Scope and Consent
Collection of Information
Our Services can be used by a broad range of industries in connection with their products, services, activities and administrative functions, whether they are involved in government, retail, health, politics, human resources, technology or anything else. Accordingly, a broad range of information may be uploaded to or sent through our Services.
Without collecting some minimal amount of information, we may not be able to provide Organization/Users with the Services or the support Organization/Users request.
Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information from children under the age of 13.
Information Organization/Users Provide
We collect and store certain information Organization/Users provide when Organization/Users apply or sign up for a GBC account and when Organization/Users provide information as part of our identity or account verification process.
We collect information about Organization/Users, including:
The mobile phone number of individual users. This is stored only for Organization/Users that use GBC text messaging services. Without storing the mobile phone numbers it would be impossible for Organization/Users to send or receive text messages using the Services. If Organization/Users cancel the contract with GBC, GBC will delete all records from its system.
Use Information. We collect information about how Organization/Users use our Services, including Organization/Users access time and Internet Protocol (‘IP’) address.
Information Collected by Cookies. The only occasion where cookies are used is an optional feature that Organization/User can turn on to capture what mobile web pages within the GBC Service a user is viewing. Only if the feature called “Track Mobile Web Page Usage” is turned on by Organization/User will the specific mobile web pages viewed by a user be tracked. Once this feature is turned off by Organization/User this information is deleted by GBC.
Information We Collect from Other Sources
We do not collect any information about Organization/Users from third parties.
Third-Party Advertising and Analytics
We do not allow third-party service providers to deliver content and advertisements in connection with our Services.
Use of Information
We may use information about Organization/Users to provide, maintain, and improve our Services, such as:
Displaying historical information in the GBC Reporting module;
Developing new products and Services;
Delivering the information and support Organization/Users request, including technical notices, security alerts, and support and administrative messages.
We may use information about Organization/Users:
To protect our rights or property or the security or integrity of our Services;
To enforce the terms of our Seller Agreement or other applicable agreements or policies;
To verify Organization/Users identity as required by anti-money laundering, anti-terrorism and security law (e.g., some of the government-issued identification numbers we collect are used for this purpose);
To investigate, detect, and prevent fraud, security breaches and other potentially prohibited or illegal activities;
To comply with any applicable law, regulation, legal process or governmental request.
Sharing of Information
We may share information about Organization/Users only as follows:
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce the terms of our Seller Agreement or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services or (iv) to protect us, Organization/Users of our Services or the public from harm or potentially prohibited or illegal activities; or
Organization/Users may access, change or correct information about Organization/Users by logging into Organization/Users GBC account at any time.
Deactivating or Deleting Organization/Users Account
If Organization/Users wish to deactivate or delete Organization/Users GBC account, Organization/Users may do so by emailing us at firstname.lastname@example.org or calling (415) 297-6677. The account can be deactivated or deleted immediately with all information deleted from GBC system.
No location information is collected.
There are no promotional communications sent to Organization/Users.
Nevertheless, GBC cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Organization/Users personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.
The General Data Protection Regulation (GDPR)
GBC is committed to complying with the requirements of the GDPR and to protecting all personal data received from data subjects in the United Kingdom and European Union member countries in accordance with the Privacy Shield Framework’s Principles, which are aligned with the data protection requirements in the UK and EU: Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity & Purpose Limitation; Access; and Recourse, Enforcement & Liability.
If Organization/Users use the Services in Europe Organization/Users have the legal right under European data protection law to a copy of all the personal information that GBC holds about Organization/Users. If Organization/Users request this information from us we will provide it to Organization/Users for a fee not exceeding the amount permitted by law. As mentioned above, Organization/Users can also ask us to correct any errors in this information. Also, as referred above, Organization/Users have a right to prevent the use of Organization/Users personal information for direct marketing purposes.
Train by Cell Inc.
Attention: David Asheim
300 Beale Street, Suite 608
San Francisco, CA 94105
If Organization/Users have any questions or concerns regarding our policy or if Organization/Users believe our policy or applicable laws relating to the protection of Organization/Users personal information have not been respected, Organization/Users may file a complaint with our Privacy Department listed above and we will respond to let Organization/Users know who will be handling Organization/Users matter and when Organization/Users can expect a further response. We may request additional details from Organization/Users regarding Organization/Users concerns and may need to engage or consult with other parties in order to investigate and address Organization/Users issue. We will keep records of Organization/Users request and any resolution.
Update: April, 2018