Effective on June 3, 2022
This privacy notice (“Notice”) describes how Ting Inc. (“we,” “our,” “us”) collects, uses, and discloses your personal information. This Notice applies to all of our products (including devices), services, mobile applications, and websites (the “Services”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. If you do not wish to accept this Notice, please do not use our Services.
When information identifies, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “Personal Information.” Personal Information does not include information that is not used to identify you, including aggregate or anonymous information.
Collection of Personal Information
There are several ways we may obtain Personal Information, including from:
- You directly;
- Third party service providers; and
- Tracking technologies.
This Personal Information may include the following categories:
- Identifiers/Contact Information: These include your name, postal and email address, phone number, and other unique identifiers that may identify your device or browser, but not you by name, including your username, account number, and password.
- Commercial Information: Your purchase and usage history, goods and service preferences, and payment and billing information.
- Internet Activity: Your IP address, web/app browsing, and search history related to our Services, including information regarding your interaction(s) with our Services.
- Profile Inferences: The inferences that we draw from your Personal Information and web activity to create a personalized profile so we can better identify goods and services that may be of interest.
- Location Information: We may collect precise and coarse information about your location when you use our Services.
Personal Information You Provide
We also collect information from you when you choose to provide it to us, such as when you contact customer service, create an account, or otherwise with your consent. We may combine this information with other information collected from or about you to provide and improve our products, services, content, and advertising. If you refuse to provide any requested information (whether or not required), you may not be able to take full advantage of our Services.
If you provide Personal Information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Personal Information Collected Automatically
Whenever you use, visit, or interact with the Services, we, as well as third-party advertisers and/or service providers, may use a variety of technologies to collect Personal Information, such as:
- Usage Information: We collect Personal Information about your activity on the Services, such as your location, login date and time, features you use, and website and product interactivity.
- Device Information: We collect Personal Information from and about the electronic devices that you use to access the Services, including IP address, advertising IDs, browser type and language, operating system, time zones, and identifiers associated with cookies or other technologies that uniquely identify your device or browser.
- Third Party Analytic and Advertising Technologies: We also use third parties’ analytics and tracking tools to help us track, segment, and analyze usage of the Services, and to help us or those third parties serve more targeted ads to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store your information. We also combine such information with information that these tools collect from other sources. To learn more, please see the “Choice/Opt Out” section below.
Personal Information Received from Other Third Parties
We obtain information about you from other third party sources to update or supplement the Personal Information we’ve collected from you. For example, we obtain address information about you from third party sources, such as the US Postal Service, to verify your address so we can properly ship your order to you and to prevent fraud.
We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Services, target communications so that we can inform you of products and services or other offers that may be of interest to you, measure ad quality and responses, and for internal business purposes.
Combination of Information
We may combine the Personal Information we receive from and about you. We may also de-identify or aggregate information so it is no longer Personal Information.
Use of Personal Information
We use your Personal Information to:
- Provide the Services to you;
- Analyze the performance of our network and your devices;
- Process your orders, including to fulfill your order and send you an order confirmation;
- Respond to customer service requests, questions, and concerns, and solicit your feedback on the quality of our customer service;
- Administer your account, including allowing you to (a) login to, navigate, and use our website; (b) view and adjust the services you have purchased from us inside your account; and (c) pay your bill or update your billing information;
- Send you communications about how to use our Services, including your phone(s);
- Send you communications about new service offerings;
- Offer promotions and ads that are relevant to your interests;
- Improve the Services and develop new ones;
- Prevent, detect, and fight fraud or other illegal or unauthorized activities including to enforce this Notice;
- Ensure legal compliance; and
- Otherwise with your consent.
Sharing Personal Information
Sharing of Personal Information by You
Our Services offer publicly-accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your Personal Information; we will let you know if we are unable to do so.
Sharing of Personal Information by Us
We may share Personal Information, as follows:
- With our service providers: We use service providers to help us operate and improve the Services, such as for data hosting and maintenance, analytics, customer care, marketing, payment processing, order fulfillment, and security operations.
- With our affiliates: We may share Personal Information with affiliated entities for approved business purposes. For example, we may share information about your use of the Services with our affiliates in order to provide the Services and measure the performance of our network and your devices.
- For corporate transactions: We may transfer your Personal Information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use Personal Information provided through the Services in a manner that is consistent with this Notice.
- Legal obligations; Safety: We may access and disclose your Personal Information to respond to subpoenas, judicial processes, or government requests and investigations, in connection with an investigation on matters related to public safety, or as permitted or otherwise required by law. We may disclose your Personal Information to protect the security of our Services, servers, network systems, and databases. Where allowed, we will inform you of these types of disclosures, so that you may object to this type of sharing.
- To enforce legal rights: We may also share Personal Information (a) if disclosure would mitigate our liability in an actual or threatened lawsuit; (b) as necessary to protect our legal rights and those of our users, business partners, or other interested parties; (c) to enforce our agreements with you; and (d) to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing.
- With your consent or at your request: We also may share your information as disclosed to you at the time of collection, or with your consent.
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at firstname.lastname@example.org.
Certain parts of the Services require cookies. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings.
To learn more about such interest-based advertising, please review the information below. Please note that even if you opt-out, you may still receive advertisements from us that are not customized based on your Usage Information.
- To opt-out of such collection and use for online behavioral advertising by the Digital Advertising Alliance participating companies in the United States, please visit: www.aboutads.info/choices/ and www.aboutads.info/appchoices/.
- To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: www.networkadvertising.org/choices/.
Access and Updates to Your Personal Information
To review and update your personal information to ensure it is accurate, you should first log in to your account and review your contact information. If you have difficulties, please contact us at email@example.com. We reserve the right to request that you provide information to confirm your identity. We may not be able to correct or delete information shared with third parties. Pursuant to applicable law, we may be entitled to refuse to act on the request.
Your California Privacy Rights
Categories of Personal Information Sold
We do not knowingly sell Personal Information.
Categories of Personal Information Disclosed
In the last 12 months, we have disclosed the following categories of Personal Information for a business purpose (such as with our service providers who are restricted from using your Personal Information outside the scope of their services for us):
- Identifiers/Contact Information, disclosed to billing providers, retail platforms, customer service platforms, data analytics providers, operating systems, security providers, and cloud storage services;
- Commercial Information;
- Internet Activity;
- Location Information;
Access and Deletion Requests
You have the right to know what Personal Information that we collected, disclosed, and sold about you. In particular, you may:
Request, up to two times each year, that we disclose to you:
- the categories and specific pieces of Personal Information that we collected about you in the preceding 12 months, the business purpose for such collection, and corresponding categories of sources from which we collected the information;
- the categories of Personal Information, and the categories of third parties to whom we disclosed your Personal Information in the preceding 12 months, and the business or commercial purpose for such disclosure; and
- the categories of Personal Information and the categories of third parties to whom we sold your Personal Information in the preceding 12 months, and the commercial purpose for such sale.
Request that we delete any Personal Information that we have collected from or about you. Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, for our internal purposes, or to comply with a legal obligation.
To take advantage of these rights, please contact us by email at firstname.lastname@example.org, by phone at 1-855-846-4389, or by mail at the address listed in the Feedback section below. We may request certain information to verify your identity before we can respond to your access and deletion requests. We will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days, after proper verification, unless we need additional time, in which case we will let you know.
You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf, and that they are registered with the California Secretary of State to conduct business in California, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention. Authorized agents may go here to submit a request.
We take information security seriously. We use commercially reasonable efforts to protect information we collect and maintain against loss; misuse; and unauthorized access, disclosure, alteration, or destruction. However, even with appropriate security measures in place, we cannot guarantee the security of the information under our control.
If you have any questions about security on our Services, you can contact us at email@example.com.
We will retain your information for as long as your account is active, as needed to provide you services, or as permitted by applicable law to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account, contact us at firstname.lastname@example.org.
Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect any Personal Information from, children under the age of sixteen. If we learn that a child under the age of sixteen has provided Personal Information through the Services, we will use reasonable efforts to remove such information from our files.
Notification of Changes
We may update this Notice to reflect changes to our information practices. Any changes we may make to our Notice will be posted on this page. If you do not agree or consent to these updates or changes, do not continue to use the Services. If we make any material changes we will provide appropriate notice to you. We encourage you to periodically review this page for the latest information on our privacy practices.
You can contact us about this Notice by mail, phone, or email using the information below: