- WHAT TYPES OF INFORMATION WE COLLECT ABOUT YOU
We collect information about you and your associated device(s) when you use our products or services or otherwise interact with us or with third-party services through our products and services. Examples of the types of information we collect include:
- Personal Information: “Personal Information” means information that we directly associate with a specific person or entity (for example: name; addresses; telephone numbers; email address; Social Security Numbers; payment information; call records; wireless device location). Personal information does not include “de-identified,” “anonymous,” or “aggregate” information – which are not associated with a specific person or entity.
- Customer Proprietary Network Information (CPNI): Customer Proprietary Network Information, or “CPNI,” is a subset of Personal Information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number.
- Network and Device Information: We may collect information about your use of our network (or other carriers’ networks when roaming domestically and internationally) and the device(s) associated with your account, network data related to WiFi usage and device, and performance information, as well as data relating to your use of our website, applications and other products and services.
- Location Data: We may collect your device’s location whenever it is turned on (subject to coverage limitations).
- Performance and Diagnostic Data: We may collect performance and diagnostic data about your use of our network, networks you roam on, WiFi services or your device. For example, we may collect information about the performance of the device, signal strength, dropped calls, data failures, battery strength and other device or network performance issues. We may also collect information about applications on your device, the fact that an application has been added, when an application is launched or fails to launch, and length of time an application has been running.
- Collection of Information About Children: We do not knowingly solicit children to purchase our services or products. If, however, you authorize a child to use our services or products by providing them a device associated with your account, any information associated with such use will be treated as your information in accordance with this Policy.
- Our websites are not designed to attract children under the age of 13 and we do not intentionally or knowingly collect Personal Information on our websites from anyone under the age of 13. We encourage parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission.
- HOW INFORMATION ABOUT YOU IS COLLECTED
Surge collects information about you in three primary ways:
- Information You Provide: We collect information that you provide to us when you apply for and use or purchase our products or services or otherwise communicate with us. For example, some of the ways you may provide information to us include:
- When you sign up for our voice or data services or purchase other products or services, we may collect personal contact, billing, and credit information.
- When you establish or modify an account online, we may collect user identification information, passwords, and/or security question responses that you will use for future sign-on.
- When you interact with our customer service representatives, enter information on our websites, submit survey responses, or pay for services, we may also collect Personal Information and other information. We may monitor and record phone calls, e-mails, live chats, or other communications between you, your device, and our Customer Service representatives or other employees or representatives.
- Information We Collect Automatically: We automatically collect a variety of information associated with your use of your device (on our network, when roaming, or in WiFi mode) and our products and services, some of which may be associated with you. For example, some of the ways we may automatically collect information include:
- Our systems capture details about the type and location of wireless device(s) you use, when the device is turned on, calls and text messages you send and receive, and other data services you use.
- We may also gather information about the performance of your device and the network. Some examples of the types of data collected include: the applications on the device, signal strength, dropped calls, data failures, and other device or network performance issues.
- Cookies, Web Beacons, and Similar Technologies
- We may use, or we may engage third-parties to use on our behalf, cookies or similar web tags (small data text files placed on your computer or device) or similar technologies to identify your computer or device and record your preferences and other data so that our websites can personalize your visit(s), see which areas and features of our websites are popular, and improve our websites and your experience.
- We may also use web beacons (small graphic images on a web page or an HTML e-mail) to monitor interaction with our websites or e-mails. Web beacons are generally invisible because they are very small (only 1-by-1 pixel) and the same color as the background of the web page or e-mail message.
- The information we receive through cookies, web beacons and similar technologies may enable us to recognize users across devices, such as smartphones, 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 our websites. If we combine or link cookie or web beacon information with Personal Information, we will treat the combined or linked information as Personal Information under this Policy.
- Web Browsing Activity
- Our Websites. When accessing our websites, mobile websites and related applications and widgets designed for your device or web-based experience, we automatically collect certain information about your device and your visit, such as your IP address, browser type, date and time, the web page you visited before visiting our website, your activities and purchases on our websites, and other analytical information associated with the sites.
- Other Websites. When your device’s web browser utilizes our data services to access websites other than our own, we automatically capture information associated with your browsing activities, and measure and monitor network and Internet connection performance, throughput, latency, and similar network data.
- Do Not Track Policy. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Those sites (or the third party content on those sites) may continue to engage in activities you might view as tracking even though you have expressed this preference, depending on the sites’ privacy practices. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals on when you use our services and products or interact with our websites or online services. We do allow you to exercise choice regarding the collection of information by third parties about your online activities over time and across third-party websites or online services for online interest based advertising purposes as described below.
- Voice Controlled Applications: If you use a voice-controlled application, that application may collect and record your requests and other information from you and your phone.
- Retail Beacons: We may use beacon devices in our retail locations that collect data about your device. These programs use signals from smart devices (like mobile phones and tablets) to track movement and wait times. Retail beacons collect a unique identifier that your device routinely transmits (e.g., a MAC address) and coverts it to an identifier unique to Surge. In some cases, we will use identifiers that are already routinely collected by the network in order to provide you with wireless service. We use aggregated data in order to understand general traffic trends in our stores. This helps us to better service our customers.
- Information From Other Sources: We may also obtain information about you from other sources. For example, we may receive credit information from third-party sources before initiating your service, and updated address information from our shippers or other vendors. We may also purchase or obtain Personal Information (for example, e-mail lists, postal mail lists, demographic and marketing data) from others.
- HOW WE USE INFORMATION WE COLLECT ABOUT YOU
We use the information we collect for a variety of business purposes, such as:
- To route your calls or messages or otherwise provide you with service;
- To provide and bill for products and services you purchase and charge to your account;
- To deliver and confirm products and services you obtain from us;
- To verify your identity and maintain a record of your transactions and interactions with us;
- To provide customer and technical services to you;
- To create, modify, improve, enhance, remove or fix our network, products and services and their performance;
- To identify and suggest products or services that might interest you;
- To make internal business decisions about current and future product and service offerings;
- To provide you customized user experiences, including personalized product and service offerings;
- To protect our rights, interests, safety and property and that of our customers, service providers and other third parties; and
- To comply with law or as required for legal purposes.
- Fraud Prevention: We may use Personal Information, including account information (such as purchase patterns) and device information for investigations or prevention of fraud or network abuse. We provide fraud prevention services to banks or other third parties. As part of this service, we may verify your phone number to help those third parties prevent your personal information from being used for fraudulent purposes. We also may provide the information you report as spam to a third party to prevent fraud or network abuse, and we may share such information with government agencies and others that work to combat spam and prevent fraudulent, deceptive, and unfair practices.
- Information Collected from Cookies: We may also use information collected from cookies or other similar technologies to improve our websites, make recommendations, and complete transactions you request.
- Marketing: We may use information we collect to contact you about Surge or third-party products, services, and offers that we believe you may find of interest. We may contact you by telephone, postal mail, e-mail, or other methods. You may opt-out of receiving marketing communications from us at any time as outlined below in Choices Regarding Use of Your Information.
- Performance, Diagnostics & Management: We collect information about devices, our network and WiFi usage to perform diagnostic analyses and understand how your device is performing overall. Diagnostic data helps us troubleshoot technical issues related to your device’s performance such as battery life, dropped calls, processing speed, device memory, service coverage, and network and WiFi signal strength that you and other customers may experience. If you are using a device in WiFi mode, we may collect information about that usage, such as the routing address and IP address. We also may use diagnostic data to identify and recommend products and services.
- Location-Based Services: We use location information to route wireless communications and to provide 911 service, which allows emergency services to locate your general location. We may disclose, without your consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm.
Depending on your device, you may also be able to obtain a wide array of services based on the location of your device (for example, driving directions, enhanced 411 Directory Assistance or search results, etc.). These data services, known as Location-Based Services (“LBS”) are made available by us and others, usually via applications. These services use various location technologies and acquire location data from various sources.
These applications and services use various location technologies (including Global Positioning Satellite (“GPS”), Assisted GPS (“AGPS”), cell ID and enhanced cell ID technologies) to identify the approximate location of a device, which is then used in conjunction with the application to enhance the user’s experience (for example, to provide driving directions, to provide enhanced 411 Directory Assistance or search results, etc.)
LBS may, or may not, involve any interaction with or dependency on our network, and location-based services may or may not look to our network to obtain location data. Where we allow third parties the capability of accessing data about your location that is derived from our network, we require those third parties to observe specific privacy and security protections consistent with this policy.
It is important that you understand the location capabilities and settings of your device, and that you carefully read and understand the terms under which these services are provided – whether by us or another entity.
You should carefully review the privacy policies and other terms of third-parties with whom you have authorized the sharing of your location information, and you should consider the risks involved in disclosing your location information to other people.
Where we provide a location-based service, you will receive notice of the location features of the service and collection of location data is with your consent. You will be provided options for managing when and how such information should be shared.
- Advertising: You may see advertisements when you visit our websites, mobile websites, in mobile applications, or on your device. We may help advertisers’ better reach our customers by providing certain customer information, including device type, geographic information, language preferences or demographic information obtained from other companies. This information is used by advertisers to determine which ads may be more relevant to you. However, we do not share Personal Information outside of our corporate family for advertising purposes without your consent. Some examples of the types of advertising you might see include:
- Our Ads on Our Websites. We may provide advertisements, such as banner ads, on our websites, mobile websites, and in mobile applications and widgets you may download, access or use on your device.
- Other Company Ads on Our Websites. You may also see third-party advertisements on some of our websites, services, in applications or on devices. These third-party advertisers, or their ad networks, may place or access cookies, web beacons, or similar technologies on your device and may collect certain anonymous or de-identified information about your visit on our websites. The third-party advertisers who provide these ads may use this information to provide you with advertising on our websites, as well as on other websites. We do not have control over or access to any information contained in the cookies that are set on your computer or device by ad servers, ad networks, or third-party advertisers.
- Interest-Based Ads. You may receive ads from us and our ad providers that are tailored to your interests. These interest-based ads are selected based on your use of our services and products as well as other information obtained by us and our ad providers. None of this information is Personal Information.
We do not provide your Personal Information to third-party advertisers without your consent.
Advertising may be tailored to the interests that advertisers have inferred from rom your browsing of our websites or other websites or applications with which the third-party partners to provide advertising.
We may provide third-party advertisers with aggregated or de-identified location, demographic or similar data (unrelated to your browsing activities) that does not personally identify you. This data may be used by advertisers to help tailor their ads on our websites, and on other sites and applications.
We, and our providers, may use a de-identified profile of your web-browsing and application use activity and interests. This profile does not contain information that identifies you personally, but may include a unique or encrypted identifier that enables your device to be matched to a profile of your browsing activity and de-identified characteristics about your interests.
When we use information associated with your web browsing activities on websites that are not our own to provide interest-based advertising or offers, we will provide you with notice and appropriate choice.
For more information see Surge Ad Options for Your Device
- Choices about Advertising. Surge adheres to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising.
On Your Mobile Device. Where we offer interest-based ads, you can opt-out of certain interest-based advertising by clicking on the ad options link on or near the advertisement.
If you turn off interest-based ads, you will still see just as many ads, but the ads may not be based on your interests and may be less relevant to you.
Your choice only affects the ads you see on websites and applications you access on your device.
If your device’s browser cookies are deleted, or your device is reset, you may need to reset the interest-based ads feature.
If you are using your device, but are not on our network (such as a WiFi network), we, and our ad providers, may not be able to identify your ad choices.
On Your Computer or Non-Mobile Device. For information about targeted advertising, or to opt-out of use of your browser information for purposes of certain third-party advertising, please visit www.aboutads.info/choices. Please note that if you opt out, you will continue to receive the same number of ads, but they may be less relevant because they will not be based on your interests. You may still see ads related to content on a web page or based on other non-personal information. Please note that this opt-out is cookie-based. If you change computers or devices, change web browsers, or delete cookies, you will need to visit the about ads site and opt-out again.
- WHEN WE SHARE INFORMATION COLLECTED ABOUT YOU
We do not sell, license, rent, or otherwise provide your Personal Information to unaffiliated third-parties (parties outside the Surge corporate family) to market their services or products to you without your consent. We may, however, disclose your information to unaffiliated third-parties as follows:
- With Your Consent: We may disclose Personal Information about you to third-parties with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of disclosures on your phone for certain applications or services; orally, in our stores or on the phone, including through interactive voice response; or implicitly, for example, when you purchase a product and ask that it be shipped to your home, consenting to our disclosure of your name and address to a third-party shipping company to complete delivery.
- To Others On Your Multiline Account: We encourage you not to share your password or pin. If you provide your account password or pin number or security question responses to third parties, including other line holders on a multiline account, they will have access to your personal information – including CPNI, such as call detail and service information – when they access your account with your account password or pin number.
- To Our Service Providers: We may disclose information to 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).
- Third-Party Carriers and Suppliers: If you are roaming on the network of another carrier or WiFi service provider, your wireless telephone number, your location, the numbers you dial, and other information about your usage will be available to that carrier to facilitate that service.
- In a Business Transfer: We may sell, disclose, or transfer information about you as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third-parties as a business asset in the transaction.
- For Legal Process & Protection: We may disclose Personal Information, and other information about you, or your communications, where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary:
- to satisfy any applicable law, regulation, legal process or enforceable governmental request;
- to enforce or apply agreements, or initiate, render, bill, and collect for services and products (including to collection agencies in order to obtain payment for our products and services);
- to protect our rights or interests, or property or safety or that of others;
- in connection with claims, disputes, or litigation – in court or elsewhere;
- to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
- When information is reported to the Spam Reporting Service, it may be shared with government agencies and others that work to combat spam and prevent fraudulent, deceptive, and unfair practices.
- to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
- in an emergency situation.
- De-Identified Information: We may provide information that does not identify you personally to third-parties for marketing, advertising or other purposes.
- Directories: We do not publish directories of our customers’ wireless numbers; nor will we provide or make such numbers available to third-parties for listing in their public directories, without the customer’s prior consent.
- HOW WE STORE AND PROTECT THE INFORMATION COLLECTED ABOUT YOU
- Protecting Your Information: We use a variety of physical, electronic, and procedural safeguards to protect Personal Information from unauthorized access, use, or disclosure while it is under our control.
Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted policies and procedures designed to ensure compliance with those rules. We will not intentionally disclose your CPNI to third-parties without your permission, except as allowed under FCC rules, applicable law, or explained in this Policy.
- Retention and Disposal: We retain information only for as long as we have a business or tax need or as applicable laws, regulations, or government orders allow. 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).
- HOW YOU CAN UPDATE YOUR INFORMATION AND CHOOSE HOW WE CONTACT YOU
- Access to Your Information: You may access and modify your contact information by contacting us using the information in the “How to Contact Us” section below. You may also modify some information on through https://surgephone.com/my-account/.
- Choices Regarding Use of Your Information: We may send you communications about services or products we, or our partners, sell. We want to provide you with meaningful choices regarding our marketing communications and you may choose to limit or opt-out of marketing communications from us at any time. Although you may elect not to receive marketing information from us, if you subscribe to our services or buy our products, you will continue to receive customer-service and transactional notices, and similar communications.
You may manage your marketing preferences by contacting Surge Customer Service at 855-467-8743 from any phone, by email at email@example.com or, with respect to marketing e-mails and text messages, by following the “unsubscribe” instructions on any marketing e-mail we send you, or by managing your preferences in MyAccount online at https://surgephone.com/my-account/.
- Do Not Call Registry: The FTC maintains a National Do Not Call Registry at https://www.donotcall.gov/, and your state may maintain its own Do Not Call Registry. Putting your number on these Registries also may limit our telemarketing calls to that number.
- YOUR ROLE IN PROTECTING YOUR PRIVACY
- Protecting Your Personal Information: You play an important role in ensuring the security of Personal Information. We encourage you to use passwords or PIN to prevent unauthorized access to your device, your online account, and your voicemail. You may also establish an optional password to identify yourself during calls with our Customer Service representatives. We recommend that you use unique, non-obvious passwords, that you periodically change your passwords, and that you not share your passwords with others.
Many devices store information in the device’s memory, on the SIM card, and/or on SD memory cards. Therefore, before selling, discarding, trading in, or giving away your device, be sure you remove and retain your SIM and SD memory card and follow the manufacturer’s instructions for deleting Personal Information or other data on the device. (This can be found in your owner’s manual or on the manufacturer’s web site.)
- Lost or Stolen Devices: In order to protect you, please notify us immediately by calling Customer Care at 855-467-8743 if you believe your device has been lost or stolen or if you believe your Personal Information has been accessed without your consent.
- Limit Third-Party Access: If you provide a third-party with access to your device, or share your password or PIN, you should understand that your Personal Information may be accessed, deleted, altered, or transferred to another device or our network servers by the person using the device, and that we will treat that user as you for purposes of this Policy.
- Caller ID Blocking: When you use Surge communications services, your name and/or telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill unless you block that information. Refer to the specific instructions for your communication device regarding Caller ID Blocking. Caller ID Blocking does not prevent the display of your information when you dial certain business numbers, including 911, 900 numbers, or toll-free numbers.
- Social Networking, Forums and Chat Rooms: If you use or link to a public forum, bulletin board, chat room, or social network on or from a Surge web site, be aware that any information you post or submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We urge you not to share your Personal Information (for example, your name, phone numbers, addresses, passwords or PIN, etc.) on these websites. We are not responsible for access to or use of information you choose to submit or share with others. For example, if you post your wireless number on a social network in order to receive updates by text message, standard message charges will apply to such messages.
- OTHER INFORMATION YOU SHOULD KNOW
- Consumer Code for Wireless Service: We follow the Consumer Code for Wireless Service established by the Cellular Telecommunications & Internet Association (“CTIA”). In doing so, we want to help customers understand their bills, receive quality service, and make informed choices and conform our information practices under this Policy to meet the requirements of applicable federal and state laws and regulations.
- Your 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 “How to Contact Us” section below.
- How We Communicate Changes to This Policy: We may update this Policy at any time to provide updates to or clarification of our practices. If we make changes, we will notify you by revising the date at the bottom of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to the homepage of our website or sending you a notification). You should refer to this Policy often for the latest information and the effective date of any changes
- How to Contact Us: If you have any questions or comments about this Policy or about Surge’s privacy practices, please call Customer Service at 855-467-8743 or send an e-mail message to firstname.lastname@example.org. You may also direct your privacy-related comments or questions to the address below:
PO Box 34638
Bartlett, TN 38134