(Last modified: December 20, 2016)

This Privacy Policy applies to the KoolSpan website and the following KoolSpan’s products (collectively, the “KoolSpan Products”) and services hosted by KoolSpan:

  • TrustCall™
  • TrustText™
  • TrustChip®
  • TrustBridge™
  • TrustCenter™
  • TrustRelay Server

The KoolSpan Products consist of (a) applications that are installed on end-user phones or other devices (“Applications”), (b) connectivity services between the Applications (“Services”), and (c) management features for customer organizations. The information KoolSpan collects depends on whether the Services are operated and/or managed by KoolSpan (“TrustCall Global Service”), or operated and/or managed by a third party, such as the end user’s company or some other managed service provider.

If your Services are operated and/or managed by an entity other than KoolSpan, contact that entity to obtain their privacy policy.

KoolSpan is committed to protecting and respecting privacy. This Privacy Policy details the information we process and how long we retain that data. This includes information provided to us voluntarily as well as other information generated by the KoolSpan Products.

KoolSpan TrustCall encrypts and secures your phone calls and text messages for the privacy and security of mobile communications. We take this responsibility seriously.

We will post any Privacy Policy changes to our website.

1.   Our Commitment to Privacy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our information practices and the choices you can make about the way your information is collected and used. The Privacy Policy is always available on our website.

We will update the Privacy Policy as needed to ensure it accurately describes the information we collect, how long we retain it for and what we do with that information.

2.   Information We Collect through Use of KoolSpan Products

This notice applies to all information collected by the KoolSpan Products. Some of this information is requested by the KoolSpan Products while installing and configuring these products. Other information may be created by the KoolSpan Products when placing calls or sending messages. Configuration information may be provided by you or it may be provided in batches by your system administrators pre-configuring the KoolSpan Products.

If the TrustCall Services are operated by a third party (“TrustCall Direct Enterprise” or “TrustCall Direct Service Provider”), KoolSpan does not collect private information. An exception to this is if you deliberately share information with KoolSpan via the Send Feedback function of the TrustCall application. The Send Feedback function shares detailed debugging information with KoolSpan, including TrustCall logging information. As debugging information could contain the output of application errors, the exact contents is unpredictable, but does not exceed the items of information detailed below for TrustCall Global Service.

Information collected or maintained by the TrustCall Global Service (the “Collected Information”) is destroyed by KoolSpan after a maximum of 90 days. Collected Information includes:

  • End user’s organization/company
  • End user’s name
  • End user’s TrustCall account access information, such as the username and password
  • End user’s phone number
  • End user’s device hardware IDs
  • Logging information with the dates, times, duration, organization, names, and phone numbers of other users with whom you communicate via the KoolSpan Applications.
  • Aggregated statistics generated from the above logging information that provides overall metrics for Service use (“Aggregated Information”). All personally identifiable information is removed from Aggregated Information as part of the data aggregation process.

For TrustCall Global Service only, KoolSpan system administrators may have access to this type of information, although it is against KoolSpan’s policy for KoolSpan system administrators to access this information unless they are required to do so as part of supporting your system.

In addition, we may collect other personal information from you when communicating with you as part of a technical support call or email conversation.  All such information will be requested verbally over the phone or in the email conversation.

3.   Information We DO NOT Collect

The KoolSpan Applications and TrustCall Global Service do not store or retain the actual content of any secure voice communications from calls. The Services do provide for store and forward-based secure text messaging, but TrustCall Global Service cannot decrypt or otherwise collect any information regarding the content of secure messages. These secure messages are retained by the Services until delivered to the intended recipient or until they expire based on a user configured delivery expiration date. TrustCall Global Service destroys all personally identifiable metadata obtained from your secure call and secure message transactions after a maximum of 90 days.

4.   How We Use Information

4.1   Information Collected through Use of KoolSpan Products

We only use email addresses for support purposes. We do not share Collected Information with any outside parties except as provided in this section. All of this information is used strictly for technical support purposes.

TrustCall Global Service is provided to contracting organizations/companies as a paid service. KoolSpan may, on request, provide Collected Information to the contracting organization/company. We recommend you contact your service provider for information on how they use Collected Information and how long they retain it.

Certain features of the KoolSpan Products require KoolSpan to pass your Device Hardware ID to third party services (such as Google or Apple) in order to either provide push-notification services, or to remotely activate critical services on the device. This information exchange does not include any other information about you.

If a regulatory body or law enforcement agency requests Collected Information maintained on TrustCall Global Service under court order from a court of competent jurisdiction, KoolSpan will we provide the Collected Information. It should be noted that KoolSpan, by design, can never disclose the audio of your secure phone calls or the content of your messages.  We have no way to decrypt the content of your communications.

We use non-identifying and aggregate information to better design the KoolSpan Products and Services but we do not retain any identifying information as part of the aggregate information.

4.2   Information Collected on the KoolSpan Website

KoolSpan utilizes HubSpot marketing and sales software for tracking visitor behavior and engagement across koolspan.com, as well as collecting information using online forms. Please note that if you submit a request via our website, we may collect any personally identifying information you volunteer in addition to the standard browsing-related information. See https://legal.hubspot.com/privacy-policy for the HubSpot privacy policy.

5.   Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have defined appropriate physical, electronic, and managerial procedures to safeguard and secure the Collected Information as part of the KoolSpan Products.

As of the Effective Date of this Privacy Policy, KoolSpan has not received a national security order from any nation, nor have we been required by a FISA court to keep any secrets that are not discussed in this Privacy Policy.

6.   How You Can Access or Correct Your Information

Upon request, KoolSpan will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:

  • To review the user information that you have supplied to us
  • To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
  • To request that your user information not be used to contact you
  • To request that your user information be removed from any solicitation list that we use
  • To request that your user information be deleted from our records (unless you are a customer, where minimal information described above is required)

To exercise any of these rights, please contact your system administrator or email us at info@koolspan.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

6.1   To Unsubscribe from Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by emailing us at info@koolspan.com. Customers cannot opt out of receiving transactional emails related to their account with us.

7.   How to Contact Us

We are a secure encrypted mobile communications company responsive to the needs of our customers. If you feel your privacy has been violated by your use of the KoolSpan website or Products, you may register your complaint with us and we will respond to your requests. To do so, please contact us via one of the Support options as shown on our website at http://info.koolspan.com/contact-koolspan.

Please contact us if you have any questions and comments regarding this Privacy Policy.

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