PROPRIETARY & CONFIDENTIAL
Cellit is committed to revolutionizing the way people think about mobile handsets and brand promotion campaigns used by consumers and businesses. The mobile handset will be one of the primary new, media and communications delivery channels of tomorrow. Towards that end, we have the utmost respect for the consumer’s privacy, and the trusted relationship between brands, wireless carriers and their consumers. To avoid unsolicited messages (e.g. spam), and as part of our privacy policy, Cellit requires that consumers opt-in to marketing programs run by brands using our proprietary campaign management tools. Our business policies and licensing agreements also require that consumers be allowed to opt-out of marketing programs at any time. We want you to be confident that we will not use any information given to us for purposes other than those we communicate to you at the time it is given, and that our customers share this same commitment. To demonstrate our commitment to fair information practices, we have adopted the leading Internet industry privacy guidelines certified by TRUSTe and used by leading brands and carriers, and we are leading the development of new privacy standards applicable to the wireless industry.
Our policy is based on several simple beliefs:
- Consumer protection is at the core of our industry’s sustainability.
- Consumers must opt-in to and have an easy way to opt-out of any promotional campaigns.
- Consumers should be informed through notice of our products, what personal information is collected, and how your personal information will be used.
- Consumers should have an easy option to exercise his/her choice to limit the disclosure of any personal information.
- No information about the consumer should be shared with a third party except in the form of aggregated data for all participants of a given promotion, unless the consumer has given their explicit consent.
- Information about consumers should be accurate and maintained in secure systems.
- Consumers should be able to communicate with specific participating brands and us quickly and easily if you have any concerns. We will keep consumers informed through this site of any changes to our Policy.
These beliefs are reflected in Cellit’s contractual restrictions with our licensees, the technical controls we have established in our campaign management software, the industry initiatives we have under way to lead best practices, and our internal business principles. These business principles focus on the consumer’s right of choice to participate, right to control the decision to stop participating, right to customize the type of messages received, and the right to receive relevant value for participating in promotional campaigns.
Consumer Opt-in
It is Cellit’s policy that to participate in a program a consumer must explicitly opt-in to that program. Cellit provides three ways to opt-in. First, in response to an advertisement, a consumer can send an SMS message to an Cellit phone number as part of a program promotion. Second, a consumer can call a voice response unit that will link to Cellit’s messaging platform indicating their willingness to participate. Third, a consumer can register on a customer’s brand Web site that links to our messaging platform. In each case the cell phone number of the consumer is registered within our messaging platform as interested in participating in a particular marketing program, or as a part of an on-going program (e.g. Loyalty or points based programs).
Consumer Opt-out
It is Cellit’s policy that just as a consumer should opt-in to a marketing campaign, they have the right to opt-out of a particular program. Our messaging platform manages consumer opt-out requests on a global or on a per-brand basis. Cellit provides three ways for a consumer to opt-out. First, a consumer can reply to an SMS marketing message requesting opt-out. Second, a consumer can call a brands administrator and ask to be removed. Third, a consumer can call Cellit’s (800) helpline, which can be found by replying HELP to any message they have received, and ask a customer service representative to be removed. Our platform manages consumer opt-out requests on a global basis and is shared with all participating parties. When a consumer chooses this third option, he or she will no longer receive any messages unless they were to opt-in again using one of the mechanisms identified above.
Gathering Personal Information
Cellit might gather some personal information specific to participating in promotional campaigns. The information requested may include contact and demographic information. Information you supply is voluntary and will relate to the relationship Cellit has with you or your organization and will be only requested to the extent it is necessary to provide the services you have requested. Cellit may also log IP addresses and phone numbers to analyze trends, administer the site, track visitor movements, and gather broad demographic information for aggregate use; provided, that such use is for internal purposes of Cellit or its affiliates or partners only.
Using Personal Information
If you do choose to give us personal information related to participating or not participating in promotional campaigns we will let you know how it will be used. For instance, we may use the data to make our services more relevant to you or to notify you of information and offers you may be interested in. You should know that when you sign-up or use any of our services we may use information about who you are, where and when you respond to promotions, where your wireless device is located, and how you use our network, or other information as described in this Policy. Cellit employs a unique message throttling mechanism within our platform. Since the consumer brand or company owns the consumer data, they may have collected cell phone numbers from a number of sources.
Sharing Personal Information
Cellit may share aggregated, non-personal, non-individual information collectively with its marketing partners for research purposes only. We will not share individual information regarding transactions or participation in promotional programs with any third party. We will not sell or disclose your personal information to third parties without your consent or as otherwise provided in this Policy.
Storing Personal Information
Cellit insures that Personal Information is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.
Cellit will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.
We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.
Cookies
A cookie is a piece of data stored on the user’s hard drive containing information about the user. Some Cellit branding customers’ web pages may use cookies or other technologies so that they can better serve you when you return to their site. Usage of a cookie is in no way linked to any personally identifiable information while on their site. Cellit does not use cookies on its own web site.
Consent
We reserve the right to disclose any and all pertinent customer information to law enforcement or other government officials, as we believe necessary or appropriate.
Security
To help prevent unauthorized access or disclosure of visitors’ information, maintain data accuracy, and to help with the appropriate use of the information, Cellit has put in place reasonable physical, electronic, and managerial procedures to protect the information we collect from the site and participation in our mobile promotions. These procedures are designed to provide:
- Security of our service (e.g. firewalls, anti-virus software, etc).
- Protection of subscriber data that we maintain.
- Protection from fraudulently benefiting from the participation in promotions and contests.
- Protection from receiving unwanted messages.
Your Acceptance
By using the Cellit site and participating in our mobile promotions, you signify your understanding and acceptance of this Privacy Statement. If we decide to change our privacy policy, we will post those changes on www.Cellit.com so you are always aware of what information we collect, how we use it, and under which circumstances, if any, we disclose it. Your continued usage of the Cellit site and our mobile promotions following the posting of additions and/or changes to this Privacy Statement means you accept those changes. If users have questions or concerns regarding this statement, they should first contact the Cellit privacy team at privacy@Cellit.com. Or they can send mail to: Cellit, Attn: Privacy Council, 213 W Institute Place, Suite 603, Chicago, IL 60610. They can also call us at 800-790-6597 or FAX us at 866-856-3936. If they do not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process. TRUSTe will serve as a liaison with the Web site to resolve users’ concerns.
Mobile Marketing Code of Conduct
Cellit believes that the key to a thriving, long-term mobile marketing industry creating value for brands and carriers is the active, zealous protection of consumer interests, rights, and privacy. With this in mind, Cellit operates according to the following Code of Conduct, and asks the same of its clients, business partners, and responsible fellow providers:
- Choice – As the proliferation of unsolicited promotional messages (or “SPAM”) to mobile devices is unacceptable to consumers, carriers, and responsible brands; consumers must be asked to register for (or “Opt-in” to) all mobile marketing programs delivered through the Cellit Studio Mobile Marketing Platform. Consumers may opt-in to a program by sending an SMS, calling a voice response unit, registering on a Web site, or through some other legitimate paper-based method.
- Control – Consumers must also be allowed to terminate their participation in an ongoing mobile marketing program (or “Opt-out”) through channels identical to those through which they can Opt-in to a given program. In addition, Cellit will work with mobile carriers to provide a “blanket opt-out” for consumers undesirous of any mobile marketing communication.
- Customization – As mobile marketing campaigns are most effective and efficient when appropriately targeted, consumers will be asked to provide demographic, offer preference and other information. All “follow on” offers targeted at an existing Opt-in universe will be encouraged to use this data to optimize message volumes, offer redemption rates, and return-on-investment.
- Consideration – The consumer must receive and/or be offered something of value to them in return for receiving the promotional communication of a brand. Value may be delivered in the form of sweepstakes, contests, information, entertainment or discounts.
- Constraint – Cellit will provide a global “throttling mechanism” capable of managing the number of messages received by an individual consumer. The purpose of the throttle is to effectively manage and limit mobile marketing programs to a reasonable number of programs, defaulted to 3 per day. Consumers will have the option to override the throttle through an additional Opt-in available through the standard channels.
- Confidentiality – Cellit does not rent, sell or share personal information about Consumers participating in programs delivered through its platform with other people or nonaffiliated companies except to provide the products and services requested. We may share aggregated, non-personal, non-individual information collectively with marketing partners for research purposes only. All Cellit customers are subject to the terms and conditions of our Privacy Policy, which is aligned with the individual policies of our carrier partners.