Flash Number Privacy Policy
Overview
This Privacy Policy describes how Lubap treats information that it collects and receives related to your use of Lubap's products, services, and websites. Our primary goal in collecting information is to provide and improve our products and services.
Children's Personal Information
All Lubap products, services and websites are not intended for children under the age of 13, so children under the age of 13 should not use them at any time.
Lubap does not knowingly collect any information from children under the age of 13. In the event that Lubap discovers that it has received personal information from a child under the age of 13, Lubap will promptly delete such personal information in a secure manner.
Information Lubap Collects and Uses
Lubap collects information when you use and access Lubap's products, services and website. We categorize the information we collect into three categories (collectively referred to as "Customer Information"): Personal Information, App Data and Share Data.
"Personal Information" is information about you that is personally identifiable, including your full name, business or residential address, email address, land-line or existing mobile phone number, or billing information.
"App Data" is information about the nature of your usage of Lubap's website and products and services and non-personal information. App Data can include: IP addresses, domain servers, referring/exit pages, operating system information, unique device identifiers, such as UDID and/or Ethernet MAC address, date/time stamp, clickstream data and information about actions taken by you through interaction with Lubap's products and/or advertising displayed within Lubap products, messages sent and received using Lubap services, information about those messages (date, duration, recipients, size, attachments), type of device, location information, age, gender, type of web browser, one or more cookies that identify your browser, and telecommunications carrier information.
"Share Data" is data and information you provide for use with Lubap's products or services, such as text, audio, and photos you make available through the Apps or contacts you add or import for use with Lubap products, and which may be made available to third parties by your actions when using Lubap products or services.
Information Sharing and Disclosure
Lubap uses Customer Information to enhance your use of the Lubap services by processing such information for various purposes, including improving and providing Lubap's products and services, product notifications, delivering advertisements and related links, for sending, sharing and storing your Share Data as you direct through use of Lubap products and services, and other purposes relating to offering you Lubap products and services.
If you provide your phone number as part of a request for information about Lubap products or services or in setting up an account, we may use that phone number and share that phone number with third parties to contact you about Lubap products and services and to provide advertisements to you about Lubap Products and services.
Lubap does not rent, sell, or share any Customer Information except as provided above and unless: you initiate the sharing through the Lubap products, services or website; you have provided your express consent; and in the following circumstances:
(i) Lubap may engage a trusted third party to perform limited functions on our behalf, such as fulfilling newsletter subscriptions, sending requested postal mail and e-mail, SMS, MMS, and voice communications, analyzing and processing data (such as billing information), and providing customer service. We require that these parties agree to use such information in a confidential manner. These third parties may have access to Personal Information needed to perform their functions, but we do not permit them to use it for other purposes.
(ii) Lubap may share App Data and certain aggregated, non-personal information with third parties, but such information does not include your name, email address or any other Personal Information.
(iii) Lubap may share Customer Information to respond to legal requirements, when legally required to do so, or at the request of governmental authorities.
(iv) Lubap may share Customer Information to verify or enforce compliance with user agreements and applicable laws, to protect against fraud, to detect and prevent security or technical issues, to protect against misuse or unauthorized use of the Lubap products, services, computing systems, or website, or to protect against imminent harm to the rights, property or safety of Lubap, its subscribers or the public.
(v) Lubap may share Customer Information with a successor entity or in connection with a corporate merger, consolidation, sale of assets or other corporate reorganization provided that use of Customer Information is in compliance with this Privacy Policy.
(vi) Lubap may share your Customer Information with a third party if you have consented to receive information from that third party through Lubap products or services. Such third parties will handle, store, retain and access such user information in accordance with the terms and conditions of their agreements with you, if any, as well as their own privacy policies and as authorized and agreed upon by you as part of agreements for use of our products and services. It is your responsibility to carefully review such agreements and privacy policies. You acknowledge that Lubap shall have no liability to you for sharing of such information to such third parties as authorized by you and Lubap disclaims any and all liability relating thereto. If Lubap desires to use Personal Information for any purposes other than those described in this Privacy Policy, we will offer you the opportunity to opt out of such use for those other purposes.
Cookies and Tracking
When you visit Lubap or use Lubap applications, we may send cookies to your computer that uniquely identify your browser or use tracking pixels, agents or other visitor identification technology (collectively, "Tags") that collect App Data. We may also include Tags in promotional materials in order to determine whether messages have been opened and acted upon.
We use and share App Data as provided above.
Most browsers allow you to disable cookies or set your browser to alert you when cookies are being sent to your computer. If you disable cookies, you may not be able to utilize certain Lubap products and services.
We use analytics tools provided by Google, Facebook, Flurry, adjust, braze and Crashlytics ("Analytics Tools") which also use Tags to collect and analyze information about your use of our desktop and mobile applications. We use Analytics Tools to collect App Data, which we use as provided above. That information is also used by the Analytics Tools providers according to their privacy policies.
You can find more details about how Google uses data it collects here: http://www.google.com/policies/privacy/partners/. Some applications may use Google Contacts API to allow access to your contacts using https://www.googleapis.com/auth/contacts. That information is stored on your device and not uploaded to our servers, and is used solely to allow you to communicate with contacts using the features of those applications. For more, see https://console.cloud.google.com and https://console.cloud.google.com/tos?id=universal. To learn how Flurry collects, uses, and stores such information, see the Flurry privacy policy at https://policies.yahoo.com/us/en/yahoo/privacy/index.htm. You may choose to opt out of the Flurry services via the Flurry Opt-Out Page, available at https://dev.flurry.com/secure/optOut.do. To learn more about data collection with Facebook Analytics, see https://developers.facebook.com/docs/analytics/overview. To learn more about how braze uses data it collects, see https://www.braze.com/terms/. Crashlytics privacy policy can be found at http://try.crashlytics.com/terms/privacy-policy.pdf.
You hereby expressly consent that we is entitled to place Tags for the above-mentioned uses on your computer or device and to use the information gathered from Tags as provided in this Privacy Policy.
Currently, we do not respond to "Do Not Track" browser features.
Security and Data Integrity
We have physical, electronic, and procedural safeguards to protect the loss, misuse, and alteration of the Customer Information under our control. Customer Information we collect is stored in a secure manner that is accessible only by authorized Lubap personnel, contractors, and agents bound by confidentiality obligations and is only disclosed under the provisions of this Privacy Policy. Our processing of Personal Information is only for the purposes for which it was collected and in accordance with this Privacy Policy. Periodically, Lubap undertakes a review of its privacy practices to ensure that that the information we collect is needed to provide or improve the services we provide.
Links to Third Party Sites
As a convenience to you, we may provide links and/or connections to third-party web sites or services from within our website or our products or services. Lubap is not responsible for the privacy practices or content of these third-party sites.
Access/Removal of Your Personal Information
If you want us to remove your Personal Information from our database, or would like to access the Personal Information we have that was collected from you, you can contact us using the contact information provided below. Certain of our products and services require the use of App Data and such data is retained by Lubap and used as described in this Privacy Policy.
Modifications of Privacy Policy
Lubap reserves the right, at our discretion, to change, update or modify this Privacy Policy at any time by posting such change, update or modification on the Lubap website and in the app stores from which Apps are made available. Any such change, update or modification will be effective immediately upon notice, which Lubap may provide by any means, including, without limitation, posting on the Lubap website, notifications within Lubap applications, or electronic mail. Your continued use of the Lubap website and/or any Lubap products and services following the posting of changes will mean you accept those changes. Use of information that we gather is subject to the Privacy Policy in effect at the time of use.
Contact Us
If you have any questions or concerns regarding this Privacy Policy, please send us an email at contact@lubap.com or write to us at Lubap LLC. 530-B Harkle Road STE 100, Santa Fe, NM 87505. If we receive formal privacy-related complaints, it is our policy to use reasonable efforts to communicate with the complaining party about its concerns to resolve privacy complaints.
Interest-Based Advertiser Opt Outs
Lubap is not a member of any self-regulatory bodies for interest-based advertising like the DAA and NAI, but some of our advertisers and advertising services providers are members of self-regulatory bodies and require that we provide you with the following out links to the NAI and DAA opt out programs: for the NAI, see http://www.networkadvertising.org/choices, and for the DAA, see http://www.aboutads.info.
Last updated March 29, 2020