If you would like to submit a Consumer Request, you can contact Voyage Mobile at support@voyagetext.com or by calling (877) 886-9243. If you choose to submit a Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. Voyage Mobile will only use the information it receives to respond to your request. Voyage Mobile will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.
“Personal information” means any information that identifies, relates to, describes, is linked or could be reasonably linked, directly or indirectly, to an identified or identifiable natural person or household. “Personal information” does not include publicly available information. [“Sensitive data” means a category of personal information that includes Social security number, driver’s license number, state identification card, or passport number; account log-ins, financial accounts, debit or credit card numbers in combination with a security or access code, password, or other credentials; precise geo-location; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email or text messages; genetic or biometric data; mental or physical health diagnosis, sexual orientation; or personal data from a known child.]
We may collect, use, and share in accordance with applicable privacy law the following categories of personal information that identify, relate to, describe, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics or samples (such as breath, blood, or urine), or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for
Our reasons
To provide products and/or services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or our organization
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
To display advertisements to our advertisers’ target audiences.
For our legitimate interests or those of a third party, i.e., to efficiently and accurately advertise to you so we can deliver the best service for you at the best price.
Processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to existing and former customers, third parties who have previously expressed an interest in our services and/or third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts
For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
The Right to Know / Confirm & Right to Access. You have the right to know/confirm whether we are processing your personal data and access any personal data we have processed, including:
- The categories of personal information we have collected about you
- The categories of sources from which the personal information was collected
- Our business or commercial purpose for collecting, selling, or sharing personal information
- The categories of third parties with whom we sell or share personal information, if any; and
- The specific pieces of information we have collected about you
You also have the right to obtain a copy of the personal information you have provided to us in a portable, readily usable format that can be easily transferred to a third party.
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify, de-aggregate, or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy.
The Right to Delete or Correct. You have the right to delete or correct the information we have retained about you. Subject to certain exceptions, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records;
- Direct any service providers to delete your personal information from their records; and
- Correct any inaccuracies in your personal information.
Your request to know or delete may be denied for any reason allowable under applicable state privacy law. For example, we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or Services requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act or other applicable state law.
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information; or
- Comply with a legal obligation.
The Right to Opt-Out. You have the right to opt-out of the following uses of your personal information:
- Targeted (behavioral) advertising, or sharing of personal data
- Processing of sensitive data, including precise geolocation information
- Profiling, as described above
We will act upon your request to opt-out no later than 15 days from the date we received the request. Note that we may deny a request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent or for any other reason allowable under applicable state privacy law. However, you may change your mind and opt back in to personal information processing at any time by contacting us at support@voyagetext.com or by calling (877) 886-9243.
Special Notice to Nevada Residents. Voyage Mobile does not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at support@voyagetext.com or by calling (877) 886-9243.
The Right to Non-Discriminatory Treatment You have the right to not be discriminated against by us because you exercised any of your rights under the applicable state privacy law. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you if that difference is reasonably related to the value provided to our business by your personal information.
How to Exercise Your Rights. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. If you are a resident of California, [Virginia, Colorado, Utah,] or Nevada, you may exercise the rights described above, subject to limited exceptions under applicable law.
If you [or an authorized representative] would like to review, verify, correct, withdraw consent to the use of your personal information, or otherwise would like to submit a Consumer Request, you can contact Voyage Mobile at support@voyagetext.com or by calling (877) 886-9243. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. To verify a request, you will need to provide:
- Enough information to identify you;
- Proof of your identity and address; and
- A description of what right you want to exercise and the information to which your request relates.
- If your request is submitted on your behalf by an authorized representative, you may also have to provide a copy of the written authorization contract.
If we are unable to verify your request, we may deny the request or ask you for additional information that is reasonably necessary to authenticate your identity in connection with the consumer request.
Once submitted, you will receive an email within 10 days that we will use to verify your identity and provide confirmation of your request. We will respond to your request to know or delete or correct within 45 days from the day we receive the request. If necessary, we may extend the time period to a maximum of 45 additional days from the day we receive the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will be delivered in a readily useable format, by mail or electronically at the consumer’s option.
Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are a resident of Virginia or Colorado, you also have the right to appeal our decision if we deny your consumer request. If we deny your consumer request, you can contact us at support@voyagetext.com to request an appeal of the denial. Within 45 days of receipt of your appeal, we will inform you of the action we took or did not take in response to your appeal. We may extend the 45-day period by an additional 15 days where reasonably necessary and inform you of the delay and the reasons for the delay. If your appeal is denied, we will provide you with an online mechanism to contact the Attorney General to submit a complaint in your respective state.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information that is aggregated or de-identified.
- Information that is part of a formal dispute resolution process.
- Information that is about another individual that would reveal their personal information or confidential commercial information.
- Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at support@voyagetext.com or by calling (877) 886-9243.
Personal Data Collected on Behalf of Voyage’s Customers. In connection with performing services for our customers, Voyage, as a Service Provider, may also collect, process and store Personal Data owned and controlled by our customers at their direction. To the extent Voyage receives requests directly from consumers regarding Personal Data of our customers, Voyage will work with such customer to comply with their obligations under the CCPA, as well as any other applicable laws.
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