(Last modified: October 25, 2018)

This Privacy Policy applies to the KoolSpan may collect from you through the KoolSpan website and the KoolSpan’s products and services (collectively, the “KoolSpan Products”), including the following:

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

The KoolSpan Products include (a) applications that are installed on end user phones or other devices (“Applications”), (b) portal(s) through with end users register for the KoolSpan Products, (c) connectivity services between the Applications (“Services”), and (d) management features for customer organizations.  In certain circumstances the Services are operated and/or managed by KoolSpan (“TrustCall Global Service”), and in others the Services are operated and/or managed by a third party, such as the end user’s company or some other managed service provider (“TrustCall On-Prem Services” or “TrustCall Hybrid Services”).  If you are receiving TrustCall On-Prem Services or TrustCall Hybrid Services, the provider of those services is the data controller for the data collected during your use of the KoolSpan Products and you must contact that entity to obtain their privacy policy and to seek any remedies you may have under law with respect to the collection, use and storage of your personal information.

KoolSpan is committed to protecting and respecting privacy. This Privacy Policy details the information we process, store, use and disclose 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. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the KoolSpan Products. It is our policy to post any changes we make to our privacy policy on this page.

2.   Information We Collect, including through Use of KoolSpan Products and TrustCall Global Service

We collect the information you provide that is requested from you during the process of registering, installing and configuring KoolSpan Products.  We may also collect information in batches from your system administrators when they pre-configure the KoolSpan Products.

Except as may be otherwise required by applicable law, information collected or maintained by the TrustCall Global Service (the “Collected Information”) is destroyed by KoolSpan after a maximum of 14 days. Collected Information includes: dates, times, duration, organization, names and phone numbers of other users with whom you communicate via the KoolSpan Applications.

Information you elect to share with KoolSpan via the “Send Feedback” function of KoolSpan TrustCall™ is also destroyed by KoolSpan after a maximum of 14 days. When you use the Send Feedback function in addition to the Collected Information, it also shares detailed debugging information with KoolSpan, including:

  • Information that identifies the device (model, serial number, IMEI)
  • Information that identifies the SIM (carrier, SIM Serial Number)
  • Location information in the form of WIFI access points and the network the SIM is current connected to
  • Native Contact if contact filtering or invitation features are enabled

In addition, we may collect other personal information from you when communicating with you, including as part of a technical support call or email conversation, in response to surveys and as a result of searches through the website.

Aggregated and anonymous statistics that provide overall metrics for Service use (“Aggregated Information”). All personally identifiable information is removed from Aggregated Information as part of the data aggregation process.

With respect to TrustCall On-Prem Services, KoolSpan does not collect personal information. The exception to this is would be if the user shares information with KoolSpan via the “Send Feedback” function of the TrustCall application.

3.   Information We DO NOT Collect

The KoolSpan Products and TrustCall Global Service do not store or retain the actual content of any secure voice communications from calls. The TrustCall Global Service does provide for store and forward-based secure text messaging, but the TrustCall Global Service cannot decrypt or otherwise collect any information regarding the content of secure messages. These messages are encrypted while retained by the TrustCall Global Service and only decrypted on the recipients device after delivery. TrustCall Global Service destroys all personally identifiable metadata obtained from your secure call and secure message transactions after a maximum of 14 days.

4.   How We Use Information

4.1   Information Collected through Use of KoolSpan Products

KoolSpan only uses information collected from you to provide you the KoolSpan Products and TrustCall Global Service, and to support and troubleshoot, and to evolve and otherwise enhance, the KoolSpan Products and TrustCall Global Service, and to otherwise respond to your inquiries.  KoolSpan may also notify you about changes or additions to the KoolSpan Products and TrustCall Global Service.  KoolSpan does not sell user data or analysis of user data to third parties.

We only use email addresses for support purposes and to otherwise communicate with you regarding the KoolSpan Products and TrustCall Global Service. We do not share Collected Information with any outside parties except as provided in this section.  We may disclose Collected Information to fulfill the purpose for which it was disclosed to KoolSpan, in a manner KoolSpan discloses to you around the time you disclose the Collected Information to KoolSpan, and otherwise with your consent.

We share Collected Information only with our personnel and advisors as needed to assist with the support and troubleshooting of the KoolSpan Products and TrustCall Global Service.  However, TrustCall Global Service is also provided to contracting organizations/companies as a paid service.  If you receive the TrustCall Global Service through an organization/company who contracted for such TrustCall Global Service, then KoolSpan may, on request, provide Collected Information to such contracting organization/company.  In such case such organization/company is a co-data controller and we recommend you contact such contracting organization/company 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 IS to third party services (such as Google or Apple) in order to either provide push notifications services, or to remotely activate critical services on the device. This information exchange does not include any other information about you other than the Device Hardware ID.

If a court or other governmental authority, 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 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.  Additionally, KoolSpan reserves the right to disclose Collected Information if KoolSpan believe disclosure is necessary or appropriate to protect the rights, property, or safety of KoolSpan, our customers, or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We use non-identifying and aggregate information to better design the KoolSpan Products and Services but in creating such aggregate information we do not retain any identifying information.

4.2   Information Collected on the KoolSpan Website or Otherwise by Third Parties

KoolSpan utilizes 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.

In processing credit card payments, you may be paying through a third party service.  In such case your submission of information in connection with such payment will be governed by the Stripe Privacy Policy.

KoolSpan complies with United States export regulation. For more information, please refer to the Visual Compliance 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; Remedies

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 other than as necessary for our transactional relationship;
  • To request that your user information be removed from any solicitation list that we use; and
  • 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, or otherwise raise any complaint regarding any Collected Information please email us at info@koolspan.com or, if you procured the KoolSpan Products and/or TrustCall Services through a third party please contact that system administrator. KoolSpan reserves the right to ask you for specific information from you to confirm your identity before disclosing any Collected Information. In some circumstances KoolSpan may charge a reasonable fee for access to your information. 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.

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with KoolSpan and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raise the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you.

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 unless terminating all use of the KoolSpan products and services.

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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