Kajeet Privacy Policy

Kajeet Inc. (“Kajeet,” “we,” or “us”) provides its customers (“Customer” or “Customers”) with anytime, anywhere wireless connectivity solutions. Kajeet is committed to ensuring that the information of your institution and its users is secure, and that both your and your users’ privacy is protected.  This Privacy Policy addresses Kajeet practices concerning gathering, using and distributing personal information from all users (“User” or “Users”) of Kajeet products, including customers and any guests who access Kajeet services through any Kajeet-owned or -operated application, device, website or service (collectively, “Kajeet Services”).

Kajeet may update this Policy from time to time. We will notify Customers about any material changes to the policy via email to the primary email address specified in the Kajeet account or by placing a prominent notice on our site. Any information collected from the Customer subject to an earlier version of this Privacy Policy will continue to be treated in accordance to that earlier version. Kajeet will not change how data are collected, used or shared in any material way without advance notice to and consent from the Customer.

By using Kajeet Services, the User consents to the terms and conditions of this Kajeet Privacy Policy. If the User does not agree with the terms and conditions, please do not use Kajeet Services. A User’s continued use of Kajeet Services after the posting of changes to the Privacy Policy will constitute acceptance of those changes and the revised Privacy Policy.

OUR CORE PRIVACY PRINCIPLES

Data Ownership: Kajeet considers and acknowledges all data that Kajeet may gather from a Customer or the devices it owns and manages is the property of the Customer, including the personal information of Users (“Customer Data”). Customers have complete and unequivocal rights to their data and how they wish their data to be utilized, subject to any exceptions provided below.

Data Collection and Use: Kajeet will only collect Customer Data as necessary to fulfill Kajeet’s duties as outlined in the Customer’s contract or service agreement (“Agreement”). Furthermore, Kajeet will use Customer Data only for the purpose of fulfilling its duties and providing services to Customer, and for improving its services. Kajeet will not use any data to advertise or market directly to users.

Security:  Kajeet takes securing Customer Data and the personal information of their Users seriously, and uses appropriate administrative, physical and technical safeguards to protect data from unauthorized access, disclosure, and use.

WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

Kajeet limits the amount of personal information it collects about Users.  The different ways we collect personal information and the types of personal information we collect are described below.

Sentinel Platform

The Sentinel Management Platform allows Customers to access their data collected from their use of Kajeet Services. This information can include: device identifiers and information (IP, IMEI, ESN/MEID, MDN, UICC, Device Type, Device Nickname, usage data, Policy group associated with devices, Checkout status & suspend status, URI history (including timestamp, MDN and device/IP address), Allowed/blocked policy decisions for each URI request, Categorization decisions for each URI request, and notes and other information input by the Customer.

For Customers that utilize the Sentinel “Media Center”, additional information collected may include: Check-in and Check-out status, Due date, Content filter group, Borrower ID (optionally entered by Customer), Notes (optionally entered by Customer), and Checkout history. Customer should not enter any PII in any of the Customer entered data fields.

Authorized users of the Sentinel Management portal are designated by Customer. In addition to login information, Kajeet may collect profile information about such authorized users including name, address, phone number, time zone, and security questions. In addition, Kajeet collects application log data (such as when the user has logged in) and page access statistics.

Connected Devices

Kajeet Services are provided through connected devices including, but not limited to: routers, hotspots, cellular embedded devices (tablets, Chromebooks, laptops, handhelds, and wearables) and IoT devices (sensors and gateways).

Device network identifiers and connectivity data related to the use of voice telecommunications service is commonly referred to as Customer Proprietary Network Information (“CPNI”).  CPNI is subject to special Federal laws and regulations, with which Kajeet fully complies.

Aggregate Customer information (“ACI”) is collective data that relates to a group or category of services or customers, from which information identifying individual Customers and Users have been removed.

It is the policy of Kajeet to treat all CPNI and ACI in a confidential manner and to limit access, disclosure and use of such information in a manner that is compliant with the 1996 Telecommunications Act and by the FCC.  All employees or representatives of Kajeet, including those who have access to or use CPNI or ACI, receive mandatory annual CPNI training, including, without limitation, training with respect to when they are and are not authorized to access and use CPNI or ACI.

As required by Rule 64.2009(e) set forth at 47 CFR Part 64, the compliance certification and supporting statement of Kajeet is publicly available at the offices of Kajeet, Inc. 7901 Jones Branch Drive, Suite 350, McLean VA 22102.

Knowledge Center

The Kajeet Knowledge Center maintains Customer login information as well as support ticket history, including any chat history.

Kajeet Websites

When visitors browse Kajeet websites, Kajeet may collect certain electronic information, such as the IP address of the visitor’s computer.  Kajeet websites also use cookies (i.e., a small piece of code stored on your device for record-keeping purposes) or similar mechanisms to better understand how visitors use our website and for analytics purposes.  At times, Kajeet may utilize third-party providers that collect certain electronic information, such as your computer’s IP address and how you use Kajeet’s websites, directly from Kajeet websites.  Finally, Kajeet may collect information that is provided by visitors to Kajeet websites by contacting Kajeet directly through email links to ask questions or make comments.

Kajeet records essential information about user activity and interactions with this website for the purposes of security and site optimization analytics. This limited first-party data may be further enhanced with the help of third-party data sources to help facilitate visitor segmentation and re-engagement through verified marketing channels, within the respective boundaries of applicable legal standards.

Some browsers have incorporated “Do Not Track” features.  Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked.  Because there is not yet a common understanding of how to interpret Do Not Track signals, Kajeet does not currently respond to those signals.  For more information regarding Do Not Track mechanisms, see https://allaboutdnt.com/.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Kajeet uses the information we collect to provide our contracted services and to improve our services.  Kajeet will not use any data to advertise or market directly to Users.

Kajeet may use de-identified data for product development, research, or other purposes.  De-identified data will have all direct and indirect personal identifiers removed.  Furthermore, Kajeet agrees not to attempt to re-identify de-identified data and not to transfer de-identified data to any party unless that party agrees not to attempt re-identification.

Kajeet collects IP addresses to assist in system and network administration, collect aggregate information, track trends and audit use and performance of Kajeet Services. Kajeet does not associate IP addresses with an individual.

Kajeet does not use any information about how individuals surf the Internet or browse our sites to conduct direct marketing to Users.  Kajeet may, however, use aggregated information (i.e., anonymous and not tied to any individual) for our own research and to analyze the efficiency of our network and services, which may include sharing such information with our partners.

On various web pages, users can contact Kajeet directly through email links to ask questions or make comments.  Kajeet may retain submissions to improve Kajeet Services or Kajeet may discard them.

HOW WE SHARE PERSONAL INFORMATION

Customer Data will not be shared with any additional parties without the prior written consent of the Customer except as required by law.  At no time will we sell Customer Data to advertisers or other third parties for payment.  We also will never sell any personal information we collect that is not Customer Data to advertisers or other third parties for payment, though we may share that information with partners and service providers in order to provide and improve Kajeet Services.

We may, however, disclose the personal information we collect and Customer Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or other governmental or law enforcement request, (b) enforce our Terms of Use, including investigation of potential violations, (c) detect, prevent, or otherwise address fraud, security or technical issues, (d) protect against or mitigate harm to the rights, property or safety of our company, the services we provide, Users or the public as required or permitted by law, and (e) in order to respond to or report on suspected or actual abuse or misuse of Kajeet Services.

OTHER IMPORTANT INFORMATION

In the Event of Merger or Acquisition

If Kajeet becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, Kajeet will require that the acquiring entity carry out the terms of this Privacy Policy.  In such cases, Kajeet may provide any information (including Customer Data, CPNI, ACI, or personal information) to that third party and assign all of Kajeet’s rights and obligations under this Privacy Policy related to such information to that third party.

Security

Kajeet strives to protect the security of the Customer Data and other personal information stored and processed by Kajeet.  Kajeet implements appropriate administrative, physical, and technical safeguards to secure data from unauthorized access, disclosure, and use.   Kajeet, however, is not responsible for any breaches in security caused by Customers or Users, such as the disclosure of a password to a third party by a Customer’s authorized user.

Children’s Privacy

Kajeet does not knowingly collect any personal information from children under the age of 13.

Third-Party Sites

This Privacy Policy applies to Kajeet Services only.  We, however, do not exercise control over any other sites that may be linked to or accessed through our services or websites.  You should review the policies of any third-party sites before providing personal information to those organizations.

Social Media Sites

Kajeet may have pages or other presence on various social networking sites or services, such as Facebook, Twitter, Instagram, LinkedIn, and the like.  Any information you post or provide through such sites and services will be subject to the policies of those sites and services.