SUMMARY – POLICY OVERVIEW Telecom Technology Services Incorporated, its other affiliates and its subsidiaries (collectively, “TTS Inc”, “us”, “our” or “we”), owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, and communities (collectively “Services”). This Privacy Policy applies to all 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 you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise noted in this Privacy Policy, TTS Inc is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)) and the Brazilian General Data Protection Law (“LGPD”), which means that we decide how and why the information you provide to us is processed. Please contact us using our DSAR Portal. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

This Privacy Policy covers information collected through the following websites and mobile applications:

Websites:

• TechInsights

• Mobile Trace

• IMNOS

Applications:

• TechInsights

• Mobile Trace

SUMMARY – CATEGORIES OF INFORMATION WE MAY PROCESS “Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.


“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment 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; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
• Demographic information: salutation; job title, company information, and language preferences.
• Contact details:postal address; telephone and/or mobile number; and email address.
• Consent records: records of any consents you may have given, together with the date and time, means of consent 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 (“Precise Location Data”).

• Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
• Views and opinions: any views and opinions that you or other users choose to send to us, including but not limited to feedback on third party services, or publicly post about us on social media platforms or in the Services, including on forums.

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” 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 aggregated.
• Browsing history including the websites or other services you visited before and after interacting with the Services.
• Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device but is different than a hardware serial number.
• Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• Internet connection means, such as internet service provider (“ISP”), mobile network operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
• Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content therein (collectively, “Online Data”).
• Device type, settings and software used.
• Log files, which may include IP addresses, browser type, serving mobile operator, operating system, date/time stamps and/or clickstream data, network serving cells, network performance checks taken, and general available network performance data.
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to 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 HTML5.
• 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 constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

SUMMARY – SENSITIVE PERSONAL INFORMATION
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 actual 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. Where it 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 the Processing is required or permitted by applicable law;

• Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is 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 Information where 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 with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the 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 are 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 information immediately.

SUMMARY – COLLECTION AND CREATION OF INFORMATION Collection of User Information: 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 our Services (e.g., 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 search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software 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 course of our 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 choose to make 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 or register to use any part of our Service.

• Mobile Trace by TTS Inc: When conducting a test and uploading to the web portal on any device or platform, we 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 settings allow it); and (c) Other Information, including, but not limited to, the IP address, the ISP, college or organization 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 mobile device, TTS Inc may collect your Precise Location Data, both while you are running a test and when the application is 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 parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or 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 information available 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 discussions 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 public 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 available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us via email: support@ttswireless.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.

This Privacy Policy does not cover the practices of third parties, including those that may disclose information 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 analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

SUMMARY – PURPOSES FOR WHICH WE MAY PROCESS YOUR INFORMATION
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 including (i) chat areas, forums and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.

• Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.

• 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 message, social 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; maintaining and 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 promotional strategies on various platforms and channels, both within the Service and on Channels.

• User Engagement: tracking activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.

• Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, 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 and platforms, such 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 licenses the Mobile Trace results, including any feedback you submit in connection therewith, to its business customers. TTS Inc also licenses the Mobile Trace applications to business customers who wish to have their end users test their own networks’ internet connectivity or, in the case of Mobile Trace to test an end user’s connection(s) between a product and a network of servers.

• TechInsights: TechInsights is offered on multiple devices, products, and platforms. TechInsights collects data on outages of third-party services, including anonymous reporting of outages directly to TechInsights, comments 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 business customers.

• Marketing to Customers: We may market to current and prospective customers and their employees who have 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 conducting phone 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 device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

• Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.

• Financial Management: general business and financial management purposes, including economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements

• Investigations: detecting, investigating, and preventing breaches of policy, and criminal offences, in 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 of Services when we have grounds to believe that the user is in violation of our Terms of Use or other published 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 entities, civil 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 protecting the rights, property, safety or security of TTS Inc, any of our users or the public, or to respond to an emergency.

SUMMARY – DIRECT MARKETING We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to 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 in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

SUMMARY – COOKIES AND SIMILAR TECHNOLOGIES TTS Inc and its partners may use cookies and other tracking technologies to analyze trends, administer Services, track users’ movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services. Please see our Cookie Policy for more information, including a more in-depth explanation of what cookies are, 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 partners. Certain tracking technologies enable 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. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can 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 or 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 information with other data we collect to use for some or all of the purposes outlined in this Privacy Policy.

We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also 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 methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third-party companies on an individual and aggregated basis. For example, we may connect information about your 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 Shared Objects please click here.

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

SUMMARY – LAWFUL BASIS FOR PROCESSING USER INFORMATION In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
• Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
• Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
• Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
• Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purposes of managing, operating, improving or promoting our business, and that legitimate 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 the 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 with mobile network operators, hardware manufacturers and industry regulators to help them understand and create a better and faster mobile network experience.

SUMMARY – DISCLOSURE OF USER INFORMATION TO THIRD PARTIES

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 law. 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 public security;
• 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 shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and
• to third parties whose practices are not covered by this Privacy Policy (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 address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry 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 downloads.

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 that partner, which may include third-party service providers whose services are embedded into and/or appear within the Services;

With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise, we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where TTS Inc advises users of the possibility of such disclosure at the time they take the survey, TTS Inc reserves the right to disclose any information provided by users, provided that no user Information identifying a specific user is disclosed.

We may also sell or transfer Online Data to certain third parties such as mobile network operators who will use this data for network evaluation purposes. Some of these third parties may combine the Online Data with their 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 and the providers are required to maintain the confidentiality of this information. These third-party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information 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 Inc 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 of Mobile Trace which are made available pursuant to a user belonging to a specified third-party within their profile.

Information collected through Mobile Trace may not be anonymous as follows: for some ISPs and mobile carriers, 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 device 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 may 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 binding 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 ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

SUMMARY – INTERNATIONAL TRANSFERS OF INFORMATION
Because of the international nature of our business, we may need to transfer your User Information within the TTS Inc group of companies, and to third parties as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a 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 a copy of the relevant standard contractual clauses via email at support@ttswireless.com.

Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

TTS Inc privacy practices described in this Privacy Policy comply with the Asia-Pacific Economic Cooperation (“APEC”) 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 editions of Services.

SUMMARY – DATA SECURITY We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not 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 you are responsible for ensuring that any Personal Information that you send to us are sent securely.

SUMMARY – DATA ACCURACY 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 inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

SUMMARY – DATA MINIMIZATION 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 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 will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need. TTS 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 purposes.

Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by TTS Inc for not more than 365 days after which it shall expire. However, the 365 day period may commence again if the same user subsequently visits or interacts with an email, the Services or a Channel.

SUMMARY – WHAT CAN I DO TO CONTROL MY INFORMATION? 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 information by logging into your account or contacting us via email at support@ttswireless.com. 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 at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to 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 that 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 you 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 cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

Location Based Services. You may opt-out of having your Precise Location Data collected by TTS Inc at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device). Mobile Trace App. To turn off the automated log upload feature of the Mobile Trace application, go to the 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.

California Residents. In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “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 parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 17 below.

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These 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 that 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 by emailing support@ttswireless.com. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

Brazilian Residents. LGPD provides certain rights for Brazilian residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the 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 of 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 we process your information on the basis of your consent, you have the right to withdraw that 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 by emailing support@ttswireless.com. 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 national authority.

SUMMARY – TERMS OF USE The TTS Inc Terms of Use governs your use of the Services.

For more information concerning your use of the Services, please visit TTS Inc Terms of Use. The TTS Inc Terms of Use is incorporated by reference into this Privacy Policy.

We recommend that you review our Terms of Use regularly, in order to review any changes, we might make from time to time.

SUMMARY – CONTACT DETAILS If you are an EU or Brazilian resident, you may contact our Data Protection Officer or submit GDPR or LGPD related inquiries by emailing support@ttswireless.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:

SUMMARY – CALIFORNIA CONSUMERS

• 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 support@ttswireless.com.
  
  If you have an account with us, we will verify the request by confirming the email address used to make the 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 additional 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, Demographic Information, Contact Details, Consent Records, Location Information including Precise Location Data, Purchase 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, this may 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 and 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 We Collect User Information”). As defined in Section 4, this may be: Data You Provide; Relationship Data; Data You Make 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 defined in Section 2 (“What Categories of Information We Process”): GeoIP Data; ID; IDFA; IP address; ISP; SSID; IMSI; IMEI; Log files; Web Beacons; Pixel Tags; Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, and equivalents.
  
  We use this data for the purposes listed above in Section 5 (“Purposes for which we may Process your Personal 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 (“What 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 a business purpose:
  
  other entities within the Company group for a legitimate business purpose such as operating the Services and providing the Services to you;
  
  third party Processors for the purpose of providing the Services to you;
  
  third party providers where our Services use third party plugins or content;
  
  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 a business purpose or a commercial purpose:
  
  third parties for the purpose of recognizing our users and delivering interest-based content to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information 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;
  
  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 employer’s name, company size and other industry data) is provided in connection with webcasts, white papers or other downloads.
  
  If you run a Mobile Trace log, ISPs and mobile carriers may receive full IP addresses and/or network hardware or devices identifiers for such ISP or mobile carrier’s customers upon request. Equipment manufacturers and core network or wholesale providers may also receive full IP addresses and/or network, hardware and device identifiers on a case-by-case basis for network research purposes. Third parties may receive GeoIP Data and/or Precise Location Data.
  
  The Services are not intended for use by minors. We do not sell personal information of minors under 16 years of 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 so, please submit a request via email support@ttswireless.com. If submitting a request by email, we may ask for additional 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 submit a request via email support@ttswireless.com. If submitting a request by email, we may ask for additional 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 privacy rights conferred to you by the California Consumer Privacy Act.
  
  g.Authorized Agent
  
  To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a signed authorization letter from the consumer to support@ttswireless.com
  
  h. Contact for More Information If you have any questions or concerns about our privacy policies and practices, you may contact us via email support@ttswireless.com.
  
  i. Date Privacy Policy Last Updated
  
  Our Privacy Policy was lasted updated as of the date indicated at the beginning of the policy.

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.