What Is Personal Data at SOTA+?
At SOTA+, we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That's why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by SOTA+ as “personal data”, no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy. This Privacy Policy covers how SOTA+ handles personal data whether you interact with us on our websites. SOTA+ may also link to third parties on our services or make third-party apps available for download on our website. SOTA+'s Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.
Your Privacy Rights at SOTA+
At SOTA+, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from SOTA+. SOTA+ does not sell your data. There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and SOTA+ is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti- fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.
Personal Data SOTA+ Collects from You
At SOTA+, we believe that you can have great products and great privacy. This means that we strive to collect only the
personal data that we need. The personal data SOTA+ collects depends on how you interact with SOTA+.
When you create an accaunt, purchase and/or activate a product or device, connect to our services, contact us (including
by social media), participate in an online survey, or otherwise interact with SOTA+, we may collect a variety of
information, including:
• Account Information. Related account details, including email address, devices registered, account status, and
age.
• Device Information. Data from which your device could be identified, such as device serial number, or about your
device, such as browser type.
• Contact Information. Data such as name, email address, physical address, phone number, or other contact
information.
• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit,
or other payment card information.
• Fraud Prevention Information. Data used to help identify and prevent fraud, including a device trust score.
• Usage Data. Data about your activity on and use of our offerings, such as app launches within our services,
including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and
other usage data.
• Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances,
including when setting up a wireless account and activating your device, for the purpose of extending commercial credit,
managing reservations, or as required by law.
• Other Information You Provide to Us. Details such as the content of your communications with SOTA+, including
interactions with customer support and contacts through social media channels.
You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many
cases we will not be able to provide you with our products or services or respond to requests you may have.
Personal Data SOTA+ Receives from Other Sources
SOTA+ may receive personal data about you from other individuals, from businesses or third parties acting at your
direction, from our partners who work with us to provide our products and services and assist us in security and fraud
prevention, and from other lawful sources.
• Individuals. SOTA+ may collect data about you from other individuals — for example, if that individual has sent
you a product or gift card, invited you to participate in an SOTA+ service or forum, or shared content with you.
• At Your Direction. You may direct other individuals or third parties to share data with SOTA+. For example, you
may direct your mobile carrier to share data about your carrier account with SOTA+ for account activation, or for your
loyalty program to share information about your participation so that you can earn rewards for SOTA+ purchases.
• SOTA+ Partners. We may also validate the information you provide — for example, when creating an accaunt, with a
third party for security, and for fraud-prevention purposes.
For research and development purposes, we may use datasets such as those that contain images, voices, or other data that
could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable
law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and
development, we do not attempt to reidentify individuals who may appear therein.
SOTA+'s Use of Personal Data
SOTA+ uses personal data to power our services, to process your transactions, to communicate with you, for security and
fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.
SOTA+ uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance,
SOTA+ may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your
vital interests or those of other persons, or to comply with law. We may also process your personal data where we
believe it is in our or other's legitimate interests, taking into consideration your interests, rights, and
expectations.
• Power Our Services. SOTA+ collects personal data necessary to power our service, which may include personal data
collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.
• Process Your Transactions. To process transactions, SOTA+ must collect data such as your name, purchase, and
payment information.
• Communicate with You. To respond to communications, reach out to you about your transactions or account, market
our products and services, provide other relevant information, or request information or feedback. From time to time, we
may use your personal data to send important notices, such as communications about purchases and changes to our terms,
conditions, and policies. Because this information is important to your interaction with SOTA+, you may not opt out of
receiving these important notices.
• Security and Fraud Prevention. To protect individuals, employees, and SOTA+ for loss prevention and to prevent
fraud, including to protect individuals, employees, and SOTA+ for the benefit of all our users, and prescreening or
scanning uploaded content for potentially illegal content, including child sexual exploitation material.
• Personal Data Used for Personalization. If you choose to personalize your services or communications where such
options are available, SOTA+ will use information that we collect so that we can offer you those personalized services
or communications. You can learn more about how relevant services use information to personalize your experience by
reviewing the privacy information presented when you first use a service that asks to use your personal data.
• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to
comply with a lawful governmental request.
SOTA+ does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.
SOTA+ retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.
SOTA+'s Sharing of Personal Data
SOTA+ may share personal data with SOTA+-affiliated companies, service providers who act on our behalf, our partners,
developers, and publishers, or others at your direction. Further, SOTA+ does not share personal data with third parties
for their own marketing purposes.
• Service Providers. SOTA+ may engage third parties to act as our service providers and perform certain tasks on our
behalf, such as processing or storing data, including personal data, in connection with your use of our services and
delivering products to customers. SOTA+ service providers are obligated to handle personal data consistent with this
Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and
must delete or return the personal data once they've fulfilled our request.
• Partners. At times, SOTA+ may partner with third parties to provide services or other offerings. SOTA+ requires
its partners to protect your personal data.
• Others. SOTA+ may share personal data with others at your direction or with your consent, such as when we share
information with your carrier to activate your account. We may also disclose information about you if we determine that
for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or
appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that
disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the
event of a reorganization, merger, or sale.
Protection of Personal Data at SOTA+
At SOTA+, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. Children and Personal Data SOTA+ understands the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction. That is why SOTA+ has implemented additional processes and protections to help keep children's personal data safe.
Cookies and Other Technologies
SOTA+'s websites, online service, and advertisements may use “cookies” and other technologies such as web beacons.
These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell
us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and
web searches.
• Communications Cookies. These cookies are used to enable network traffic to and from SOTA+'s systems,
including by helping us detect any errors.
• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you
have accessed or requested. For example, they allow us to display our websites in the proper format and language, to
authenticate and verify your transactions.
• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services,
including by helping us to assess the effectiveness of advertisements and web searches. SOTA+ also uses these cookies to
remember choices you make while browsing, so we can provide you with a customized experience.
If you prefer that SOTA+ not use cookies, we provide you with the means to disable their use. If you want to disable
cookies and you're using the Safari web browser, choose “Block all cookies” in Safari's privacy settings. If
you are using a different browser, check with your provider to find out how to disable cookies. Certain features of the
SOTA+ website may not be available if all cookies are disabled.
In addition to cookies, SOTA+ uses other technologies that help us achieve similar objectives.
In some email messages SOTA+ sends to you, we provide a “click-through URL” that links you to content on the SOTA+
website. When you click one of these URLs, they pass through a separate server before arriving at the destination page
on our website. We track this click-through to help us determine interest in particular topics and measure whether we
are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or
text links in email messages.
SOTA+ generally treats data we collect using these cookies and similar technologies as nonpersonal data. However, to the
extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also
treat these identifiers as personal data in those regions. In addition, SOTA+ sometimes combines nonpersonal data
collected from these technologies with other personal data SOTA+ holds. When we combine data in this way, we treat the
combined data as personal data for purposes of this Privacy Policy.
Transfer of Personal Data Between Countries
SOTA+ products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world, including SOTA+-affiliated companies, to perform processing activities such as those described in this Privacy Policy in connection with your use of our service. SOTA+ complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be. The SOTA+ entity that controls your personal data may differ depending on where you live. If you do not reside in the U.S., your personal data may be processed by SOTA+ Inc. and other SOTA+-affiliated companies on behalf of the SOTA+ entity controlling personal data for your jurisdiction. Personal data relating to individuals in China mainland may be processed by SOTA+ in countries outside of China mainland. Where this occurs, it will be done in compliance with local laws, including the Personal Information Protection Law. As outlined in this Privacy Policy, SOTA+ may also transfer such personal data to third parties, who may in turn store or transfer the data outside of China mainland.
Our Company wide Commitment to Your Privacy
To make sure your personal data is secure, we communicate our privacy and security guidelines to SOTA+ employees and strictly enforce privacy safeguards within the company.
Privacy Questions
If you have questions about SOTA+'s Privacy Policy or privacy practices including where a third-party service
provider is acting on our behalf, would like to contact our Data Protection Officer, or would like to submit a
complaint, you can contact us at info@sotaplus.com. You can also ask us questions
about how to submit a privacy complaint and we will endeavor to help.
SOTA+ takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to
your question or concern, including those inquiries received in response to an access or download request. In most
cases, all substantive contacts receive a response within seven days. In other cases, we may require additional
information or let you know that we need more time to respond.
Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to
make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative
impact on you or another person, we will take steps to address that with you or that other person.
If you are not satisfied with SOTA+'s response, you may refer your complaint to the applicable regulator. If you
ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to
your circumstances.
When there is a material change to this Privacy Policy, we'll post a notice on this website at least a week in
advance of doing so and contact you directly about the change if we have your data on file.