TERMS OF USE & PRIVACY POLICY

The following terms of use and privacy policy information will outline out how North Pole Wireless will operate and will describe the expectations of all users. It will also be explained how we collect, store, use, and protect information about you that is exchanged when you use or interact with our website http://www.northpolewirelessfun.com as well as with other affiliates where we otherwise obtain or collect information about you. These terms will be in effect from January 1, 2021 and are subject to change at any time.

By activating your North Pole Wireless cELFone and registering with the affiliated website https://www.northpolewirelessfun.com you are agreeing to comply and acknowledge the terms and policies set forth in this page that are listed below:

  • Registration will include mandatory information fields that are necessary for us to provide the services of our brand. In order to utilize all amenities of the brand, all mandatory information must be completed during the registration process. 
  • All information provided accurate and is your own. Providing any falsified information could result removal from the website and its amenities and or prosecution. This includes not only registration information, but also all incidents of login including the credentials provided during login. 
  • Activation of the cELFone will be the result of your purchase, a purchase made on your behalf, or a unit which has been gifted to you be a previous owner who is no longer utilizing the cELFone or any of its amenities
  • The activation code provided during registration is accurate and valid, and is the result of your purchase, a purchase made on your behalf, or through a unit gifted to you by a previous owner who is no longer utilizing the unit or any of its amenities
  • Any behavior or communication via the website and/or any of its affiliates, current or future, will be conducted in a manner which is respectful, appropriate, and family friendly. Anyone found to be in violation of this expectation will be notified and possibly lose privileges to the website
  • All graphics, verbiage, and amenities of www.northpolewirelessfun.com are the trademarked property of North Pole Wireless and its parent company ZRC Ltd. None of the components of the cELFone or the website may be duplicated or utilized without authorization of the owners. Anyone found to be in violation of these property ownership bylaws will be notified, and potentially risk loss of website privileges, and/or prosecution. 
  • The purchase of a North Pole Wireless Mobile cELFone will include network connection to www.northpolewirelessfun.com for 12 months, including the first holiday season following the purchase. For all future holiday seasons, there will be the option to subscribe annually to amenities which are deemed as outside the scope of basic registration. The terms and conditions apply to any current and future years of use. 
  • Purchases made via the North Pole Wireless website (www.northpolewirelessfun.com) may be considered commissionable by means of affiliate relationships with select outside vendors. Any purchases made through the website or any partner websites are deemed agreeable to the terms of any affiliate relationships with select outside vendors.

COLLECTION OF INFORMATION

General information will be collected, such as name, certain contact details, customized selections, and login information. Should future amenities require payment information, this information will be collected by a select third party to provide secure transactions. At any time your IP address, information from cookies, information about your computer or device (i.e. device and browser type), information about how you use our website (i.e. specific website pages viewed, time and duration of viewing, clicked items, geographical location of browser (based on your IP address), your participation in events or contests, and information about your internet connection may be reviewed. 

DATA CONTROLLER

When you provide information to us (i.e. completing registration, contacting us via email, phone, or mail, providing information onto our website, sign up services or newsletters, event participation) from your use of our website, using cookies and similar technologies, and occasionally, from third parties. 

The data controller in respect of our website is:

ZRC Ltd. of 617 McCorkle Blvd #2636 Westerville, Ohio 43086

You can contact the data controller by writing to ZRC Ltd., C/O Data Controller 617 McCorkle Blvd #2636 Westerville, OH 43086 or sending an email to help@northpolewirelessfun.com

If you have any questions about this Privacy Policy, please contact the data controller.

HOW THIS INFORMATION IS USED

We will use any information provided for one or more of the following purposes: administrative and business purposes (i.e. to provide services utilized on our website or to contact you), for business improvements, to fulfill our contractual obligations of products sold, promotion of goods and services, analysis of website utilization, all in connection with our legal rights and obligations.

THIRD PARTY DISCLOSURE

Your information will be shared with third parties only when it is deemed necessary to: fulfill our product obligation, required by our service providers, to fulfill any contracts we enter into with you, and where required by law or to enforce our legal rights. With the exception of mergers/acquisitions, we will never sell your information to third parties

DATA RETENTION

We will not store nor utilize your information for any longer than necessary as per the services we offer. Exceptions to this include, but are not limited to legal obligations we have (required financial record management), any other legal basis we have for using your information (consent, performance of a contract with you or our legitimate interests as a business). 

You have the following rights with regard to your information:

  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • to complain to a supervisory authority

Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

COOKIES

We use cookies and similar technologies on our website, including essential, functional, analytical and advertising cookies and web beacons. For further information on how we use cookies, please see our cookies policy, which is available here: https://northpolewirelessfun.com/pages/cookie-policy

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

PRODUCT ACTIVATION AND REGISTRATION

In order to create an account to utilize the amenities of our product and affiliated website, we will collect the following registration information: name, email address, password, activation ID, PIN number, and login credentials. If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

There will be other times where additional information may be requested (i.e. contests, newsletters, special events, network renewal, etc.) and any additional information collected will be exclusively for these purposes and given only with your consent. 

MAIL

If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.

ELECTRONIC COMMUNICATION

We will communicate electronically with regard to any system failures, outages, or privacy threats by sending alerts to the email address provided during registration. 

We anticipate the creation of an electronic newsletter in the future. Registration to our website will enroll you into future communications. At that point should you choose to opt out or adjust communications at any time, you may do so under “manage communication” tab in your account.

We will use a third party service to send out our e-newsletter and administer our mailing list; this third party is to be determined.  

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

OPTIONAL INFORMATION

We will often reach out for feedback in for form of a survey following product purchase or technical assistance. Any information collected during the survey will be exclusively for the utilization of improving products and services. 

PAYMENT PROCESSING

Should there be an option for making purchases on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we will use a third party payment processor (Shopify Payments) and a fraud gateway to ensure that your order is not fraudulent (Signify Inc.). 

Shopify Payments will process your payment. Shopify Payments collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link(s): Shopify Payments: https://pay.shopify.com/tos-privacy-policy

Signify: https://www.signifyd.com/privacy/

BRAND AFFILIATES

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

THIRD PARY INFORMATION SHARING

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies with whom we do joint promotions.

It is also possible that third parties with whom we have had no prior contact will provide us with information about you. Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you that they provide to us.

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

ADVERTISEMENTS AND PROMOTIONAL INFORMATION

We may automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy available here: https://northpolewirelessfun.com/pages/cookie-policy

Use of profiling in marketing emails:

We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (https://northpolewirelessfun.com/pages/cookie-policy ).

Our third party service providers are located in the United States and Canada.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display all the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email at help@northpolewirelessfun.com and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

DISCLOSURE OF INFORMATION TO THIRD PARTIES

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]

FRAUDULENT USE AND HOSTILE BEHAVIOR

If we suspect that criminal or potential criminal conduct has occurred, in certain circumstances we will need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we are victims of fraud or a cybercrime has been committed or if we receive threats or malicious communications towards third parties or us. We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way. If you are found to have engaged in any act of fraud or cybercrime, including that of falsifying or duplicating registration information, this may result in the revoking of your account with North Pole Wireless, including access to the website and all associated amenities. We also reserve the right to provide information about you to appropriate authorities, including police, if you are found to be in repeated violation of our terms of service. 

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

LEGAL DISPUTES AND/OR PROCEEDINGS

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

E-Newsletter: we will retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

DETERMINING RETENTION PERIODS

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • relevant surrounding circumstances (such as the nature and status of our relationship with you).

SECURING YOUR INFORMATION

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers

TRANSMISSION OF INFORMATION VIA EMAIL

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means) you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you because of your decision to transmit information to us by such means.

IDENTITY VERIFICATION

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information. Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances, when you make such a request.

The right to object to the processing of your information for certain purposes:

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to ZRC Ltd. 617 McCorkle Blvd #2636 Westerville, OH 43086 or sending an email to help@northpolewirelessfun.com

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://northpolewirelessfun.com/pages/cookie-policy

SENSITIVE PERSONAL INFORMATION

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We will not intentionally or knowingly collect sensitive personal information from individuals, and you must not submit sensitive personal information to us. If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

CHANGES TO POLICY/TERMS

Our Terms of Use and affiliated Privacy Policy are subject to change at any time. Minor changes will be updated with a new effective date, which is stated at the beginning of this page, and terms will be effective as of that date onward. When major changes to our Privacy Policy are made, or if there is intent to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website. We will provide you with the relevant information about major changes before your information is utilized for the purpose(s) in question. Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

CHILDREN’S USE OF WEBSITE

The safety and privacy of children online is a key priority to our organization, and therefore we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit personal or photographic information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this type of occurrence, we will immediately verify the information via legal and ethical manner when required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to help@northpolewirelessfun.com

DELETING PERSONAL INFORMATION
To make a request for the disclosures or deletion described above, please email us at help@northpolewirelessfun.com. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.