PRIVACY POLICY

CLIQA, Inc.
Effective and Updated March 14, 2014

General
CLIQA, Inc. and its affiliates (“CLIQA”, “we”, “us”, “our”) are committed to protecting the privacy of our customers’ personal information. This Cliqa App Privacy Policy (the “Policy”) is designed to inform you of our policies and procedures regarding the collection and use of your personal information, and your options with regard to that collection and use.

We may update this Policy from time to time and you are advised to review it periodically for changes. Any updated Policy will be posted at www.MiCliqa.com/politica-de-privacidad.html. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in the Cliqa App User Agreement, which can be found at www.MiCliqa.com/terminos-y-condiciones.html.

This Policy applies to:

our Cliqa App customers in the United States;
visitors and users of www.MiCliqa.com, any other Cliqa App website and any Cliqa App mobile application (collectively, the “Cliqa App Websites”); and
users of our Cliqa App products and services (collectively, the “Services”) whether purchased on the Cliqa App Websites or through an authorized Cliqa App retailer.

Information We Collect and How We Use It
We collect and use both Personal Information and Non-Identifying Information about you. “Personal Information” means information either on its own or in conjunction with other data that enables a specific person to be identified, but does not include “de-identified,” “anonymous,” or “aggregate” information, which is not associated with a specific person. “Non-Identifying Information” means information that by itself cannot be used to identify a specific person (e.g., zip code, location information and individual preferences). Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from others who use the Services to attempt to provide you with a better experience, to improve the quality and value of the applicable Service and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

Our primary goals in collecting information from you are to provide and improve our Services, to administer your account, and to provide better targeted advertising. As used in this Policy, the terms “use,” “using” and “processing” information include using cookies or other similar technologies on a computer/phone/device, subjecting the information to statistical or other analysis and using or handling information in any way, including but not limited to, scanning, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

We collect and use information about you in the following ways.

1. Information Collected When You Communicate with CLIQA
When you communicate with us, we may collect the following information:

your name, address, cell phone number, email address, birthdate, frequently called numbers, and other personal, phone or social network contact information;
the reason for your contact;
your Cliqa App login credentials, security code and password; and/or
your credit card details and other payment information.

We use this information to (i) provide, confirm, change, bill, monitor, maintain and repair your Cliqa App Services, (ii) resolve any issues with your order, with our Services, or with your Cliqa App account and (iii) establish and maintain your account, authenticate you, and contact you about products and services that we offer.

When you contact us or we contact you, we may monitor or record that communication to help us train employees and provide high-quality customer service or for legal or regulatory purposes.

2. Information Collected When You Use Cliqa App Products and Services
We collect information about you when you register with us and use our Services. The information we collect this way includes:

Personal Information, including login credentials related to your Services, your social networks and other third party sites;
call records, frequently called numbers and network traffic data;
product and device-specific information;
mobile and device numbers; and/or
information about your phone, system and application software.

We use your Personal Information mainly to provide the applicable Service and administer your account and inquiries. We also use this information for billing purposes, to facilitate, deliver and maintain our Services, customize data presented to you and to help you with service-related issues or questions. We may also use this information for other purposes such as: (i) providing you with information about Service enhancements; (ii) determining your eligibility for new products and services; (iii) marketing to you based on your use of our Services; (iv) managing and protecting our networks, Services and users from fraudulent, abusive, or unlawful uses; and (v) subject to consent practices described in this Policy, helping us improve our Services, researching and developing new products, and offering promotions and other services. We may aggregate this type of information in a manner that does not personally identify you for business and marketing uses by us or by third parties.

3. Information Provided to Us by Third Parties
When you purchase our Services, we may obtain credit information about you from outside credit reporting agencies to help us with customer authentication and credit-related decisions.

CLIQA also obtains aggregate information from outside companies that collect consumer information such as demographic and interest data. Examples of this information include gender, age range, sports enthusiast, or pet owner. We use this data and combine it with other information we have about you to help us predict customer preferences and to direct marketing offers that might be more relevant to you.

We may also obtain contact information and other marketing lead information from third parties, and may combine it with information we have to contact you or direct CLIQA’s marketing offers to you. Website visitors and others may provide us with your email address or mobile phone number through “refer-a-friend” options or social networking platforms. We use these email addresses and mobile phone numbers to send promotional offers, free trials, Services purchased by others for your use and CLIQA promotional marketing information, all in accordance with applicable law.

4. Information Collected on Cliqa App Websites
When you use and browse the Cliqa App Websites, we collect information about your device and your visit, including:

your browsing, searching and buying activity;
your IP address;
websites visited and application and feature usage;
web addresses of the sites you come from and go to next;
information about your connection, including your device’s browser, operating system, platform type and Internet connection speed, your mobile telephone or device number;
device identification; and/or
with your consent, certain data on your device including your contacts.

We use this information for operational and performance measurement purposes including monitoring statistics such as how many people visit our websites, which pages people visit on our sites, how much time is spent on each page, or which browsers are used to visit our sites. We also may provide statistical “ratings” information (not Personal Information) to our website partners about how our members, collectively, use the Cliqa App Websites.

When you establish an online account with us, we maintain information about your user identification, security code and password. This information is used to identify you when you sign in to your account.

The Cliqa App Websites may certain web technologies such as “cookies” or “web beacons.” We use cookies (small text files stored locally on your computer or device to serve as markers) to protect and authenticate access by customers to our websites. Web beacons are used to tell us how and when pages in our site are visited, by how many people, their point of origin and operating system and to monitor performance with our websites. These technologies do not collect Personal Information and we do not combine information collected through these technologies with other Personal Information. We may also use information collected from cookies or other similar technologies to improve the Cliqa App Websites, make recommendations, and complete transactions you request. We do not honor any web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of Personal Information about your online activities over time and across third-party websites or online services.

This data is used by CLIQA and its vendors to deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area. This content may be delivered on our websites, on non-CLIQA websites, on our mobile apps, by our representatives, via email, via SMS, via push notifications or via other CLIQA services. In addition, responding to or interacting with a particular advertisement, may result in you later receiving a targeted advertisement on our websites or on other sites as a result of an ad server or ad network concluding that you fit within a particular audience we or an advertiser is trying to reach. We use this information in order to, among other things, ensure that you see the correct product information, manage the frequency with which you see an advertisement, tailor advertisements to better match your interests, and to understand the effectiveness of our advertising.

We use certain Google Analytics Advertising Features, including Remarketing and Demographics and Interest Reporting. Google Analytics is a web analysis service provided by Google that allows us to collect data about the traffic on our websites through Google cookies and other identifiers. Google utilizes the data collected to track and examine the use of our websites and to prepare reports on the activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. You may be able to opt out of the Google Analytics Advertiser Features through your browser ads settings. In addition, Google has developed the Google Analytics opt-out browser add-on to provide website visitors the ability to prevent their data from being used by Google Analytics. The add-on can be found at www.tools.google.com/dlpage/gaoptout.

5. Information You Provide
When you contact us for information about our Services or promotions, we may collect information from you such as:

personal contact and billing information;
email address or phone number;
credit information; and/or
other information you provide to us.

If you enter a promotion or sweepstakes, your information may be disclosed as part of the program’s administration, such as in connection with the publication of winners, prize fulfillment, and as required by law or permitted by the promotion’s official rules. We may also collect information from you when you agree to participate in surveys or provide other feedback to us regarding our products or services. We use this information only for the purposes disclosed to you at the time you provide it.

When you open a CLIQA email or SMS message or click on links within these emails or text messages, we may collect and retain information to provide you with future communications that may be of more interest to you. Please note that CLIQA will not ask you to send us via email any Personal Information or account information.

How We Share Information
We share your information in the following ways.

1. Information Shared Within the CLIQA Telecom Family of Companies
CLIQA shares customer information within the CLIQA Telecom, Inc. family of companies (“CLIQA Family of Companies”) for operational purposes, our own marketing purposes and for general administration purposes. Sharing this information allows us to provide you with the latest information about the CLIQA Family of Companies’ products and services and to offer you our latest promotions.

2. Information Shared Outside the CLIQA Family of Companies
CLIQA does not sell, license or share Personal Information with others outside the CLIQA Family of Companies for non-CLIQA purposes without the consent of the person whose information will be shared, except as explained in this Privacy Policy.

CLIQA does not sell, rent or lease its customer lists to third parties. CLIQA does not publish directories of our customers’ phone numbers, and we do not provide or make them available to third parties for listing in directories without prior customer consent.

CLIQA uses vendors and partners for a variety of business purposes such as to help us offer, provide, operate, repair and bill for products and services we deliver to you. We share information with those vendors and partners to the extent reasonably necessary for them to perform work on our behalf. For example, we may provide your credit card information and billing address to our payment processing company solely for the purpose of processing payment for a transaction you have requested. We request that these vendors and partners protect your Personal Information and limit their use of CLIQA customer data to the purposes for which it was provided.

CLIQA also may share certain de-identified information with third parties for marketing, advertising or other purposes, including the delivery of advertising campaigns and preparing and sharing aggregate business and marketing reports. We may share aggregated information that includes Personal Information and we may otherwise disclose Non-Identifying Information and log data with third parties for industry analysis, demographic profiling and to deliver targeted advertising about other products and services.

If you purchase products or services offered jointly by CLIQA and one of our partners, your customer information may be received by both CLIQA and our partner that is providing the product or service. For these jointly offered products and services, you should also review the partner company’s privacy policy, which may include practices that are different from the practices described here.

We may disclose information that individually identifies our customers or identifies customer devices in certain circumstances, such as:

to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise permitted by law;
in cases involving danger of death or serious physical injury to any person or other emergencies;
to protect our rights or property, or the safety of our customers or employees;
to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of or subscription to our products and services and to protect our network, services, devices and users from such use;
to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere;
to credit bureaus or collection agencies for reporting purposes or to obtain payment for CLIQA-billed products and services;
to a third-party that you have authorized to verify your account information;
to prospective purchasers of all or part of our business or assets;
to outside auditors and regulators; or
with your consent.

3. Information Provided to or Used by Third-Party Advertising Entities or Social Networks
You may see third-party advertisements on our products and/or the Cliqa App Websites. Some advertisements are chosen by companies that place advertisements on behalf of other third-party advertisers. These companies, often called ad servers, may place and access cookies on your device to collect information about your visit to the Cliqa App Websites. The information they collect from our sites is in a form that does not identify you personally. This information may be combined with similar data obtained from other websites to help advertisers better reach their targeted audiences. Targeting may be accomplished by tailoring advertising to interests that they infer from your browsing of our sites and your interaction with other websites where these ad servers also are present.

If you choose to interact with specific advertisers who advertise on the Cliqa App Websites, the information you provide to them is subject to the conditions of their specific privacy policies. In addition, responding to or interacting with a particular advertisement, may result in you later receiving a targeted advertisement on our websites or on other sites as a result of an ad server or ad network concluding that you fit within a particular audience an advertiser is trying to reach.

The Cliqa App Websites also include social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about the CLIQA page you visit, even if you do not click on or otherwise interact with the plug-in or widget.

How to Limit the Sharing and Use of Your Information
You have choices about how CLIQA shares and uses your Personal Information.

1. Customer Proprietary Network Information (CPNI)
There are additional protections that apply with regard to certain information we collect and maintain about the telecommunications services you buy from us and how you use them. This information is categorized by the Federal government as Customer Proprietary Network Information or CPNI. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. Specific laws govern our sharing and use of CPNI.

You may choose whether to allow CLIQA to share your CPNI within the CLIQA Family of Companies for certain marketing purposes. This choice will remain in effect unless you change it. To opt-out of this sharing contact us at cliqa.developer@gmail.com

2. Do Not Call Lists
Federal “Do Not Call” laws allow you to place residential wireline and wireless phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers. If you would like to add your numbers to this list, you may do so by calling 1-888-382-1222, or by visiting www.donotcall.gov.

You should be aware that even if you add your number(s) to the Federal or a state Do Not Call list, most telemarketing laws allow companies to contact their own customers. If at any time you would like to be removed from CLIQA’s telemarketing list, please let us know by contacting us at cliqa.developer@gmail.com. Please allow 30 days for your telephone number to be removed from any sales programs that are currently underway. Please note that we may still call you regarding your Cliqa App account and Services even if you remove your number from our telemarketing list.

3. Opting Out of Email and Text Marketing Messages
Marketing emails you receive from CLIQA include an unsubscribe instruction usually found at the bottom of the email that you may use to opt out of receiving future marketing-related emails. Text and SMS message solicitations from CLIQA also contain an opt-out feature that you can use to prevent future marketing text and SMS messages from us. Your ability to manage some of our Services could be limited if you withdraw your consent to receive text and SMS messages. CLIQA does not recommend using those Services without authorization to receive such messages.

4. Information Used for Online Advertising
You have choices about whether certain information is collected on the Cliqa App Websites. You can limit the collection of certain website information by deleting or disabling cookies. Most computers’ Internet browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please note that disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

Working Together to Help Keep Children Safe
CLIQA does not knowingly market to or collect information from children under the age of 13 without obtaining verifiable parental consent. If you allow a child to use your device or our Services, you should be aware that their Personal Information could be collected as described in this Policy. We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission. The CLIQA network may not be used by customers in any manner for the storage, transmission or dissemination of images containing child pornography or any other illegal or inappropriate activity involving children and we will report any instances of such activity of which we become aware to the appropriate law enforcement authorities.

Information Security
CLIQA has technical, organizational and physical safeguards in place to help protect against unauthorized access to, use or disclosure of the customer information we collect or store, including your Personal Information. Employees are trained on the importance of protecting privacy and on the proper access to, use and disclosure of customer information. Under our practices and policies, access to Personal Information is authorized only with your consent, in limited circumstances permitted by law and only for those who have a business need for such access. Personal Information and records are retained only as long as reasonably necessary for business or legal purposes. CLIQA secures Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. Personal Information (such as a credit card number) is transmitted to our websites through the use of Secure Socket Layer (SSL) encrypted protection. The Cliqa App Websites are PCI compliant in connection with your credit card information.

Although we work hard to protect the Personal Information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose Personal Information. CLIQA maintains security and incident response plans to handle incidents involving unauthorized access to private information we collect or store. If you become aware of a security issue, please contact us.

Contact Information
If you have questions, concerns or suggestions related to our Privacy Policy or our privacy practices you may contact us at:
CLIQA, Inc.
2828 SW Corbett Avenue ste. 116
Portland, OR 97201
Telephone: 1-888-531-1132
Email: cliqa.developer@gmail.com

Accessing and Updating Your Information
We strive to keep our customer records as accurate as possible. You may correct or update your Cliqa App customer information by calling an CLIQA customer service representative at 1-888-531-1132 or by accessing your account online and providing the updated information there.

Links to and from non-CLIQA Websites and Content
Cliqa App Websites may contain links to non-CLIQA sites. In addition, Cliqa App applications or other content may be included on web pages and web sites that are not associated with CLIQA. We have no control over these non-CLIQA sites and are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms. We recommend that you review the policies and practices of the sites you visit.

Information Sharing: Social Networking
Some CLIQA Cliqa App Websites, applications, and services may allow you to participate in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews. Please be aware that these forums are accessible to others. We urge you to not submit any Personal Information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. CLIQA is not responsible for the information you choose to submit in these forums. If you post content to information sharing forums, you are doing so by choice and you are providing consent to the disclosure of this information.

Your California Privacy Rights
California Civil Code Section 1798 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. As stated in this Policy, CLIQA will not sell or share your Personal Information outside the CLIQA Family of Companies for their direct marketing purposes without your consent.

Changes to This Policy
We reserve the right to make changes to this Policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the beginning of the Policy.

If CLIQA elects to use or disclose information that identifies you as an individual in a manner that is materially different from that stated in this Policy at the time we collected that information from you, we will give you a choice regarding such use or disclosure by appropriate means, which may include use of an opt-out mechanism.