Privacy Policy

U2opia Mobile Pte. Ltd. having its registered office at 10 Jalan Besar, #10-02 Sim Lim Tower, Singapore-208787 & owns and operates the service with the brand name of “Message Central”, (the “Service(s)”).

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We know your privacy is important to you, and we want you to know it’s important to us too. This Privacy Policy is meant to explain our practices when it comes to your use of our products, services, and websites. We encourage you to take the time to review it carefully, to understand what information we collect, why we collect it, and what we do with it. Below, we cover the following topics:

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Who we are

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U2opia Mobile Pte. Ltd., including its affiliates, (“U2opia,” “we,” “our”) is a global provider of cloud communications that offers various services. For our business and customers, we offer a complete and fully-configured unified communications solution for the delivery of end-to-end communications via text, mobile applications, and collaboration tools. We also provide our communications services in programmable modules delivered via APIs and SDKs, enabling our customers to incorporate these services into their own applications to serve their own customers.

This Privacy Policy applies to our customers, prospective customers, our customers’ customers (both direct and indirect), job applicants, current and former employees, contractors, visitors to our company websites, and recipients of our e-mail communications.

When you use our websites or our services, you acknowledge and understand that U2opia will collect, use, and share your information, as we describe in this Privacy Policy. Note: if you’re a user of an application that is integrated or built using U2opia’s products and services, that application’s privacy policy will describe how it collects, uses, stores, and shares your data. We are not responsible for the privacy policies or actions of our customers or business partners.

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What information we collect

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We collect your information in the following ways:

• Information you provide directly to us. When you subscribe to our newsletters, register for one of our webinars, sign up for our services, request us to contact you, or through other interactions with us, we may ask you for certain personal information that identifies or is linked or reasonably linkable to you (“Personal Data”), such as your name, postal address, e-mail address, telephone number, company name, job title, or payment information, as well as non-Personal Data. For instance, and without limitation:
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  -   When you request support from us, we may also collect information from you, including Personal Data, such as contact information, documentation, screenshots, or other information you or we may believe is helpful to solving the issue.
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  -  When you speak with our customer service or sales representative on the phone, your calls may be recorded and/or monitored for quality assurance, training and research purposes.
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  -   In certain circumstances and depending on the country where you reside, we may collect your Social Security number from you for a limited purpose, such as for tax reporting relating to a payment for a customer referral or to facilitate an international money transfer.
• Information we collect automatically when you visit our websites. We, our vendors and third-party services, such as our advertising and analytics providers, collect information about your visits to our websites and your interactions with our ads or content, together with information such as your IP address, location, cookies, and other tracking technologies (e.g., web beacons, device identifiers, pixels, and cross-device tracking).
• Information we get from third parties. Third party sources of information include, without limitation:
  
  -  Third party services and social media. If you create an account or access our services through your account with a third-party service, such as Facebook, Google, LinkedIn, GitHub or Twitter, or use a social media feature through our services, certain Personal Data and other information from those third-party social media services may be shared with us, such as your interests, “likes,” and friends list. We may use this information we receive from them, for example, to personalize your U2opia experiences and marketing communications, to enhance our services, and to better serve you. Some third parties enable you to control this data sharing via options in your social media accounts. We may also collect information from third party services that are integrated with our services, such as third-party CRMs or other applications that you authorize our services to connect with. The privacy policies of third party services, and not this Privacy Policy, govern those third parties’ practices and services. This Privacy Policy only governs our receipt of Personal data from them.
  
  -  Consumer reporting agencies. We may obtain your credit information from third party reporting agencies in order to control our own credit risk in onboarding new customers.
  
  -  Demographic, lead, and interest data. We may obtain Personal Data and other information from outside companies such as those that collect customer information including demographic and interest data. Examples of this information include your employment status, your job title with your current employer, and your business contact information. We may use this data and combine it with other information we have about you, for example, to help us predict your preferences and to direct marketing offers that might be more relevant to you. We also obtain where permitted by law contact information and other marketing lead information from third parties, website “refer-a-friend” options or social media platforms and may combine it with information we have, for instance, to contact you or direct U2opia marketing offers to you.
• Information about our customers’ users. Our customers and other third parties may also provide us with Personal Data and other information about our customers’ users and others. For example, we may receive Personal Data and other information from our customers, message senders, mobile network operators, databases with information relevant to mobile telephone numbers submitted to our services, and other third parties. This information may include, without limitation, telephone numbers, telephone numbers’ validity, type (e.g., mobile, landline, etc.), corresponding device status (e.g., whether or not it is currently available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported and is used, for instance, to help us provide our services.
• Information collected in connection with your use of services delivered via our platform. We and our service providers may collect Personal Data and other information in connection with your use of communications services delivered via our platform, including, without limitation:
  
  -  Communications usage information. This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination identifiers, from/to phone numbers, completion status, location, IP address, and amount of usage.
  
  -  Communications content. To enable you to send and receive communications via our platform, we need to be able to handle the content of the messages, calls, and other communications channels used by you. This also includes, for example, , messages recorded via our services.
  
  -  Device information. We use the device information we collect in order to deliver and improve our services. Device information is also collected when you visit our websites.

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Why we collect your information and how we use it

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How we use the information we collect depends on the nature of the data, which of our services you use, how you use them, and specific preferences you may have communicated to us. We reserve the right to collect, share and otherwise use non Personal Data for any purpose except where limited by applicable law, and to create non-Personal Data from Personal Data in order to do so. We list below the specific purposes for which we collect, use and otherwise process your Personal Data:

• To deliver our services. We use your Personal Data and other information as necessary to perform our obligations in delivering our services to our customers. This includes delivering your communications to the intended end user, processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, and operating and maintaining our services. We also need your information to communicate with you about the services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.
• To carry out core activities relating to our services. To effectively deliver our services to you, we use your Personal Data and other information to engage in important supporting activities such as:
  
  -  Billing and collections, including maintenance of records in the event of a subsequent billing dispute;
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  -  Preventing fraud, violations of our acceptable use policies, and unlawful activities;
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  -  Troubleshooting, quality control, and analytics; and
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  -  Monitoring the performance of our systems and platform.
• For research and development. We are constantly looking for ways to improve our services, to make them more reliable, secure, and useful to you and our users generally and we may use the Personal Data and other information we collect to help us do so. For instance, we use data regarding our users’ communications on our platform to understand how our services are performing and how they are being used in order to identify areas where we can do better. For instance, we may use message delivery information to gauge the effectiveness of our routing to ensure that your messages are delivered.. We and our service providers may use your information, including information obtained through customer surveys, to assess the level of interest in, and use of, our services, our communications to our customers, and our other messaging campaigns, both on an individual basis and in the aggregate. Surveys are optional and customers can opt-out from receiving such surveys via opt out links in survey invitations. We also use information about your use of our websites to understand how our website visitors are using our websites. Among other things, this usage information, along with tracking technologies, enables third-party analytics companies to generate analytics reports on the usage of our services.
• To improve our services and develop new services. We use your data in the provision of the services. We also use data we collect in existing services to improve and develop new services.
• To market, promote, and drive engagement of our products and services. We use Personal Data and other information about you to send promotional communications, such as e-mail messages, text messages, phone calls, faxes and postal mail, and for marketing when we have an adequate legal ground to do so. When prior opt-in consent is required by applicable laws, we will obtain such consent. We do not send marketing communication to our customers’ customers who are end users. Based on information we collect about you, we may decide whether and how to promote certain of our products or services to you over others. These communications are to drive your engagement and maximize the value of our services to you, and to help you receive more relevant information from us. To perform the above functions and others described in this Privacy Policy, we may match information collected from you through different means or at different times, including Personal Data and usage information, and use such information along with information obtained from other sources (including third parties) such as contact information, demographic information, and personal interest information. Where local law permits, an auto-dialer and/or artificial or pre-recorded message may be used to make calls to you. Consent on behalf of someone else or provide someone else’s contact information will not be accepted. You are not required to agree to promotional communications in order to purchase goods or services from us. You can control whether you receive these kinds of communications as described below in Opt out of communications.
• To comply with legal requirements. Applicable laws or regulations may require our processing of your Personal Data and other information, such as laws mandating retention of communications data, including disclosures required by law or legal process.
• To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights and interests, or the interests of others, we use Personal Data and other information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

According to your explicit consent. If we wish to use your Personal Data for certain purposes which require consent under applicable law, we will first seek out and obtain your consent. This may include, for example, testimonials or case studies that identify you in your individual capacity.

Who we share your information with and why

We reserve the right to collect, share and otherwise disclose non-Personal Data for any purpose except where limited by applicable law, and to create non-Personal Data from Personal Data in order to do so. We may share your Personal Data and other information as detailed below:

- Third-party service providers that help us to deliver the services and allow us to operate our businesses.

• Communications providers: As the provider of a communications platform, we share the data we collect from you with communications providers (including traditional PSTN telecommunications companies and over-the-top communications service providers) as necessary in order to provide you with the services. These are the telecommunications companies, for instance, who we need to ensure your calls, messages and other communications reach the people you want to contact.
• Payment gateways: In the provision of conversational commerce services, we use payment gateways as necessary in order to provide you with the services. These are payment gateways companies that ensure the payment is completed in relation to conversational commerce services.
• Business operations vendors: We work with third-parties to help us run our business, such as to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, marketing and advertising, and other services for us, which may require them to access or use Personal Data and other information about you. We only work with carefully selected vendors, and take reasonable efforts to protect your Personal Data that they process for us.
• Partners: In the event that you purchase services offered by U2opia or a partner through a special marketing arrangement (for example, through a co-branded advertisement or offer, or an arrangement where we and a partner market or offer the other’s products or services), we may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.
• U2opia events: If you attend a U2opia event, we may also share any information that you have submitted to us with a third party business partner. We will always disclose to you the name of the business partner with whom we intend to share the information and obtain your prior opt-in consent to do so.
• Third party services: Our services and websites may include links or other tools (e.g., plug-ins, “like” and share buttons, SDKs, etc.) that direct you to other websites or services whose privacy practices may differ from ours. If you submit Personal Data or other information to any of those third parties, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any third party with which you interact.
• Compliance with law enforcement requests and applicable laws; enforcement of our rights. We may disclose Personal Data and other information as required by applicable law, regulation, legal process or government request; to protect U2opia, our services, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms. If U2opia receives a civil or criminal subpoena, warrant, or other official and written request that is legally binding (“Request”) by a public authority for disclosure of personal data, U2opia will promptly notify the customer to the extent U2opia is not precluded from doing so by the Request. In the event that the information must be provided, U2opia will (a) ensure that the disclosed Personal Data is the minimum required to satisfy the Request; and (b) take all commercially reasonable steps to ensure that such personal information is afforded confidential treatment by the authorities.
• With your explicit consent: We share Personal Data and other information about you with third parties when you give us consent to do so. For example, we often display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity. If you are a business customer, and have requested this, your business name and phone number may be included in public directories.
• Sharing with senders and recipients of communications: The name on your account, or a portion thereof, and/or your phone number may be displayed to people that you make calls to and to other users of the services so that they may contact you. Depending on the service you’re using, you may be able to control what’s displayed by adjusting your settings within the mobile app or your customer account, or by contacting customer care at the address provided when you signed up for the services.
• U2opia affiliates; business transactions: We share your Personal Data and other information with and among our corporate affiliates, for instance in order to operate and improve the services we provide to you; and we may share your information in connection with a sale, merger, financing, liquidation, or reorganization of our business or assets.
• Credit control: When permitted by applicable laws, we obtain credit reports on new customers in order to evaluate customers for the risk of non-payment. In the event of non- or late payment, we may furnish your name, address and other details to credit bureaus and other consumer reporting agencies. They may include that information in preparing credit reports and use that information in calculating credit scores provided to their customers.

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How we protect your information

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U2opia has implemented administrative, physical, and technical safeguards to help protect the Personal Data that we transmit and maintain. Those measures are heightened for sensitive data such as Social Security numbers and payment account numbers. However, no system or service can provide a 100% guarantee of security, especially a service that relies upon the public internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your Personal Data and other information. Keep your account password secret and please let us know immediately if you think your password was compromised. Remember, you are responsible for any activity under your account using your account password or other credentials.

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Where we store your information and international transfers

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Personal information held by U2opia is stored on and processed on computers situated in the UK, the EEA, the United States, and in other jurisdictions. We and/or our service providers also process data in some other countries for customer care, account management and service provisioning.

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How long we store your information

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We store your information until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected. This time period may vary depending on the type of information and the services used, as detailed below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. We may also retain aggregate, de-identified or anonymized information beyond this time for, among other uses, research purposes and to help us develop and improve our services. We will take measures to prevent reidentification de-identified information retained or used for these purposes consistent with applicable law, and will not make efforts (or authorize others to make efforts) to re-identify it.

• Customer account information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the services, or for so long as we need to retain it for legitimate purposes, such as to collect debts, o comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our services.
• Communications usage information. While you’re an active customer, we retain the communications usage information generated by your use of the services until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our services.
• Marketing information, cookies and web beacons. If you receive marketing e-mails from us, we retain information about your e-mail marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an e-mail from us or visited our websites. We also retain information regarding your giving or removal of consent as business records and to honour consent choices. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
• Device information. We collect device-specific information from you when you have installed our software on your device. If you do not revoke our access to this information via the privacy settings on your device, we will retain this information for as long as your account is active.

Notwithstanding with the above and the fact that we will generally store your personal data until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected, please note that we may also retain your information for a longer period of time to defend and/or protect our legal or business interests during the applicable statute of limitation period or as otherwise required by law, court order, or other applicable regulation.

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How to access and control your information

• Your choices. To request deletion of your U2opia account, please contact our support team or contact us at the contact information provided in this notice. You should know that deletion of your U2opia 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 U2opia’s servers in an aggregated or anonymized form that does not specifically identify you, or as otherwise noted above in the prior section. For instance, data associated with your account that we are required by law to maintain will also not be deleted. If you are an end user of an application that uses U2opia’s services, you should direct requests for access and/or deletion of your data associated with that application to the relevant application provider in accordance with that application provider’s own privacy policy.
• Access to your account information. Consistent with applicable laws and data security requirements, we will reasonably honour written requests from you, to access or amend your account information, such as name, address, and billing information. You are responsible for ensuring that the information on file with U2opia is current and accurate. You may access and update your account information by logging into your account or contacting us as described in this Privacy Policy. Where permitted by law, we may charge a reasonable fee to process requests for access to data and may limit the number of requests per year. Your right to amend your information is subject to our records retention policies.
• Opt out of communications. You may opt out of receiving promotional communications from us by using some or all of the following methods: the unsubscribe link within each e-mail, updating your e-mail preferences within your service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional e-mail list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our services. Depending on your type of account with U2opia, you may be able to opt out of some notification messages in your account settings.
• Device information. We collect device-specific information from you when you have installed our software on your device. If you do not revoke our access to this information via the privacy settings on your device, we will retain this information for as long as your account is active.

Mobile Information

• No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. However, U2opia will exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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Contact information

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If you have questions or complaints about U2opia’s privacy practices and/or this privacy policy, we would like to help resolve your issue so please contact us at:

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Email address: operations@messagecentral.com

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Or write to us via post to:

U2opia Mobile Pte. Ltd. 10 Jalan Besar, #10-02 Sim Lim Tower, Singapore-208787

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Other important information

• Information from children. U2opia does not sell products or services for purchase by children, and we do not knowingly solicit or collect personal data from children or teenagers under the age of eighteen. If you believe that a minor has disclosed personal data to U2opia, please contact us at operations@messagecentral.com
• Changes to this policy. In the event we make changes to this Privacy Policy, we’ll let you know by posting a notice on our website at https://cpaasbucket.s3.ap-south-1.amazonaws.com/Privacy%20Policy.pdf and, in relation to substantive changes that broaden the types of personal data collected or their usage, we not apply the new policy to Personal Data collected under an inconsistent prior policy without notice.

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Use of CAPTCHA

Our website and service platforms use CAPTCHA, (“Completely Automated Public Turing test to tell Computers and Human Apart”), which are tools used to distinguish between real and automated users, such as bots. CAPTCHAs sometimes pose tasks that are easy for humans but difficult for computers to solve, or sometimes run virtually invisible to the user. Some data may be collected and shared with Google such as:

• Browser cookies
• IP
• Operating system
• Mouse movements and keyboard strokes
• Length of pauses between actions
• Device settings (e.g. language or location),