1. Our Core Privacy Principles
Data Ownership: Kajeet considers and acknowledges all data that Kajeet may gather from a Customer or the devices it owns and manages is the property of the Customer, including the personal information of Users (“Customer Data”). Customers have complete and unequivocal rights to their data and how they wish their data to be utilized, subject to any exceptions provided below.
Data Collection and Use: Kajeet will only collect Customer Data as necessary to fulfill Kajeet’s duties as outlined in the Customer’s contract or service agreement (“Agreement”). Furthermore, Kajeet will use Customer Data only for the purpose of fulfilling its duties and providing services to Customer, and for improving its services. Kajeet will not use any data to advertise or market directly to users.
Security: Kajeet takes securing Customer Data and the personal information of their Users seriously, and uses appropriate administrative, physical and technical safeguards to protect data from unauthorized access, disclosure, and use.
2. What Personal Information We Collect and How We Collect It
Kajeet limits the amount of personal information it collects about Users. The different ways we collect personal information and the types of personal information we collect are described below.
The Sentinel Management Platform allows Customers to access their data collected from their use of Kajeet Services. This information can include: device identifiers and information (IP, IMEI, ESN/MEID, MDN, UICC, Device Type, Device Nickname, usage data, Policy group associated with devices, Checkout status & suspend status, URI history (including timestamp, MDN and device/IP address),
Allowed/blocked policy decisions for each URI request, Categorization decisions for each URI request, and notes and other information input by the Customer.
For Customers that utilize the Sentinel “Media Center”, additional information collected may include: Check-in and Check-out status, Due date, Content filter group, Borrower ID (optionally entered by Customer), Notes (optionally entered by Customer), and Checkout history. Customer should not enter any PII in any of the Customer entered data fields.
Authorized users of the Sentinel Management portal are designated by Customer. In addition to login information, Kajeet may collect profile information about such authorized users including name, address, phone number, time zone and security questions. In addition, Kajeet collects application log data (such as when the user has logged in) and page access statistics.
Kajeet Services are provided through connected devices including, but not limited to: routers, hotspots, cellular embedded devices (tablets, Chromebooks, laptops, handhelds and wearables) and IoT devices (sensors and gateways).
Device network identifiers and connectivity data related to the use of voice telecommunications service is commonly referred to as Customer Proprietary Network Information (“CPNI”). CPNI is subject to special Federal laws and regulations, with which Kajeet fully complies.
Aggregate Customer information (“ACI”) is collective data that relates to a group or category of services or customers, from which information identifying individual Customers and Users have been removed.
It is the policy of Kajeet to treat all CPNI and ACI in a confidential manner and to limit access, disclosure and use of such information in a manner that is compliant with the 1996 Telecommunications Act and by the FCC. All employees or representatives of Kajeet, including those who have access to or use CPNI or ACI, receive mandatory annual CPNI training, including, without limitation, training with respect to when they are and are not authorized to access and use CPNI or ACI.
As required by Rule 64.2009(e) set forth at 47 CFR Part 64, the compliance certification and supporting statement of Kajeet is publicly available at the offices of Kajeet, Inc. 7901 Jones Branch Drive, Suite 350, McLean VA 22102.
The Kajeet Knowledge Center maintains Customer login information as well as support ticket history, including any chat history.
directly from Kajeet websites. Finally, Kajeet may collect information that is provided by visitors of Kajeet websites by contacting Kajeet directly through email links to ask questions or make comments.
Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, Kajeet does not currently respond to those signals. For more information regarding Do Not Track mechanisms, see http://allaboutdnt.com/.
3. How We Use the Personal Information We Collect
Kajeet uses the information we collect to provide our contracted services and to improve our services. Kajeet will not use any data to advertise or market directly to Users.
Kajeet may use de-identified data for product development, research, or other purposes. De-identified data will have all direct and indirect personal identifiers removed. Furthermore, Kajeet agrees not to attempt to re-identify de-identified data and not to transfer de-identified data to any party unless that party agrees not to attempt re-identification.
Kajeet collects IP addresses to assist in system and network administration, collect aggregate information, track trends and audit use and performance of Kajeet Services. Kajeet does not associate IP addresses with an individual.
Kajeet does not use any information about how individuals surf the Internet or browse our sites to conduct direct marketing to Users. Kajeet may, however, use aggregate information (i.e., anonymous and not tied to any individual) for our own research and to analyze the efficiency of our network and services, which may include sharing such information with our partners.
On various web pages, users can contact Kajeet directly through email links to ask questions or make comments. Kajeet may retain submissions to improve Kajeet Services or Kajeet may discard them.
4. How We Share Personal Information
Customer Data will not be shared with any additional parties without prior written consent of the Customer except as required by law. At no time will we sell Customer Data to advertisers or other third parties for payment. We also will never sell any personal information we collect that is not Customer Data to advertisers or other third parties for payment, though we may share that information with partners and service providers in order to provide and improve Kajeet Services.
5. Other Important Information
In the Event of Merger or Acquisition
Kajeet strives to protect the security of the Customer Data and other personal information stored and processed by Kajeet. Kajeet implements appropriate administrative, physical and technical safeguards to secure data from unauthorized access, disclosure, and use. Kajeet, however, is not responsible for any breaches in security caused by Customers or Users, such as the disclosure of a password to a third party by a Customer’s authorized user.
Kajeet does not knowingly collect any personal information from children under the age of 13.
Third Party Sites
Social Media Sites
Kajeet may have pages or other presence on various social networking sites or services, such as Facebook, Twitter, Instagram, LinkedIn and the like. Any information you post or provide through such sites and services will be subject to the policies of those sites and services.
6. Kajeet’s Contact Information
If you have questions about this policy, you can contact us at:
7901 Jones Branch Drive, Suite 350
McLean VA 22102