Songwhale Service Privacy Policy

Overview

The Songwhale Service (“Service”) is comprised of a suite of mobile messaging products (“Products”) provided to commercial customers (“Customers”) for purposes of providing mobile products and services to “Subscribers” (also known as “individuals”) of mobile operators (“Operators”). The Service is provided to Customers in the United State(“US”).

In providing this Service, Songwhale enables the transmission of mobile messages (“Data”) from its Customers to the Subscribers requesting the product or service. The treatment of this Data is extremely important and an integral part of Songwhale’s product offerings.

Privacy policy statement

Information collection and use

Songwhale provides its Service, which at its core, enables the transmission of Data to those mobile Subscribers agreeing to the terms and conditions of its Customers. Specifically, the Songwhale Service provides a means for its Customers to offer to Subscribers mobile services or products that contain Data which ultimately may be used for mobile services such as alerting, marketing, advertising, content delivery, as well as mobile billing and a number of other products offered by Songwhale and its Customers.

In providing this Service, the Data transmitted to, from or between is retained for purposes of Songwhale providing its Service, including its internal business operations. Data is never disclosed to third parties not included in the chain of transmission (e.g., Customer, Songwhale, or Operator). Songwhale does not solicit or directly collect Data about its Customers or Subscribers.

Songwhale currently does not directly collect an individual’s personal information, sensitive or otherwise. The Data is collected by our Customers as well as the Operators, and entrusted to Songwhale for reporting and invoice generation. The information collected from our Customers is not used for any other purpose than the intent for which the information was originally collected.

Notice

If personal information, outside of the use of Data for purposes of Songwhale’s Service, is intentionally collected from individuals, they will be informed of the purpose for which the information is collected and how the information will be used and shall agree to such use via an opt in procedure.

In the event any personal information is disclosed to a third party without the requisite consent from the individual, notice of the disclosure and intended use of their information shall be promptly provided in clear and conspicuous language.

Choice

Songwhale and its Customers will give Subscribers the opportunity to choose (opt-out) if their personal information is to be disclosed to a third party, or used for a purpose incompatible with the purpose for which it was originally collected, or subsequently authorized by the individual.

For sensitive information, Songwhale and its Customers will give individuals explicit (opt-in) choice if their information is to be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected, or subsequently authorized by the individual.

Songwhale currently does not share any information, sensitive or otherwise, with any third parties.

Onward transfer

Songwhale does not transfer or disclose any information with third parties. In the event that Songwhale was to disclose information to a third party, Songwhale would apply the Notice and Choice Principles described above

Security

When Songwhale transmits and processes personal information, Songwhale does take reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, as well as alteration and destruction. These precautions are a part of an Information Security Program, are a part of our services to our clients and are under continual analysis for applicability and effectiveness.

Data integrity

Information that is entrusted to Songwhale for transmission and processing will be used in a manner that is consistent with the purpose for which the information was intended. Songwhale will not alter, change or destroy the information without prior authorization and currently takes reasonable steps to ensure that the data is accurate, complete and current.

Enforcement

Any employees determined by Songwhale to be in violation of this privacy policy will be subject to disciplinary action up to and including termination of employment.

Dispute resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to the address given below. Songwhale will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Statement.

Policy changes

Songwhale reserves the right to modify this Statement at any time without notice. If changes are made to this Statement, the changes will be posted on the Songwhale website and other places Songwhale deems appropriate

Compliance Office

Songwhale

100 43rd st #115

Pittsburgh, PA 15201

info@Songwhale.com