Privacy Policy

Last Updated: May 30, 2023

M2nGage Telecommunications II Corp (“us”, “we”, or “our”) operates the www.m2ngage.com website (hereinafter referred to as the “Website”).  We provide a variety of voice and data services and applications (the “Services”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Website and the choices you have associated with that data, and regarding the collection, use and disclosure of personal data in connection with the Services you have ordered.

We use your data to provide and improve the Website and the Services you have ordered. By using the Website and/or accepting the Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.m2ngage.com

Definitions

  • Website

Website is the www.m2ngage.com website operated by M2nGage Telecommunications II Corp

  • Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).  Please see below for the types of Personal Data we collect, including:

Contact Information.  Our Continuity UC app (not our website, or any other Services) will request your permission to access contact information stored on your device.  If permission is granted, the app will access your stored contacts solely to facilitate your communications using the app, or as required by law.  If you deny permission, we will not access this information.  Your denial of permission will not affect your ability to use the app.

  • Usage Data

Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit). Please see below for the types of Usage Data we collect.

  • Cookies

Cookies are small files stored on your device (computer or mobile device).

  • Customer Proprietary Network Information (or CPNI)

With respect to telecommunications or Voice over IP (VoIP) Services, CPNI is information that relates to the quantity, technical configuration, type, destination, location, and amount of use of such Service to which you subscribe, and that is made available to us by you solely by virtue of the provider-customer relationship; and information contained in the bills pertaining to telephone exchange service or telephone toll service.

  • Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

  • Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

  • Data Subject (or User)

Data Subject is any living individual who is using our Website or Service and is the subject of Personal Data.

  • Services

The voice, data, information technology or other services provided by M2ngage to its customers.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information includes:

  • Your email address
  • Your first name and last name
  • Your phone number
  • Your address, State, Province, ZIP/Postal code, City
  • Your physical location, for voice services (to be entered by you in accordance with our E911 Disclosure Notice)
  • Telephone numbers you dial
  • CPNI (for VoIP customers; see below)
  • Your contacts (app only, with customer permission only)
  • Cookies and Usage Data

We may use your Personal Data to provide you with the Services you have ordered, including for purposes of billing and customer support. For voice services, if you dial 9-1-1, we may transmit the phone number of and the physical location you entered for your device to route and complete the call to the appropriate emergency call center.

We will use the phone numbers that you dial in order to complete and bill you for calls, and we will transmit that information to other carriers or service providers as necessary to complete your calls and comply with applicable laws.  Please see below regarding CPNI.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you (subject to the provisions regarding CPNI, below). You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Access to Contacts – UC Continuity App Only.

If you download the UC Continuity app and allow the app to access to contacts stored on your device, it will access your contacts, which may be used or disclosed for purposes of facilitating your placement, receipt and identification of calls, texts or other communications using our Service, or as required by law.  We will not sell the information in your contacts, nor use your contacts for marketing purposes.  If you do not give permission for access to your contacts, neither the app nor any of our Services will access them.

Specifically, only when enabled via system permission on the Continuity UC app, M2 nGage 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 M2 nGage’s vendor’s API. M2 nGage does not store this number with any other personally identifying information, and it cannot be directly or indirectly attributed to any person or persons; M2 nGage stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and M2 nGage 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.

The Continuity UC app 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.

The app is not necessary for the use of M2 nGage’s Services.

Usage Data

We may also collect information on how the Website is accessed and used (“Usage Data”). This Usage Data includes:

  • your computer’s Internet Protocol address (e.g. IP address),
  • your browser type and browser version,
  • the pages of our Website that you visit,
  • the time and date of your visit,
  • the time spent on the pages of our Website that you visit,
  • unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Website.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

M2nGage Telecommunications II Corp uses the collected Usage Data for various purposes:

  • To provide and maintain our Website and Service
  • To notify you about changes to our Website or Service
  • To allow you to participate in interactive features of our Website or Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Website or Service
  • To monitor the usage of our Website or Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Remarketing

Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our website and elsewhere on the internet, and use that information to provide measurement services and target ads. With Facebook remarketing you may see our ads on Facebook after you have visited our site. For this to happen, Facebook uses a Pixel that is activated when a visitor lands on a webpage and a unique “cookie” is placed in their browser. Facebook lookalike audience targeting allows us to show ads on Facebook to people who are similar to those who have already visited or made a purchase from our website. To opt out of Facebook’s collection and use of information for ad targeting visit:  https://www.facebook.com/help/568137493302217.

Customer Proprietary Network Information (CPNI)

Certain of the information that we collect from you may constitute Customer Proprietary Network Information, or CPNI.  CPNI is certain information that we obtain solely by virtue of providing you with VoIP Services, and that concerns the VoIP Services you purchase, including the type, destination, technical configuration, location and amount of use of such Services, along with related billing information.

From time to time, we will use the CPNI information we have on file to provide you with information about our communications-related products and services or special promotions. Our use of CPNI may also enhance our ability to offer products and services tailored to your specific needs. We may use your CPNI to let you know about communications-related services other than those to which you currently subscribe that we believe may be of interest to you. In some instances, we will want to share your CPNI with our independent contractors, suppliers, vendors, or agents in order to provide you with information about our communications-related products and services or special promotions.  Your signature on a service agreement or sales order signifies your consent that we may use and disclose CPNI as described herein.

Nonetheless, you do have the right to restrict our use of your CPNI as described above. You may deny, withdraw or restrict our right to use CPNI at any time by advising us via email message to helpdesk@m2ngage2.com. If you deny or restrict approval for us to use your CPNI, you will suffer no effect, now or in the future, with regard to how we provide any Services to which you subscribe. Any denial or restriction of your approval remains valid until your Services are discontinued or you affirmatively revoke or limit such approval or denial.

We may disclose CPNI without your consent, and without asking for or receiving your authorization, in any of the following circumstances:

  • When disclosure is required by law or court order.
  • To protect our rights and property or to protect us, you and other carriers from fraudulent, abusive, or unlawful use of services.
  • For directory listings.
  • To provide Services to you, including assisting you with troubles associated with the Services. Without limiting the foregoing, if you purchased your Services through a reseller of our Services, that entity may provide you with certain support services, and we and such reseller will share your CPNI as necessary to provide you with customer support.
  • To bill you for Services.

Federal privacy rules require us to authenticate the identity of the Customer calling us prior to disclosing CPNI. Customers calling us can discuss their Services and billings with a M2ngage representative once that representative has verified the caller’s identity. There are three methods by which we will conduct Customer authentication:

  1. By having the Customer provide a pre-established password and/or PIN;
  2. By calling the Customer back at the telephone number associated with the Services purchased; or
  3. By mailing the requested documents to the Customer’s address or email address of record.

In the event the Customer fails to remember their password and/or PIN, the representative will ask the Customer a series of questions known only to the Customer and M2ngage in order to authenticate the Customer.  You may manage your password by contacting us (see below) or as instructed when your Service is installed.

M2ngage will notify you of changes to your account. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

In addition to the protections described elsewhere in this Privacy Policy, M2ngage employees are trained on how CPNI is to be protected and when it may or may not be disclosed.  M2ngage maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that may utilize Customer CPNI. M2ngage also keeps records of instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.

In the event M2ngage experiences a privacy breach and CPNI is disclosed to unauthorized persons, M2ngage will notify law enforcement as required by Federal regulations. M2ngage cannot inform Customer of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, or later if law enforcement directs us to postpone disclosure pending investigation. M2ngage is required to maintain certain records regarding any breach involving the release of CPNI, and retain these records for a period of not less than two (2) years.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), M2nGage Telecommunications II Corp legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

M2nGage Telecommunications II Corp may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Retention of Data

M2nGage Telecommunications II Corp will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

M2nGage Telecommunications II Corp will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website or Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

M2nGage Telecommunications II Corp will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, M2nGage Telecommunications II Corp may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

M2nGage Telecommunications II Corp may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of M2nGage Telecommunications II Corp
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. M2nGage Telecommunications II Corp aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where M2nGage Telecommunications II Corp relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Website or Service (“Service Providers”), provide Website functionalities or one or more Services on our behalf, perform Website or Service-related services or assist us in analyzing how our Website or Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Website.

  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Clicky

Clicky is a web analytics service. Read the Privacy Policy for Clicky here: https://clicky.com/terms

Payments

We may provide paid products and/or services within the Website. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processor we work with is Paya

Their Privacy Policy can be viewed at https://paya.com/privacy-policy/

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address or target anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time, and the new Privacy Policy will be posted on this page.

We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: info@m2ngage2.com
  • By phone number: 2019689797
  • By mail: 1025 Old Country Road, Westbury, NY 11590