Privacy Policy

Updated February 2, 2022

JMZ Corporation d/b/a KwiKom Communications (“KwiKom”) knows Customers care about how their personally identifiable information (“Personal Information”) is used and shared, and KwiKom takes Customers’ privacy seriously. Please read the following to learn more about KwiKom’s Privacy Policy. By using the Service (as defined in the Terms and Conditions of Service) or accessing KwiKom’s website in any manner, Customer acknowledges that Customer accepts the practices and policies outlined in this Privacy Policy, and Customer hereby consents that KwiKom will collect, use, store and share Customer’s Personal Information in the following ways.

Remember that Customer’s use of the Service is at all times subject to Terms and Conditions of Service, which incorporates this Privacy Policy by reference. Any capitalized terms not defined in this Privacy Policy will have the same meaning as defined in Terms and Conditions of Service and Acceptable Use Policy.

Kwikom Services are designed and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. If Customer is not a U.S. citizen or does not reside in the U.S., Customer voluntarily consents to the collection, transfer, use, disclosure and retention of Customer Personal Information in the U.S. Customer also agrees to waive any claims that may arise under Customer’s own national laws.

When Customer uses the Service, the Personal Information (as defined below) Customer sends and receives is transmitted over a wireless, and/or wired network, and may be subject to interception by unauthorized third parties who seek to do you harm. While it is KwiKom’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Customer sends and receives through the Service, KwiKom cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.

KwiKom recommends that you use caution when sending any Personal Information over the Internet and use encryption technology whenever possible, such as websites that have the “https” designation in the website’s address bar and show a padlock icon in the browser’s window.

KwiKom does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Customer is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to KwiKom. If KwiKom learns that KwiKom has collected Personal Information from a child under age 13, KwiKom will delete that information as quickly as possible to the extent technically feasible. If Customer believes that its child under age 13 may have provided KwiKom Personal Information, please contact KwiKom at privacy@kwikom.com.

What types of information does this Privacy Policy cover?

KwiKom collects and stores various types of information about Customers and Customers’ use of the Service via the KwiKom website, Help Desk and call centers, postal mail, remote kiosks, the KwiKom Facebook Page or other social network platforms or by other means, generally classified as Personal Information and Non-Personal Information. Generally, KwiKom gathers and uses Personal Information internally in connection with providing the Service to Customer, including to personalize, evaluate and improve the Service and KwiKom’s ability to provide the Service to Customer, to contact Customer, to respond to and fulfill Customer requests regarding the Service, and to analyze how Customer uses the Service. KwiKom may share Your Personal Information with its Affiliates and with other third parties as described below:

What Information does KwiKom collect and how does KwiKom use this Information?

Personal Information

Personal Information is the information Customer provides to KwiKom voluntarily or passively through Customer use of the Service and/or website, and which is directly associated with or reasonably linked to a specific person, computer or device. For example, through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Customer’s premises, when Customer contacts KwiKom regarding the Service, and through Customer account settings, KwiKom collects and stores Personal Information such as Customer name, email address, phone number, billing address and billing information (such as credit card account number or other financial account information), service address, and the nature of any of Customer devices or other property making use of the Service. Customer may be required to provide certain Personal Information to KwiKom in order to register with KwiKom, to assist KwiKom in improving Customer’s Service or troubleshooting problems Customer is experiencing with the Service, Customer computer or device, or otherwise to improve the quality of the Service. KwiKom will communicate with Customer if Customer has provided KwiKom the means to do so. For example, if Customer has given KwiKom Customer’s email address or phone number, KwiKom will email or call Customer about Customer use of the Service or product improvements or upgrades, and other transactional information about Customer Service. KwiKom may also combine Customer Personal Information with additional Personal Information obtained from KwiKom Facebook Pages or other social network platforms, its Affiliates, its Operational Service Providers (third party owned companies that provide or perform services on KwiKom’s behalf, to help serve Customer better and to perform functions in order to support KwiKom businesses and operations), or other companies, such as credit bureaus, background check firms, and marketing research companies. Some forms of Non-Personal Information as described below will be classified as Personal Information if required by applicable law or when such information is directly associated with or reasonably linked to a specific person, computer or device, or is combined with other forms of Personal Information.

Non-Personal Information

Website Information, Use of Cookies and other Similar Tracking Technology

When you visit KwiKom’s website, KwiKom will collect various types of Non-Personal Information, such as information on KwiKom server logs from Customer’s browser or device, which may include Customer IP address, unique device identifier, “cookie” information, the type of browser and/or device you’re using to access the Service, and the page or feature Customer requested. (IP Address and device identifiers are traditionally classified as Non-Personal Information, unless KwiKom is required to do so otherwise under applicable law.) Cookies” and “web beacons” are text file identifiers KwiKom transfers to Customer’s browser or device that allow KwiKom to recognize Customer’s browser or device and tell KwiKom how and when pages and features on the KwiKom website are visited, by how many people, and other activity on the website. Customer can change the preferences on Customer’s browser or device to prevent or limit Customer’s device’s acceptance of cookies, web beacons or other similar technology, but this may prevent Customer from taking advantage of some of the features on the KwiKom website, or accessing certain functions and conveniences. If Customer clicks on a link to a third party website or service, such third party may also transmit cookies to Customer. Again, this Privacy Policy does not cover the use of cookies or other such tracking technology by any third parties, and KwiKom is not responsible for their privacy policies and practices. KwiKom also uses Personal Information and Non-Personal Information to enhance the KwiKom website and KwiKom Service offerings. For example, such information can tell KwiKom how often visitors use a particular feature of the KwiKom website and which products and services are most interesting to current and potential customers, and KwiKom can use that knowledge to make the website useful and interesting to as many users as possible and to enhance and refine KwiKom’s Service offerings. KwiKom will continue to conduct analytics on KwiKom website performance; Customer may not opt-out of this use of cookies or other Personal Information or Non-Personal Information. Technology is improving every day and to improve KwiKom’s Services’ operation and function KwiKom may introduce new technologies and monitoring techniques without advance notice

Network Information

We use Network Information to monitor and enhance the performance of the KwiKom network. KwiKom will not monitor the content of the websites viewed or email communications as part of KwiKom’s standard network management. Generally, KwiKom will only monitor and preserve the following Network Information:

  • When Customer is using the Service;
  • How Customer is using the Service, such as monitoring traffic patterns regarding websites visited, amount of data being sent or received, or other activity;
  • The amount of data Customer is transmitting and receiving through the Service; and
  • General information regarding the performance of the Provider Equipment installed on Customer’s property or at Customer’s premises, and its interaction with the rest of KwiKom’s network.

How is Personal Information used for marketing and advertising purposes?

KwiKom will use Personal Information to send Customer marketing and advertising messages related to KwiKom’s Service and website using Customer’s email address, postal address, or telephone number (for voice, texts, and pre-recorded calls). KwiKom may deliver a marketing or advertising message based on Customer visits to KwiKom website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter. KwiKom may also send Customer “First Party Advertising,” which is advertising that is customized or personalized based on a history of Customer’s use of our Services (possibly combined with information from our Facebook fan page or other social network platforms). First Party Advertising is based solely on a combination of information KwiKom collects from Customer – not from Customer’s visits to other websites across the Internet.

Customer may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage Customer is viewing. And Customer may continue to receive general advertising if Customer opts-out of First Party Advertising, it will not be customized or personalized for Customer.

KwiKom does not provide third party “Network Advertising,” which is advertising based on Customer’s overall Internet usage across different third party websites or online services. Multiple third party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers

Because KwiKom does not provide network ads, KwiKom does not recognize the “Do Not Track” settings on various Internet browsers. KwiKom does not engage or allow third parties to track you across the Internet and across time for advertising purposes.

Links to other websites and online services

The KwiKom website and/or Facebook Pages (or other social networking platforms) may contain a variety of content and functionality and may provide links to other third party websites or online services. Despite such links, this Privacy Policy applies only to KwiKom and our Affiliates. The presence of a link does not constitute or imply KwiKom’s endorsement, recommendation, or sponsorship of the content, goods, services, business or privacy practices on such websites or online services. KwiKom encourages Customers to be aware and informed when Customers leave KwiKom’s website and KwiKom’s Facebook Pages, or any other social networking platforms.

Will KwiKom share Customer Personal Information?

Customer’s Personal Information will only be disclosed to third parties (including KwiKom’s Affiliates) as listed in this Privacy Policy, if KwiKom has received your prior consent. KwiKom reserves the right to fully use, disclose and process any Non-Personal Information collected from Customer in any manner as well as any information Customer makes public via KwiKom Services or website. KwiKom will not rent, sell or disclose Personal Information to anyone not related to KwiKom for marketing or promotional purposes, unless in connection with a potential or actual sale, merger or a corporate restructuring by or of KwiKom. (See “For Business Transfers” below for more information.) KwiKom will share Customer Personal Information with its Affiliates and with other third parties as described in this section for the following reasons:

  • To Our Affiliates. KwiKom relies on various Affiliates in order to provide the Service to Customers. These are companies that are related to KwiKom by common ownership or control. KwiKom may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, promotional and/or marketing and advertising purposes.
  • To Operational Service Providers: KwiKom and its Affiliates contract with other companies and people to perform tasks or services on KwiKom’s behalf and need to share Customer Personal Information to provide products or services to Customers. For example, KwiKom may use a payment processing company to receive and process Customer’s ACH or credit card transactions for KwiKom, or KwiKom may contract with third parties to assist KwiKom in optimizing KwiKom’s network. Unless KwiKom tells Customer differently, KwiKom does not grant its Operational Service Providers any right to use the Personal Information KwiKom shares with them beyond what is necessary to assist KwiKom.
  • For Business Transfers/Restructuring: KwiKom may choose to buy or sell assets, or KwiKom may sell assets or be sold. In these types of transactions, customer Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if KwiKom (or KwiKom’s assets) are acquired, or KwiKom goes out of business, enter bankruptcy, or go through some other change of control, including restructuring, re-organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.
  • For Protection of KwiKom, and Our Affiliates, Employees, Operational Service Providers, Users and Subscribers and Public Safety: KwiKom reserves the right to access, read, preserve, and disclose any Personal Information KwiKom has access to if KwiKom believes doing so will implement and/or enforce the Terms and Conditions of Service, Acceptable Use Policy, Privacy Policy or any legal document; protect our Network(s), website(s), and company assets; protect the interests, rights, property, and/or safety of KwiKom or Our Affiliates, employees and officers/directors, Operational Service Providers, Users and Subscribers, agents, third party licensors or suppliers, or the general public.
  • When Required by Law or in Response to Legal Process: KwiKom reserves the right to access, read, preserve, and disclose any Personal Information to which KwiKom has access if KwiKom is required by law or legal process to do so, or if KwiKom has a good faith belief that KwiKom is required by law or legal process to do so.

Is Customer Personal Information secure?

KwiKom endeavors to protect the privacy of Customer’s account and other Personal Information KwiKom holds in its records using reasonable administrative, technical and physical security measures. However, KwiKom cannot and does not guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Information at any time.

Customer’s account is protected by a password for Customer privacy and security. It is Customer’s responsibility to prevent unauthorized access to Customer’s account and Personal Information by selecting and protecting Customer password and/or other sign-on mechanism appropriately and limiting access to Customer computer, tablet or device and browser by signing off after Customer has finished accessing Customer’s account. Customer is required to notify us immediately if Customer’s password or account has been disclosed to a person whose name does not appear on Customer’s account, even if you have allowed such disclosure. Customer understands, acknowledges and agrees that Customer is solely responsible for any use of KwiKom Services via Customer’s username and password.

Additionally, if Customer contacts KwiKom, KwiKom will ask Customer for verification of Customer’s identification and account. KwiKom will not send an email or text, nor should Customer respond to any email or text communications asking for any sensitive or confidential Personal Information, such as social security number, bank account or credit card account number, or a driver’s license number. If Customer receives an email or text requesting any such information from KwiKom or someone that claims they are with KwiKom or Our Affiliates please contact our Privacy Administrator immediately: privacy@kwikom.com

For KwiKom’s IT Support Services as detailed in our Terms and Conditions of Service, the code that allows KwiKom to access Customer’s computer desktop to help your resolve technical problems is limited only for that specific session. KwiKom is not able to access Customer’s Computer without Customer’s knowledge, affirmative consent and involvement.

What Personal Information can Customers access, modify and/or delete?

Generally, Customer may access the following Personal Information in Customer’s account:

  • Full Name
  • Username
  • Email address
  • Telephone number
  • Billing and Service address
  • Account and billing information

By contacting KwiKom at privacy@kwikom.com, or through any online access portal KwiKom may create to enable Customers to view and modify Customer account settings, Customer may access, and, in some cases, edit or delete the Personal Information listed above. For example, KwiKom may retain historic email, billing and/or Service addresses for security and verification purposes. Customer may not delete such information.

When Customer updates Personal Information, however, KwiKom may maintain a copy of the unrevised information in KwiKom’s records for internal security reasons and recordkeeping. Some information may remain in KwiKom’s records after it is modified, amended or deleted by Customer or KwiKom. KwiKom may use any aggregated data derived from or incorporating Customer’s Personal Information after Customer updates or deletes it, but not in a manner that would identify Customer personally. KwiKom may also maintain Personal Information regarding Customer and Customer’s use of the Service after Customer is no longer a KwiKom customer as required by KwiKom’s business practices, by law, and/or tax reporting purposes.

The information Customer can view, update, and delete may also change. If Customer has any questions about viewing or updating information KwiKom has on file about Customer, please contact KwiKom at privacy@kwikom.com.

What third party disclosure choices do Customers have?

Customer can always choose not to disclose Personal Information to KwiKom; however, certain Personal Information is necessary for KwiKom to provide the Service to Customer. Customer may opt out of sharing Personal Information with Our Affiliates only for marketing or advertising purposes, but not for business or operational purposes.

Customer may opt out of email marketing and advertising from KwiKom or its Affiliates using the “Unsubscribe” mechanism in each email. Before KwiKom sends Customer a text for any reason, or sends Customer a pre-recorded call that contains advertising or marketing information, KwiKom will secure Customer’s prior written express consent, which can be given via a voice recording, email, text message, postal mail, or telephone key press. Non-telemarketing pre-recorded calls do not require Customer’s prior express consent in writing, unless they are sent to a wireless device. Customer understands, acknowledges and agrees that such texts and pre-recorded telemarketing calls may be sent using an auto-dialer and are not conditioned on your purchase of the Service. Customer may opt out of receiving text messages any time by replying “STOP” or “UNSUBSCRIBE” to the text message. Customer may opt out of receiving pre-recorded calls by the opt-out instructions in the call. However, Customer will continue to receive calls related to debt-collection and Customer’s current Service. Customer may also opt-out of First Party Advertising, but not Contextual Advertising, as detailed in the “Use of Personal Information for Marketing or Advertising Purposes” section above.

Customer may not opt out of KwiKom’s use of cookies or other similar technology, or use of Customer’s Personal Information and Non-Personal Information for KwiKom’s internal analytics used to monitor activity on KwiKom’s website, measure KwiKom Service performance, or to operate and protect the KwiKom network.

Indirect End User Phone Contact Information (Personal Identifiable Information)

KwiKom acts as a data processor with regard to indirect end user personal identifiable information and our Clients act as the data controller of such data. In the course of KwiKom Communications’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.

Specifically, only when enabled via system permission on KwiKom Mobile Android and KwiKom Mobile iOS, KwiKom Communications shows personal contacts within the respective application. When the user sends an SMS message to one of his/her phone contacts, or when the user initiates a call to one of his/her phone contacts, the phone number is sent securely through KwiKom Communications’ API. KwiKom Communications does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; KwiKom Communications stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and KwiKom Communications does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on his/her mobile device at any time, and his/her app experience is not hindered or interrupted.

KwiKom Mobile Android and iOS also uses Gravatar, only when enabled via Settings and UIConfigs, which is a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that, only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings or via UIConfig, and his/her app experience is not hindered or interrupted.

Will this Privacy Policy ever change?

Yes, KwiKom is constantly working to improve the Service, so KwiKom will need to update this Privacy Policy from time to time as KwiKom’s business practices change and service offerings increase, and/or there are changes in local, state or federal laws. Additionally, KwiKom will also make stylistic, organizational and/or grammatical changes to present KwiKom privacy practices in a user-friendly easy-to-read manner. KwiKom will alert Customers to any such changes by placing a notice on https://kwikom.com/legal with the effective date of the revised Privacy Policy, and/or by sending Customers an email, or by some other means to the extent required by law. Please note that if Customers have not provided KwiKom with Customer’s email address or Customer has not updated Customer contact information, those legal notices will still govern Customer use of the Service, and Customer is still responsible for reading and understanding all notices posted on KwiKom’s website. Customer’s continued use of the Service or website after notice of any changes have been provided will indicate Customer’s acceptance of such changes, except where further steps are required by applicable law.

Use of Customer’s Personal Information is primarily governed by the Privacy Policy in effect at the time Customer subscribed to the Service or visited the KwiKom website. If KwiKom elects to use or to disclose Personal Information that identifies KwiKom as an individual in a manner that is materially different than that stated in the Privacy Policy in effect at the time you subscribed to the Service or visited the KwiKom website, KwiKom will provide Customer with an opportunity to consent to such use or disclosure. Depending on the circumstances, that consent may include an opt-out.

What if you have questions or comments about this Privacy Policy?

If you have any questions or concerns regarding KwiKom’s privacy practices and policies, please contact KwiKom at privacy@kwikom.com.