Last Modified April 23, 2019
Protecting your privacy is an important priority of Sweet., an assumed name of Lunar Labs, Inc., a Delaware corporation with offices at 3434 Russell St. #406, Detroit, MI 48207 (“us,” “we” or “Sweet”), and we are committed to maintaining strong and meaningful privacy protections. The privacy of your information is a significant responsibility and we value the trust you place in us.
This Policy applies to visitors of Sweet’s website, https://savewithsweet.com/ (the “Site”), any users of Sweet’s SIM Card (“SIM”) and/or mobile phone application (“App”) installed or downloaded onto a mobile device, and Sweet customers in the United States (all of whom may be referred to as “you” in this Policy). The App, the SIM and any corresponding products, the wireless data and other communication services provided by Sweet are referred to collectively as the “Services.”
Security & Encryption – SSL.
The security of your personal information is very important to us. In an effort to protect your personal information we have a number of federally compliant guidelines and standards we adhere to in order to protect your information.
On the Site, we use Secure Socket Layer (SSL) technology with a minimum of AES 256 bit encryption. Most web browsers support SSL and therefore those protocols will automatically encrypt the information you provide through the secure pages of the Site.
When visiting a given page on the Site that requires you to include your personal information, you will see https// as part of the URL, which means the page is secure and you have successfully connected with the Sweet secure server.
WHAT TYPES OF INFORMATION WE COLLECT ABOUT YOU
We collect information about you when you communicate with us and when you use our Services, Site, and App.
Information you give us. The “personal information” we collect includes information you provide us, such as name, postal address, telephone number, email address, date of birth, demographics, activities, location information, personal preferences, and payment information. Personal information does not include “de-identified,” “anonymous” or “aggregate information,” which are not associated with a specific person or entity.
You may give us personal information in a variety of ways, including, without limitation, when you:
1. Create an account with Sweet to use the App and to receive Services (e.g., first name and last name, physical address, billing address and other credit card/purchasing processing information, email address, telephone number, date of birth, title, gender, user name, and password).
2. Sign up to receive our newsletters, email communications, and feeds from blogs and social media, link to our social media platforms, and use our application (e.g., addresses for email and other electronic communications, log-in information, social media account information).
3. Communicate with us (e.g., name, address, email address). Please note that you should not send confidential or proprietary information to us via email, other electronic communication, or via a post to a public platform.
4. Download content from and use the Site, App, and Services (which logs information about your use of the phone and the App) and when you otherwise knowingly provide personal information to us.
Information we automatically collect. We automatically collect a variety of information associated with your use of the Services. App and phone usage information we collect includes call and data usage and history, websites visited, wireless location, application and feature usage, network and device data including battery life, product and device-specific information and identifiers, service options you choose and other similar information.
We may also collect information about the device and SIM you used to access the Site and App or to transmit information (such as hardware model, operating system version, unique device identifiers, and mobile network information including phone number), log information (Internet Protocol address, browser type, system activity, hardware settings, browser settings and language, date and time of access, last URL visited, cookies, how you used the Site), cookies that may uniquely identify your browser, and, if you enable Site features that are enabled for location detection, we may collect information about your actual location (such as GPS signals and other geo-location data).
We may link information we automatically collect with personal information for any lawful purpose, such as to improve and analyze the use of Sweet products and services, to improve the visitor experience at the Site and App, to deliver Services, to communicate with you, to monitor the security and integrity of the Services, and to analyze our operations. We may use systems or tools to follow your use of our Services and other applications, including using cookies, web beacons and other mechanisms, along with analysis of network and device information.
We may also send a “cookie,” “pixel tag,” clear gif or web beacons to your device that contains identification unique to the device you are using. The information we receive through cookies, web beacons and similar technologies may enable us to recognize users across devices, such as smart-phones, computers, tablets or related browsers. Depending upon your device or computer, you may be able to set your browser(s) to reject cookies or delete cookies, but that may result in the loss of some functionality on the Site.
HOW WE USE YOUR INFORMATION
We use your personal information for a variety of purposes, including, without limitation:
1. To route your calls or messages or otherwise provide you with Services;
2. To charge your account for usage charges;
3. To deliver and confirm Services you obtain from us;
4. To verify your identity and maintain a record of your transactions and interactions with us;
5. To provide customer and technical services to you;
6. To create, modify, improve, enhance, remove or fix our network, products and services, and their performance;
7. To identify and suggest Services that might interest you;
8. To make internal business decisions about current and future product and service offerings;
9. To provide you customized user experiences, including personalized product and service offerings;
10. To protect our rights, interests, safety and property and that of our customers, service providers and other third parties; and
11. To comply with law or as required for legal purposes; and
12. To evaluate the eligibility of your device and network data usage for the purposes of becoming a customer.
We use personal information to investigate and verify proper conduct using the Services and the Site. We may also use personal information for investigations or prevention of fraud or network abuse.
Third parties may use non-personal information in order to display advertising that reflects the interests and preferences of our user community.
WHEN WE SHARE YOUR INFORMATION
We may share information that is de-identified or in an aggregated form that does not directly identify you.
We do not sell, license, rent or otherwise provide your personal information to unaffiliated third parties except as follows:
1. With your consent, which may be obtained in writing, online through “click-through” agreements, when you accept the terms of disclosures on your phone for certain applications or services, orally on the phone, or implicitly (for example, when you purchase Services and ask for a SIM card to be shipped to your home, consenting to our disclosure of your name and address to a third-party shipping company to complete delivery);
2. To our third-party vendors and partners who complete transactions or perform services on our behalf, for example, credit/debit card processing, billing, shipping, repair, customer service, auditing and marketing;
3. To third-party carriers and supplier, for example, if you are roaming on the network of another carrier or WiFi service provider, information about your usage will be available to that carrier to facilitate that service;
4. Pursuant to a corporate business transaction, such as a merger, acquisition, joint venture, corporate reorganization, financing or sale of company assets, or in the unlikely event of insolvency, bankruptcy or receivership;
5. As required by law and/or in response to service of legal process, such as a court order, summons, subpoena, and the like;
6. To enforce or apply agreements, or initiate, render, bill and collect for Services and products;
7. To protect our rights or interests, property or safety or those of others;
8. To protect users of our Services and other carriers or providers from fraudulent, abusive or unlawful use of or subscription to such Services;
9. To facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
10. In an emergency situation.
HOW WE PROTECT YOUR INFORMATION
We use a variety of physical, electronic and procedural safeguards to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction while it is under our control. Employees are trained on the importance of protecting privacy and on the proper access to and use and disclosure of personal information. Under our practices and policies, access to sensitive personally identifiable information is authorized only for those who have a business need for such access.
Although we work hard to protect personal information that we collect and store, no data security measures are 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal information. Sweet maintains security and incident response plans to handle incidents involving unauthorized access to private information we collect or store.
If you become aware of a security issue, please contact us at the address, email address or telephone number provided at the bottom of this Policy. We will work with you to address any problems.
We retain information only as long as reasonably necessary for business, accounting, tax or legal purposes. When we dispose of personal information, we use reasonable procedures designed to erase or render it unreadable for example, shredding documents and wiping electronic media.
YOUR CONTROL OVER PERSONAL INFORMATION
We strive to keep our customer records as accurate as possible.
If you have created an account with us, you may correct, update and delete your account. You may change your choices for receipt of our print and electronic newsletters and other communications. Where applicable, you may choose whether to receive targeted advertising from third parties. Please note that deleting certain personal information and changing your communications preferences may limit or prevent us from providing goods or services to you.
If you have provided personal information to us and wish to revoke our use of it, you will need to send us a written request (first class mail, email, or other reliable form of written communication) to delete or cease use of your personal information. We are not required to alter or delete information stored for purposes of backup or disaster recovery, other than as specified in our Services Agreement Terms and Conditions, located at https://savewithsweet.com/terms-of-service. In addition, you should be aware that it may not be technologically possible to remove each and every record of information you have provided to us from our servers.
Federal privacy rules require Sweet to authenticate your identity prior to disclosing any of your personal information. When you contact us we will ask you a series of question in order to authenticate your identity as the account owner. Sweet will only discuss account information with you once you have been authenticated as a valid Sweet customer and the account owner in question.
In the event you are not able to validate your information there will be additional means that Sweet will use to validate your authentication, including, without limitation: 1) by having the Customer provide a pre-established password, personal identification or uniquely identifiable information you had provided; 2) by Sweet calling you back at the telephone number associated with your account and the Services purchased; or 3) by mailing the requested documents to the address of record associated with your account.
In the event you are not able to remember your password and/or your personal identification number, Sweet will ask you a series of questions, the answers of which you have previously provided to Sweet, in order to authenticate you as the customer. If such an event occurs and you are not able to provide this information, we may require you to provide additional information in order to validate your identity, and you will then be required to establish a new password and or personal identification number associated with your account. Or you may be required to sign up for a new account, re-establish all of your previous information along with new information, and provide your confirmation of a new Services Agreement Terms and Conditions, since you may lose rights and access to all data stored in your previous customer account information file.
To protect your privacy and your security we will take all reasonable steps to verify your identity prior to our granting any access and/or prior to your making any corrections of your information.
From time to time Sweet may notify you of certain account changes. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, Sweet may notify you.
You play an important role in ensuring the security your personal information. We encourage you to use safeguards to protect your information and phone and update us immediately if any of your personal information changes.
If you choose to do so, you may opt out of all Sweet promotional and informative emails, as well as all emails from our third party affiliates at any time by sending an email to: email@example.com. When you send your email to opt out please include your email address in the subject. You may also have the ability to opt out from emails in places during the signup process by simply checking off the opt-out boxes, as well as in the footer section of the emails in question using the “Unsubscribe” link.
In the event we experience a privacy breach and your confidential personal information may be affected and/or possibly disclosed to unauthorized persons, federal rules require us to report any such breaches to law enforcement and to you as soon as we become made aware of such breach. Specifically, we will: (a) reasonably notify law enforcement no later than ten (10) business days after a reasonable determination that such breach has occurred by sending electronic notification to the appropriate governmental authorities and (b) reasonably notify you directly as soon as practically reasonable. We cannot inform you of any breach or malicious activity which may have affected your confidential personal information until at least seven (7) days after notification has been provided to the proper governmental authorities and/or the appropriate law enforcement divisions. Unless provided however the appropriate law enforcement office and/or government agency informs us and/or our third party affiliates to postpone disclosure to you due to a pending investigation. Further for a period of no less than five (5) years we will maintain all records of any discovered breaches, including but not limited to; the date that we discovered the breach, the date of which we notified the proper governing agencies and copies of any and/or all notifications. We will also retain a detailed description(s) of the breach, including the parameters of the breach and the applicable agencies response (if any) of the reported breach.
OTHER INFORMATION YOU SHOULD KNOW
Credit Card Information. Your credit card information will be transmitted to a third party processor and is not retained by us.
Information About Children. We are committed to protecting the privacy of children. The Site is not designed or intended to attract or target children under the age of 18. The Site does not collect personal information from any person whom we actually know is under the age of 18. Please refer to our Product and Services Agreement Terms & Conditions of Service (https://savewithsweet.com/terms-of-service) and our Acceptable Use Policy (https://savewithsweet.com/acceptable-use-policy) if you are purchasing Sweet Products and Services for a minor. When you purchase Services for the intended use by a minor, any personal information will appear to be the personal information of the actual adult subscriber and treated as such under this Policy. You are at all times solely liable and responsible for any account you create and the Services stemming therefrom that may be used by a minor.
California Privacy Rights. California Civil Code Section 1798 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. As stated in this Policy, we will not sell or share your personal information with non-affiliated companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the contact provide below.
Links to Other Websites, Applications. At the Site, we may provide links to third party websites. We are not responsible for the content or information collection practices of those sites, including their privacy policies. Please review the privacy policies of such sites. Within our App, you are also able to access third party websites or applications. As with the links we provide on our Site, any third party application or website you access from the App is subject to content or information collection practices of those sites and we are not responsible for their operations, policies or practices. Please review their privacy policies before using third party applications or visiting their sites.
Changes to This Policy. We reserve the right to make changes to this Policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the top of the Policy. If we make any significant changes to this Policy, we will notify you by email, post a notice of such changes on the Site or within the App, or flag this Policy on the Site (as determined in our sole discretion).
Place of Business; Governing Law. The Site is delivered from, and the relationship created between you and Sweet through this Policy, is deemed to take place in Detroit, Michigan USA. The Policy is entered into and performed in Detroit (Wayne County), Michigan USA. The Policy does not give rise to personal jurisdiction over Sweet, either specific or general, in jurisdictions other than Michigan. The terms of this Policy, including their validity and enforceability, is governed by the internal substantive laws of the State of Michigan, without respect to its conflict of laws principles. Without limitation, Sweet does not represent that its Policy complies with privacy laws outside the U.S., including the European Union Data Protection Directive, the Switzerland Data Protection Law, or the Canadian Privacy Law.
Dispute Resolution. The parties shall attempt to resolve any disputes through good faith business negotiations or facilitative mediation in Detroit, Michigan. All disputes or claims arising out of or relating to this Policy shall be settled by arbitration, to be conducted by a single arbitrator in Detroit, Michigan, by and in accordance with the then effective commercial rules of the American Arbitration Association; provided that the arbitrator shall not have authority to issue injunctions. The costs of the arbitration and the reasonable attorneys’ fees of the prevailing party shall be included in any award rendered by the arbitrator. The proceedings shall be conducted only in the English language. Judgment upon the award may be entered in any court having jurisdiction thereof. Other legal proceedings, if any, shall be initiated and maintained in Wayne County, Michigan, or in the U.S. District Court of the Eastern District of Michigan, Southern Division. The parties expressly submit to the exclusive personal jurisdiction and venue of these courts and waive any objection on the grounds of personal jurisdiction, venue, or forum non conveniens. Please refer to our Services Agreement Terms & Conditions of Service (https://savewithsweet.com/terms-of-service) for our full Dispute Resolution Policy.
Severability. If any portion of this Policy is found to be unenforceable, such portion will be modified to reflect the intent of the parties set forth in such portion and only to the extent necessary to make it enforceable. The remaining provisions will remain in full force and effect.
Contact. If you have any questions or comments about this Policy or about Sweet’s privacy practices, please call us at (844) 835-8627 or send an email message to firstname.lastname@example.org. You may also direct your privacy-related comments or questions to the address below:
Sweet Labs, Inc.
3434 Russell St. #406
Detroit, MI 48207
Effective Date April 23, 2019
Version Number 1.2