Message Technologies, Inc.

Privacy – February 1, 2018

Introduction

Below is a summary of our practices when it comes to your data collected when you use the Message Technologies, Inc (MTI) account portal and our products and services.

For purposes of this notice, the words “our,” “us,” “we,” and “MTI" refer to Message Technologies, Inc. and our affiliates (which includes any person or entity that controls us, is controlled by us, or is under common control with us, such as our subsidiary, parent company, or our employees).

Before you submit any information on or through the MTI account portal or use MTI products and services, please carefully review this Notice. By using any part of the MTI Site, you consent to the collection, use, disclosure and sharing of your information as further outlined below in this Notice.

Overview

What is MTI? MTI is a cloud communications company. Our customers are generally private companies or software application developers (or companies that have software application developers working for them). Our customers generally use MTI’s products and services, which include APIs and SDKs, to build communications features and capabilities into their applications. Our customers then often have their own customers or users of the applications they build using MTI’s products and services. To avoid confusion, we’ll call the individuals that use our customers’ applications the “end users.”

MTI generally does not interact directly with our customers’ end users. Instead, end users interact with our customers’ applications, which in turn interact with our products and services. So, if you’re an end user of an application that is integrated with MTI’s products or services, you should check out that application’s terms of service and privacy policy to find out how that application collects, uses, stores and shares your data. We are not responsible for our customers’ privacy policies or privacy practices.

Categories of Customer Data. There are three general categories of customer data that we collect or generate from our customers’ use of our products and services. We’ll call these “Customer Content,” “Customer Account Data,” and “Customer Usage Data.”

·         Customer Content. Customer Content consists of the communications that are sent through integration with MTI’s products and services, like the body of a message or voice communication.

·         Customer Account Data. Customer Account Data is all the data that relates to the relationship between MTI and its customers, like our customers’ names, contact information, and billing information and records.

·         Customer Usage Data. Includes operational data like API requests, call or messaging logs, origination and termination points (i.e. to/from numbers), traffic routing information, or usage information.

What data we collect, how we collect it and why

Customer Account Data you share with us directly. When you sign up for an account with MTI through our account portal, you’ll be asked to give us your name, email address, and optionally, your company name. You’ll also be asked to create a password. We collect this Customer Account Data so that we know who you are, we can communicate with you about your account, and we can recognize you when you communicate with us through the account portal or otherwise. We may also ask you for a telephone number to contact you, like when you ask to be contacted by our sales team.

For some products, we may have to obtain a physical address from you. For example, to get a phone number in certain countries, local regulations may require us to have a physical address on file for you or your end user. We may also need your physical address or billing address this for tax purposes. We may have to share your physical or billing address with the telecommunications carrier from whom MTI obtained the phone number or local government authorities upon their request. Unless prohibited from doing so by law, we’ll let you know if we have to share your address like this.

Similarly, for some of our products, you may have to complete an application form providing details about your company and your intended use of the product, like when you are interested in getting a short code. We’ll use this data for the purpose for which it was gathered from you.

Also, we gather information about you when you interact with our customer support team, sales team or account management team. For example, when you contact our customer support team, you will be asked to give your account data and tell us the question you have or any problem you’re experiencing. We gather this information so that we can help you with your question or problem. When you communicate with our sales team or account management team, we’ll gather data about you, such as your use case and your business requirements, so that these teams are better equipped to assist you. We may also use this data so that we can improve our products and services and train our team members.

Customer Account Data we generate and collect automatically when you create an account. When you sign up for an account with MTI, we’ll assign you an Account ID, which may or may not act as a username. You will need to use these credentials in connection with making requests to our APIs. We keep a record of these credentials, so that when your application makes requests to our API using these credentials, we know that it is you making the requests.

Customer Usage Data we collect from you from your use of our products and services, like our APIs. When you use our products and services, we collect Customer Usage Data. This may include data like what commands your application has communicated to MTI, your IP addresses, how many times you used a MTI product or service, when the product or service was used by you or your end users, the number of calls or messages made or received, the length of calls or messages, where those calls or messages originated or terminated, how those calls or messages were routed, and whether or not the connection was successful or failed.

We collect Customer Usage Data so that you can view it in the account portal and can manage your use of our products and services. We also collect it so that we can properly bill you for your use of our products and services, appropriately manage and route customer traffic, analyze and improve our products and services, and identify and solve problems that arise.

Customer Content we collect from you from your use of our products and services, like our APIs. We also may collect Customer Content in connection with your use of certain products or services. For example, if you use our messaging services, we collect the messages being sent and received so that we can convey those messages to and from the carrier networks. Similarly, to transmit voice calls to and from the telecommunications carrier networks, we have to collect the voice communications being sent and received to route them appropriately. You can also use our products and services to record voice communications or have them transcribed, in which case, we will also collect those voice recordings or transcriptions.

What we use your data for:

Generally, we use all the data that you provide to us or that we collect from you to provide our products and services to you, to enable you to access and use our products and services, to deliver your communications to their intended destination, and to analyze our customers’ use of our products and services, to improve our products and services, and to detect fraudulent or unlawful activity in connection with MTI accounts.

Below are some additional details regarding how we use categories of data we collect.

Customer Content. We use Customer Content for the purposes that you allow us access to it, like conveying it to and from telecommunications carrier networks or recording and transcribing it per your instruction. We may also use Customer Content stored on our systems to troubleshoot issues such as call quality concerns.

Customer Account Information. We use your email address in connection with your account password to authenticate your account and allow you to access your account data through the account portal. And, we use your AccountID to authenticate that it is your application that is making requests to our APIs.

We also use contact information you provide to MTI to communicate information regarding your account and the products and services you are using or to respond to an inquiry you have sent us.

In addition, we will use your email address to send you information about other MTI products, services, or events that you might be interested in. You can choose not to receive marketing emails from MTI. If you wish to stop receiving MTI marketing emails you may click on the unsubscribe link that will appear at the bottom of any MTI marketing emails or you can contact customer support.

We will use publicly-available Customer Account Data about your company, such as your industry, the size of your company, and your company’s website URL, to help us understand our customer base better and to tailor information we send you about other MTI products, services, or events.

If you provide us with a physical address in order to obtain a number for which MTI is required to have your physical address on file, we’ll use that address so that we can confirm we can allow you to have that number. We may also check the physical address you provide and/or your billing address, as well as other information you provide or that we obtained from your use of our service about your identity such as your name, email address, and IP address, with our fraud prevention and identity validation providers (to confirm you have provided us with accurate details). We may also use your address information to calculate taxes. We may also have to share these addresses with the telecommunications provider from whom MTI obtained the phone number or local authorities upon their request. Unless prohibited from doing so by law, we’ll let you know if we have to share your address information like this.

We use your payment information so we can bill you and be paid for your use of our products and services.

Your Customer Usage Data. We use your usage data so we can properly bill you for your use of our products and services, appropriately manage and route customer traffic, analyze and improve our products and services, and identify and solve problems with our products and services that arise.

Data collected through tracking technologies like cookies and web beacons. We collect data through tracking technologies so we can understand how customers are using our account portal and what regions our customers are coming from. This helps us understand our customers better and how we can improve our account portal. We also use this to improve our customer’s navigation experience with our account portal.

Who we may share your data with

Unless you give us your permission, we won’t share your Customer Content, Customer Account Data, or Customer Usage Data with third parties, except as described below:

·         Telephony operators as necessary for proper routing and connectivity. One of the things that MTI provides is an easier way for developers to build applications that make use of the publicly switched telephone network (PSTN) to send communications. Therefore, Customer Content and certain Customer Usage Data is shared with and received from telephony operators to the extent necessary to route and connect those communications from the sender to the intended recipient. How those telephony operators handle your Customer Content and Customer Usage Data is generally determined by those operators’ own policies and local regulations.

·         Third-party service providers or consultants. We may share your data stored on our systems with third-party service providers or consultants who need access to the data to perform their work on MTI’s behalf, like sharing relevant Customer Account Data with our payment processor so it can process payments on our behalf, or our storage provider for storing your data on our behalf. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.

·         Compliance with Laws. We may disclose your data stored on our systems to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If MTI is required by law to disclose any of your data that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.

·         Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, customer data we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of MTI may continue to use your data as set forth in this notice.

We do not share your data (including, but not limited to, the personal data of your end users) with third parties for their direct marketing purposes, unless you give us your express consent to do so.

Add-ons

Add-ons are additional features, functionality or services offered by MTI’s Add-on Partners (third parties not affiliated with MTI). MTI may make Add-ons available to you through our service offerings. Some Add-ons may need to access or collect some of your Customer Data. If you choose to use an Add-on, MTI will share your data with the Add-on Partner as necessary in order for you to be able to use the Add-on. MTI does not control Add-on Partners use of your data, and their use of your data will be in accordance with their own policies. If you do not want your data to be shared with an Add-on Partner, then you should not to use the Add-on. Example Add-ons include third party reporting tools, compliance scrubbing, application monitoring, etc.

How we secure your data

We use appropriate security measures to protect the security of your customer data both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note though that no service is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

You may access your account through our account portal by using your email address and a password that you chose when you signed up for MTI’s products and services. To protect the confidentiality of your customer data and protect from unauthorized use of your account, you must keep your password confidential and not disclose it to any other person. Please let us know right away if you think your password or was compromised or misused

How we tell you about changes to our privacy practices

Changes to the privacy policy will be shown on the account portal sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice.

How to make choices about your data

To request deletion of your MTI account, email us at accountmanagers@messagetech.com. You should know that deletion of your MTI account will result in you permanently losing access to your account and all customer data to which you previously had access through your account. Please note that certain data associated with that account may nonetheless remain on MTI’s servers in an aggregated or anonymized form that does not specifically identify you. Similarly, data associated with your account that we are required by law to maintain will also not be deleted.

Promotional communications. You can choose not to receive promotional emails from MTI by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting your account manager. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services.

Cookies and tracking technologies. How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used.

 

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