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Privacy Policy

Last Updated: December 20, 2024

Gigs Wireless, LLC and our affiliated companies (collectively, “Gigs,” “our,” “us” or “we”) provide a global connectivity enablement platform and related services (“Services”) to enterprises, enabling our enterprise clients (each a “Partner”) to provide connectivity and wireless-enabled devices and services to their customers and end users (each, an “End User”).  This Gigs Privacy Policy (“Privacy Policy”) describes how we collect, use, disclose and otherwise process the personal information described below, as well as the rights and choices individuals have regarding this personal information. If you are a Partner or End User, this Privacy Policy should also be read in conjunction with the Gigs Terms of Use (for Partners) or the Gigs End User Service Agreement (for End Users), respectively.

California residents: If you are a California resident, please review our California privacy notice here, which includes additional information about our information practices, as required by the California Consumer Privacy Act (CCPA), including the categories of personal information we collect about California consumers, the purposes for which we collect, use, retain and disclose this personal information, including any “sales” or “sharing” of such information, and how California consumers can exercise their CCPA privacy rights, including the right to opt out of “sales” and “sharing” under the CCPA.

Contents of the Privacy Policy

Our Privacy Policy is organized into sections. Click any section in the side bar to the right to navigate directly to that section of our Privacy Policy.

1. Overview of Gigs and its Services

Gigs enables our Partners to provide and manage wireless connectivity and subscriptions for End Users. More specifically, Partners can access and use the Services to offer or help offer End Users wireless service and other telecommunications-enabled or ‘connected’ services, such as, for example, (a) mobile wireless phone plans (i.e., voice, data, roaming, messaging), (b) connected wearables and other smart devices, and (c) travel data services (i.e., data-only connectivity when traveling outside an End User’s home country) (collectively, the “Connectivity Services”).  Gigs' provision of the Connectivity Services is supported by third party suppliers, such as mobile network operators and other telecommunications and technology partners (the “Third-Party Connectivity Providers”).  (End users in the EU or UK, please click here for additional privacy information that we are required to disclose about some of our Third-Party Connectivity Providers.)  Gigs also enables its Partners to provide, manage, and administer the Connectivity Services to End Users using Gigs’s proprietary technology platform, including interfaces, APIs, dashboards, checkout, payment, tax, and other solutions (the “Gigs Platform Services”). The ‘Services’ defined above include, the Platform Services and the Connectivity Services.

2. Scope and Applicability

This Privacy Policy describes what personal information we may collect, access, store, use, retain, or otherwise process (collectively, “process”) related to our Services, our website, www.gigs.com (the “Site”), including Partners and End Users (of the Connectivity Services), visitors to the Site (each a “Site Visitor”), and individuals that communicate or interact with us related to our Site and Services.  

Not in scope. This Privacy Policy does not apply to or describe: 

  • The data practices of any of our Partners, Third-Party Connectivity Providers, or any other third-parties that support our provision of the Services. You will need to consult the privacy policies of such parties for any questions in relation thereto.  

  • Personal information about job applicants and candidates, or employees and non-employee workers, which is subject to the terms of our employee & applicant privacy policies.

As used herein, “personal information” includes other similar terms under applicable data privacy laws—such as “personal data” and “personally identifiable information.”   

Data controller. For the purposes of the EU General Data Protection Regulation (the “GDPR”), UK Data Protection Act 2018 (“UK DPA”), and similar data protection laws, Gigs Wireless LLC is the data controller, generally, for the personal information processed pursuant to this Privacy Policy, including personal information processed related to the Site and Services.  Where you have a direct contract with another Gigs group company then they are the data controller for any personal information processed pursuant to that contract.  

Please note that Partners and Third Party Connectivity Providers are independent controllers for any personal information that they collect and process about you related to the Services, and their processing is subject to their respective privacy policies and not this one.

3.
Personal Information Collected

Summarized below is the personal information processed by Gigs.  You do not have to provide us with your personal information to access much of the Site.  If you choose not to disclose certain information, you can still visit our Site, but you will not be able to create an account with us or access and use the Services, and we may be unable to fully respond to your inquiries.  Also, where required by law, we ask for your consent or give you certain choices prior to collecting or using certain personal information.

Categories of Personal Information Collected. While the actual personal information we process and varies depending upon the circumstances, including the nature of our relationship and interactions with you (e.g., Partner, End User, Site Visitor, etc.), generally, we collect the following types of personal information:

  • Identifiers: includes direct and indirect identifiers, such as name, username, account name, address, phone number, email address, online identifier, user agent, IP address, device identifiers (e.g., device IMEI, SIM ICCID, SIM credentials, device make & model), or other similar identifiers.

  • Customer Records: includes personal information, such as name, signature, contact information, and payment information, that Partners and End Users provide us in order to purchase or access our Services.

  • Commercial Information: includes records products or services purchased, obtained or considered, or other purchasing or use histories.

  • Usage and Activity Data: includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s use of or interaction with our Site and Services, as well as our marketing emails and online ads.

  • Location Data: includes location information about a particular individual or device (e.g., we may derive location information from your IP address with which you accessed our Services, or through usage data for billing indicating in which countries your SIM was used).

  • Audio, Visual and other Electronic Data: includes transcripts and recordings of support and sales calls as well as video conferences (e.g., of customer support calls), and video recordings (e.g., CCTV) and other access logs of visitors to our offices and premises.

  • Professional Information: includes professional and employment-related information, such as current and former employer(s) and position(s) and business contact information.

  • Inferences: includes inferences drawn from other personal or business information that we collect to create a profile reflecting an individual’s preferences, behavior or other characteristics. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to clients, so that we can better reach them with relevant offers and ads.

Information Collected Directly. We may collect personal information about you directly from you or from your company.   For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, register for events we host or sponsor, or otherwise provide us information through the Site, we may collect personal information as described in the contact form (e.g., name, company name, company email address and website URL, country location, etc.).  Additionally, when you sign up to create an account for our Services as a Partner or End User, we require certain information in order to do so (e.g., name, email, phone number, device information, billing information, country location, etc.).

Automatically Collected Information. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the services or visit the Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information.  For more information, see Section 6 ”Cookies, Analytics and Tracking,” below.

Information Collected from Third Parties.  We may collect personal information about you from third party sources, such as Partners, business partners, social media platforms, public sources, joint marketing partners, our resellers (so that we can deliver our Services), and third parties to whom you have expressed interest in our products and services, as well as information that you shared on social media platforms (subject to the respective platform terms and applicable laws).

5. Disclosures of Personal Information

We may disclose the personal data that we collect to others, for the purposes described above, including:

  • Affiliates: to our affiliates and subsidiaries, whose handling of your personal information is subject to this Policy.

  • Partners: if you access or use our Services through one of our Partners, or otherwise communicate with us about our Site or Services on behalf of a company (including a prospective client), we may share personal information about your access, and your communications or requests, with the relevant company.  

  • Service providers: to third party service providers and data processors who perform functions that include the processing of personal information on our behalf, as well as Third Party Connectivity Providers.  

  • Advertising and analytics partners: to third parties we engage to provide advertising, campaign measurement, online and mobile analytics, and related services to us (with your consent, where required by applicable laws).

  • Compliance and legal process: to comply with the legal and compliance obligations and to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.  We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions. 

  • Security and protection of rights: to protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of the Gigs Terms of Use or the Gigs End User Service Agreement. 

  • Business transfers: as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including disclosures related to due diligence conducted prior to such event where permitted by law.

Personal Information may also be disclosed or available to others, including Third Party Connectivity Partners, where necessary or incidental to the provision and operation of our Services, and as otherwise directed or authorized by you.

6. Cookies, Analytics and Tracking

We and our third-party providers use cookies, pixels, local storage objects, log files, APIs, and other mechanisms   to automatically collect browsing, activity, device, and similar information on our Site and to measure and deliver more targeted advertising on other Sites. This information is used, for example, to analyze and understand how visitors interact with our Site and our content and ads on third party sites; identify and resolve bugs and errors on our Site; assess, secure, protect, optimize and improve the performance of our Site and Services; conduct marketing and analytics; and reach customers and prospective customers with more relevant ads; and evaluate our marketing and ad campaigns. 

Cookies. Browser cookies are alphanumeric identifiers that we transfer to your device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process, support the security and performance of the Site or allow us to track activity and usage.

Pixels.  Also referred to as tags, web beacons or clear GIFs, pixels are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these in connection with our Site and our ads and content on other sites and platforms, to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also include these in  HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.  

Third-party analytics and tools. We use third-party tools, such as Google Analytics, which are operated by third-party companies. These third-party analytics companies may use cookies, pixels, and other similar tools to collect usage data about our Site in order to provide us with reports and metrics that help us evaluate usage of our Site and improve performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Targeted advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services, and others (“third-party ad companies”) to personalize content and display advertising on our Site, as well as to manage our advertising on third-party sites and platforms. We and these third party ad companies may use cookies, pixels, and other tools to collect Usage and Activity Data on our Site, and on third-party sites, and platforms, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. The information enables us to provide more relevant ads and content within our Site and on third-party sites and services, and to evaluate the success of such ads and content.

Managing your Site preferences. We make available several ways for you to manage your preferences regarding targeted advertising, matching and cookies within our Site.  Many of these are browser and device-specific, which means that you need to set the preference for each browser and device you use to access our Site; in addition, if you delete or block cookies, you may need to reapply these preferences.  Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us (and others).

  • Cookie preference manager: you can review or change your preferences for targeting cookies and tags on our websites by adjusting your cookie settings.  These settings are browser and device specific.

  • Browser signals: if our website detects that your browser is transmitting a “global privacy control”—or GPC—signal, we will apply that to opt that browser on your device out of targeting cookies on our website.  If you come to our website from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.  More information about GPC is available at www.globalprivacycontrol.org. Please note: our websites do not recognize or respond to browser “do not track” signals.  

  • Industry ad choice programs: you can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at:

  • Browser settings: if you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The ‘Help’ portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.

7. International Transfers

Gigs is a multinational company with operations and service providers in multiple jurisdictions, including the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States, the United Kingdom (“UK”) and the European Economic Area (“EEA”), Canada, Australia, Singapore, and Japan) that may not provide equivalent levels of data protection as your home jurisdiction. Personal information may also be accessible to law enforcement and public authorities in these jurisdictions.  We take steps designed to protect your personal information in the jurisdictions in which we process it, including through appropriate contractual terms.

If you are in the EEA or the UK, and we process your personal information in a jurisdiction that has not been found, respectively, by the European Commission or the UK ICO to  provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA or the UK. Such right may also exist in other jurisdictions. You may request such details by contacting us as set forth in Section 13 “Contact Us,” below.

8. Children and Minors

Our Site is not targeted to children under 13 or to other minors under the age of 18.  In general, we do not knowingly or intentionally collect personal information from children or minors.  In limited instances, End Users of our Partners may be minors.  In such cases, our Partners are responsible for ensuring consent is obtained, including verifiable parental consent where required under the U.S. Children’s Online Privacy Protection Act (“COPPA”).   If you believe we have collected your child’s personal information without obtaining any required consent, please notify us as set out in Section 13 “Contact Us,” below. 

9. Security

We take steps to protect the personal information that we collect from unauthorized access or disclosure.  Regardless of the precautions taken by us, Gigs cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. You are responsible for all actions taken with your account, if any.

For additional information about Gigs security practices as it relates to the Site and our Services, please visit the Gigs Trust Center.

10. Retention

As a general rule, we retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.  We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.

11. Your Choices and Rights

Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request to data-request@gigs.com.  We will review your request and make reasonable efforts to respond to it as soon as practicable and in accordance with applicable law. We may ask you for additional information so that we can confirm your identity.

Direct Marketing. You may always opt-out of direct marketing emails. If you would like to unsubscribe from Gigs email subscriptions or otherwise change your email preferences with Gigs, please follow the instructions in any Gigs promotional email that we send to you. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.

Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information.  You also have the right to raise a complaint with the privacy regulator or supervisory authority in your jurisdiction.

Additional Information for Certain Jurisdictions. In Section 14 “Additional Information under Certain Privacy and Data Protection Laws,” we provide additional information for users in certain jurisdictions, including EU and UK data subjects, California residents, and residents of certain other US states.  Users in these jurisdictions should review this section for more information regarding their rights under applicable privacy laws.

12. Changes to the Policy

Gigs may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. Revisions will be posted on our website, here. If the changes will materially affect the way we use or disclose personal information we have previously collected about you, we will endeavor to notify you in advance of the change, such as by sending a notice to the primary email address associated with your account or by posting a notice on the Site. We encourage you to periodically review this Policy for the latest information on our privacy practices.

13. Contact Us

To submit a privacy request or other inquiry related to this Privacy Policy or our privacy practices, you may contact us at data-request@gigs.com.   If you are in the EU or UK, please also see Section 14.A below.

14. Additional Information Under Certain Privacy and  Data Protection Laws

This section contains additional information for data subjects under the GDPR and UK data protection laws, as well as for residents of California  and other U.S. states.

A. EU and UK Data Subjects

Subject to the conditions set out in the applicable law, individuals in the EU/EEA and UK may have the following rights (or some of them) with regard to our processing of their personal information:

  • Right of access: You can ask us to: confirm whether we are processing your personal information; give you a copy of that information; provide you with other information about your personal information such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your information from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Policy.

  • Right to rectify and complete personal information: You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.

  • Right of erasure: You can ask us to erase your personal information, but only where: it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see ‘Objection’ below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your personal information if the processing of your personal information is necessary: for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request. Brazilian users may also request the anonymization, blocking or erasure of unnecessary or excessive personal information or personal information processed in violation of the LGPD.

  • Right of restriction: You can ask us to restrict (i.e., keep but not use) your personal information, but only where: its accuracy is contested, to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal information following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.

  • Right to object to our use of your personal information for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

  • Right to object for other purposes: You have the right to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

  • Right not to be subject to automated decision-making: You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us. Depending on applicable law, users may also request the revision of any decision made solely on the basis of automatic processing, to the extent such decision affects your interests.  We do not engage in automated decision-making.

  • Right to (data) portability: Depending on applicable law, you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another controller, but only where our processing is based on your consent and the processing is carried out by automated means.

  • Right to withdraw consent: You can withdraw your consent in respect of any processing of personal information which is based upon a consent which you have previously provided.

  • Right to obtain a copy of safeguards: you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside the EU/EEA, UK or other countries where such a right exists. We may redact data transfer agreements to protect commercial terms.

  • Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.

Data subject requests and other privacy inquiries may be submitted to Gigs at data-request@gigs.com. If you are in Germany, you may also contact our German Data Protection Officer at: heyData GmbH, Schützenstr. 5, 10117 Berlin, datenschutz@heydata.eu.  In addition: 

  • European Union (“EU”) Representative: We have appointed Gigs GmbH, Bergstr. 77, 10115 Berlin, DE,  legal@gigs.com, as our EU representative pursuant to Art. 27 of the GDPR.  

  • United Kingdom (“UK”) Representative: We have appointed Gigs U.K. Ltd, 2 Leman Street, London, United Kingdom, E1W 9US, legal@gigs.com, as our UK representative pursuant to UK data protection law.  

B. Residents of Certain U.S. States

If you are a California resident, please see Section 14.C below for additional information about your privacy rights under the CCPA.  

In addition to the choices and rights set forth above, consumers that are residents of certain U.S. states (including Colorado, Connecticut, Montana, Delaware, Iowa, Nebraska, New Hampshire, Oregon, Texas, Utah and Virginia) have additional rights regarding their personal data under applicable state privacy laws, which may include the following rights, subject to certain conditions and limitations:

  • Access: to confirm whether we are processing their personal data and to obtain a copy of their personal data in a portable and, to the extent technically feasible, readily usable format.

  • Correction: to correct inaccuracies in their personal data, taking into account the nature and purposes of the processing of the personal data.

  • Deletion: to delete their personal data provided to or obtained by us.

  • Opt-out: to opt out of certain types of processing, including:

    • to opt out of the “sale” of their personal data;

    • to opt out of targeted advertising by us; and

    • to opt out of any processing of personal data for purposes of making decisions that produce legal or similarly significant effects.

  • Appeal: to appeal our denial of your request.

  • Withdraw consent: where your consent has been obtained, you may withdraw your consent to certain types of processing, including your consent to our collection and processing of sensitive personal data.

You may submit a request to exercise one of your other privacy rights, or appeal a denial of your request, by emailing us at data-request@gigs.com.  We will take steps to verify your request, which may include sending you an email confirmation link which you must click to confirm your request and matching the information provided by you with the information we have in our records.  We will process your request based upon the personal data in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request.  

You may also opt out of targeted advertising via our Site by adjusting your cookie settings or enabling Global Privacy Control—or GPC—signals for your browser, as described under the “Managing your Site preferences” section above.  

C. California Privacy Notice

In this section, we provide additional information for California residents about how we handle their personal information, as required under California privacy laws, including the CCPA. This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

Categories of Personal Information Under the CCPA

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months.

Categories of Personal Information Collected and Disclosed. Below we identify the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. In addition to the categories of disclosures below, personal information may be disclosed to our service providers who act on our behalf and others where required by law or directed or authorized by you.

Identifiers
This includes direct identifiers, such as name, username, account name, address, phone number, email address, online identifier, user agent, IP address, device identifiers (e.g., device IMEI, SIM ICCID, SIM credentials, device make & model), or other similar identifiers.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; enterprise clients.

Customer Records
This includes personal information, such as name, signature, contact information, and payment information, that individuals provide us in order to purchase or obtain our products and services.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; enterprise clients.

Commercial Information
This includes records of products or services purchased, obtained or considered, (or other purchasing or use histories), billing address, credit card last-four digits, bank account and routing information.  Please note that Gigs does not collect or have access to full credit-card information.  Instead, Gigs uses payment processors (such as Stripe, Inc.). For other information about Gigs’s subprocessors, see the Gigs Trust Center.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; enterprise clients.

Usage and Activity Data
For the Services, this includes information pertaining to text/SMS usage (e.g., text timestamp, incoming/outgoing text phone number), voice usage (e.g., voice timestamp, incoming/outgoing voice phone number, call duration), data usage (e.g., data timestamp, data duration, data volume usage), country usage information, and aggregate Services usage data.

For the Site, this includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites and services, and our marketing emails and online ads.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; enterprise clients.

Location Data
This includes precise location information about a particular individual or device.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries.

Audio, Visual and other Electronic Data
This includes transcripts and recordings of support and sales calls and other video conferences (e.g., of customer support calls), as well as video recordings (e.g., CCTV) and other access logs of visitors to our offices and premises.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries; enterprise clients.

Professional Information
This includes professional and employment-related information, such as current positions, business contact information, business-related social media information (e.g., LinkedIn, Twitter/X).

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries; enterprise clients.

Inferences
This includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, behavior or other characteristics. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.

This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries.

Sensitive Data
Some of the personal information we collect is considered sensitive personal information, including SSNs and government identifiers, financial account numbers. This may also include health and disability information, which we may collect in order to provide accommodations to you, as well as precise geolocation.

This may be disclosed to: affiliates and subsidiaries; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries.

Sales and sharing of personal information.  Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value and “sharing” includes communicating personal information to a third-party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We do not disclose personal information to third parties in exchange for monetary compensation, but we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as to improve and measure our ad campaigns and reach users with more relevant ads and content. Accordingly, as defined by the CCPA, we may sell or share Identifiers, Usage and Activity Data and Inferences with third party advertising networks, social media networks, and data analytics providers.  However, we do not sell personal information about individuals we know to be under 16 years old, nor do we sell or share any sensitive personal information about California residents. 

Sources of personal information. As further described above,  in Section 3 “Personal Information Collected,” we may collect personal information from individuals directly as well as the following sources:

  • Partners and Third Party Connectivity Providers

  • Directly from the individual

  • Advertising networks and social media platforms

  • Data analytics providers

  • Internet service providers

  • Operating systems and platforms

  • Publicly available sources

Business and Commercial Purposes for Collecting, Using, Disclosing and Otherwise Processing. As further described above, in Section 4.B “Purposes of Use, Disclosure and Processing” and Section 5 “Disclosures of Personal Information,” we collect, use disclose and otherwise process the personal information we collect for the following business and commercial purposes:

  • Operating the Site and Services and providing related support

  • Responding to inquiries and requests

  • Analyzing and improving the Site, Services, and our business

  • Personalizing experiences

  • Advertising and marketing

  • Protecting our legal rights and preventing misuse  

  • Complying with legal obligations

  • In support of our business operations

Sensitive Personal Information. Notwithstanding the purposes described above, we only use and disclose sensitive personal information about California residents as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.

CCPA Rights. In general, California residents have the following rights with respect to their personal information, subject to certain limitations:

  • Deletion: the right to request deletion of their personal information that we have collected about them.

  • Know/access: the right to request and receive a copy of the specific items of personal information that we have collected about them and the right to request that we provide them certain information about how we have handled their personal information during that period including the:

    • categories of personal information collected;

    • categories of sources of personal information;

    • categories of personal information about them we have disclosed for a business purpose or sold;

    • categories of third parties to whom we have sold or disclosed for a business purpose their personal information;

    • the business or commercial purposes for collecting or selling their personal information; and

    • a copy of the specific pieces of personal information we have collected about them.

  • Correction: the right to request the correction of inaccurate personal information the company maintains about them.

  • Limit certain uses and disclosures of sensitive personal information: the right to request that we limit uses or disclosures of sensitive personal information to those uses authorized by the CCPA; however, as noted we do not use or disclose sensitive personal information beyond these purposes.

  • Non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

  • Opt out of sales and sharing: to opt out of sales or sharing of their personal information by us, by using our do not sell or share my personal information link.

Requests to Opt Out. You may opt out of targeted advertising via our Site by adjusting your cookie settings or enabling Global Privacy Control—or GPC—signals for your browser, as described under the “Managing your Site preferences” section above.  

Submitting Requests to Access, Delete, Correct or Limit. Data subject access requests may be submitted to Gigs via email at data-request@gigs.com.

When you submit a data subject right request, we will take steps to verify your request by matching the information you provide with the information we have in our records and verifying your registered email address. We may request additional information in order to verify your request or where necessary to process your request. Authorized agents may also initiate a request on behalf of another individual by contacting us as at the email listed above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Contact Us. You can contact us regarding this Privacy Policy via email at data-request@gigs.com.