This policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
This website is not intended for children and we do not knowingly collect data relating to children.
PhoneX, Inc. is the controller and responsible for your personal data.
Collection of Information
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by postal mail, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to our publications;
- request marketing to be sent to you;
- create an account on our Website;
- inquire about or place an order for our products; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, web beacons, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. See our section on Cookies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data about you from analytics providers or search information providers such as Google.
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
Please rest assured that this Website shall only collect personal information that you knowingly and willingly provide by way of completed forms and emails, or information about the type of browser, IP address, or type of operating system you are using to assist us in providing and maintaining superior quality service. It is the intent of this Website to use personal information only for the purpose for which it was requested and any additional uses specifically provided on this Website.
It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent as a means to better understand the way in which other websites garner, make use of, and share information collected.
Use of Information Collected
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more
than one basis has been set out in the table below. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new contact, customer, or partner of the Company||(a) Identity|
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to keep our records updated and to grow our business)
|To process and deliver your order including:|
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) Necessary to comply with a legal obligation|
(b) Necessary for our legitimate business interests (to keep our records updated and to study how customers use our products)
|To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences||(a) Technical|
(c) Marketing and Communications
|Necessary for our legitimate interests (to define types of customers for our products, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business|
Promotional Offers from Us
At times, we may find it necessary to use personal data as a means to keep you informed of other possible products and/or services that may be available to you from the Website. We may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future products and/or services that may be offered. You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing, or if you have opted in to our marketing program. See our section on Unsubscribe or Opt-Out for more details.
The Company does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties.
Disclosures of Your Personal Data
We may deem it necessary to follow websites and/or pages that our users may frequent in an effort to glean what types of services and/or products may be the most popular to customers or the general public.
We may disclose your personal information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
- Remain in conformance with any decrees, laws, and/or statutes or in an effort to comply with any process which may be served upon us and/or our Website;
- Maintain, safeguard and/or preserve all the rights and/or property of the Company; and
- Perform under demanding conditions in an effort to safeguard the personal safety of users of https://www.wesellcellular.com and/or the general public.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
International Transfers of Data from the European Union
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time
Please note that certain information about your computer hardware and software and browsing actions and patterns may be collected by the Company through automatic data collection technologies as you navigate through and interact with our Website. This information is used by us for operation of our Website and our business, to maintain quality of the Website and our business, and to provide general statistics regarding use of the Website. The technologies we use for this automatic data collection may include:
- Flash cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the “Choices About How We Use and Disclose Your Information” subsection below.
- Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
The Website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you visit certain Website pages, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please see the “Choices About How We Use and Disclose Your Information” subsection below for more information about managing your computer’s settings for cookies.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Choices About How We Use and Disclose Your Information” subsection below.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. Certain mechanisms are available to you on your browser settings that provide you with the following control over your information:
- Promotional Offers from Us. If we have sent you a promotional email, you may click on the unsubscribe link at the bottom of the email to be omitted from future email distributions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s website.
Children Under the Age of 16
Our Website is not intended for children under sixteen (16) years of age. No one under age sixteen (16) may provide any personal information to or on the Website. If you are under (sixteen) 16, do not use or provide any information on this Website or through any of its
features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. The Company does not knowingly collect personal data from children under the age of sixteen (16) without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of sixteen (16), we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database. Anyone under the age of sixteen (16) must seek and obtain parent or guardian permission to use this Website.
Unsubscribe or Opt-Out
All users and/or visitors to our Website have the option to discontinue receiving communications from us and/or reserve the right to discontinue receiving communications by way of email, text messages, or newsletters. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. If you wish to unsubscribe or opt-out from any third party websites, you must go to that specific website to unsubscribe and/or opt-out.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Links to Other Web Sites
The Company has put in place appropriate security measures and shall take every precaution to maintain adequate physical, procedural, and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of the user’s personal information under our control. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We also use Secure Socket Layer (SSL) for authentication and private communications in an effort to build users’ trust and confidence in the internet and website use by providing simple and secure access and communication of credit card and personal information.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us as set forth below in How to Contact Us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Accessing and Correcting Your Information
Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Acceptance of Terms
How to Contact Us
18 West 18th StreetNew York,
New York 10011
Attn: Data Privacy Manager
Email address: firstname.lastname@example.org
Telephone number: (516) 334-6400
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties are other companies in our company group acting as joint controllers or processors and who are based in the United States and provide IT and system administration services and undertake reporting.
External Third Parties are:
- Service providers acting as processors based United States who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, and insurers based in United States who provide consultancy, banking, legal, insurance, and accounting services.
- Marketing providers, including public relations specialists, advertisers, and sales.
- Payment processing companies based United States who provide credit card processing services.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”)
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
In cases where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
At any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Policy ID: WSC-F62
Issue Date: 07/29/2019
Rev Date: 08/20/2019