Privacy Policy

CGM, LLC understands that privacy is important, and it is committed to protecting the privacy of its customers, visitors to its websites, and users of its mobile applications. Please carefully review this Privacy Policy.

This Privacy Policy is designed to help you better understand the information that CGM gathers from its websites and mobile applications; how it handles the information once gathered; whether it discloses the information to anyone; and the choices you have regarding CGM’s use of, and your ability to correct, the information CGM gathers.

This Privacy Policy applies only to CGM’s websites and mobile applications—not to other companies, organizations, services, websites or mobile applications. Other companies, organizations, services, websites or mobile applications may have separate privacy policies—please refer to those privacy policies. By visiting CGM’s websites and/or using CGM’s mobile applications, you acknowledge that this Privacy Policy is part of CGM’s Terms of Use, and by accessing or using CGM’s websites and/or using CGM’s mobile applications, you agree to be bound by all terms and conditions in this Privacy Policy. If you do not agree to these terms, please do not access or use CGM’s websites and/or mobile applications.

CGM reserves the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, issuing an email to the email address listed by registered users and posting the revised Privacy Policy. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered user, review this Privacy Policy periodically, and be aware of any modifications. Your continued use of CGM’s websites and/or mobile applications after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by the modified Privacy Policy.

Types of Information Collected

In order to better provide you with CGM’s services, CGM collects different types of information, including the information identified below, about its users. CGM’s primary goal in collecting this information is to provide you with a smooth, efficient, and customized experience while using CGM’s websites and mobile applications.

Non-personally Identifiable Information. This refers to information that does not, by itself, identify a specific individual. CGM gathers certain information about you based upon your use of CGM’s websites and mobile applications in several ways. This information is compiled and analyzed on an aggregate basis. This information may include the Uniform Resource Locator (“URL”) that you visited before visiting CGM’s website, the URL that you visit after leaving CGM’s website, the browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web (“WWW”). An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the WWW. Networks like the WWW use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer or mobile device whenever you are surfing the WWW, which allows WWW servers to locate and identify your computer or mobile device. Computers and mobile devices require IP addresses in order for users to communicate on the internet. This collective data helps CGM develop and improve its websites and applications. It also helps CGM conduct internal research on its customers’ demographics, interests, and behavior in order to better understand and serve them.

Personally Identifiable Information. This refers to information that lets CGM know the specifics of who you are. When you engage in certain activities on CGM’s websites and/or mobile applications, such as logging into your account, opening a customer support ticket or contacting CGM to request information, CGM may ask you to provide certain information. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, CGM may ask that you provide personal information, such as your first and last name; your birthdate; either your full Social Security Number or the last four digits of your Social Security Number (depending upon your state of residence); your mailing address, email address, and/or phone number; your company (if applicable); the benefits you receive from qualifying programs and the dates associated with the same; proof of your identity; and/or other personal identifying information. When ordering products or services on CGM’s websites or website applications, you may be asked to provide a credit card number. Depending upon the activity, some of the information CGM asks you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

Username and Password. To activate and manage your account and obtain access to certain web-based and/or mobile application-based services, CGM requires you to select a username and create a password. When using your account and/or providing your password, you must provide accurate and complete information to CGM. You are entirely responsible for maintaining the confidentiality of your password and are solely responsible for any activity conducted using your password. You agree not to use the account, username, or password of any other customer at any time.

Location Information. CGM may also collect location information, which may include your ZIP-code and street address, as well as the whereabouts of your mobile device. Location information is generated when your mobile device communicates with cell towers, W-Fi routers or access points and/or with other technologies, including the satellites that comprise the Global Positioning System.

Customer Proprietary Network Information. Customer Proprietary Network Information (“CPNI”) is personally identifiable information related to a subscriber’s use of your network (i.e., call detail information) and information contained within your subscribers’ bills. CPNI does not include directory information such as name, mailing address, or telephone number. As CGM provides telecommunications products and services to you, CGM may obtain from you information about the quantity, technical configuration, type, location and destination of telecommunications services you provide to your customers, as well as some other information found on your customer bill/invoices. This information may constitute CPNI, as defined by federal law. Any CPNI that CGM collects from you will be handled in accordance with federal law, CGM’s internal CPNI policy and this Privacy Policy. Under federal law, you have the right and duty to protect the confidentiality of your customers’ CPNI.

Information collected from other sources. CGM may obtain personal information about you from other sources, including from commercially available sources such as data aggregators and public databases, as well as from CGM’s affiliates. This information may include your name, demographic information, interests and publicly-observed data, such as from social media. CGM may combine this information with the information we collect from and about you to help CGM tailor its communications to you and to improve its services and products.

Collection Methods and Use of Information

Third Party Providers: CGM may use third party providers to facilitate its services, and therefore, may provide some of your personally identifiable information directly to them. In addition, CGM employs other companies and individuals to perform work on its behalf. These service providers have access to personally identifiable information and may use it as needed to perform their functions, but may not use it for any other purpose, except that they may aggregate your personally identifiable information with similar information from other customers in a manner that does not potentially identify you. CGM will encourage its service partners to adopt and post privacy policies. However, the use of your personally identifiable information by CGM’s service partners is governed by the privacy policies of those service partners, and is not subject to CGM’s control.

Cookies: Cookies are small files placed on your hard drive; each website can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You are free to decline CGM’s cookies if your browser permits, although in that case, you may not be able to use certain features on CGM’s websites and/or mobile applications. Alternatively, a number of companies not related to CGM offer utilities designed to help you visit websites anonymously.

Cookies assist CGM in providing customized services and can also help it provide information that is targeted to your interests. CGM also uses cookies to remember you when you “sign in” to its websites and/or mobile applications, so that CGM can provide you with customized content. CGM’s cookies do not combine information collected through cookies with other personally identifiable information. CGM uses two kinds of cookies. Each time you log on to any of CGM’s websites or mobile applications, CGM uses a “session cookie,” to help it remember you until the earlier of approximately 60 minutes or the closing of your browser and to help make sure that you remain logged in to the website and/or mobile application. Session cookies are automatically deleted from your hard drive at the end of a session. CGM also uses “persistent cookies,” which enable CGM to aggregate certain non-personally identifiable usage data in ways that help CGM to improve its services. Additionally, you may encounter cookies or other similar devices on CGM’s websites or mobile applications that are placed by third parties. CGM does not control the use of cookies by third parties, including third party websites to which CGM may link.

CGM uses Google Analytics and/or other third party analytics companies to help analyze how customers use its websites and mobile applications through the use of cookies. The information generated by the cookie about your use of our websites and/or mobile applications (including your IP address) is transmitted to and stored by these analytical partners. This information is used for the purpose of evaluating your use of our websites and/or applications, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. These analytical partners may transfer this information to third parties where required to do so by law, or to third parties that process information on their behalf.

Requests from Law Enforcement or Judicial Authorities: CGM may be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities. CGM will disclose personally identifiable information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. CGM fully cooperates with law enforcement in identifying those who use CGM’s services for illegal activities. CGM reserves the right to report to law enforcement agencies any activities that it believes, in good faith, to be unlawful.

Acquisition or Merger: If CGM is acquired or merges with other business entities, CGM may share some or all of your personally identifiable information to continue to provide service. You will receive notice of any such event (to the extent it occurs), and all entities will follow the practices disclosed in this Privacy Policy or notify you of any changes.

Updating and Correcting Information/span>

CGM believes you should have the ability to access and edit the personally identifiable information that you have provided. You may change any of your personally identifiable information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this website and/or mobile application. You may also access and correct your personal information and privacy preferences by contacting us at:

CGM, LLC

101 Vickery Street

Roswell, GA 30075

888.594.3860 (tel.)

770-594-3878 (fax)

ecphelpdesk@cgminc.com

Please include your name, address, and/or email address when you contact us.

CGM encourages you to promptly update your personally identifiable information if it changes. You may ask to have the information on your account deleted or removed; however, because CGM keeps track of past transactions, you cannot delete information associated with past transactions. In addition, it may be impossible to completely delete your information without some residual information because of backups.

California Privacy Rights

Pursuant to California Civil Code Section 1798.83 (the “Shine the Light” law), California consumers are entitled to request information concerning whether a business has disclosed personal information to any third parties for that business’s direct marketing purposes. California residents may request the categories of personal information shared with third parties during the previous calendar year, if any. To make your request for information or to opt-out, please contact us at the address, phone number, fax number and/or email address above. CGM will not disclose your personal information to third parties for use in their direct marketing to you, without your consent.

The Children’s Online Privacy Protection Act of 1998

CGM is concerned about the safety and privacy of children who use the WWW. Pursuant to the Children’s Online Privacy Protection Act of 1998, CGM will never knowingly collect personally identifiable information from anyone under the age of 13 without prior verifiable parental consent and may limit participation in certain services CGM provides to individuals over 13 years of age. A customer must be 13 in order to retain CGM’s services. If CGM becomes aware that a child under the age of 13 has or has attempted to provide it with personally identifiable information, CGM will use its best efforts to remove such information from its files. If a parent or guardian becomes aware that his or her child has done this, he or she should contact CGM at the address, phone number, fax number and/or email address above.

Security of Information

CGM uses standard industry practices to safeguard the confidentiality of your personally identifiable information. The security of your personally identifiable information is of CGM’s utmost concern. Your personally identifiable information is protected in several ways. Access by you to your personally identifiable information is available through a username and password selected by you. This password is encrypted. CGM recommends that you not share your password with anyone. In addition, your personally identifiable information resides on a secure server that only selected CGM personnel and contractors have access to via password. CGM encrypts your personally identifiable information to prevent unauthorized parties from viewing such information when it is transmitted.

Non-personally identifiable information also resides on a secure server and is only accessible via password. Since this information is not accessible from outside CGM, you will not be asked to select a password in order to view or modify such information.

To the extent available, and in order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process your order.

Unfortunately, no data transmission over the WWW or any wireless network can be guaranteed to be 100% secure. As a result, while CGM strives to protect your personally identifiable information, you acknowledge that: (a) there are security and privacy limitations of the WWW, which are beyond CGM’s control; (b) the security, integrity and privacy of any and all information and data exchanged between you and CGM through this website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

Other Privacy Issues

If you have any questions about this Privacy Policy, the practices of this website, or your dealings with this website, please contact us at the address, phone number, fax number and/or email address above.