which case we may not be able to provide some of the features and functionality of
Services. These rights include, in accordance with applicable law, the right to object to or request the
restriction of processing of your information, the right to request the deletion, blocking or anonymization
your information, if you believe we are processing your information in an unnecessary, excessive or
non-compliant manner, the right to request information about the entities with which we have shared your
information and to request access to, rectification, erasure and portability of your own information. Where
process your information on the basis of your consent, you have the right to withdraw that consent (noting
such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we
notice of such withdrawal and does not prevent the Processing of your Personal Information in reliance upon
other available legal bases). Requests should be submitted by contacting us by emailing
If you are a Brazilian resident and have any unresolved privacy concern that we have not addressed
satisfactorily after contacting us, you have the right to petition against the controller before the
17. Contact Details
SUMMARY – CONTACT DETAILS
18. California Consumers
You may contact us at the addresses set out below or by emailing
Telecom Technology Services Incorporated
Attention: Legal Department
7901 Stoneridge Drive, Suite 500
Pleasanton, CA 94588
If you are an EU or Brazilian resident, you may contact our Data Protection Officer or submit GDPR or LGPD
related inquiries by emailing email@example.com
If you have any comments, questions, or concerns about any of the information in this Policy, or any other
issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
Telecom Technology Services Incorporated
Attention: Legal Department
7901 Stoneridge Drive, Suite 500
Pleasanton, CA 94588
SUMMARY – CALIFORNIA CONSUMERS
The California Consumer Privacy Act (“CCPA) provides certain rights for California
consumers. If you are a
consumer residing in California, the following additional terms apply to you.
- Right to Know About Information Collected, Disclosed or Sold
You have the right to request that we disclose what personal information we collect, use, disclose,
and sell. To
submit a verifiable request, please email firstname.lastname@example.org.
If you have an account with us, we will verify the request by confirming the email address used to
request is the same as the email address on file for the account. If you do not have an account with
us, we will
verify the request by sending an email to the email address used to make the request. We may ask for
information reasonably related to the request to verify the request.
- Collection of Personal Information
The categories of California consumers’ Personal Information we may collect are listed above in
Section 2 (“What
Categories of Information We Process”). In reference to Section 2, we may collect Personal Details,
Information, Contact Details, Consent Records, Location Information including Precise Location Data,
and Payment Details, Employer Details, Views and Opinions. We also collect other kinds of
information from you
or other sources, which we refer to as “Other Information” in this Policy. As detailed in Section 2,
include, but is not limited to, information about your use of, visits to and interaction and
engagement with the
Services, content and Channels, all of which may be aggregated; browsing history; and searches for
interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
We may collect California consumers’ Personal Information from the sources listed in Section 4 (“How
User Information”). As defined in Section 4, this may be: Data You Provide; Relationship Data; Data
Public; Service Data; Content and Advertising Information; Third Party Information; Mobile Trace
data if you
submit a data collection log. We may obtain personal information from the following sources as
Section 2 (“What Categories of Information We Process”): GeoIP Data; ID; IDFA; IP address; ISP;
IMEI; Log files; Web Beacons; Pixel Tags; Local Shared Objects, such as Flash cookies, and Local
as HTML5, and equivalents.
We use this data for the purposes listed above in Section 5 (“Purposes for which we may Process your
Information”) or for Direct Marketing as outlined in Section 6 (“Direct Marketing”).
Disclosure or Sale of Personal Information
We may and may have disclosed or sold the categories of Personal Information listed in Section 9
Information We Disclose to Third Parties”) for a business or commercial purpose.
We may and may have disclosed Personal Information to the following categories of third parties for
other entities within the Company group for a legitimate business
purpose such as operating the Services
providing the Services to you;
third party Processors for the purpose of providing the Services to
third party providers where our Services use third party plugins or
third party providers to assist with the collection, storage and
segmentation of Online Data;
We may have disclosed or sold Personal Information to the following categories of third parties for
purpose or a commercial purpose:
third parties for the purpose of recognizing our users and delivering
interest-based content to them. We
share your User Information with our partners such as your name, postal address, email, or other
partners may also: (i) collect information directly from your device, such as your IP address,
advertising ID, and information about your browser or operating system; (ii) combine User
received from TTS Inc with information about you from other sites or services; and (iii) place or
unique cookie on your browser;
third party providers of goods and services on a rental or other basis
for some of our Services when
information (such as the name of our users or email address - and in certain circumstances their
name, company size and other industry data) is provided in connection with webcasts, white papers or
If you run a Mobile Trace log, ISPs and mobile carriers may receive
full IP addresses and/or network
or devices identifiers for such ISP or mobile carrier’s customers upon request. Equipment
network or wholesale providers may also receive full IP addresses and/or network, hardware and
identifiers on a case-by-case basis for network research purposes. Third parties may receive GeoIP
Precise Location Data.
The Services are not intended for use by minors. We do not sell personal information of minors under
age without affirmative authorization.
d. Right to Request Deletion of Personal Information
You have the right to request deletion of Personal Information collected or maintained by us. To do
submit a request via email email@example.com. If
submitting a request by email, we may ask for
information to verify your request.
e. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of Personal Information by a business. To do so, please
request via email firstname.lastname@example.org. If submitting a request by email, we may ask for
information to verify your request.
f. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have the right not to receive discriminatory treatment by the business for exercising your
conferred to you by the California Consumer Privacy Act.
To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a
authorization letter from the consumer to email@example.com
h. Contact for More Information
If you have any questions or concerns about our privacy policies and practices, you may contact us
effective at the time we post
the terms and conditions that apply to you.