Updated: May 14th, 2018
There are three general categories of customer data that we collect or generate from our customers’ use of our products and services. We’ll call these “Customer Content,” “Customer Account Data,” and “Customer Usage Data.”
- Customer Content. Customer Content consists of the communications that are sent through integration with certain of Pingly’s products and services, like the body of a message or voice communication.
- Customer Account Data. Customer Account Data is all the data that relates to the relationship between Pingly and its customers, like our customers’ names, contact information, and billing information and records.
- Customer Usage Data. Includes operational data like API requests, call or messaging logs, origination and termination points (i.e. to/from numbers), traffic routing information, or usage information.
When you sign up for an account on Pingly we collect your Name, Email, Password and Username. We collect this Customer Account Data so that we know who you are, we can communicate with you about your account, and we can recognize you when you communicate with us through Pingly or otherwise. We may also collect a Phone Number to provide verification or two-factor authentication services for your account. Other, optional, data items we collect from you are: avatar, bio, website, location and social network usernames. This information is used for your Pingly Profile that other Pingly users can see.
When you use our products and services, we collect Customer Usage Data. This may include data like your IP addresses, location derived from IP address and how many times you used a Pingly product or service, when the product or service was used by you, the number of calls or messages made or received, the length of calls or messages, where those calls or messages originated or terminated, how those calls or messages were routed, and whether or not the connection was successful or failed.
We collect Customer Usage Data so that you can manage your use of our products and services. We also collect it so that we can properly bill you for your use of our products and services, appropriately manage and route customer traffic, analyze and improve our products and services, identify and solve problems that arise and prevent abuse.
Generally, we use all the data that you provide to us or that we collect from you to provide our products and services to you, to enable you to access and use our products and services, to deliver your communications to their intended destination, and to analyze our customers’ use of our products and services, to improve our products and services, and to detect fraudulent or unlawful activity in connection with Pingly accounts.
In addition, we will use your email address to send you information about Pingly products, services, or events that you might be interested in. You can choose not to receive marketing emails from Pingly. If you wish to stop receiving Pingly marketing emails you may click on the unsubscribe link that will appear at the bottom of any Pingly marketing emails or you can contact customer support.
Pingly does not sell your data to any parties. Also, unless you give us your permission, we won’t share your data with third parties, except as described below:
- Email and Telephony operators as necessary for proper sending, routing and connectivity. One of the things that Pingly provides is an easier way for developers to build applications that make use of the publicly switched telephone network (PSTN) to send communications. Therefore, Customer Content is shared with and received from Email/Telephony operators to the extent necessary to route and connect those communications from the sender to the intended recipient. How those Email/Telephony operators handle your Customer Content is generally determined by those operators’ own policies and local regulations.
- Third-party service providers or consultants. We may share your data stored on our systems with third-party service providers or consultants who need access to the data to perform their work on Pingly’s behalf, like sharing relevant Customer Account Data with our payment processor so it can process payments on our behalf, our storage provider for storing your data on our behalf, or to our data providers to provide profile information to you about your contacts. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.
- Compliance with Laws. We may disclose your data stored on our systems to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If Pingly is required by law to disclose any of your data that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.
- Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, customer data we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of Pingly may continue to use your data as set forth in this notice.
We do not knowingly collect any personal information directly from children under the age of 13.
Cookies are small text files sent by us to your computer and from your computer to us, each time you visit our website. They are unique to your Pingly account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.
Some cookies are associated with your Pingly account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your Pingly account but are unique and allow us to do site analytics and customization, among other similar things. If you access Pingly through your browser, you can manage your cookie settings there but if you disable all cookies you may not be able to use Pingly.
Pingly sets and accesses our own cookies on our company-owned domains. In addition, we use 3rd parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on their respective websites. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
We use appropriate security measures to protect the security of your customer data both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note though that no service is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.
You may access your account through our account dashboard by using your email address and a password that you chose when you signed up for Pingly’s products and services. To protect the confidentiality of your customer data and protect from unauthorized use of your account, you must keep your password confidential and not disclose it to any other person. Please let us know right away if you think your password was compromised or misused. For instructions on changing your password, go to your account settings.
Deletion, access, and changes to Customer Data. You may access and make changes to certain of your Customer Account Data through the Account Dashboard in Pingly. You will also be able access Customer Content stored on our systems and various types of Customer Usage Data through the account dashboard as well.
To request deletion of your Pingly account, email us at firstname.lastname@example.org. You should know that deletion of your Pingly account will result in you permanently losing access to your account and all customer data to which you previously had access through your account. Please note that certain data associated with that account may nonetheless remain on Pingly’s servers in an aggregated or anonymized form that does not specifically identify you. Similarly, data associated with your account that we are required by law to maintain will also not be deleted.
If you would like to export your data, rectify any incorrect data about you or request to have your data deleted from our systems, email email@example.com
Promotional communications. You can choose not to receive promotional emails from Pingly by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting firstname.lastname@example.org. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services.
We may change our Privacy Notice from time to time. If we make changes, we’ll revise the “Last Updated” date at the top of this notice, and we may provide additional notice such as on the Pingly website homepage, account dashboard sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice.
We do not participate in, or co-operate with, any kind of blanket surveillance or monitoring. We also take technical measures where feasible to prevent surveillance of our users occurring without our co-operation, such as:
- Using encrypted SMTP for sending and receiving messages when the outside server supports it.
- Using Perfect Forward Secrecy where feasible for all encrypted connections.
- Encrypting all messages while at rest on our servers.
- Encrypting communications between our data centers.
Like any company, we can never guarantee our measures are 100% effective, as we don't know the full capabilities of any attackers. However, these measures do act to increase the difficulty and expense of any surveillance.
Pingly does not accept legal process directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where Pingly is located. Pingly responds to legal process in a manner consistent with the Electronic Communications Privacy Act, 18 U.S.C. §§2501 et seq., and relevant case law. Pingly does not disclose account content absent a search warrant in criminal cases. In civil cases, Pingly cannot disclose content without sufficient legal process and the consent of the appropriate Pingly customer(s).
Unless prohibited by law, we will disclose to the account holder when we receive a warrant for their account.
We do not condone illegal activity. We deal with all law enforcement requests personally and we are satisfied that all we have seen are justified.
Due to the nature of their jobs as system administrators, some of our employees have the capability to access Pingly accounts. We hold all of our employees to the highest ethical standards, and this includes not accessing anyone's account without their permission. If you request us to look at a specific message in your account for debugging purposes, we may ask you to provide certain data around this message to help us in the debugging process and to ensure that we only access the message you have specified.
If we receive abuse reports for an account, backed up with evidence that it has been used for sending spam or fraud, we may look at the account to decide whether to lock it permanently. This is to reduce the likelihood of accidentally locking a legitimate account. In this instance, it will normally be sufficient for us to just scan the subject and preview lines in a mailbox, but not read any full emails (and we certainly have no wish to do so).
We do not sell or give information about our users to any third parties. Payments are securely handled via Stripe
Incoming messages are scanned for the purpose of spam detection unless you disable spam protection for your account. We may also scan some outgoing messages with the same software to prevent people using our service to send spam. Messages you report as spam are automatically analyzed to help train our spam filter. Also, if enabled, messages reported as spam are forwarded on to some external email reporting services. These services aim to help monitor and reduce overall spam on the Internet.
To make message searching fast, we build an index of your messages (this is a table, just like you would find at the back of a reference book, in which you can look up a word to quickly find the messages in which it appears).
No information from any of these activities is used for any other purpose, or to create any kind of profile on our users.
We retain backups of deleted messages for at least a week. This is for the purpose of restoring messages in case of accidental deletion. After this point, deleted messages will be purged from all our backups, although the time this takes to happen may vary due to automated load balancing.
We normally keep logs of message, email, SMS and server activity for up to 6 months. This is for the purposes of diagnosing and fixing problems, which are often reported to us weeks or months after they occur. Message subjects may be contained in these logs, but not message bodies. Aggregate or anonymous data, which cannot be linked to individual user accounts, may be kept for longer periods, for the purpose of improving the Pingly service.
Backups and logs may be kept longer than these limits in special circumstances. For example, if a problem is taking a long time to resolve, logs relevant to that investigation may be retained. Or if a server that contains backups or logs is temporarily offline because of a fault, then those backups or logs may not be deleted until the server is brought back up.
These situations are unusual, however, and when they do occur, they are temporary.
Should you close your account, all data will be permanently deleted 7 days after closing. It may take a further 30 days to purge from all our backups.
You may contact via email at email@example.com. Or, you may write to us at the address listed below.
P.O. Box 22126
Charleston, SC 29413