Last Updated: December 20, 2024
Gigs Wireless, LLC and our affiliated companies (collectively, “Gigs,” “our,” “us” or “we”) provide a global connectivity enablement platform and related services (“Services”) to enterprises, enabling our enterprise clients (each a “Partner”) to provide connectivity and wireless-enabled devices and services to their customers and end users (each, an “End User”). This Gigs Privacy Policy (“Privacy Policy”) describes how we collect, use, disclose and otherwise process the personal information described below, as well as the rights and choices individuals have regarding this personal information. If you are a Partner or End User, this Privacy Policy should also be read in conjunction with the Gigs Terms of Use (for Partners) or the Gigs End User Service Agreement (for End Users), respectively.
California residents: If you are a California resident, please review our California privacy notice here, which includes additional information about our information practices, as required by the California Consumer Privacy Act (CCPA), including the categories of personal information we collect about California consumers, the purposes for which we collect, use, retain and disclose this personal information, including any “sales” or “sharing” of such information, and how California consumers can exercise their CCPA privacy rights, including the right to opt out of “sales” and “sharing” under the CCPA.
Contents of the Privacy Policy
Our Privacy Policy is organized into sections. Click any section in the side bar to the right to navigate directly to that section of our Privacy Policy.
Gigs enables our Partners to provide and manage wireless connectivity and subscriptions for End Users. More specifically, Partners can access and use the Services to offer or help offer End Users wireless service and other telecommunications-enabled or ‘connected’ services, such as, for example, (a) mobile wireless phone plans (i.e., voice, data, roaming, messaging), (b) connected wearables and other smart devices, and (c) travel data services (i.e., data-only connectivity when traveling outside an End User’s home country) (collectively, the “Connectivity Services”). Gigs' provision of the Connectivity Services is supported by third party suppliers, such as mobile network operators and other telecommunications and technology partners (the “Third-Party Connectivity Providers”). (End users in the EU or UK, please click here for additional privacy information that we are required to disclose about some of our Third-Party Connectivity Providers.) Gigs also enables its Partners to provide, manage, and administer the Connectivity Services to End Users using Gigs’s proprietary technology platform, including interfaces, APIs, dashboards, checkout, payment, tax, and other solutions (the “Gigs Platform Services”). The ‘Services’ defined above include, the Platform Services and the Connectivity Services.
This Privacy Policy describes what personal information we may collect, access, store, use, retain, or otherwise process (collectively, “process”) related to our Services, our website, www.gigs.com (the “Site”), including Partners and End Users (of the Connectivity Services), visitors to the Site (each a “Site Visitor”), and individuals that communicate or interact with us related to our Site and Services.
Not in scope. This Privacy Policy does not apply to or describe:
As used herein, “personal information” includes other similar terms under applicable data privacy laws—such as “personal data” and “personally identifiable information.”
Data controller. For the purposes of the EU General Data Protection Regulation (the “GDPR”), UK Data Protection Act 2018 (“UK DPA”), and similar data protection laws, Gigs Wireless LLC is the data controller, generally, for the personal information processed pursuant to this Privacy Policy, including personal information processed related to the Site and Services. Where you have a direct contract with another Gigs group company then they are the data controller for any personal information processed pursuant to that contract.
Please note that Partners and Third Party Connectivity Providers are independent controllers for any personal information that they collect and process about you related to the Services, and their processing is subject to their respective privacy policies and not this one.
Summarized below is the personal information processed by Gigs. You do not have to provide us with your personal information to access much of the Site. If you choose not to disclose certain information, you can still visit our Site, but you will not be able to create an account with us or access and use the Services, and we may be unable to fully respond to your inquiries. Also, where required by law, we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Categories of Personal Information Collected. While the actual personal information we process and varies depending upon the circumstances, including the nature of our relationship and interactions with you (e.g., Partner, End User, Site Visitor, etc.), generally, we collect the following types of personal information:
Information Collected Directly. We may collect personal information about you directly from you or from your company. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, register for events we host or sponsor, or otherwise provide us information through the Site, we may collect personal information as described in the contact form (e.g., name, company name, company email address and website URL, country location, etc.). Additionally, when you sign up to create an account for our Services as a Partner or End User, we require certain information in order to do so (e.g., name, email, phone number, device information, billing information, country location, etc.).
Automatically Collected Information. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the services or visit the Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see Section 6 ”Cookies, Analytics and Tracking,” below.
Information Collected from Third Parties. We may collect personal information about you from third party sources, such as Partners, business partners, social media platforms, public sources, joint marketing partners, our resellers (so that we can deliver our Services), and third parties to whom you have expressed interest in our products and services, as well as information that you shared on social media platforms (subject to the respective platform terms and applicable laws).
In this section, we describe the purposes for which we collect, use, disclose and otherwise process personal information, as well as the legal basis for our processing pursuant to the GDPR and similar data protection laws.
Certain laws, including the GDPR, the UK DPA, and the LGPD, require that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other similar laws), we process personal information for the following legal bases:
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes of Use, Disclosure and Processing
The purposes for which we may process personal information will vary depending upon the circumstances. In general, we use personal information for the business and commercial purposes set forth below, and where the GDPR or other applicable laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases):
Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and Services, and for similar research and analytics purposes. Where we rely on de-identified data, we will take steps to prevent its reidentification and require any vendors or third parties that receive and process such data to do so as well.
We may disclose the personal data that we collect to others, for the purposes described above, including:
Personal Information may also be disclosed or available to others, including Third Party Connectivity Partners, where necessary or incidental to the provision and operation of our Services, and as otherwise directed or authorized by you.
Your mobile information will not be sold or shared with third parties for promotional or marketing purposes without your consent.
We and our third-party providers use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect browsing, activity, device, and similar information on our Site and to measure and deliver more targeted advertising on other Sites. This information is used, for example, to analyze and understand how visitors interact with our Site and our content and ads on third party sites; identify and resolve bugs and errors on our Site; assess, secure, protect, optimize and improve the performance of our Site and Services; conduct marketing and analytics; and reach customers and prospective customers with more relevant ads; and evaluate our marketing and ad campaigns.
Cookies. Browser cookies are alphanumeric identifiers that we transfer to your device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process, support the security and performance of the Site or allow us to track activity and usage.
Pixels. Also referred to as tags, web beacons or clear GIFs, pixels are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these in connection with our Site and our ads and content on other sites and platforms, to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also include these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third-party analytics and tools. We use third-party tools, such as Google Analytics, which are operated by third-party companies. These third-party analytics companies may use cookies, pixels, and other similar tools to collect usage data about our Site in order to provide us with reports and metrics that help us evaluate usage of our Site and improve performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Targeted advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services, and others (“third-party ad companies”) to personalize content and display advertising on our Site, as well as to manage our advertising on third-party sites and platforms. We and these third party ad companies may use cookies, pixels, and other tools to collect Usage and Activity Data on our Site, and on third-party sites, and platforms, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. The information enables us to provide more relevant ads and content within our Site and on third-party sites and services, and to evaluate the success of such ads and content.
Managing your Site preferences. We make available several ways for you to manage your preferences regarding targeted advertising, matching and cookies within our Site. Many of these are browser and device-specific, which means that you need to set the preference for each browser and device you use to access our Site; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us (and others).
Gigs is a multinational company with operations and service providers in multiple jurisdictions, including the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States, the United Kingdom (“UK”) and the European Economic Area (“EEA”), Canada, Australia, Singapore, and Japan) that may not provide equivalent levels of data protection as your home jurisdiction. Personal information may also be accessible to law enforcement and public authorities in these jurisdictions. We take steps designed to protect your personal information in the jurisdictions in which we process it, including through appropriate contractual terms.
If you are in the EEA or the UK, and we process your personal information in a jurisdiction that has not been found, respectively, by the European Commission or the UK ICO to provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA or the UK. Such right may also exist in other jurisdictions. You may request such details by contacting us as set forth in Section 13 “Contact Us,” below.
Our Site is not targeted to children under 13 or to other minors under the age of 18. In general, we do not knowingly or intentionally collect personal information from children or minors. In limited instances, End Users of our Partners may be minors. In such cases, our Partners are responsible for ensuring consent is obtained, including verifiable parental consent where required under the U.S. Children’s Online Privacy Protection Act (“COPPA”). If you believe we have collected your child’s personal information without obtaining any required consent, please notify us as set out in Section 13 “Contact Us,” below.
We take steps to protect the personal information that we collect from unauthorized access or disclosure. Regardless of the precautions taken by us, Gigs cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. You are responsible for all actions taken with your account, if any.
For additional information about Gigs security practices as it relates to the Site and our Services, please visit the Gigs Trust Center.
As a general rule, we retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.
Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request to data-request@gigs.com. We will review your request and make reasonable efforts to respond to it as soon as practicable and in accordance with applicable law. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails. If you would like to unsubscribe from Gigs email subscriptions or otherwise change your email preferences with Gigs, please follow the instructions in any Gigs promotional email that we send to you. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator or supervisory authority in your jurisdiction.
Additional Information for Certain Jurisdictions. In Section 14 “Additional Information under Certain Privacy and Data Protection Laws,” we provide additional information for users in certain jurisdictions, including EU and UK data subjects, California residents, and residents of certain other US states. Users in these jurisdictions should review this section for more information regarding their rights under applicable privacy laws.
Gigs may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. Revisions will be posted on our website, here. If the changes will materially affect the way we use or disclose personal information we have previously collected about you, we will endeavor to notify you in advance of the change, such as by sending a notice to the primary email address associated with your account or by posting a notice on the Site. We encourage you to periodically review this Policy for the latest information on our privacy practices.
To submit a privacy request or other inquiry related to this Privacy Policy or our privacy practices, you may contact us at data-request@gigs.com. If you are in the EU or UK, please also see Section 14.A below.
This section contains additional information for data subjects under the GDPR and UK data protection laws, as well as for residents of California and other U.S. states.
A. EU and UK Data Subjects
Subject to the conditions set out in the applicable law, individuals in the EU/EEA and UK may have the following rights (or some of them) with regard to our processing of their personal information:
Data subject requests and other privacy inquiries may be submitted to Gigs at data-request@gigs.com. If you are in Germany, you may also contact our German Data Protection Officer at: heyData GmbH, Schützenstr. 5, 10117 Berlin, datenschutz@heydata.eu. In addition:
B. Residents of Certain U.S. States
If you are a California resident, please see Section 14.C below for additional information about your privacy rights under the CCPA.
In addition to the choices and rights set forth above, consumers that are residents of certain U.S. states (including Colorado, Connecticut, Montana, Delaware, Iowa, Nebraska, New Hampshire, Oregon, Texas, Utah and Virginia) have additional rights regarding their personal data under applicable state privacy laws, which may include the following rights, subject to certain conditions and limitations:
You may submit a request to exercise one of your other privacy rights, or appeal a denial of your request, by emailing us at data-request@gigs.com. We will take steps to verify your request, which may include sending you an email confirmation link which you must click to confirm your request and matching the information provided by you with the information we have in our records. We will process your request based upon the personal data in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request.
You may also opt out of targeted advertising via our Site by adjusting your cookie settings or enabling Global Privacy Control—or GPC—signals for your browser, as described under the“Managing your Site preferences”section above.
C. California Privacy Notice
In this section, we provide additional information for California residents about how we handle their personal information, as required under California privacy laws, including the CCPA. This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
Categories of Personal Information Under the CCPA
While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months.
Categories of Personal Information Collected and Disclosed. Below we identify the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. In addition to the categories of disclosures below, personal information may be disclosed to our service providers who act on our behalf and others where required by law or directed or authorized by you.
Identifiers
This includes direct identifiers, such as name, username, account name, address, phone number, email address, online identifier, user agent, IP address, device identifiers (e.g., device IMEI, SIM ICCID, SIM credentials, device make & model), or other similar identifiers.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; enterprise clients.
Customer Records
This includes personal information, such as name, signature, contact information, and payment information, that individuals provide us in order to purchase or obtain our products and services.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; enterprise clients.
Commercial Information
This includes records of products or services purchased, obtained or considered, (or other purchasing or use histories), billing address, credit card last-four digits, bank account and routing information. Please note that Gigs does not collect or have access to full credit-card information. Instead, Gigs uses payment processors (such as Stripe, Inc.). For other information about Gigs’s subprocessors, see the Gigs Trust Center.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; enterprise clients.
Usage and Activity Data
For the Services, this includes information pertaining to text/SMS usage (e.g., text timestamp, incoming/outgoing text phone number), voice usage (e.g., voice timestamp, incoming/outgoing voice phone number, call duration), data usage (e.g., data timestamp, data duration, data volume usage), country usage information, and aggregate Services usage data.
For the Site, this includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites and services, and our marketing emails and online ads.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries; advertising networks; data analytics providers; social networks; internet service providers; enterprise clients.
Location Data
This includes precise location information about a particular individual or device.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; affiliates and subsidiaries.
Audio, Visual and other Electronic Data
This includes transcripts and recordings of support and sales calls and other video conferences (e.g., of customer support calls), as well as video recordings (e.g., CCTV) and other access logs of visitors to our offices and premises.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries; enterprise clients.
Professional Information
This includes professional and employment-related information, such as current positions, business contact information, business-related social media information (e.g., LinkedIn, Twitter/X).
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries; enterprise clients.
Inferences
This includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, behavior or other characteristics. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.
This may be disclosed to: service providers; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries.
Sensitive Data
Some of the personal information we collect is considered sensitive personal information, including SSNs and government identifiers, financial account numbers. This may also include health and disability information, which we may collect in order to provide accommodations to you, as well as precise geolocation.
This may be disclosed to: affiliates and subsidiaries; advisors and agents; government entities and law enforcement when required by law; our affiliates and subsidiaries.
Sales and sharing of personal information. Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value and “sharing” includes communicating personal information to a third-party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We do not disclose personal information to third parties in exchange for monetary compensation, but we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as to improve and measure our ad campaigns and reach users with more relevant ads and content. Accordingly, as defined by the CCPA, we may sell or share Identifiers, Usage and Activity Data and Inferences with third party advertising networks, social media networks, and data analytics providers. However, we do not sell personal information about individuals we know to be under 16 years old, nor do we sell or share any sensitive personal information about California residents.
Sources of personal information. As further described above, in Section 3 “Personal Information Collected,”we may collect personal information from individuals directly as well as the following sources:
Business and Commercial Purposes for Collecting, Using, Disclosing and Otherwise Processing. As further described above, in Section 4.B “Purposes of Use, Disclosure and Processing” and Section 5 “Disclosures of Personal Information,” we collect, use disclose and otherwise process the personal information we collect for the following business and commercial purposes:
Sensitive Personal Information. Notwithstanding the purposes described above, we only use and disclose sensitive personal information about California residents as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.
CCPA Rights. In general, California residents have the following rights with respect to their personal information, subject to certain limitations:
Requests to Opt Out. You may opt out of targeted advertising via our Site by adjusting your cookie settings or enabling Global Privacy Control—or GPC—signals for your browser, as described under the “Managing your Site preferences” section above.
Submitting Requests to Access, Delete, Correct or Limit. Data subject access requests may be submitted to Gigs via email at data-request@gigs.com.
When you submit a data subject right request, we will take steps to verify your request by matching the information you provide with the information we have in our records and verifying your registered email address. We may request additional information in order to verify your request or where necessary to process your request. Authorized agents may also initiate a request on behalf of another individual by contacting us as at the email listed above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Contact Us. You can contact us regarding this Privacy Policy via email at data-request@gigs.com.
