Privacy Statement for Communications Data

Cleveland Group Privacy Policy for Communications Data

Effective Date: November 11, 2024
Last Updated: May 29, 2025

At Cleveland Group we are dedicated to protecting the privacy and confidentiality of our customers’ personal and telecommunications data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information in compliance with applicable laws and regulations in communications.

1. Information We Collect
1.1 Personal Information
We collect personal information that you provide to us, including but not limited to:
• Name, address, phone number, and email address.
• Account preferences and service-related details.
1.2 Telecommunications Data
As part of providing our services, we may collect telecommunications related information such as:
• Call records (e.g., call logs, duration, and timestamps).
• SMS/MMS metadata (e.g., sender, recipient, and timestamp).
• Internet usage data (e.g., bandwidth and service performance metrics).
1.3 Automatically Collected Information
When you use our services, we may automatically collect data such as:
• Device and network information (e.g., IP address, browser type, and operating system).
• Usage logs and service interaction data.

2. How We Use Your Information
We use the information collected for the following purposes:
• To provide, maintain, and improve our telecommunications services.
• To comply with legal, regulatory, and security requirements.
• To troubleshoot technical issues and monitor service performance.
• To communicate updates, promotions, and other service-related information (you can opt out of marketing communications at any time).

3. Information Sharing and Disclosure
We do not sell your personal or telecommunications data. However, we may share your information under the following circumstances:
• With Service Providers: To third parties that help us provide and manage our services (e.g., technical support).
• For Legal Compliance: When required by law, subpoena, or other legal process.
• To Protect Our Rights: To prevent fraud, enforce our terms, or protect Cleveland Groups legal and contractual rights.
• With Your Consent: When you have provided explicit consent for sharing.

Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4. Data Security
Cleveland Group employs robust measures to safeguard your information, including:
• Encryption and secure storage for sensitive data.
• Access controls to limit information to authorized personnel.
• Regular system audits to identify and address vulnerabilities.
While we strive to protect your data, no security system is infallible.
Therefore, we cannot guarantee the absolute security of your information.

5. Your Rights and Choices
You have certain rights regarding your personal information, including:
• Accessing and updating your personal information.
• Requesting deletion of your personal information, subject to our legal and regulatory obligations.
• Opting out of marketing communications.
To exercise these rights, please contact us using the information provided on this page.

6. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, you may contact us at any time.