Privacy Policy
We (“Dialup”, “Dialup, Inc.”) value your privacy. This privacy policy governs your use of the Services (as defined herein) (the “Privacy Policy”) and applies to your usage of the Dialup software and services, including the website located at https://dialup.com and our mobile app (the “App”) provided by Dialup, Inc. (collectively referred to as the “Services”).
The Information You Provide
During the registration and/or through your use of the Services we ask you to provide your personal data such as name, email address, phone number, and billing information. We use that information to provision the Services, contact you when necessary, improve the Services and as further described in this Privacy Policy.
In order to create an account to be able to utilize the Services, we may ask you to provide us:
your first and last name, email address, home or other mailing address, telephone number, mobile number, credit and debit card numbers and date of birth or other information that could reasonably be used to identify you personally (hereinafter "personal data");
and/or phone contacts and phone number list imported through your use of the Services
We may collect this information from you at various times and places, such as when you:
Make a purchase through the Services;
Submit account registration forms or otherwise save your information with us on our Services;
Sign up or request to be placed on our mailing, SMS text and/or email marketing lists; and/or
Contact us regarding a question or concern such as when you make inquiries concerning the Services;
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information you may not be able to take advantage of all of the Services’ features, including making purchases or payments through the Services.
Children’s Privacy
We understand the importance of protecting children's privacy in the interactive world.Our Services are not intended to be used by children and we do not knowingly collect personal data from children under the age of 13. If you are a child under 13 years of age, you are not permitted to use or otherwise access the Services and should not send any information about yourself to us through the Services.
Information we Collect When you Use the Services
In addition to information that you choose to submit to us, we automatically receive and store certain information when you visit or interact with the Services ("Usage Information"). Usage Information is stored on and accessed from your personal computer, laptop, tablet, mobile phone or other device (a "Device") whenever you visit or interact with our Services.
Usage Information includes:
your IP address, UDID or other unique identifier ("Device Identifier"); A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the areas within our Services that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
other Device data, including the time of day you visit our Services.
Tracking Technologies
We use various methods and technologies to store or collect Usage Information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. Currently, we do not respond to Do Not Track Signals. A few of the Tracking Technologies used through the Services, include, without limitation, the following (and subsequent technology and methods later developed):
Cookies and Firebase Analytics. Cookies are a small piece of data used to exchange information between your browser and the server. We use cookies to store your session identifier. The server erases your cookies when you log out. We may use the permanent cookies to store some of your preferences, such as user interface language. We also use Google’s offering, Firebase Analytics, which allows us to gain helpful insight regarding App usage and user engagement. To learn more about Firebase Analytics, please visit https://firebase.google.com/docs/analytics.
Usage Information and Server Logs. As further described above, every time you visit the Services’ web interface, servers log an entry that includes date and time, your IP address, browser type, browser language, referrer and an address of the page requested. When you connect using client software, the server log file adds that includes timestamp, your IP address, your Services username, client platform and client software version.
Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Services’ pages and messages. Web beacons may be used by us for a number of purposes, including counting visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent by us were actually opened or to count how many particular links were actually viewed.
How We Utilize Tracking Technologies
We use the above Tracking Technologies (or ones we incorporate in the future)
to allow you to use and access the Services
for the prevention of fraudulent activity and improved security functionality
to assess the performance of the Services, as part of our analytic practices and to improve the Services;
to identify you when you visit or sign in to our Services
to keep track of your specified preferences and to track your online activities over time and across third-party sites; and
to deliver content, including ads, relevant to your interests on our Services and third party sites based on how you interact with our advertisements and/or content.
Do Not Track Signals
Some third parties utilize signals or other mechanisms for the expression of consumer choice regarding the collection of information about each consumer's online activities over time and across third-party websites or online services (e.g., browser do not track signals). As noted in this Privacy Policy above, currently, we do not monitor or take any action with respect to these signals or other mechanisms.
Information We Collect When You Interact with Third-Party Sites
The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party website or application (for example, the link to Facebook or Twitter). The use of this functionality may involve the third-party site providing information, including personal data to us. For example, we may provide links through the Services to facilitate sending a communication from the Services, or we may use third parties to facilitate emails, Tweets or Facebook, Instagram, or Pinterest postings. These third parties may retain any information used or provided in any such communications or activities and these third parties' practices are not subject to our Privacy Policy. We do not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you should review the applicable third-party privacy policies.
Public Communication
If you send someone else a communication from the Services, such as an invitation to a friend or if you request to connect with your partner, the information you provide (e.g., names, email addresses, mobile number, etc.) will be used to facilitate the communication. You need to ensure that you have the recipient's permission to use his or her information for this purpose. Please be aware that when you use any send-to-a-friend functionality on or through the Services, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s).
When you connect to your partner, they can see your username and name. Record of the connection may be stored in the call history on you and your partner’s computers or mobile devices. Your partner will never see your phone number or email address.
How we Use your Information
We use your personal data, Demographic Information and Usage Information for purposes of:
Sending you marketing information about Dialup and other third parties we work with, including through direct mail offerings;
Sending you email communications such as electronic newsletters about our Services;
Improving the effectiveness of our Services;
Processing Services’ account registration;
Providing customer service, including responding to your inquiries regarding Services;
Sending you information about orders you have made on the Site;
Helping us address problems with and improve our Services;
Providing mobile marketing messages and other communications and messages;
Protecting the security and integrity of the Services;
Creating aggregated data and statistics (which does not identify you and which we freely use and share);
For internal business purposes; and
For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
Sharing of Information with Third Parties
When You Request We Share With Third Parties
You may be presented with an option to receive certain information directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their content through the Services. This may include using third-party tools such as Facebook, Twitter, Instagram, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.Third Parties Providing Services to Company
We may use third-party service providers to perform certain services on behalf of us or the Services, such as: (i) to assist us in the operations of the Services; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special updates or perform other administrative services; and (vii) other services designed to assist us in our business as it relates to the Services. We may provide these vendors with access to user information, including Device Identifiers and personal data, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, which may include personal data, about you. For any third party we share your personal data with, we enter into contracts limiting their use of your personal data to their provision of services for us.To Protect the Rights of Company and Others
To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Dialup or third parties (including through the enforcement of this Privacy Policy, our Terms & Conditions, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have the absolute discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.Affiliates and Business Transfer
We may disclose and transfer your information: (i) to a subsequent owner, co-owner or operator of the Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.Online Marketing
Where permitted by law, we may share your personal information and data related to your activities on our Services for purposes of retargeting our advertisements and other companies' direct marketing purposes.
Data Storage
Services uses third party hosting providers to store your data. Our third party providers store your username, encrypted password, phone number, and email address.
Transfer of Information to and from the United States
Our Services are operated in the United States. If you are located outside of the United States, please be aware that you will be sending your personal data to the United States.
Help us Help you; Securing Your Login Information
If you receive an email that appears to be a request from us for personal data, Do Not Respond as this may be a "phishing" scam designed to steal your information. Never include your credit or debit card number or other sensitive information in an email, as it is not a secure means of transmitting information. We will only request this kind of information during secure transactions on or through the Services. It is your responsibility to safeguard any password you create to access the Services.
Communications Preferences
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. If you wish to update, delete or modify your personal data or do not wish to be contacted via email, direct mail and/or telephone for commercial purposes, please make changes to “My Account” online by clicking the “Settings” option. Provide your exact name and postal or email address or telephone number so that we may identify you accurately. You may also “unsubscribe” from our email by using the link provided at the bottom of each email. In most cases it takes ten (10) days or less to process your “do not email” request. It may take up to eight (8) weeks to process your “do not mail” request because mailings are planned long in advance. You may also opt out of our SMS Program by replying STOP to the last message received. You may receive a single subsequent SMS message confirming your opt-out. If you change your mind about choices you’ve previously made, make changes to “My Account” online or contact us for assistance. You understand and acknowledge that it may not always be possible to completely remove or delete all of your information from the Services and that residual data may remain on backup media or for other reasons.
Disclosure
In addition to the other usage rights reserved by Dialup as set forth in this Privacy Policy, the Services may disclose personally identifiable information when it’s required to comply with law enforcement requests or subpoenas, including when you violate the Terms of Service.
Privacy Policy Changes and Modifications
This Privacy Policy may be modified or changed from time to time in our sole discretion. When changes are significant, we will notify you by emailing you a notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Services indicates your consent to the Privacy Policy posted at the time of use. However, we will not use your previously collected personal data in a manner materially different than indicated at the time it was collected without your consent. Further, any material changes or revisions to the Privacy Policy will be communicated to you via email, at the most current address you have on file with us. It is accordingly, very important that you keep your email address up-to-date in our systems! To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable. If you have any comments or questions concerning our Privacy Policy, please contact us at legal@dialup.com.
NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Dialup to third parties for the third parties’ direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details. If any other state enacts a similar law as the California law, then this provision will also apply to such state. Nevertheless, if you wish to make such a request, please contact us at legal@dialup.com or write us at P.O. Box 427211 San Francisco, CA 94142.
EU AND EEA USERS, SPECIFICALLY
This Section provides additional information on how we manage personal data that we receive from residents of the European Union ("EU") and European Economic Area ("EEA"). These rights may be limited in some circumstances by local law requirements.
Data Controller
Dialup, Inc.
Danielle Baskin
Email
legal@dialup.com
Phone
+1.415.481.3366
Mailing
P.O. Box 427211
San Francisco, CA 94142
Purpose of Processing EU Data
We use, transfer, disclose, and process personal data in several ways. We use the data we collect, including personal data, for several purposes of:
Sending you marketing information, newsletters and other promotional communications, including through direct mail offerings; the legal bases of which our processing is based upon, is affirmative opt-in consent from you (Art. 6.1.a GDPR);
Your Rights Under the GDPR
To request to be provided with a copy of your personal data held by us;
To request the rectification or erasure of your personal data held by us, if applicable;
To request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
To object to the further processing of your personal data, including the right to object to marketing;
To request that your provided personal data be moved to a third party;
To lodge a complaint with the competent supervisory authority;
Your right to withdraw consent: Where the processing of your personal data by us, is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at legal@dialup.com. You can also change your marketing preferences at any time by logging into your account and going to the “Settings” page.
Contact Us
All requests to exercise your Rights, or inquiries about your personal data should be made to the legal department at legal@dialup.com or by writing to: Dialup, Inc. at P.O. Box 427211 San Francisco, CA 94142.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. To help determine who your local data protection authority is, please refer to https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.
