Privacy Policy and Compliance for Carolina Digital Phone Inc.

Effective December 27, 2021

Carolina Digital Phone (“us”, “we”, or “our”) operates the Carolina Digital Phone Mobile mobile application and other web-based communications Services also known as digitalphone.io (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, 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.

Carolina Digital Phone Inc is a North Carolina corporation and has created this Privacy Policy in order to demonstrate our firm commitment to our client’s privacy. In addition to this privacy policy, we are in compliance with the Federal Communications Commission CPNI (Customer Proprietary Network Information) rules 47 C.F.R. S: 64.2009(e) and file annually a CPNI Compliance Certification. The annual CPNI Compliance Certification filed with the F.C.C. is available to review at Annual CPNI Compliance Letter to the Federal  Communications Commission on January 12, 2022 [PDF]

Carolina Digital Phone Inc is a Registered Interconnected VoIP Provider as listed with the Federal Communications Commission FCC Registration Number (FRN) is 002-13989-38 and our FCC Filer ID at FCC Filer ID 829591. As a provider of telecom services under the license by the FCC International calling under Section 214 we are granted the authority to provide resale service in accordance with section 63.18(e)(2) of the Commission’s rules posted at the FCC Public Notice dated April 4, 2013, 47 C.F.R. § 63.18(e)(2) international calling termination. 

In addition to being registered with the FCC, Carolina Digital Phone, Inc. was granted on February 5, 2021, by Public Notice from the FCC Notice of Interconnection VoIP Number Authorization.  As originally filed as Application to Obtain Numbering Resources FCC Docket WC-20-315.

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 may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Cookies and Usage Data

Indirect End User Phone Contact Information (Personal Identifiable Information)

Carolina Digital Phone 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 Carolina Digital Phone’s 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 Smartphone Carolina Digital Phone’s Android and Smartphone Carolina Digital Phone’s iOS, Carolina Digital Phone 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 Carolina Digital Phone’s API. Carolina Digital Phone does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; Carolina Digital Phone stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and Carolina Digital Phone 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.

Gravatar Usage

Smartphone Carolina Digital Phone’s 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.

Clients

Carolina Digital Phone uses such personal information only for relevant, appropriate, and customary purposes. Carolina Digital Phone will not share or disclose personal information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in the Client’s Services Agreement. The following are examples of some of the personal information Carolina Digital Phone may process.

Business Contact Information:

Carolina Digital Phone may collect and use personal information about individual contacts of Clients and others who access Carolina Digital Phone public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals in the course of receiving Products and Services from Carolina Digital Phone and/or requesting information about Carolina Digital Phone. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding Carolina Digital Phone Products and Services.

Text and E-Email

Many clients of Carolina Digital Phone, Inc. find it helpful to communicate through the use of text messaging and e-mail, but they are not considered secure methods of communication. By using our hosted voice services and being a client of Carolina Digital Phone, Inc. you assume the risks of texting or e-mailing our company and individuals in our company at your own risk. Additionally, by agreeing to our Master Services Agreement, you are consenting to receive occasional text reminders about services we offer that might include a collection of past-due invoices for services. These text messages may come from an “800” number and will not share any confidential information

Usage Data

When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).

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

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service 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 Service. 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 Service. Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• 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

Carolina Digital uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

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 and choose to provide information to us, please note that we transfer the data, including Personal Data, to and process it there.

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

Carolina Digital 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 – Legal Requirements

Carolina Digital 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 Carolina Digital
• 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.

Service Providers

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

Links to Other Sites

Our Service 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 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. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, 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.

Billing Applications

Our site’s billing application requires users to provide contact information (e.g. name, e-mail address, phone number). The information gathered is not used to contact the visitor and is never shared with any party outside of Carolina Digital Phone.

Credit Card processing is done externally using a gateway processor. Authorize.net and CyberSource, a VISA company provide a complete portfolio of services that simplify and automate payment operations. Our application uses CyberSource and Authorize.Net brand solutions to process online payments, streamline fraud management, and simplify payment security. In this web portal, you can view previous and current monthly invoices, update your credit card information, make one-time payments, and view call records. If you need help with your billing account call (336) 544-4000 Monday-Friday, during business hours 8:00 AM – 5:00 PM EST.

Contacting the Web Site Owner: If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this website, please contact: [email protected] or by US Mail to Carolina Digital Phone, 301 S Elm Street, Suite 601, Greensboro, NC 27401.

Carolina Digital Phone is a member of NENA Company ID CDP which serves the public safety community as the only professional organization solely focused on 9-1-1 policy, technology, operations, and education issues. With more than 7,000 members in 48 chapters across North America and around the globe, NENA promotes the implementation and awareness of 9-1-1 and international three-digit emergency communications systems. NENA works with public policy leaders; emergency services and telecommunications industry partners; like-minded public safety associations; and other stakeholder groups to develop and carry out critical programs and initiatives; to facilitate the creation of an IP-based Next Generation 9-1-1 system; and to establish industry-leading standards, training, and certifications.