Privacy Policy

UPDATED: JANUARY 1, 2025

Gabbit, LLC and its affiliates and subsidiaries (collectively “Gabbit”, “us”, “we”, “our”) is committed to protecting your privacy while providing you with a positive experience while visiting our website and when using our products and services.

We provide voice over IP services and equipment for businesses and consumers (the “Services”) as well as a related mobile application (the “App”). Except as set forth in this Privacy Policy (the “Policy”), we will not trade, sell, or disclose to any third party any form of “Personal Information” (as defined below) without your consent. This Policy explains how we collect and use information from visitors to our website (www.gabbit.com), customers who use the Services and App (including End Users), and potential customers who have communicated, contacted, or otherwise interacted with Gabbit in connection with the Services. The Terms and Conditions which appear on our website, as amended from time to time, are incorporated by reference herein. This Policy also describes choices that may be available to you regarding use, access, deletion, and correction of Personal Information. Any capitalized term not otherwise defined herein shall have the meaning ascribed to it in the Terms and Conditions.

This Policy only applies to the Gabbit website and Services that link to or reference this Policy. Additional information on our personal information practices may be provided in supplemental terms and conditions, supplemental privacy statements, or notices provided prior to or at the time of data collection.

Please read this Privacy Policy carefully and in full to ensure you are fully informed. By using and/or accessing our Website, Services, and App, you acknowledge that you have read and understood this Privacy Policy. This Policy is not, however, a contract and does not create any legal rights or obligations.

Any capitalized term used but not otherwise defined herein shall have the meaning ascribed to such term in the Terms and Conditions.

HOW WE COLLECT PERSONAL INFORMATION

In order to provide you with our products and services and to keep you informed, we collect a variety of information about you when you interact with us or use our products, services, websites, and applications. This information is needed for us to efficiently provide our services to you on a cost-effective basis and to tailor our products and services to best meet your needs and interests. For example, in order to provide timely and effective customer service, we keep track of when you called, what the issue was and what is the best way to get in contact with you.

If you are a Gabbit customer and you allow others to access and/or use your accounts, products, or services, we will collect information about those users, as well. We may also collect information about you from third parties.

We may collect personal information from or about you in a variety of ways.

  • We collect your personal information when you actively provide it to us. For example, users provide us with personal information when signing up for an account, communicating with Gabbit, responding to surveys, participating in events or promotions, or modifying an account profile.
  • We may also collect personal information about you when another user actively provides it to us. For example, if an account holder invites you to a meeting or conference call, etc. using our App and Services, Gabbit would collect your email address.
  • We may automatically collect personal information from you as you use our App and Services or visit our Website.
  • We may receive personal information about you from third parties (such as a business or commercial partner). For example, we may receive personal information from third-party service providers that you have linked to your use of our Services (including social media accounts, single-sign-on services, and scheduling applications), publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks and analytics providers.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

As used in this Notice, “Personal Information” or “Personal Data” means any information or data relating to an identified or identifiable natural person or household that we process in connection with our Website, App, and Services (including but not limited to CPNI (as defined below)). An identifiable natural person or household is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person or household. Personal Information includes, but is not limited to, your name, physical address, email address and telephone number (which may be needed to create your account or to use our Services such as cellular calling or providing emergency services as set forth in our Terms and Conditions); in-app messages (to provide chat functionality); voice calls and recordings (to provide VoIP call and call recording functionality); image, video or other files (to provide MMS functionality); and contact information added by you, such as phone numbers and email addresses (to provide address book functionality).

Information You Provide to Us Directly or When You Create an Account

We collect information you provide to us when you establish a customer or user account, register to use and/or connect to certain of our services, and when you contact us, request us to contact you, or when you otherwise communicate with us, such as:

  • contact information (e.g., name, address, email address, and phone number) usernames, passwords, images, biometric data (e.g., voiceprints), and other authenticating information, associated with a your account;
  • information about the types of services to which you subscribe, orders you place, the service options you have chosen, and any customized setting you have created;
  • information about your payment methods, such as your payment card number or bank account information;
  • information related to a credit application for a product or service or to protect against fraud, which may include your birth date, Social Security number, driver’s license number, or other government issued identifier;
  • information you provide when you enter contests, respond to customer surveys, or participate in events sponsored by us; and
  • information we keep in our records when you correspond or otherwise communicate with us, including through our call centers, online chat sessions, and through social media.

When you request support from us, we may also collect information from you such as contact information, documentation, screenshots, or other information you or we may believe is helpful to solving the issue. When you speak with our customer service or sales representatives on the phone, your calls may be recorded and/or monitored for quality assurance, training, and research purposes.

You should be aware that any Personal Information which you voluntarily include and transmit through publicly accessible forums may be viewed and used by anyone with access to such forums. We are not responsible for other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on such forums.

Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

Information We Collect Automatically and Through Your Use of the Services, Website and App

When you use our Services or App and/or visit our Website, we receive data that you or others voluntarily enter, as well as data that is automatically logged by the Website – for example, duration of session, connections made, hardware, equipment and devices used, IP addresses, location, language settings, operating system used, unique device identifiers and other diagnostic data. We need this information to provide, operate, and improve our Services. We collect location-based data for the purpose of providing, operating, and supporting the Services and for fraud prevention and security monitoring; you can disable location data transmission on mobile devices at any time by disabling location services from the settings menu on your device.

If you subscribe to or use services that require us to transfer or store communications such as voicemail service, it will be necessary for us to collect the content of those communications to provide you with the service you have requested because it is required in order for the services to function.

Location Information

If your mobile device is equipped with GPS or can connect with wireless access points or hot spots, or if your mobile device is also a phone that communicates with cell towers or satellites, then your mobile device is able to use these features to determine its precise geographic location. Your precise geographic location is considered your Personal Data. To the extent our App collects precise geographic location, you may at any time opt out from allowing us to have access to your mobile device’s precise location information via the App’s location settings on your mobile device, but doing so may limit certain functions and features of the App.

When you access the Gabbit Network or the Admin Portal, we may collect general location information, such as the city or zip code that correlates with the license of your device IP address, or more precise geolocation data that indicates where you are at a specific point in time. We may also collect location information when you use some of our services and applications, including precise geolocation information, such as your service address and the location of your mobile device or another device in which you have installed a Spectrum application.

Information We Get from Third Parties

Generally. We may collect names, e-mail addresses, postal addresses, and business location information from third parties to market our products and services. This collection of information and marketing is always carried out in compliance with applicable law. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. For our End Users, we do not use Service Data for marketing purposes without your consent.

Third party services and social media. Certain Gabbit products and services may also access and store Personal Information about you from a Customer’s social media accounts or accounts a customer may have with other third-party services when the Customer chooses to connect its Gabbit accounts with its other accounts. This Personal Information may include name, email, geolocation, and any other publicly available information on these platforms. With respect to social media, only Personal Information that an End User has directly provided to the relevant Gabbit customer or that an End User has designated as publicly accessible will be accessed or stored. We use this Personal Information in connection with providing our Services to our customers. For example, we use this Personal Information to enable Gabbit customers to respond to social media posts and messages from within their Gabbit accounts, and to enable Gabbit customers to track and analyze their interactions with End Users via social media.

Credit agencies. We may obtain your credit information from third party reporting agencies in order to determine your creditworthiness, credit score, and credit usage and to evaluate our own credit risk.

Device information. Where we have provided equipment to you, such as an analog telephone adapter or a VoIP phone, or you have installed our software on your device, we collect device-specific information from you. This includes, for example, your hardware model, operating system version, firmware, browser information, device and network configuration, device identifier, IP address, device performance, signal strength, call quality, telemetry, and mobile or wireless network information. We use the device information we collect in order to provide and improve our services.

Your contact lists and address book. If you use our App, we may request your permission to access and store the contact list or address book maintained on your mobile phone, tablet, or other broadband-connected device. Your contact list is considered your Personal Data. We may use your contact list information to facilitate certain services where selected by you such as to enable you to make calls easily and to facilitate calls, texts, and other services. We may also facilitate the delivery of messages to individuals in your contact list that you wish to invite to download our App so that you can utilize our services with these selected individuals, although it is always your choice to send invites to such individuals. We will not use your contact list information for other purposes. You do not have to allow us to access your contact list information, but if you do not, certain features of our mobile apps may not be available to you. You may at any time opt out from allowing this access via the privacy settings on your device.

Mobile device camera, microphone, and photos. If you use our App, we may request your permission to access the camera, microphone, and photos on your mobile device, to make and receive voice and video calls and messages and to send photos to others. You do not have to allow us to access these functions of your device, but if you do not, certain features of our mobile apps may not be available to you. You may at any time opt out from allowing this access via the privacy settings on your mobile device.

If we receive, combine or associate information from other sources with Personal Information that we collect from you or through the Equipment and Services, we will treat the combined information as Personal Information in accordance with this Policy.

We strive to limit the types and categories of Personal Data that is collected from, and processed on behalf of, our Customers to include only information which is necessary to achieve the purpose(s) for which it was collected, and we do not use Personal Data for additional purpose(s) which are incompatible with their initial collection. In other words, we have measures and policies in place designed to ensure that we only collect and process information from you that we believe is necessary to provide you with world-class service.

CPNI

Gabbit is committed to protecting the privacy of all Personal Information, and in particular the privacy of customer proprietary network information (or “CPNI”). CPNI is defined by federal statute to mean: (a) information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (b) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier.

CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services.

We may use your CPNI, in a manner consistent with applicable law, to market additional communications-related services to you and conduct surveys in order to improve our service offerings. To “opt out” of Gabbit marketing additional communication related services to you, you must call customer service at 855-542-2248 during regular business hours or e-mail us at privacy@gabbit.com. Your approval or denial of approval of the use of CPNI outside of the Services to which you already subscribe will remain valid until you revoke or limit the approval or denial. Gabbit will not use your CPNI for purposes other than those described above unless we first obtain your express “opt in” consent. For example, without such consent we will not use CPNI to market services not provided by Gabbit and will not share your CPNI with third parties (subject to the limitations discussed herein).

HOW WE USE YOUR PERSONAL INFORMATION

Generally

First and foremost, we use the information we collect to provide you with reliable, high-quality products and services. We also use the information we collect to communicate with you, make improvements to our products and services, investigate theft and other illegal activities, and personalize your experience, as described below. This may involve linking and combining information about you from across the Spectrum platform of products and services, as well as from third parties (“Combined Information“).

We use the data we collect from visitors to our Website to: (a) maintain, provide and improve our Services; (b) address and respond to service, security, and customer support needs including through the use of recorded or monitored communications between you and our customer service agents); (c) detect, prevent, or otherwise address fraud, security, unlawful use, abuse or technical issues with respect to our Services; (d) comply with applicable laws and administrative requests, protect our rights and assert and defend against claims; (e) manage and configure our device(s), system(s) and network(s); (f) assess the needs of your business to determine and promote other Gabbit products and services which we believe may be helpful to you; (g) provide product updates, marketing communications, and service data; (h) conduct research and analysis for business planning and product development; (i) protect our rights, our personnel, our property, and the safety of others; and (j) maintain our accounting, tax and other business records. To the extent permitted by law, we may combine, correct, and enrich personal data that we receive from you with data about you from other sources, including publicly available databases or from third parties to update, expand, and analyze our records, identify new prospects for marketing, and provide products and services that may be of interest to you.

We also may use information we collect to deliver and personalize our communications with you. For example, we may use the information to remind you of a service appointment, to follow up with you after a service request, and to send you important service-related notices and announcements.

Use of Cookies and Other Similar Technologies

The Gabbit Website also uses a technology called “cookies” to collect certain information. A cookie is a piece of computer code that your internet browser is given when you access the Website.

We and third parties may use the following types of cookies to collect Personal Information:

  • Functional cookies. Some cookies are strictly necessary to make our websites and mobile applications available to you. For example, our Website may set a cookie on your browser that allows you to access the Website without needing to remember and then enter a password more than once during a visit to the Website, to provide chat functionality, and to remember your consent and privacy choices. We cannot provide you with the Services without this type of cookie.
  • Analytical cookies. We also use cookies for analytics purposes in order to operate, maintain and improve our Services. We may use third party analytics providers to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, mobile applications, and online resources.
  • Advertising cookies. We work with third-party advertising companies to show you ads we think may interest you. To do so, we and our advertising partners may place and access cookies through our websites and otherwise collect or access Personal Information collected over time and across different online services. These third–party partners and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites.

Where required by applicable law, we obtain your consent to use cookies. You can find more information about your rights and choices, and how to opt out of the use of certain cookies in “Your Privacy Rights”, below.

If available, please refer to your web browser’s instruction guide or help section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to better take advantage of some of the Services.

SHARING AND DISCLOSURE OF PERSONAL INFORMATION

Generally

We share information with others when it is necessary to provide you with the Services you have purchased, and others in the limited circumstances described below. We do not sell or otherwise share information that personally identifies our customers, including CPNI, to third parties for those third parties’ own use, such as marketing or advertising of their own products and services. While we have no plans to do so, if we ever changed this business practice, we would provide Customers with advance notice and obtain their express consent. We may also disclose personally identifiable information about you, without your consent, to protect our Customers, employees, or property; in emergency situations; to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions, or policies; and/or as otherwise required by law.

Account Holders and Other Authorized Users

We may disclose any information about a Customer’s account and use of the Services (or any features thereof) to the primary account owner after appropriate authentication. The primary account owner may also authorize other users to access information on the account, which may include information about the primary account owner’s use of the Services.

Gabbit Related Businesses

We may share information about you with Gabbit related companies and affiliates in order to provide the Services, or to make your customer experience more streamlined, such as through combining account information into a single location for easier access. We may also share information about you with these related companies for their own marketing purposes after we have obtained any necessary consent required to do so.

Service Providers

We may disclose your information to third-party service providers who perform business activities and functions on our behalf to support our interactions with you such as billing and collections, payment processing, analytics and research, marketing, service delivery and customization, maintenance and operations, and fraud prevention. These third-party service providers are authorized to use your Personal Information only as necessary to provide these services on our behalf.

We may also disclose personally identifiable information about you, without your consent, to protect our Customers, employees, or property; in emergency situations; to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions, or policies; and/or as otherwise required by law.

Third Parties

We do not sell or share information that personally identifies our Customers with third parties for their own marketing or advertising purposes.

If you subscribe to our telephone service, your name, address and/or telephone number may be transmitted via Caller ID, published, and distributed in affiliated or unaffiliated telephone directories, and available through affiliated or unaffiliated directory assistance operators. We take reasonable precautions to ensure that non-published and non-listed numbers are not included in the telephone directories or directory assistance services, although we cannot guarantee that errors will never occur. Please note that Caller ID blocking may not prevent the display of your name and/or telephone number when you dial certain business numbers, 911, 900 numbers or toll-free 800, 855, 844, 866, 877 or 888 numbers. But note that Gabbit does not publish directories of customers’ phone numbers and we do not make those numbers available to others for listing in directories.

Some of the advertisements we display may invite interactive or transactional follow-up from you. When you interact and provide your consent, we may share your contact information with such advertiser for the purpose of fulfilling your request. We may also share individually de-identified and/or aggregate information, including our business and marketing reports, with third parties for their own purposes.

If we enter into a merger, acquisition, or sale of all or a portion of our assets, we may disclose information about our Customers, including information that personally identifies you, as part of the transaction. All such information shall be treated as Confidential Information.

DATA REQUESTS – GOVERNMENTAL ENTITIES OR PURSUANT TO VALID LEGAL PROCESS

General Provisions

We cooperate with government and law enforcement officials and private parties when we, in our sole discretion, deem it necessary or appropriate to respond to claims and legal process or where may be required by law to do so (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical. These disclosures may be made with or without your consent and with or without notice, in compliance with the law. A “Data Request” is a request for information relating to a Gabbit Customer account in connection with an official criminal or administrative investigation or proceeding, or a filed civil legal action. Customers or End Users who need copies of their own data should download that data through their Admin Portal or by opening a ticket through Gabbit’s customer support portal. Please note that fees and charges may apply in the event a Customer makes a request as provided herein that is deemed to be repetitive or excessive under the circumstances.

Request by Legal Process

Service of Process – Civil or Private Parties. Except in extremely limited exigent or emergency situations, Gabbit generally will not respond to Data Requests unless they are made through formal legal processes and procedures. Examples of legal processes that may serve as the basis for a Data Request include: (a) subpoenas; (b) court orders; and (c) search warrants. Gabbit will review and respond to properly served request for data as required by law and in accordance with the Terms and Conditions and this Privacy Notice. Gabbit may object to requests for data in any manner prescribed by applicable law including, but not limited to, if a request has been deemed by Gabbit to have been improperly served, is overly broad or vague, or is unduly burdensome. All service of process in civil matters should be localized through the Missouri state or federal courts, as applicable, and conform to the laws of the State of Missouri and applicable Federal law.

Service of Process by Law Enforcement. Gabbit accepts service of subpoenas, warrants, court orders, and governmental civil investigative demands or related legal process which do not require the oral testimony or personal appearance of a Gabbit representative, via email at legal@gabbit.com, with a copy served by any means authorized under the Federal Rules of Civil Procedure or Missouri State Law on Gabbit’s registered agent for service of process. Acceptance of service of process by email is strictly voluntary and may change at any time and without notice. Gabbit does not consent to service by fax or email for subpoenas, warrants, court orders, and civil investigative demands or related legal process that seeks oral testimony or requires or demands the personal appearance of a Gabbit representative. Gabbit requests personal service on Gabbit’s registered agent for service of process of legal process seeking oral testimony or the personal appearance of a Gabbit representative.

Response Parameters. If required by law to disclose data in response to a law enforcement request or otherwise by legal process, Gabbit will conduct a reasonable search and produce responsive data where applicable. Alternatively, Gabbit may respond with objections that require curing and reissuing the defective subpoena. All valid subpoenas will be processed. Gabbit reserves its rights to any legal remedy available.

Emergency Requests by Law Enforcement

Emergency Data Requests as permitted by 18 U.S.C. §§ 2702(c)(4) will not be considered unless they are made using the Emergency Data Request Form or are made in connection with a court order. A copy of the Emergency Data Request Form can be downloaded HERE or contact Gabbit at legal@gabbit.com to request one. Emergency Data Requests (if made without a court order) are only appropriate in cases involving the risk of serious bodily harm or death, and (absent a court order) Gabbit responds to such requests only when Gabbit reasonable believes that such harm may be imminent if we do not respond.

Information to Include in Data Requests

General Parameters. Our database is not designed to enable any kind of search a requestor might desire. In addition, certain features of our business make many common search requests virtually worthless. For example, a given telephone number may be assigned to many different users over a comparatively short period of time. Thus, a request for information relating to a given telephone number may (unless targeted to a very short period of time) relate to more than just the user(s) who is relevant to the data request and impinge on the privacy rights of those other users. For these reasons, Gabbit cannot reasonably consider a request for information unless it includes at least the following:

  • Telephone Number or User Identification Number (“UID”)
  • A specific date or a narrowly tailored date range (generally up to 2 months)
  • Any other potentially identifying information (for example a customer’s name, physical address, email address) in the possession of the requesting party

Please note that Gabbit customers register through an online portal or pursuant to information provided directly to Gabbit by the Customer as part of the Customer on-boarding process and the names, addresses and other contact information are not verified or regulated by Gabbit in any way. As a result: (a) in some cases the identifying information provided by a requesting party may not be used in a search; and (b) searching by username may be unreasonably overbroad so Gabbit may require the requesting party to provide narrower criteria.

Required Information. The following contact information is required for the requesting party and its counsel of record:

  • Requesting Party’s Name
  • Counsel Name and State Bar Number
  • Telephone Number
  • E-mail Address
  • Mailing Address (P.O. boxes will not be accepted)
  • Requested Response Date (please allow a reasonable time for processing)

Responsive Information

Responsive information is generally returned via e-mail in the form of a compressed, password protected file; however, if the volume of returned data is larger than a few megabytes, we may place the compressed, password protected file for download via a secured cloud account or other similar-type arrangement. Keep in mind that while Gabbit is generally able to provide data such as basic subscriber information, billing history information, additional number or extensions, call log data, fax log data, SMS log data and comment log data, we cannot guarantee that we can provide data responsive to each Data Request. Each Customer’s circumstances are unique; information that is readily accessible or useful in some cases may not be in others. For example, the production of Call Logs, Fax Logs, and SMS Logs is frequently unduly onerous, and Gabbit may object to the production of these records to private litigants. Additionally, Gabbit is typically prohibited from providing Customer Content to private litigants.

Private litigants are strongly encouraged to seek data directly from the Gabbit Customer or End User, who can use automated account tools to download the relevant Data from their Gabbit Admin Portal.

Notification of Customers.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you if we are required to provide your Personal Information to third parties as part of a legal process. Law enforcement officials who believe that notification would jeopardize an investigation should obtain an appropriate court order or other valid legal process that specifically prohibits customer notification prior to sending a Data Request to Gabbit. If a Data Request draws attention to an ongoing violation of our Terms and Conditions or Privacy Policy, we may take action to prevent any further abuse in order to protect the Gabbit Network, comply with our legal obligations and/or protect other Gabbit customers. This may include actions that could (explicitly or implicitly) notify the customer that we are aware of misconduct.

Questions/Status Requests

Questions regarding the Data Requests and these guidelines should be directed to: legal@gabbit.com. For security reasons, Gabbit will only respond to questions submitted in writing. To prevent delays in response to your Data Request and those of others, please allow Gabbit five (5) business days to respond to your Data Request before you inquire as to its status.

Cost Reimbursement

To cover the cost of compliance to Gabbit, Gabbit may require payment, to the extent allowable by law, of certain reimbursable costs and fees (regardless of format or identity of the requesting party). A schedule of these fees can be downloaded HERE or contact Gabbit at legal@gabbit.com to request one.

YOUR PRIVACY RIGHTS

Generally

You may decline to share certain Personal Information with us, in which case we may not be able to provide you some or all of the features and functionalities of our Equipment and Services. You also have the right to access the Personal Information you have provided to us.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by contacting us using the contact details at the end of this Policy.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request and you may receive promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.

These choices do not apply to service notifications or other required communications that are considered part of the App or Services, which you may receive periodically unless you stop using or cancel the App or Service in accordance with its terms and conditions.

Your Cookie Choices

It is usually possible to stop your browser from accepting cookies or to stop it from accepting cookies from a specific website. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, you can use the ‘Help’ option in your browser for more details. It is solely your responsibility to stop cookies in your browser.

Note: If you block the use of cookies, then this will limit the service that we are able to provide to you and may affect your visitor/user experience.

THIRD-PARTY SITES

This Policy does not apply to, nor are we responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.

BLOGS AND FORUMS

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request at legal@gabbit.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in blogs and community forums.

SECURITY

Keeping your information secure is important to us. Like all businesses, we cannot guarantee the security of the personal information we collect and process in connection with our Website, App and Services. We have, however, taken certain steps (including technical, physical, and administrative controls) designed to reduce the risk that your personal information will be subject to loss, misuse, unauthorized access, disclosure, alteration, or destruction. Gabbit has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links from our Website.

You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public, or otherwise unsecured networks. For more information on things you can do to help protect the privacy of your own information, visit www.OnGuardOnline.gov.

DATA RETENTION

We will retain your Personal Information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes. Where we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it.

CHILDREN’S PRIVACY

Gabbit does not knowingly provide products or services directly to children under the age of 16, or knowingly collect, maintain, or use personal information from children under the age of 16. If you learn that a child has provided us with Personal Information, then you may alert us at legal@gabbit.com.

YOUR RIGHTS UNDER STATE PRIVACY LAWS

If you are a resident of California, Colorado, Connecticut, Oregon, Texas, Utah, Montana, or Virginia, you may have additional rights with respect to the personal information we collect about you.

We have adopted this notice to comply with the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA“), Oregon Consumer Data Privacy Act (“OCDPA”), Texas Data Privacy and Security Act (“TDPSA”), Montana Consumer Data Privacy Act (“MCDPA”), and Virginia Consumer Data Protection Act (“VCDPA”). Please take the time to read and understand this State Privacy Supplement. Please also read our U.S. Privacy Policy which includes important information regarding how we collect, process, and disclose your personal data. For residents of California, please read our California Privacy Notice, below.

Scope

Some personal data we collect from you may not be covered by this US State Privacy Supplement. The CPA, CTDPA, OCDPA, TDPSA, UCPA, MCDPA, and VCDPA include certain exemptions that may apply to our collection and processing of your personal data. Therefore, this US State Privacy Supplement and the privacy rights set out herein may not apply to you or to all of your personal data. For example, personal data we have collected from individuals in their capacity as current or former Dechert employees and job applicants is not covered by this US State Privacy Supplement.

Collection, Processing and Disclosure of Personal Data

The CPA, CTDPA, OCDPA, TDPSA, UCPA, MCDPA, and VCDPA require us to give you information about the categories of personal data we process, our purpose for processing it, the categories of third parties with whom we share personal data, and the categories of personal data we share with such third parties. Our collection, processing and disclosure of personal data depends on your relationship with us and your interaction with the Services we may provide you. More information regarding our privacy practices is set forth above in this Privacy Policy.

Your Rights as a Colorado, Connecticut, Oregon, Texas, Utah, Montana, or Virginia Resident

As a Colorado, Connecticut, Oregon, Texas, Utah, Montana, or Virginia resident, you may have certain rights in relation to your personal data.

Right to Confirm or Access

You may have the right to confirm whether we process your personal data and to access such personal data.

Right to Delete

You may have the right to request that we delete your personal data that we have collected about you. Subject to certain exceptions, we must delete your personal data.

Right to Correct Inaccurate Personal Data

You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Right to Opt-Out of Processing of Personal Data for Targeted Advertising

You may have the right to opt-out of the processing of your personal data for purposes of targeted advertising.

Right to Opt-Out of the Sale of Personal Data

You may have the right to opt-out of sale of your personal data. We do not sell your personal data for purposes of the CPA, CTDPA, OCDPA, TDPSA, UCPA or VCDPA.

Right to Opt-Out of Profiling

You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Obtain a Copy of Your Personal Data

You may have the right to obtain a copy of your personal data that you previously provided to us.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the CPA, CTDPA, OCDPA, TDPSA, UCPA, MCDPA, or VCDPA.

How to Exercise Your Privacy Rights

If you wish to exercise your right to confirm, access specific pieces of personal data we have about you, delete, correct inaccuracies in your personal data, opt-out of profiling (where relevant) or to obtain a copy of your personal data, please call us at 855-542-2248 or contact us at privacy@gabbit.com.

To make a request to opt-out of the processing of your personal data for purposes of targeted advertising, click Cookie Settings and then “Reject All” cookies. Some cookies and tracking technologies that are necessary to our site or its functionality may still be placed on your device.

Information for Authorized Agents

You can authorize a person (“Authorized Agent”) to exercise your privacy rights on your behalf. To submit a request to Dechert on behalf of another person as an Authorized Agent, please call us at 855-542-2248 or contact us at privacy@gabbit.com.

Authenticating Your Requests

We only comply with requests when we can authenticate that you are a Colorado, Connecticut, Oregon, Texas, Utah, Montana, or Virginia resident exercising your rights regarding your personal data.

We may need additional information from you to authenticate your request. We may need additional information from you to match the information we already have about you in order to authenticate your request. If you provide us with new personal data that we do not already have about you, we will use it solely for the purpose of authenticating your request. We will let you know via email if we need more information from you to authenticate your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot authenticate your identity, we will let you know.

Responding To Your Requests

We aim to promptly authenticate and respond to your requests within 45 days of receipt but may require a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s).

Limitations

As set out in “Scope” above, the CPA, CTDPA, OCDPA, TDPSA, UCPA, MCDPA, or VCDPA is not fully applicable to some personal data collected from you. Therefore, even if you are a Colorado, Connecticut, Oregon, Texas, Utah, Montana, or Virginia resident and submit an authenticated request, we may not be required to comply with your request.

Information provided in response to a consumer request shall be provided free of charge, up to twice annually per consumer. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the Gabbit, LLC Privacy and applies solely to all visitors, users, and customers who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together and each as may be amended from time to time, the “CCPA”) and any terms defined in the CCPA or the Privacy Policy, as the case may be, have the same meaning when used in this notice.

We collect personal information, as that term is defined in the CCPA, from and about California residents (“CCPA personal information”). CCPA personal information includes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household, with certain exceptions for de-identified information, and other specific types of information.

Categories of Information We Collect

Here are the categories of CCPA personal information we collect from or about consumers:

Category

Examples (some CCPA personal information included in one category may overlap with other categories)

Identifiers.

A real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, address, or telephone number.

Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Sensitive personal information.

Account log-in, access code, passwords, credentials, precise geolocation, and contents of email and text messages.

Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data.

Physical location or movements.

Sensory data.

Audio, electronic, visual, or similar information.

Inferences drawn from other personal information.

Profile reflecting a person’s preferences or characteristics.

Use of Personal Information

We may use each of the categories of CCPA personal information listed above for one or more of the business purposes described in our Privacy Policy, or for another purpose that we describe to you when or before collecting your CCPA personal information. We will not collect additional categories of CCPA personal information or use the CCPA personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining any legally required consent.

Selling or Sharing Personal Information

Disclosures of Personal Information

We may disclose any of the categories of CCPA personal information listed above to one or more of our service providers or other third party for the purpose of helping us engage in one or more of the purposes described in our Privacy Policy, or for another purpose that we describe to you when or before collecting your CCPA personal information. For instance, we may sell or share your Identifiers, Commercial Information, Sensitive Personal Information and/or Internet or Electronic Network Activity Information to advertising, marketing, and analytics providers.

Personal Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. Please see Section 1.2 (Personal Information Collected via Automated Means) of our Privacy Policy for more information.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their CCPA personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your CCPA personal information since the date that is the later of: January 1, 2022 or the date we first began collecting CCPA personal information about you, unless doing so proves impossible or would involve a disproportionate effort. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will disclose to you:

  • The categories of CCPA personal information we collected about you.
  • The categories of sources for the CCPA personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that CCPA personal information.
  • The categories of third parties with whom we share that CCPA personal information.
  • The specific pieces of CCPA personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your CCPA personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the CCPA personal information categories that each category of recipient purchased; and
    • the business purpose(s) for which the disclosure was made, identifying the CCPA personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your CCPA personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will delete (and direct our service providers to delete) your CCPA personal information from our records, unless an exception applies.

Correction of Personal Information

You have the right to request that we correct any factual errors in your CCPA personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will update any factual errors in your CCPA personal information from our records, unless an exception applies.

Opt-Out of Selling or Sharing of Your Data

You have the right to opt out of the sale and/or sharing of your CCPA personal information, subject to certain exceptions. You can exercise this right by emailing Gabbit at privacy@gabbit.com. Once we receive and confirm your verifiable consumer request we will stop sharing and/or selling your CCPA personal information (if applicable) unless an exception applies. Any opt-out choices you make will only apply to the specific email address that you provide when making the request.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will limit the use or disclosure of your “sensitive personal information,” unless an exception applies.

Exercising Your CCPA Rights

To exercise your CCPA rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your CCPA personal information. You may also make a verifiable consumer request on behalf of your minor child, if applicable.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CCPA personal information or an authorized representative; in particular, we will validate your telephone number and/or email address maintained in our customer database from the communication we receive from you via email, telephone or through our online customer portal. In addition, we may also ask you to confirm your state of residence.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with CCPA personal information if we cannot verify your identity or authority to make the request and confirm the CCPA personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to CCPA personal information associated with that specific account.

We will only use CCPA personal information provided in a consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the period from the date that is the later of: January 1, 2022, or the date we first began collecting CCPA personal information about you, unless doing so proves impossible or would involve disproportionate effort, through the date of our receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your CCPA personal information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Financial Incentives

We offer various financial incentives. For example, we may provide discounts, coupons and other benefits for customers who sign up to receive our marketing emails. When you participate in a financial incentive, we may collect certain personal and other information from you. You can opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt-out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at privacy@gabbit.com. In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up.

Retention of Your Personal Information

Please see “Data Retention” in our Privacy Policy for more information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice for California Residents

We reserve the right to amend this notice at our discretion and at any time. You should review this notice regularly for changes, which will be indicated by the “Updated” date at the top of this Privacy Policy. Your continued use of our website and Services following the posting of changes constitutes your acceptance of such changes.

UPDATES TO THIS NOTICE

The most current version of our Privacy Policy is published and maintained at www.gabbit.com. The needs of our customers and the business may change from time to time and, when that happens, we may need to modify this Privacy Policy. Any changes will be posted at this website. If we make any changes that materially affect your rights or the ways in which we use or disclose information, we will notify you in advance through written, electronic, or other means, as permitted by law, so that you can make any necessary decisions about your ongoing use of the Gabbit Services.

CONTACT US

If you have any questions, comments, or concerns about this Policy, please e-mail us at privacy@gabbit.com. Or, you can write to us at:

Gabbit, LLC
PO Box 11251
St. Louis, MO 63105

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