This Privacy Notice describes the types of Personal Information that LATAMSUL collects, processes, maintains, protects, and shares. What does this Privacy Notice cover?   This Privacy Notice applies to Personal Information collected when you use or interact with LATAMSUL’s products, services, networks, and platforms, including our websites. This may include LATAMSUL-branded services and products.   It also applies to Personal Information that we collect from third parties and potential business customers to market our products and services, enter into service contracts, complete installations, obtain support, and bill for services.   As used in this Privacy Notice, “Personal Information” refers to any information relating to you as a person. It may be information that on its own can identify you, such as your name, or it may be information that identifies you only when combined with other available information, such as your social media username when combined with your email address.   We may collect the following types of personal information from you:  

• Identifiers, such as your first name, middle name, last name, salutation, date of birth, social security number, financial account details (i.e., credit card or bank account number), email address, postal address, service address, telephone number, and similar contact details.
• Customer records,  such as customer account or profile information, name, account name, other characteristics, identifiers or descriptions, email and physical address, phone number and other contact information, account credentials, communication preferences, billing and payment information, online account/profile creation for an account, tickets, and customer service and support records,  preferred contact method and other information you provide to purchase and use our products or services.
• Customer support records such  as email correspondence, recorded conversations with our agents, and recorded online sessions for quality assurance, training, and analysis of online sessions.
  • This can include text or recording “click-to-chat” sessions, screenshots for remote access for technical support.
  • For network support, we may record dates, times and phone numbers of calls to and from our customers, for activities such as toll collection.
• Employment and Applicant Information, such as information about your personal and employment history, current job title, role, racial origin (as required by law), gender, citizenship, veteran, or military status. For additional details on LATAMSUL’s Privacy Practices for candidates.

• Information about activities on the Internet or other electronic networks,  such as information about your interaction with LATAMSUL, including cookies, session logs, search history, and website interaction analysis about your activity and any changes made to the business accounts you are authorized to manage, inquiries submitted, feedback, and similar information about business activities.
• Commercial Information, such as electronic marketing materials, products or services purchased, obtained, or considered, or other purchase or consumption histories or tendencies. For telecommunications services such as voice calls or text messages, LATAMSUL and third parties may also analyze Personal Information collected during such interactions.
• Sensitive Personal Information, such as your precise geolocation, government identifier, financial account information, and health data. (LATAMSUL does not collect your health data as part of providing its services; however, if you provide this information, it may be noted in your account). Where required, LATAMSUL will obtain your consent before collecting and using Sensitive Personal Information.

  There may be circumstances in which we request Personal Information other than those identified above. LATAMSUL will do so only when necessary or justified to improve the services we provide and to increase the relevance of its portfolio of services and will be treated in the same way as the other Personal Information identified in this Privacy Notice.   How we use your personal information:   LATAMSUL will use your Personal Information to provide services, set up and maintain accounts, provide and repair our services and equipment, respond to customer inquiries and concerns, bill and bill for our services, plan the future development of our network and services, market our services, communicate with our customers and others about our services. We also use the Personal Information we obtain from third parties, including demographic data, to help us serve our customers, predict what new services they may want, and determine a customer’s creditworthiness. LATAMSUL may also use your Personal Information to evaluate and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.   LATAMSUL may combine Personal Information in our systems, platforms, and databases. This includes combining information we receive from third parties and information related to your use of LATAMSUL’s services. LATAMSUL will use your Personal Information only for the purpose for which it was obtained and will keep it only for as long as necessary.   Use of LATAMSUL internet services by children: We understand that children can use our internet services. When using our internet services, authorized legal guardians have the responsibility to monitor what their children are doing on the internet and what websites they are visiting. For more information about online safety, visit the Federal Trade Commission’s resource for internet safety.   When and with whom we share Personal Information:   LATAMSUL may share your Personal Information with other entities, including our affiliates, subsidiaries, and third parties that provide certain functionality for some of our commercial products and service offerings, to the extent applicable to your interaction with LATAMSUL and your management of the commercial customer accounts or functions for which you are authorized.   LATAMSUL may also share Personal Information with third parties:

• When you direct us to do so, including to authorize other users on your account;
• Where it is necessary to provide our services, including credit reporting agencies;
• When required by law or to respond to legal process;
• To protect or enforce our property or rights or the safety of our employees, customers, or other individuals; or
• By merging, selling, or transferring segments of our business, assets, or acquiring other businesses

  LATAMSUL partners with other parties and channel partners to provide certain commercial products and services. These partners may support the services, engage other service providers to transmit, collect, process, or store information, or engage in sales and marketing activities on behalf of LATAMSUL. LATAMSUL contractually requires these service providers and channel partners to treat the Personal Information shared as confidential and use it only to provide services on our behalf.   Where do we send your personal information?   In certain circumstances, LATAMSUL may transfer your Personal Information to our affiliates and subsidiaries outside of your country or region or to international organizations as necessary to conduct our business operations, provide our services, and engage in our marketing activities. Accordingly, when transferring your Personal Information to any international area or organization, LATAMSUL uses safeguards to enable the security and protection of your Personal Information, including the use of standard agreements approved by various national and regional governments in accordance with global data protection requirements. Personal Information is used to confirm and enable those authorized by our business customers to interact with LATAMSUL on their behalf. Personal Information contained in our systems, records, activity logs, and marketing databases may be accessed by our affiliates and subsidiaries located in the United States and other countries around the world. Where appropriate, our affiliates and subsidiaries located in countries that do not have legal requirements to provide adequate protection for Personal Information have signed an agreement and agreed to terms to ensure that Personal Information is adequately protected.   How we protect your personal information:   LATAMSUL implements a variety of security and organizational measures to help prevent your Personal Information from being accessed, used, or disclosed without authorization. We limit our collection and use of your Personal Information to the minimum necessary. LATAMSUL limits the availability of your Personal Information to the purposes specified in this Privacy Notice.   Your Choices and Control Over Your Personal Information:   In certain U.S. states, you have the right to ask us to provide access to and obtain a copy of the Personal Information we have about you, to request correction and deletion of your Personal Information, the right to ask us to restrict our use of your Personal Information, to object to our use of your Personal Information,  including the sale or sharing of Personal Information and, in certain circumstances, the right to direct us to submit your Personal Information to another entity and not to be discriminated against for exercising your rights. You can designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also directly ask you to verify that you have authorized your authorized agent to act on your behalf. We also share information about your use of our website with our social media, advertising, and analytics partners. You can exercise your rights to opt out of the sale or processing of personal data for targeted advertising by clicking on the “Your Opt-Out Rights” link. For more details, see our cookie notice.   We have no actual knowledge that we sell or share Personal Information of individuals under the age of sixteen (16).   Data Subject Requests (DSR):   You have many choices about how we communicate with you and how we use or share your information. You can manage these settings or preferences by submitting a Data Subject Request or by submitting a request to our Privacy Office at privacy@latamsul.com. Please identify the right(s) you wish to exercise, the Personal Information involved, and why you believe LATAMSUL has your Personal Information. We may request additional information to help us research the Personal Information you have requested or authenticate your request, so you should be as precise as possible when making your request. We will provide you with a copy of the Personal Information we hold about you free of charge. For any additional copies requested, we may charge a reasonable fee based on administrative costs. For any request made by email, unless you request otherwise, we will provide the information by email in a commonly used format, such as a Word document, Excel spreadsheet, or PDF, as appropriate. LATAMSUL is committed to maintaining and using de-identified information in compliance with applicable law.   Cookies:   LATAMSUL’s use of cookies is managed by our Cookie Settings consent tool, which is presented on the LATAMSUL website. Cookie settings are based on your location and specific to the regulatory requirements described in various U.S., EEA, and other international jurisdictions. LATAMSUL also respects browser-based blocking, so if a visitor has a blocker in their browser, the visitor can block all cookies except for “strictly necessary” cookies. LATAMSUL also respects opt-out preference signals when necessary. We also use third-party tools, such as Google Analytics, which are operated by third-party companies, to evaluate the use of our Site and Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate the use of our Services, improve our Site, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review Google’s Privacy and Terms in How Google uses information from sites or apps that use our services. You can also download the Google Analytics opt-out browser add-on page to prevent your data from being used by Google Analytics. Detailed information about LATAMSUL’s cookie practices and terminology can be reviewed in the cookie notice.   How long we keep your information:   We keep your Personal Information for different periods of time, depending on the type of information and the applicable business and legal requirements. For example, if you are a customer, we retain information that personally identifies you if you subscribe to one or more of our services. If you no longer subscribe to a service, we may still need this information for business and legal requirements, such as fraud protection, tax calculation, responding to legal requests, or for pending litigation.   Changes to this Privacy Notice:   When we post changes to this Privacy Notice, we will revise the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice that alter the use of Personal Information we previously collected, we will notify you in writing, electronically, or otherwise so that you can make any necessary decisions about your continued use of our services.