Privacy POLICY

We at Tuscarora Communications, LLC, a Delaware limited liability company doing business as Carnegie Technologies (“Carnegie”, “us” or “we”) are committed to protecting your privacy. This Privacy Policy describes how we access, collect, store, use and disclose personal information collected, and applies to all individuals who use the Carnegie Wi-Fi Calling application and service (collectively, the “Service”). If you do not agree with our privacy practices as described in this Privacy Policy, or do not agree with or are not willing to comply with any portion of our applicable Terms of Service (iOS or Android), do not use the Service.

Access to and Collection of Information

Carnegie accesses and collects information about you when you use the Service, as described below:

Device Information: Carnegie collects the following device information that is generated by your use of the Service; (a) operating system, device type and wireless carrier for your mobile device (“Device Information”), and (b) date, time, location, and duration for each use of the Service application (“Usage Information”). Carnegie uses Device Information and Usage Information to improve the Service, and to make software updates, provide product support and other services more relevant to its users.  In addition, you must provide us access to the Native/System Contacts on your mobile device in order to make calls or send messages while utilizing the Service.  Carnegie does not store your contacts, however, the Service does periodically cross-reference your contacts against other users of the service in  order to more efficiently process calls to your contacts.

Other Information You Provide: We may also collect Personal Information (as defined below) from time to time through the following:

  • If/when you contact us via email (with feedback, for support, or otherwise), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
  • If/when you participate in one of our surveys, we may collect additional profile information.
  • If/when you post messages on our message boards, the information contained in your posting will be stored on our servers and other users will be able to see it.
  • We may also collect Personal Information at other points in our Site that state Personal Information is being collected.
  • If/when you order services from us, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.

How Carnegie Uses the Information

In addition to the disclosures described in the Section entitled “Collection of Information”, we may also use your information as follows. Generally, we collect, store, disclose, and use information to enable us to provide the Service, identify you as a user, respond to your inquiries and emails, improve the Service. The information may also be used to send you administrative and service related communications, newsletters, surveys, offers, and other promotional materials.

Carnegie may create anonymous information from Personal Information by excluding information (such as your phone number) that makes the data personally identifiable to you. We may use anonymous information to analyze request and usage patterns so that we may improve to the Service, and enhance the content of our Wi-Fi Calling application or other products.  We may also use your information to protect our rights and property and those of our customers or respond to legal process and emergencies. Disclosures

Our servers are located in the United States, and as such, your Device Information and Usage Information (collectively, “Data”) may be available to the U.S. government or its agencies under a lawful order made in the U.S irrespective of the safeguards we have put in place for the protection of your Data. We may disclose your Data to a third party without your consent: (a) if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our products or websites, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; (b) in connection with any legal investigation; and/or (c) when we believe in good faith that such disclosure is required by and in accordance with the law or to respond to subpoenas, warrants, production orders, litigation requests or similar documents served on Carnegie.

From time to time we may employ third parties to help operate our business and the Service. Examples of such service providers include vendors and suppliers that provide us with technology, services and/or content for analyzing data, research, providing advertising and marketing assistance, processing payments (including credit card payments), and providing customer service. Access to your Data by each of these service providers is limited to the information reasonably necessary to perform its limited function and these service providers may only use your Data to provide services on our behalf.

We may disclose Information in some other limited circumstances, but we will specifically describe them to you when we collect the information, such as in a separate consent for a new service.

We may also disclose your Data in connection with a corporate reorganization, a merger or acquisition with another entity, or a sale of all or a substantial portion of our assets or stock provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. In the unlikely event of an insolvency, bankruptcy or receivership, your Data may also be transferred as a business asset. We may share some or all of your Data with a parent company, any subsidiaries, joint ventures, or other companies under common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

Your Choice Regarding Your Information

If you wish to stop all collection of information by the Service you should uninstall the Service. You may use the standard uninstall process as may be available as part of your Device or via the mobile application marketplace or network.

Our Commitment To Data Security

The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment and have implemented commercially reasonable procedures designed to limit loss, theft or unauthorized access, use, modification, copying or disclosure of your Data. Despite these measures, you should know that Carnegie cannot fully eliminate security risks associated with your Data. You are also responsible for helping to protect the security of your Data.

Our Privacy Policy for Children

Carnegie does not knowingly collect personally identifying information from anyone who is under the age of 13 unless we first obtain permission from the child’s parent or legal guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at legal@Carnegietechnologies.com. We will delete such information from our files within a reasonable time.

Your Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of your Data may be less stringent than the laws in your country.

Changes and updates to this Privacy Notice

Carnegie may amend the terms of this Privacy Policy periodically without specific notice to you. We will provide notice of any changes to our Privacy Policy by posting a new privacy policy, and its effective date, at http://carnegietechnologies.com/demoprivacy.

Contact Us

If you have any questions about, or complaints that concern, this Policy, please call us at Carnegie or email us at privacy@carnegietechnologies.com. If you prefer, you also may write us at Office of Privacy -Legal Department, Carnegie, 8522 Broadway Street, Suite 209, San Antonio, Texas 78217.