Privacy Policy
 


Privacy Rights
Effective Date: July 1, 2020

 


RFworx, LTD (“RFworx,” “Company,” “us,” “we,” or “our”) values the privacy and security of
Subscriber Personal Information. This Privacy Policy” describes the type of Personal
Information RFWORX collects, how it is used, disclosed, secured and options regarding certain
uses of this information. This Privacy Policy applies to visitors and users of RFWORX’s website
(“Site”) and applicants and current or former Subscribers of our LTE Services, SDWAN
Services, Network Hardware and Software Sales, and Internet access services (collectively,
“Services”) residing in the United States.
Any capitalized terms used herein shall have the same meaning as defined in the RFWORX
Master Service Agreement or in the event you are on a month to month agreement and do not
have a Master Service Agreement these terms shall apply.
By using RFWORX’s Site and Services, Subscribers consent to the data practices described in
this Privacy Policy regarding the collection, use, disclosure, and disposal of your Personal
Information. RFWORX’s Site and Services are designed and targeted to United States audiences
and are governed by and operated in accordance with the laws of the U.S. If Subscriber is not a
U.S. citizen or does not reside in the U.S., Subscriber voluntarily consents to the collection,
transfer, use, disclosure and retention of Subscriber Personal Information in the U.S. Subscriber
also agrees to waive any claims that may arise under Subscriber’s own national laws.

Your California Privacy Rights


Generally, California residents are entitled by law to ask RFWORX for a notice identifying the
categories of Personal Information that RFWORX that is shared with our Affiliates and/or other
third parties for their marketing purposes the preceding year, and provide contact information for
such Affiliates and/or third parties unless RFWORX meets certain exceptions in the law. This
Privacy Policy and Site meet those exceptions. Additionally, RFWORX does not share
Subscriber Information to Affiliates or third parties for their own marketing purposes. Therefore,
a Subscriber residing in California with an established business relationship with RFWORX does
not need information about RFWORX’s opt-out and out-in policies of sharing Subscriber
Personal Information with other companies (including our Affiliates) for their marketing
purposes. If you have questions regarding our policy, Subscribers residing in California must

send a written request via email or postal mail following the instructions below. RFWORX will
not accept requests via the telephone or facsimile or respond to requests that are not
labeled or sent properly or do not have complete information.
• For all requests, include Subscriber’s full name, street address, city, state and zip code.
• In an email request, Subscriber must state “Re: Your California Privacy Rights” in the
subject line and send Subscriber email to support@rfworx.com.
• In a postal request, Subscriber must send a letter or postcard to:
RFworx, LTD
716 S. Decker Ave.
Baltimore, MD 21224
Attention: Your California Privacy Rights

I. INFORMATION RFWORX COLLECTS


A. Information You Provide
RFWORX (which hereinafter includes Operational Service Providers, unless designated
otherwise) collects information when you visit the Site, communicate with the Company in any
manner, and when you establish an online account, register to use the Services, “LIKE” or use
our social networking pages such as Facebook. This includes information you provide such as
name, billing and service address, email address, telephone or mobile number, date of birth,
gender, driver’s license number, Social Security Number, and payment information and related
financial information, including account number, CVV, expiration date, and billing address.
Personal Information also includes customer proprietary network information (“CPNI”) which is
collected and used to provide VoIP Services to you. CPNI includes any information that relates
to the quantity, technical configuration, type, destination, location, and amount of use of our
voice services, such as call detail, logs, and specifics regarding your account. A Subscriber’s
name, address and telephone number are not CPNI.
B. Information Automatically Collected
Whenever you visit, interact with, or use RFWORX’s Site or Services, RFWORX may use a
variety of technologies such as cookies, web beacons, pixel tags, log files, local shared objects
(such as Flash cookies), HTML5 cookies, or other technologies to automatically or passively
collect certain information about your online activity.
RFWORX may also collect Non-Personal information on an anonymous basis, which is not
unique to a Subscriber and cannot be used individually to identify a specific person, such as zip

code, age, gender, preferences, interests, and favorites. However, demographic and other
information that is linked to or associated with a Subscriber’s Personal Information or Account is
also deemed to be Personal Information.
Information about your computer hardware and software also may be automatically collected by
RFWORX. This information can include: your IP address, browser type, domain names, access
times and referring website addresses, browser and search history. This information is used by
RFWORX for the operation of the Services, to maintain quality of the Services, and to provide
general statistics regarding use of the RFWORX Site and Services. Please keep in mind that if
you directly disclose Personal Information through RFWORX’s public message boards or other
public areas, this information may be collected and used by others.
IP address and other persistent device identifiers such as cookies, plus the nature of any of user
devices or other personal property using the Site and Services, and web-browsing or app usage
history are traditionally classified as Non-Personal Information but could be classified as
Personal Information when such information is either 1) linked to a specific person, computer or
device; 2) is combined with other Personal Information; 3) is required by applicable law to be
classified as Personal Information.
• Site Visits. RFWORX may collect information about your visit to the Site, including the
date and time you visit the Site, the areas or pages that you visit, the amount of time you
spend viewing or using the Services, other click-stream or site usage data, emails that you
open, forward or click-through to the Services, and other sites that you may visit.
• Service and Device Information. RFWORX may collect information regarding websites
visited, application and feature usage, network and device data, router connections, IP
addresses or other unique identifier or information from the computer, mobile device,
tablet or other device you use to access the Site and Services, including but not limited to
your browser type, device type, operating system, software version, phone model, phone
operating system, and the domain name from which you accessed the Site and Services.
• Use of Third-Party Analytic Technologies. RFWORX may use third-party analytics and
tracking tools to better understand who is using the Site or Services, how they are using the
Site or Services, how to improve the effectiveness of the Site and Services and related
content. These tools may use technology such as cookies, web beacons, pixel tags, log
files, Flash cookies, HTML5 cookies, or other technologies to automatically collect and
store certain information. They may also combine information they collect from your
interaction with the Site or Services with information they collect from other sources.
RFWORX does not have access to, or control over, these third parties’ use of cookies or
other tracking technologies.


II. INFORMATION USE


RFWORX uses the information it collects to: deliver, maintain, and repair the Site and Services;
establish, monitor and maintain account and billing records; measure credit and payment risk;
provide account-related services; assist with service-related issues or questions; manage and
protect the RFWORX Network, Services, Subscribers and other users from fraudulent, abusive,

or unlawful uses; improve and personalize our Site and Services, research and develop new
products and services; determine your eligibility for new products and services; use in the
aggregate for analytical and demographic purposes; deliver first-party marketing offers to you
that are among the categories of Service to which you already subscribe and other
communications-related services; and for other purposes disclosed at the time of collection.


III. INFORMATION RFWORX SHARES WITH OTHERS


RFWORX may share your information with the following entities and reasons:
1) Affiliates, agents, Operational Service Providers, providing communications-related and
security services for business, operational, promotional and first-party marketing purposes;
2) Law enforcement or government entities in response to subpoenas, court orders, or other
regulatory or legal process (including civil and criminal) or as otherwise required by law;
3) In order to investigate, prevent, or take enforcement action regarding illegal activities,
suspected fraud, and situations involving potential threats or harm to any person (including
Subscribers), the RFWORX Network, Site, or other Company assets, or in cases where we
believe our Master Service Agreement has been/is being violated; and
4) In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other
disposition of all or part of RFWORX’s business, assets or membership unour.
RFWORX does not sell or lease our Subscriber Personal Information to third parties for their
advertising and marketing purposes without your consent. We also request that our Operational
Service Providers not sell or lease any Subscriber Personal Information for their own marketing
or advertising purposes.


IV. YOUR CHOICES


A. Cookies and Ad Choices
Certain parts of RFWORX’s Site require cookies. You may adjust your equipment or Internet
browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be
able to use certain features of the Service or take full advantage of all of our offerings. Please
refer to your equipment’s settings or your Internet browser’s “Help” section for more
information on how to delete and/or disable your equipment or browser from receiving cookies
or controlling your tracking preferences. If you wish to prevent your data from being used by

Google Analytics, Google has developed the Google Analytics opt-out browser add-on
available https://tools.google.com/dlpage/gaoptout/.
RFWORX does not provide third-party “Network Advertising,” which is advertising based on
Subscriber’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 RFWORX does not provide network ads, RFWORX does not recognize the “Do Not
Track” settings on various Internet browsers. RFWORX does not engage or allow third parties to
track you across the Internet and across time for advertising purposes.
B. Marketing Communications
RFWORX provides Subscribers with the opportunity to update their Personal Information or optout
of the use of Personal Information for purposes not directly related to placement, processing,
fulfillment, delivery or troubleshooting RFWORX’s Site and Services. RFWORX only conducts
first-party marketing, which means that we will use your Personal Information to market our
own Services. To opt-out of RFWORX’s own marketing communications, you may:
• Send us an e-mail at support@rfworx.com;
• Contact us by mail at the address below in the “Contact Us” section, or
• Unsubscribe from email or text communications at any time by unsubscribing or following
the instructions contained within the email or text messages.
We may use a Subscriber’s CPNI for marketing of RFWORX products and Services that a
Subscriber has already purchased. We will obtain a Subscriber’s consent to market unrelated
products and services.
C. Updating Your Information
If you wish to verify, correct, or update any of your Personal Information, you may visit the
“Account Page” on the Site to sign into your account, or otherwise contact RFWORX at the
address or e-mail in the “Contact Us” section below. If you choose to deactivate your account,
RFWORX may still retain certain information for analytical purposes, recordkeeping integrity
and requirements, as well as to prevent fraud, resolve disputes, enforce our Master Service
Agreement or other policies, take actions it deems necessary due to technical and legal
requirements, and as dictated by constraints related to the security, integrity and operation of the
Site and Services.

V. CHILDREN’S PRIVACY


RFWORX does not request nor do we knowingly collect any Personal Information from,
children under the age of thirteen. If RFWORX learns that a child under the age of thirteen has
provided Personal Information to our Site or Services, it will use reasonable efforts to remove
such information from our files.
VI. DATA SECURITY
RFWORX has taken certain reasonable physical, administrative, and technical steps to safeguard
the information it collects from and about Subscribers and visitors. While RFWORX makes
every effort to help ensure the integrity and security of the RFWORX Network and systems, it
cannot guarantee 100% security.


VII. REVISIONS TO THIS PRIVACY POLICY


RFWORX reserves the right, at our sole discretion, to change, modify, add, remove, or otherwise
revise portions of this Privacy Policy at any time. When it does, RFWORX will post the
change(s) on the Site. Your continued use of the Site following the posting of changes to these
terms signals your assent to these changes unless additional notice or advance consent is required
by law.


VIII. HOW TO CONTACT US


If you have any questions or concerns about this Privacy Policy or the practices described herein,
you may contact RFWORX at legal@rfworx.com or by mail to:
RFWORX
Attn: Privacy Administrator
716 S. Decker Ave.
Baltimore, MD 21224