Revised: June 1, 2020
Thank you for choosing to be part of our community at Telecom Management Group LLC, doing business as AOTMP® (“AOTMP®”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you visit our website https://aotmp.com/, mobile applications, and/or use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy notice. We seek to explain to you in the clearest way possible what information that we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites or Apps and our services.
This privacy notice applies to all information collected through our website (such as https://aotmp.com/), our mobile applications, (“Apps”), and/or any related services, sales marketing, or events (we refer to them collectively in this privacy notice as the “Services”).
Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- DO WE USE GOOGLE MAPS?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- WHAT RIGHTS DO I HAVE UNDER PRIVACY SHIELD?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Information automatically collected
In short: Some information – such as IP addresses and/or browser and device characteristics – is collected automatically when you visit our Services or Apps.
We automatically collect certain information when you visit, use or navigate the Services or Apps. This information does not reveal your specific identify (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our cookies policy: https://aotmp.com/cookies/.
Information collected through our Apps
In short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our Apps.
If you use our Apps, we may also collect the following information:
Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permission, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information collected from other sources
In short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listing (such as sponsored links). We will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within one month.
2. HOW DO WE USE YOUR INFORMATION?
In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
Below are some definitions that will help you understand the roles and responsibilities of Telecom Management Group LLC:
“data controller” means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be used.
“data processor”, in relation to personal information, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
If you provide the data and the instructions, then you are the data controller and Telecom Management Group LLC is the data processor.
If we determine the purposes for which we collect and use your personal information, then we are the Controller.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.
To post testimonials. We post testimonials on our Services or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see our Cookies Policy: https://aotmp.com/cookies/.
Request feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To deliver services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquires and solve any potential issues you might have with the use of our Services.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other website that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookies Policy: https://aotmp.com/cookies/.
We may share your information with our affiliates, in which case, we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services or Apps) or otherwise interact with public areas of the Services or Apps, such personal information may be viewed by all users and may be publicly distributed outside the Services or Apps in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services or Apps, and view your profile.
5. DO WE USE GOOGLE MAPS?
In short: Yes, we use Google Maps for the purpose of providing better service.
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
The Services or Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices or policies of any third parties, including other websites, services, or applications that may be linked to or from the Services or Apps. You should review the policies of such third parties and contact them directly to respond to your questions.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of 18, please contact us at firstname.lastname@example.org.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.
If you are a resident of the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/board/members_en.
If you would, at any time, like to review or change the information in your account or terminate your account, you can:
Log into your account settings and update your user account.
Contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps. To opt-out of interest-based advertising by advertisers on our Services or Apps visit: https://www.aboutads.info/choices/. For further information, please see our Cookies Policy: https://aotmp.com/cookies/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
Note your preferences when you register an account with the site.
Access your account settings and update preferences.
Contact us using the contact information provided.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating system and mobile applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once per year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and address of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, resident in California, and have registered an account with the Services or Apps, you have the right to request removal of unwanted data that you publicly post on the Services or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
13. COMPLIANCE AND PARTICIPATION IN PRIVACY SHIELD
In short: We comply and participate in the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework set forth by the United States Department of Commerce with respect to the collection, use and retention of Personal Data transferred from the European Union and the United Kingdom, and Switzerland to the United States, respectively.
We comply with the EU‑U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework set forth by the United States Department of Commerce with respect to the collection, use and retention of Personal Data transferred from the European Union and the United Kingdom, and Switzerland to the United States, respectively, as further described in the Scope section below. We additionally commit to cooperation with the EU data protection authorities (“DPAs”) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to unresolved Privacy Shield complaints regarding data transferred from the EU and Switzerland. This Privacy Shield Policy outlines our commitment to the Privacy Shield Principles (the “Principles”) and our practices for implementing the Principles. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Our Privacy Shield certification can be found here: https://www.privacyshield.gov/list. To learn more about the Privacy Shield Framework, please visit the Department of Commerce’s dedicated Privacy Shield website, located here: https://www.privacyshield.gov/Program-Overview.
We comply with the Principles with respect to the Personal Data the company receives from its Customers or their Users in the European Union, the United Kingdom and Switzerland in connection with the use of (i) applications downloaded to a User’s mobile device (“Mobile Applications”); and (ii) AOTMP® hosted software applications (the “Subscription Service”) and related support services (“Support Services”), as well as expert services (including professional services, training and certification) (the “Expert Services”) that we provide to Customers. In this section, the Subscription Service, Support Services and the Expert Services are collectively referred to as the “Service.”
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Customer” means any entity that purchases the Service.
“Customer Data” means the electronic data uploaded into the Subscription Service by or for a Customer or its Users.
“Device” means a mobile device.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual and (ii) received by us in the U.S. from the European Union, the United Kingdom, or Switzerland in connection with the Service.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.
“User” means an individual authorized by Customer to access and use the Subscription Service.
Types of data collected
We host and process Customer Data, including any Personal Data contained therein, at the direction of and pursuant to the instructions of our Customers. We also collect several types of information from our Customers, including:
Information and correspondence our Customers and Users submit to us in connection with Expert Services or other requests related to our Service.
Information we receive from our business partners in connection with our Customers’ and Users’ use of the Service or in connection with services provided by our business partners on their behalf, including configuration of the Subscription Service.
Information related to Users’ use of the Mobile Applications, including geographic location data and information regarding Users’ Devices and OS identification, login credentials, language and time zone.
In addition, we collect general information about its Customers, including a Customer’s company name and address, credit card information, and the Customer representative’s contact information (“General Information”) for billing and contracting purposes.
Purposes of collection and use
We may use Personal Data submitted by our Customers and Users as necessary to provide the Service and Mobile Applications, including updating, enhancing, securing and maintaining the Subscription Service and Mobile Applications and to carry out our contractual obligations to its Customers. We also obtain General Information in connection with providing the Service and maintaining our relationships with its Customers.
Third party disclosures
We may disclose Personal Data that our Customers and Users provide to our Service and Mobile Applications:
To our subsidiaries and affiliates;
To contractors, business partners and service providers we use to support our Service;
In the event we sell or transfers all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation), in which case Personal Data held by us about our Customers will be among the assets transferred to the buyer or acquirer;
If required to do so by law or legal process;
In response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements.
Individuals in the European Union, the United Kingdom and Switzerland generally have the right to access their Personal Data. As an agent processing Personal Data on behalf of its Customers, we do not own or control the Personal Data that it processes on behalf of its Customers or their Users and does not have a direct relationship with the Users whose Personal Data may be processed in connection with providing the Service. Since each Customer is in control of what information, including any Personal Data, it collects from its Users, how that information is used and disclosed, and how that information can be changed, Users of the Subscription Service should contact the applicable Customer administrator with any inquiries about how to access or correct Personal Data contained in Customer Data. To the extent a User makes an access or correction request to us, we will refer the request to the appropriate Customer and will support such Customer as needed in responding to any request.
To access or correct any General Information Customer has provided, the Customer should contact their account representative directly or by using the contact information indicated below.
In accordance with the Principles, we will offer Customers and Users choice to the extent it (i) discloses their Personal Data to third party Controllers, or (ii) uses their Personal Data for a purpose that is materially different from the purposes for which the Personal Data was originally collected or subsequently authorized by the Customer or User. To the extent required by the Principles, we also will obtain opt‑in consent if it engages in certain uses or disclosures of Sensitive Data. Unless we offer Customers and Users an appropriate choice, we use Personal Data only for purposes that are materially the same as those indicated in this Policy.
We may disclose Personal Data of Customers and Users without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third‑party Processors that we have retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserve the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
Liability for onward transfers
We comply with the Privacy Shield’s Principle regarding accountability for onward transfers. We remain liable under the Principles if its onward transfer recipients process Personal Data in a manner inconsistent with the Principles, unless we prove that it was not responsible for the event giving rise to the damage.
If we maintain your Personal Data in one of the Services within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance to email@example.com, or in the U.S., European Union, the United Kingdom, or Switzerland by regular mail as indicated below. We shall respond within 45 days.
If your complaint cannot be resolved through our internal processes, we will cooperate with an independent, third-party mediator adhering the international standard mediation rules. The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Data, publicity for findings of non‑compliance, payment of compensation for losses incurred as a result of non‑compliance, or cessation of processing of Personal Data of the Customer or User who brought the complaint.
The mediator, or the Customer or User, also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over us. Under certain circumstances, Customers and Users may be able to invoke binding arbitration to address complaints about our compliance with the Principles.
14. DO WE MAKE UPDATES TO THIS POLICY?
In short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Brettan Pyke, by email at firstname.lastname@example.org, or by phone at +1 317-275-7225 or by post to:
Telecom Management Group LLC d/b/a AOTMP®
7602 Woodland Drive
Indianapolis, Indiana 46278
If you are a resident in the European Economic Area, the “data controller” of your personal information is AOTMP® Limited. AOTMP® Limited has appointed Brettan Pyke to be its representative in the EEA. You can contact them directly regarding the processing of your information by AOTMP® Limited, by email at email@example.com, by phone at +44 0844 744 3823, or by post to:
268 Bath Road
Slough SL1 4DX