Policy Privacy

Last updated: April 15, 2024.

Introduction

This Privacy Policy summarises and describes how Surf Telecom LLC, with address at 260 Crandon Blvd, suite 32, Key Biscayne, Florida, 33149 (“we,” “our,” and “us”) collects and processes your Personal Data. In this Privacy Policy, the term “Personal Data” refers to any information about you that we hold from which you can be individually identified or identifiable, directly, or indirectly.

How Personal Data Is Used

We collect, store, and use personal information for various purposes such as:

a) to bill for products and services.
b) to allow you to purchase our services and products.
c) to verify your identity.
d) respond to your requests for service or assistance.
e) to create and improve products and services.
f) to suggest additional or different products or services.
g) provide a better user experience
h) contact you about other services offered by Surf.
i) To provide to law enforcement and any authority when requested and supported by law.

Personal Data Collection Method

We collect your personal information anytime you use our services or interact with us. Such information includes but not limited to:

Information you provide such as:

a) personal contact
b) billing, and credit information
c) address
d) phone number
e) email
f) Device IMEI
g) references

Information automatically collected due to the use the services, such as:

a) call records
b) features used, text/data/call minute usage quantities
c) mobile device location
d) data logs

We may also detect your device’s approximate location whenever it is turned on to access emergency 911 service, which permits us to provide your general location to a public safety answering point, emergency medical service provider, or emergency dispatch provider. We may also use your location without your consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm. We may also use your mobile device location to provide our wireless voice and data services, and location- based applications and services offered by us and third parties, including mapping, navigation, weather, mapping and other applications or tools. We may monitor and record phone calls, e-mails, chat, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests. We may also obtain personal information about you from other sources.

How We Share Your Personal Data

We don´t sell, rent or make your Personal Data available to any third party other than what is described in our Privacy Policy or in the terms of service or service plans purchased by you. Your Personal Data will only be disclosed to third parties with you prior consent, that can be given to us in several ways such as: when you purchase our products or services, online, orally, click trough agreements, trough our customer care (human or automated), etc.… We can disclose personal information to third parties performing services on our behalf such as: shipping companies, credit agencies, credit card companies, banks, etc... We can disclose personal information where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (for example, lawful subpoena, court order, E911 information); to protect our rights or property; in connection with claims, disputes, or litigation; to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government;

CPNI

Surf is committed to the laws and regulations to protect Customer Proprietary Network Information, CPNI, and have adopted policies and procedures designed to ensure compliance with those rules. This information includes, as an example: call details records, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. We won't intentionally disclose your CPNI to third parties without your permission, except as allowed under FCC rules, applicable law, or explained in this policy.

How Long We Retain Your Personal Data

We retain only Personal Data for as long as is reasonably necessary for the purposes for which it is Processed. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data; the potential risk of harm from unauthorised use or disclosure of the Personal Data; the purposes for which we Process the Personal Data and whether we can achieve those purposes through other means; and the applicable legal requirements. After the period specified above, we will destroy your Personal Data by deleting it.

Security Measure

To protect your Personal Data from unauthorized access, malicious attack, and other types of data breach, Surf has implemented necessary security measure to help protect the personal information you provide to us. You agree that we cannot guarantee 100% security and cannot make any guarantee, representation or warranty that use of our services, apps or Web sites is protected from all security threats, viruses, or other vulnerabilities or that your information always will be secure.

You have the following rights.:

a) Denial or Withdrawal of consent: you have the right to deny consent or withdraw your consent at any time by informing us.
b) Access to Personal Data: you have the right to be provided with complete information about your Personal Data that we hold. You also have the right to request a copy of your Personal Data.
c) Data correction: You have the right to require us to correct any incorrect information we hold about you.
d) Data deletion: You may also have the right to ask us to delete your Personal Data when certain conditions are met.
e) Restriction on Processing Personal Data: You may have the right to ask us to restrict the use of your Personal Data when certain conditions are met.

General Terms

If you subscribe our services, Terms of Service and certain other terms may apply to your use, purchase, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency. We may update this policy if we materially change our practices or if legal or regulatory changes require it. If we change our policy, you will be notified by a notice to the email address you provide to us or by a post on our Web site. You should refer to this policy often for the latest information and the effective date of any changes.

Contact

If you want to make a request for Personal Data as specified in the preceding clause or have any questions about this Notice, please contact the following department or our data protection officer. The contact details are as follows: To Legal Dept 260 Crandon Blvd, suite 32, Key Biscayne, Florida, 33149 Or Access www.surfusamobile.com Or Phone: 611 or +1 8668827873 Or WhatsApp +1 (786) 658 1400