Effective date: May 11, 2023
Conflict Between This Policy and Laws and Regulations
INFORMATION WE COLLECT
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Services to you. Note that this section is applicable only to the use of the sites and services intended for use by parents and adult members of the general population. See the section below titled “Children’s Privacy” for details of information collection for products and services intended for use by children. Some of the information we collect may personally identify, relate to, describe, or be capable of being associated with you (“Personal Information”), including:
- Personal identifiers and contact information such as name, mailing address, email addresses, phone numbers;
- Sensitive personal identifiers such as gender, age;
- Banking/financial information such as credit/debit card numbers and expiration date, checking account numbers;
- Commercial information such the type(s) of service subscribed to, service dates, customer type, account balance and status;
- Internet and network information such as IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system;
- Browsing and search history within the Gabb Sites;
- Geolocation data such as geographic location indicators from mobile devices, websites and customer addresses;
- Audio/visual information such as call recordings, and chat transcripts;
- Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The types of Personal Information we collect about you may vary based on how you use our Sites or Services, and your relationship with us, and may or may not include some of the categories identified above.
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.
Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, your IP address, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
HOW WE COLLECT INFORMATION
We may ask you to provide us with Personal Information when you communicate with us online or offline, including events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as consumer reporting agencies, marketing agencies and partners, analytics firms, and government agencies.
Cookies and Other Automated Tools
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within our Sites and are typically deleted once you close your browser.
- Persistent or Preference Cookies: Persistent or Preference cookies reside on your system and allow us to customize your experience if you leave and later return to our Sites. For example, persistent cookies may allow us to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
We employ software technology that enables us to track certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses “tracking pixels.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed.
Marketing and Advertising Partners
Information from Advertisements
If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social Media Widgets
The Sites may include social media features, such as Facebook, YouTube, Pinterest, LinkedIn, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
THIRD PARTIES THAT COLLECT INFORMATION ON OUR SITES
Third parties, including Advertisers, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as cookies and tracking pixels. These third parties’ collection, use, and disclosure of Personal Information and/or Usage Data is governed by their data policies.
HOW WE USE AND SHARE INFORMATION
We use Personal Information for business purposes, such as:
- Account creation, fulfillment, servicing and customer support: to create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their services, respond to questions and address customers concerns, deliver upgrade, updates and product improvement information;
- Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;
- Collection and credit reporting: to collect on outstanding balances, update credit reporting agencies;
- Surveys, promotional events, contests: to administer surveys, polls, sweepstakes, contests, loyalty programs and other promotional events and contests;
- Other company communications: to provide consumers with information that may be of interest such as company newsletters, announcements, reminders and service bulletins;
- Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data (such as email and IP addresses);
- Eligibility and pricing: to determine if consumers are eligible for certain products, services or offers and the pricing related to such offers;
- Product and services research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;
- Business operations: to evaluate, develop, and improve business operations, products and services offered, perform business administration and other normal business activities;
- Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
Information security and fraud prevention: to operate information security and anti-fraud programs.
Reviews and Testimonials
If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications
We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:
- Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and perform payment processing services;
- Payment processors, which help us to accept and process the payments for our products/services to you;
- Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys and other outreach campaigns;
- Research and development vendors, which help us develop and improve our products and services;
- Data and business analytics vendors, which help us collect, analyze and improve the accuracy of our data (including Personal Information);
- IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
- Professional service firms, which provide accounting, legal and other professional services; and
- General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information that we provide to them other than as specified by us.
In the past twelve months, we have shared the following categories of Personal Information with at least one Service Provider: personal identifiers and contact information; sensitive personal identifiers; other demographic information; banking/financial information; commercial information; internet & network information; geolocation data; audio/visual information; professional/employment information; education information; and inferences drawn from other Personal Information or data.
Aggregate and De-Identified Information
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to: respond to legal requests (including court orders, investigative demands and subpoenas); protect the safety, property, or rights of ourselves, consumers, or any other third party; prevent or stop any illegal, unethical, or legally actionable activity; or comply with laws.
The Sites may contain links to third party websites including social media platforms. Please be aware that if you access these links, you will be leaving our site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. A reasonable effort will be made to provide you notice via the Sites or communication (e.g., email) at least 30 days before any such transaction occurs, as allowed by law and regulatory requirements
We are concerned about the safety of children when they use the internet. We want you and your family to be safe while visiting the Sites and using our Services. We urge parents and guardians to monitor and supervise their child’s online activities.
We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that Gabb Wireless has been reviewed and approved for having policies and practices surrounding the collection, use, maintenance and disclosure of personal information from Children consistent with the iKeepSafe COPPA Safe Harbor program guidelines. COPPA protects the online privacy of Children under the age of 13. IKeepSafe Safe Harbor program can be contacted at email@example.com.
Gabb complies with the Federal Trade Commission’s (FTC) Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect Personal Information from children under the age of 16 without informed and express parental or guardian consent. If you learn that a child has provided us with Personal Information, you may contact us at firstname.lastname@example.org.
In general, Gabb Sites are not designed or intended for use by children. Children are the primary users of Gabb Devices and the included Apps, and may make use of support Services.
Information Collection, Usage, and Retention
Gabb Wireless will not collect and use any child’s data or submissions beyond what is reasonably needed to provide services. When using Gabb Devices and the included Apps, information that may be collected from users includes:
- Contact information including names and phone numbers of contacts;
- Sensitive personal identifiers such as name, gender, age (as provided through the parent account);
- Inferences drawn from account relationships between the device user and the parent account.
- Subscription information such the Apps approved and/or installed, Services subscribed to, usage statistics, and service dates;
- Internet and network information such as wifi SSIDs and IP addresses;
- Geolocation data such as geographic location indicators from mobile devices;
- Audio/visual information such as photos and videos;
- Text/multimedia messages in their entirety;
- Customizable presets, including text message, voice messaging, emojis, daily planner, step counter goals, assigned tasks, and rewards; and
- App-specific information including audio recordings, calendar entries, notes, and music preferences.
Additionally, when children utilize support Services, we may collect:
- Recordings of calls and text conversations with support staff;
- Feedback such as ratings, reviews, recommendations provided by the user through Apps.
We use this information collected from children for business purposes, such as:
- Providing services to users and parents or guardians, backup user data, and protect users from harmful content;
- Customer support such as responding to questions and address customers concerns and delivering upgrade, update and product improvement information;
- Feedback to understand user needs;
- Compliance to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
- Information security and fraud prevention to operate information security and anti-fraud programs.
We may use third-party service providers and business partners to perform functions in connection with providing Services on Gabb Devices and Apps. We may share personal information with these providers and partners as necessary to enable them to provide services. Third parties are prohibited from using personal information for any unrelated purpose. These third parties include Verizon, Telispire. Smartcom, ZTE, Samsung and Tuned Global.
Gabb Wireless does not sell or rent your child’s Personal Information to any third party for any purpose – including for advertising or marketing purposes. Third-party advertising is not permitted on Gabb Devices and Personal Information collected from children is never used for behaviorally-targeted advertising to children.
Data collected from children is only retained as long as necessary for providing services to the users and parents, plus a grace period to allow for user reactivation.
Prior to collecting any information from children using a Gabb Device, we must obtain the appropriate consent directly from the parent or legal guardian. As parents and guardians are the purchasers of Gabb Devices and approvers of Gabb Apps, usage of Devices and Apps implies parental consent to the data collection outlined in this section. In addition, parents and guardians have the opportunity to review and consent to data collection:
- When approving a GabbID creation for a child account. A GabbID is required for a user to access Apps and some Device features. A parent or guardian must provide consent for the user by obtaining an emailed code before the user’s GabbID can be activated.
Parents have the right to review, correct, or have deleted from our database, their child’s personal information and/or have the right to refuse further collection or use of a child’s personal information. Such a request may impact our ability to continue to provide some Services. If you have questions about the collection and use of children’s information or wish to make a request about your child’s personal information, or to withdraw consent for information collection, please contact us at email@example.com. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Your California Privacy Rights
Under California Civil Code Section 1798.83, California residents may request certain information from us regarding our disclosure of personal information to third parties for their direct marketing purposes. Please see the California Privacy Notice below for more information on your rights as a California resident.
PRIVACY PRACTICES RELATED TO EMPLOYEES AND JOB APPLICANTS
If you apply for or accept an offer of employment, we may collect:
- Personal identifiers and contact information such as name, address, social security number, driver’s license number, alien registration number, passport number;
- Educational information such as educational institutions attended, degrees received, college transcripts;
- Professional/employment information such as resumes, CVs, positions held, tenure, references, skill assessments;
- Internet & network information browsing/search history, data collected by cookies;
- Characteristics of protected classifications such as age, race, disabilities, citizenship;
- Medical information such as drug test results, doctors’ notes, leave of absence forms, workers compensation forms;
- Banking, financial and insurance information such as checking account and routing numbers for direct deposits, 401(k) account information, loans, mortgage documents and garnishment information, insurance policies and coverages;
- Geolocation information from mobile applications and vehicles or vehicle equipment;
- Beneficiary/Dependent information such as the names, social security numbers and gender of your beneficiaries/dependents;
Inferences drawn from the above categories of Personal Information that relate to your characteristics, behavior, attitudes, intelligence, abilities and aptitudes, including criminal background information and driving history.
We may use this information to evaluate candidates for initial and continued employment; conduct background checks and drug screening; communicate with you; provide training and mentoring; provide benefits, services, and accommodations; maintain company security; facilitate company policies; comply with legal and contractual obligations; and otherwise operate our business. We may disclose Personal Information to Service Providers to facilitate any of the above uses. We do not sell applicant or employee Personal Information to Third Parties.
How to contact Gabb with questions
If you have questions about this policy, please contact Gabb at:
Gabb Wireless, Inc.
4101 N. Thanksgiving Way, Suite 300
Lehi UT 84043, United States
Gabb Wireless CCPA Privacy Notice
Information for California Residents
For the purposes of this CCPA Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.
Personal Information does not include information that is:
- Lawfully made available from government records;
- Deidentified or aggregate information; or
- Otherwise excluded from the scope of the CCPA.
Consumer does not include a natural person acting as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, or contractor of Gabb Wireless to the extent such person’s Personal Information is collected within the context of the person acting in such role. Persons acting in those roles should review the applicable CCPA Limited Privacy Notice made available by Gabb Wireless.
California Consumers’ Rights and Choices
If you are a Consumer, the CCPA may permit you to request information regarding the:
- Categories of Personal Information (as defined by the CCPA) collected, sold or disclosed by us;
- Purposes for which categories of Personal Information collected by us are used;
- Categories of sources from which we collect Personal Information;
- Categories of third parties with whom we share Personal Information; and
- Specific pieces of Personal Information we have collected about you and in some cases your Household.
In addition, if you are a Consumer, you may:
- Opt out of the sale of your Personal Information (if applicable), in some circumstances;
- Opt out of receiving marketing communications from us; however, you may still receive administrative communications regarding our services;
- Opt in to certain financial incentive programs we may offer related to the collection, retention, or sale of your Personal Information; and
- Request that we and our service providers delete Personal Information we have collected from you, in some circumstances.
Further, the CCPA provides Consumers with the right not to receive discriminatory treatment by a business for the exercise of these CCPA privacy rights, subject to certain limitations.
Collection and Disclosure of Personal Information from Consumers
The table(s) below outline how we handle Personal Information collected about Consumers in the preceding 12 months from the date this CCPA Privacy Notice was last reviewed.
Use of Personal Information
Collection of Personal Information
In the preceding 12 months since this CCPA Privacy Notice was last reviewed, we have collected Personal Information from the following categories of sources: directly from you (e.g. forms you complete or products and services you purchase) and indirectly from you (e.g. from observing your actions on our website).
Sale of Your Information
We have not sold your Personal Information for the preceding 12 months from the date of the last review of this CCPA Privacy Notice.
If you are a Consumer, you can make requests to know what personal information we have collected from you in the past 12 months or requests to delete your personal information via https://www.requesteasy.com/61bb-0343 or by emailing firstname.lastname@example.org.
Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).
We will review the information provided and may request additional information to ensure we are interacting with the correct Consumer. If you have a password-protected online account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.
After submitting your request online, you will receive a follow-up email outlining the estimated amount of time it will take to complete your request and giving further instructions. That email may also include a link you must click on in order to verify your identity. If you do not click on that link, we will be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.
By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.
We generally will aim to avoid requesting additional information from you for the purposes of verification. However, if we cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, we may consider any of the following factors, alone or in combination, in requesting additional information:
- The type, sensitivity, and value of the Personal Information collected and maintained about the Consumer, as applicable law requires a more stringent verification process for sensitive or valuable personal information;
- The risk of harm to the Consumer posed by any unauthorized access or deletion;
- The likelihood that fraudulent or malicious actors would seek the Personal Information;
- Whether the Personal Information to be provided by the Consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
- The manner in which we interact with the Consumer;
- Available technology for verification; and
- Other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this CCPA Privacy Notice.
If your request is regarding household information, the same verification steps above may be required before we can provide you with aggregate household information. In addition, if you do not have a password-protected online account with us, for us to process a request for access to or deletion of specific pieces of information regarding your household, we may need all members of the household to make the request, and we may need to individually verify each household member and that each member making the request is currently a member of the house.
We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.
Authorized Agent Requests
You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a written authorization signed by you and the authorized agent. You may submit evidence of your designation of an authorized agent in writing to: 4101 N Thanksgiving Way, Suite 300, Lehi, UT 84043, USA.
We may require verification of your authorized agent in addition to the information for verification above for Consumers and households.
We do not knowingly collect or sell Personal Information from children under the age of 16 without informed and express parental or guardian consent. If you learn that a child has provided us with Personal Information, then you may contact us through the Contact Us section below.
Notice of Financial Incentive
We do not offer financial incentives to Consumers based upon the collection, retention or sale of a Consumer’s Personal Information.
If you have any questions or concerns regarding this CCPA Privacy Notice, contact email@example.com.
Last updated: December 17, 2021