PRIVACY POLICY

August 8, 2018

California Internet, L.P. DBA GeoLinks (“GEOLINKS”) is committed to protecting the privacy of customers and users of GEOLINKS’ website, www.GeoLinks.com, GEOLINKS’ Services, and any other GEOLINKS offering. By purchasing, subscribing to, or using GEOLINKS’ services or website, Customer agree to the terms and conditions set forth in this Policy. For other terms and conditions that govern Customer’s use of GEOLINKS’ services and its website, please review GEOLINKS’ Terms and Conditions.

INFORMATION GEOLINKS COLLECTS. GEOLINKS shall collect personally identifiable information, including but not limited to name, physical address, email address, telephone number, credit card information, and other personal information (collectively, “PII”), from Customers when initiating service and in connection with the provision or marketing of products and services. GEOLINKS may collect PII from Visitors in connection with any visit to GEOLINKS’ Websites, any communication about GEOLINKS’ services and products, or other transactions or interactions with GEOLINKS.

GEOLINKS may also collect non-personally identifiable information from Customers and Visitors regarding usage of GEOLINKS’ services or GEOLINKS’ Website (“Non-PII”). Non-PII may include Website pages viewed, time spent using certain services, demographic data, cookies, and other information which does not specifically identify any one individual.

“Cookies” are pieces of information that may be placed on Customer’s computer by a Website for the purpose of facilitating and enhancing Customer’s communication and interaction with that Website. Many Websites use cookies for these purposes. GEOLINKS may use cookies to customize Customer’s visit to GEOLINKS’ Websites and for other purposes to make Customer’s visit more convenient or to enable GEOLINKS to enhance GEOLINKS’ service.

In addition to GEOLINKS’ cookies, GEOLINKS and its vendors and contractors may also use clear gifs, Web beacons, and third-party cookies to improve the performance of GEOLINKS’ Websites, provide certain features such as advertising, or to anonymously track usage of GEOLINKS’ Websites and the online activity of users. In addition, GEOLINKS may use such devices in GEOLINKS’ HTML-based emails to track the usage of such emails in much the same manner as usage of GEOLINKS’ Websites is tracked.

Customer may stop or restrict the placement of cookies on Customer’s computer, including third party cookies, or flush them from Customer’s browser by adjusting Customer’s Web browser preferences, in which case Customer may still use GEOLINKS’ Website, but it may interfere with some of its functionality.

USE OF PERSONALLY IDENTIFIABLE INFORMATION. GEOLINKS’ Internal Use: In general, GEOLINKS uses personally identifiable information to serve GEOLINKS’ existing and prospective customers and to enhance and extend GEOLINKS’ customer relationships. By understanding how Customer uses GEOLINKS’ services and GEOLINKS’ website, GEOLINKS is able to customize and personalize GEOLINKS’ interactions with you. More specifically:

  • GEOLINKS uses personally identifiable information for billing purposes, to provide services or complete transactions Customer has requested, to anticipate and resolve problems with Customer’s services, and to create and inform Customer of products or services from GEOLINKS or others that better meet Customer’s needs.
  • Subject to Customer’s agreement, GEOLINKS uses e-mail, telemarketing, and direct mail to inform Customer about GEOLINKS products or services GEOLINKS thinks will interest you. If Customer does not wish to receive these types of communications Customer can choose at any time not to continue receiving them by contacting GEOLINKS at [email protected]
  • GEOLINKS uses mobile device information to conduct anonymous mobile analytics so GEOLINKS has a better idea on how Customer interacts with Customer’s mobile device.
  • To allow Customer to capture and upload Customer’s profile picture, the application needs access to the camera. GEOLINKS does not use this information for any purposes except for the designed use as mentioned here.
  • To allow Customer to select a picture from Customer’s photo gallery and upload it to use the fax service and/or update Customer’s profile picture. GEOLINKS does not use this information for any purposes except for the designed use as mentioned here.
  • GEOLINKS sends push notifications from time to time for Customer to get call alerts.

While Customer may choose not to receive marketing information from us, Customer will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. Customer will also continue to receive communications directly related to each service Customer purchases or subscribes to.

GEOLINKS’ Customer Surveys: Periodically, Customer may be able to participate in GEOLINKS’ surveys to help GEOLINKS improve its services. Any personally identifiable information that GEOLINKS may collect from Customer in a survey will ONLY be used internally by GEOLINKS. And unless otherwise explained in the instructions for a particular customer survey, any personally identifiable information Customer provides to GEOLINKS for purposes of that survey will be used in accordance with this Policy.

DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION. Because information about GEOLINKS’ existing and prospective customers is one of GEOLINKS’ most important business assets, GEOLINKS seeks to protect it and keep it confidential. GEOLINKS does not share personally identifiable information with unaffiliated third parties, nor does GEOLINKS sell it to third parties, unless permitted to do so in accordance with this Policy.

Customer’s Consent: GEOLINKS may disclose Customer’s personally identifiable information and sensitive information if Customer consents to the disclosure in advance. Depending on the service, GEOLINKS may obtain Customer’s consent in a number of ways, including:

  • In writing;
  • Verbally;
  • Online, by clicking on a link or button; or
  • Through the use of a dialing string or buttons on a telephone handset.

In general, GEOLINKS may release personally identifiable information without Customer’s consent when GEOLINKS believes release is appropriate to do one of the following:

  • Comply with the law or a lawful government request (e.g., lawful subpoena or court order);
  • Enforce or apply GEOLINKS’ agreements to sell or provide services to Customer or enforce compliance with website policies;
  • Bill and collect for services; or
  • Protect or defend GEOLINKS’ legal rights and property, the interests of customers and website users, and the rights of third parties (e.g., to address allegations about fraudulent or unlawful activity on a GEOLINKS account);
  • Protect health and safety of users or general public in an emergency.

Disclosure to Affiliates:  GEOLINKS may share Customer’s personal data between GEOLINKS and business affiliates where it is necessary to support the services provided to you.

In order to verify payment methods and prevent fraud, GEOLINKS verifies personally identifiable information, including payment information, with payment providers and fraud prevention services. If at any time Customer applies for a credit line with GEOLINKS, GEOLINKS may perform a credit inquiry with credit reporting agencies, and such inquiry may be noted on Customer’s credit record. GEOLINKS may use automated decision-making systems to verify payment methods, assess creditworthiness, or prevent fraud, and GEOLINKS may contact Customer requesting additional information when needed.

Disclosure to Unaffiliated Third Parties: GEOLINKS may share personally identifiable information with unaffiliated third parties only as necessary to complete a transaction or perform a service that Customer has requested, or to support the technical operation and maintenance of GEOLINKS’ services and of GEOLINKS’ website. GEOLINKS may also share personally identifiable information with or to GEOLINKS’ agents, outside vendors or service providers to perform functions on GEOLINKS’ behalf. For example, GEOLINKS uses third party service providers to perform functions such as analyzing data, providing marketing assistance, providing customer service and processing orders. When the unaffiliated third-party acts solely on GEOLINKS’ behalf, GEOLINKS requires that party to follow GEOLINKS’ privacy practices. GEOLINKS does not sell its customer lists or any personally identifiable information associated with its customers to third parties.

Business Transfers: Information about GEOLINKS’ users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of GEOLINKS.

Emergency Calls: If Customer dials for emergency services (e.g., 911 in the U.S.), GEOLINKS may provide personally identifiable location information to a public safety answering point; emergency medical service provider or dispatch provider; public safety, fire service, or law enforcement official; hospital emergency or other medical care facility; or to a service provider that provides such information to such emergency responders.

CUSTOMER PROPRIETARY NETWORK INFORMATION (VoIP Customers). In the normal course of providing telecommunications and interconnected voice-over-Internet-protocol (“interconnected VoIP”) services to its users and customers, GEOLINKS collects and maintains certain customer proprietary network information (“CPNI”). Customer’s CPNI includes the types of telecommunications and interconnected VoIP services Customer currently purchase or subscribe to, how Customer uses those services (for example, Customer’s calling records), and billing information related to those services. Customer’s GEOLINKS telephone number, name, and address do not constitute CPNI.

GEOLINKS would like to share Customer’s CPNI within GEOLINKS’ company and with GEOLINKS’ affiliates and authorized agents in order to offer Customer additional products and services that may fit Customer’s needs. GEOLINKS does not sell, trade, or otherwise share Customer’s CPNI with anyone outside of GEOLINKS or with anyone who is not authorized to represent GEOLINKS to offer its services or to perform functions on GEOLINKS’ behalf, except as the law may require or Customer may authorize.

Protecting Customer’s CPNI is important to us. In the United States, Federal law permits GEOLINKS to use this information to provide the telecommunications and interconnected VoIP services Customer purchases or subscribes to, and to bill and collect for those services. GEOLINKS may also use or disclose Customer’s CPNI for legal or regulatory reasons such as to respond to a court order, to investigate fraud, to protect GEOLINKS’ rights or property, to protect against the unlawful use of GEOLINKS’ services, or to protect other users. Customer has a right and GEOLINKS has a duty under federal law to protect the confidentiality of Customer’s CPNI.

In order to opt-out and restrict access to Customer’s CPNI for GEOLINKS’ own marketing purposes, please contact GEOLINKS within 30 days of this notice by emailing [email protected] Restricting GEOLINKS’ use of Customer’s CPNI will not affect GEOLINKS’ provision of any service or product to which Customer currently subscribes, nor will Customer necessarily eliminate all types of GEOLINKS marketing.

SECURITY AND DATA INTEGRITY. GEOLINKS has invested and deployed a wide variety of technology and security features to make reasonable efforts to ensure the privacy of information on its network. In addition, GEOLINKS has implemented operations guidelines to ensure Customer and Visitor privacy is safeguarded throughout its organization. GEOLINKS will continue to revise policies and implement additional security features as new technologies become available. However, no system or service can give a 100% guaranty of security, especially a service that relies upon the public Internet. Therefore, Customer acknowledges the risk that third parties may gain unauthorized access to Customer’s information when using or accessing GEOLINKS’ services and GEOLINKS’ network.

GEOLINKS’ USE OF BANNER ADS. GEOLINKS may use third-party advertising companies to place advertisements about GEOLINKS products and services on other websites. These advertising companies may use cookies, web beacons, or other technologies to measure the effectiveness of GEOLINKS’ ads. The advertising companies may use anonymous information about Customer’s visits to GEOLINKS’ and other websites in order to measure advertising effectiveness and offer selective ad content. But they use an anonymous identifier, such as a number, to identify you. They do not link to or collect any personally identifying information. The use of such cookies, web beacons, and other technologies is subject to the advertising companies’ privacy policies, not the privacy policy of GEOLINKS. GEOLINKS does not control and is not responsible for how third-party sites handle personal information of users.

SOCIAL MEDIA FEATURES. GEOLINKS’ website includes Social Media Features, such as the Facebook or Twitter button. These Features may collect Customer’s IP address, which page Customer is visiting on GEOLINKS’ site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on GEOLINKS’ Site. Customer’s interactions with these Features are governed by the privacy policy of the third-party company providing them. GEOLINKS does not control and is not responsible for how third party social media sites handle personal information of users.

REFERRAL PROGRAMS. If Customer choose to use GEOLINKS’ referral programs to refer someone to GEOLINKS’ site, GEOLINKS will ask Customer for the intended recipient’s name, email address, and phone number. GEOLINKS will store and use this information to send emails inviting him or her to visit the site. GEOLINKS stores this information for the sole purpose of sending the emails and tracking the success of GEOLINKS’ referral program. By agreeing to the terms in this privacy policy Customer acknowledges that Customer has received any referral recipient’s consent to provide his or her information to GEOLINKS. Customer’s referral may contact GEOLINKS at [email protected] to request that GEOLINKS removes this information from GEOLINKS’ database.

BLOGS AND FORUMS. GEOLINKS’ website offers publicly accessible blogs or community forums. Customer should be aware that any information Customer provides in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of Customer’s personal information from GEOLINKS’ blog or community forum, contact GEOLINKS at [email protected] In some cases, GEOLINKS may not be able to remove Customer’s personal information, in which case GEOLINKS will let Customer know if GEOLINKS is unable to do so and why. GEOLINKS is not liable for the distribution of personal information posted on a public forum. GEOLINKS encourages all users to exercise caution when providing personal information in blogs and community forums.

TESTIMONIALS. With Customer’s input and consent, GEOLINKS may post a customer testimonial by Customer on GEOLINKS’ website, which may include Customer’s name, industry, company, title, or other identifying information. If Customer wants Customer’s testimonial removed or wish to give or withdraw consent please contact GEOLINKS at [email protected]

FEEDBACK. From time to time, GEOLINKS may send Customer surveys, comment cards, customer satisfaction forms, or other requests to provide feedback. Customer hereby grants GEOLINKS, its licensors, and suppliers a perpetual, unlimited, worldwide fully-paid up, royalty free license to use all feedback, answers, ideas, comments, or other information Customer provides to GEOLINKS.

ENFORCEMENT. GEOLINKS regularly reviews its compliance with this Privacy Policy. Please contact GEOLINKS with any questions or concerns regarding this Privacy Policy or GEOLINKS’ treatment of personal information. When GEOLINKS receives formal written complaints, it is GEOLINKS’ policy to contact the complaining customer or user regarding his or her concerns.

UPDATING OF GEOLINKS’ POLICY. GEOLINKS will revise or update this Policy if GEOLINKS’ practices change or as GEOLINKS changes existing services, add new services, or develop better ways to inform Customer of services GEOLINKS thinks will interest you. If GEOLINKS makes any material changes, GEOLINKS will notify Customer by email (sent to the e-mail address specified in Customer’s account) or by means of a notice on this website prior to the change becoming effective. Customer should refer back to this page for the latest information and the effective date of any changes.