Sonim Technologies Online Privacy and Security Policy

This Online Privacy and Security Policy (“Privacy Policy”) describes how Sonim Technologies, Inc. (“Sonim,” “We,” “Us” or “Our”) collects, Uses, shares and protects information about You.  By interacting with Sonim through Our Site or Services, You, the consumer (“You,” or “Your”) consent to the guidelines outlined in this Privacy Policy.  If Sonim amends or changes any portion of the Privacy Policy, it will be reproduced on this webpage in order to keep You up-to-date on the data We collect and how that data is Used.  Our Privacy Policy should be read alongside Our Global End User License Agreement (“Agreement”) and Terms of Use (“Terms”).  Unless noted otherwise, the capitalized terms found in this Privacy Policy have the same meaning as those in Our Agreement and Terms.  A portion of this Privacy Policy is specific to California residents, and is outlined in the “Notice of Privacy Rights for California Residents” section below.

Our Privacy Policy

Sonim takes Your privacy seriously, and is committed to safeguarding the information We collect. Sonim developed this Privacy policy to outline Our collection, use and protection best practices. This Privacy Policy also outlines Your options regarding the way Your information is collected and used.

The Information We Collect

When You interact with Sonim’s Site or Services, some or all of the following personal information may be collected:

Full Name
Physical Address
Mobile Phone Number
Email Address
Company Name
Company Address
Associated Website/URL
Wireless Carrier
Country
IMEI – International Mobile Equipment Identity number
IP address
Serial number
Mobile network code/Mobile country code
SW SKU ID
Model number
Software version
Baseband Version
Android version
Kernel version
Build number
SCOUT configuration
Mobile Network Code
Mobile Country Code
Date/time of SCOUT client check-in with cloud server
Last date/time of App Updater client check-in with server
Location (GPS coordinates)
Wi-Fi network connected
Free device memory (ROM)
Current battery percentage
Current battery status (charging/not charging)
Maximum battery temperature recorded
List of all installed applications – package name of the application
List of all installed applications – version number of the application
Application assigned to PTT Key
Application assigned to Yellow Key
Application assigned to Alarm Key

The personal information Sonim collects helps Us provision software updates, offer better Product (defined below) support and assists Us in determining what Services may benefit You in the future. A “Product” or “Products” include(s) Sonim’s (i) Handsets, (ii) data and workflow applications, (iii) industrial-grade accessories, and (iv) any other products Sonim may release from time to time.

Why We Collect and Process Your Information

Sonim collects and processes personal information that You directly provide Us, or that We believe is necessary to provide You with the best possible experience with Our Site and Services.  This can be accomplished in a variety of ways, including the following manners:

Limited Warranty Registration.  Registering Your Handset with Sonim ensures that You enjoy the full benefit of Our three year limited warranty.  The personal information You provide Us in connection with the registration of Your Handset allows Us to quickly provide You with the focused support You need to minimize any interruption in Your use and enjoyment of Our Site and Services.

Sonim’s Site.  Our Site uses cookies to understand how You use Our Site so We can design better Services in the future and customize web page content based on Your browser type and Your previous browsing activity.  A cookie is a small file that is sent from a website’s server and placed on a device when You visit a website.  These cookies may only be stored for a brief period of time – during the time You visit a Sonim Site (“session cookies”), or for a fixed period of time (“persistent cookies”).  You can adjust or disable cookies by navigating to the settings or options section of Your web browser. Limiting or disabling cookies on Our Site may prevent Sonim from providing You with the full array of Services or functionality available to You.

Feedback.  Sonim is always interested in learning how to enhance the user experience of its Site, Products and Services.  Luckily, there are several ways You can reach out to Sonim if You have input that you wish to share.  You may call us at +1 (650) 378-8100 or navigate to the “Contact Us” section on our website (https://www.sonimtech.com/contact/). Sonim may ask for Your name, phone number, email address, network carrier and company name/size in order to better assist You, or so that we can follow up on specific information You have provided Us.  Please note that the personal information You provide Us will be treated as “Feedback” according to Our Terms.  You can find a copy of Our Terms here https://www.sonimtech.com/about/terms-of-use/.

Sonim Cloud.  Sonim provide cloud-based tools and Services through the Sonim Cloud website located at www.sonimcloud.com. The tools are a valuable resource that will help You realize the potential of Your Handset.

Applications.  Sonim offers mobile applications to enhance the capability of Sonim Handsets and Services. These applications collect personal information from You and Your device to provide You with tools to better use and manage Your Handset, and to keep You up-to-date on software improvements.  Your use of Sonim’s Services shall be governed by, and remain subject to, the terms of our Agreement.

Support. Sonim provides support for its Handsets twenty-four (24) hours a day, Monday through Friday through its customer experience center (CEC).  Sonim can be reached via email, phone or chat (from its main webpage) in order to assist You with troubleshooting potential issues as they relate to Your Handset.

How We Share and Disclose Your Personal Information.

The personal information Sonim collects will only be used and transferred to Sonim, its global offices and subsidiaries, and its reseller distributors and service providers (“Partners”).  Each of these companies have been contracted by Sonim to provide specific information and services, and are permitted to use Your personal information only to the extent permitted by applicable law. While Sonim and its Partners may use the personal information We collect for a number of purposes pursuant to legal authorization, Our primary purpose for collecting information is to provide You with a positive User experience of Our Products and Services.  Sonim does not sell, lease or rent Your individualized personal information to third parties and will not do so without You providing Sonim Your consent.

Sonim may need to be in contact with You for the following reasons:

• To help You open Your account on a Sonim Site;
• To help facilitate the purchase of Our Handset or Services on Our web-based store;
• To update You on new Product or Service announcements, as well as special offers that We believe may be of interest to You, including joint sales promotions with one of Our partners;
• To provide You with support for Our Handsets or Services, We may be required to share Your personal information:
  • If Your personal information must be shared with a third party, Sonim will provide only what is needed by the third party to provide the needed support. Any third party who is provided with Your information is prohibited from using it for any purpose other than for the provision of support services.
• To alert You to information regarding Your Sonim account;
• To protect You from unauthorized communications (i.e., spam) or other security risks;
• To keep You updated on important information regarding the Services We provide;
• To execute on actions requested by You, including the resolution of disputes;
• To enforce this Privacy Policy, Our Agreement, Terms or any other applicable policies.

Sonim may also use Your personal information for the following purposes:

• To pass sales leads to one of Our distribution partners;
• To facilitate the delivery of items You purchased through Our Site;
• To provide You with relevant delivery and tracking notifications, to the extent permitted by applicable law without Your consent;
• To provide You with warranty service or Product or service updates, and information on special offers;
• To ensure You are running the latest version of software on Your Handset;
• In connection with certain business transitions, including the negotiation of a merger, sale of all or a portion of the company’s assets, or the consolidation or restructuring of the company, or
• For other legitimate purposes permitted by applicable law.

How We Protect the Information You Provide Us

Sonim understands the importance of keeping Your personal information safe and secure.  When You use Sonim’s Handsets or Services, or browse Our Site, We use appropriate technical and administrative procedures to safeguard Your personal information. Your personal information may be stored or processed on Our server Using Amazon Web Services (“AWS”), a cloud computing platform, in the United States or any other country where Sonim, its subsidiaries or its service providers are located. When You use Sonim’s Site and Services, You are transferring information to the United States and other locations where Sonim or its service providers operate. If Your personal information is transferred outside of Your country, Sonim will provide You with notice as required by law.

Sonim maintains reasonable safeguards to keep Your personal information confidential, sound and secure, but cannot guarantee the security of the personal information provided to Us, as no transmission of information over the public Internet is ever completely safe and secure. Therefore, Sonim cannot guarantee that Your personal information will not be subject to unauthorized disclosure, misuse or alteration.  Sonim will not be responsible for security breaches beyond its reasonable control.

If Sonim learns of and confirms the occurrence of a security incident leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Your personal information, or Your personal information is transmitted, stored or otherwise processed by Sonim that compromises its confidentiality, integrity or availability, Sonim may attempt to notify You electronically by posting a notice on Our Site or by sending You an email. You may have a legal right to receive this notice in writing or in any other form required by applicable law.

Disclosure to Appropriate Authorities

Sonim may use Your personal information as necessary or appropriate under applicable law, to comply with a request for information from a competent authority if We believe the disclosure of such information is required by law enforcement or any applicable law, regulation or legal process, or such disclosure is in the interest of national security.

Your information may also be used to help investigate potential violations, and to detect, prevent or tackle fraud, security or other technical issues to protect Our rights, privacy safety or property, and to allow Us to pursue available remedies to limit the damages that We may sustain.  We may use personal information without Your consent or court process in the event a claim of personal or public safety is brought forth, or for a litigation claim where the information in question is pertinent.

Your Privacy Rights and Your Choices

Sonim is committed to respecting Your rights under all applicable data privacy laws.  Should You reside or find Yourself in a jurisdiction with unique data privacy laws, Sonim is committed to respecting Your rights granted by such laws.

To the extent You have provided Sonim with personal information, Sonim encourages You to keep it accurate and up-to-date.  Your personal information may often be updated online.  If You have questions about Your privacy rights, or wish to exercise Your rights under applicable data privacy laws, You may contact Sonim at support@sonimtech.com or write Us at 4445 Eastgate Mall, Suite 200, San Diego, CA 92121.  Alternatively, You may call Us at 1-833-MY-SONIM (1-833-697-6646).  When You contact Us, You may request to:

• Access Your personal information.
• Correct, restrict or delete Your personal information.
• Obtain the personal information You provide to Us under a contract or with Your consent in a structured, machine-readable format.
• Allow Us to share or port Your personal information with or to another entity.

Should You contact Sonim for the release of Your personal information, Sonim may require additional verification of Your identity to ensure it is released only to someone authorized to view such information. In the event Sonim requests separate information to verify Your identity or Your address, We will only use this information for the sole purpose of verifying Your identity as related to Your personal information request.  The additional information You provide Us may be retained as part of Our standard recordkeeping practices for such transactions, and will be covered by Our collection, use and protection best practices.

Your Responsibility

While Sonim maintains reasonable safeguards to keep Your personal information confidential, it remains Your responsibility to keep Your login information, including Your Username and password for Your Sonim accounts safe from third parties.  Should You suspect any unauthorized disclosure of Your Sonim account password, please contact Sonim immediately.

Duration of Personal Information Retention

Your personal information will be stored by Us and Our service providers in accordance with applicable data protection laws, and to the extent necessary for Sonim to process Your personal information per Our Terms, Agreement, and this Privacy Policy.

Children and Privacy

Sonim understands the importance of protecting the privacy of children.  That’s why neither Sonim, nor its Site or Services are designed for, intended to attract, or directed toward children under the age of 16.  Sonim will not knowingly solicit personal information from children under the age of 16, send requests for personal information, or collect personal information from children on its Services.

If You are under the age of 16, please do not attempt to register on Sonim’s Site or provide Sonim with any of Your personal information. If Sonim learns that a child under the age of 16 has submitted personal information, Sonim will promptly delete the information. If Your child has submitted personal information and You would like to request such information be deleted from Sonim’s records, please contact Sonim at 1-833-MY-SONIM (1-833-697-6646), support@sonimtech.com, or via mail at 4445 Eastgate Mall, Suite 200, San Diego, CA 92121.

Linked Third Party Sites

Sonim’s Sites may provide links to other third-party websites that are outside of Sonim’s control and not covered by this Privacy Policy.  Notwithstanding the above, Sonim will not disclose Your personal information to organizations operating such third party websites.  Sonim will not be liable for any information, services, software, products or other documentation or materials made available on or through a third party website.  Sonim does not review or endorse the information found on a third party website, nor is it responsible for the privacy practices of these organizations.   It is Your responsibility to review the privacy policies of the third party websites You visit.

Privacy Policy Changes

From time to time, Sonim may update its Privacy Policy.  If and when We make changes that will impact Your personal information, Sonim will alert You to these updates by posting a revised statement on Our Sites.  By continuing to use Sonim’s Sites, You hereby agree to be bound by the revised terms of Our Privacy Policy, Agreement and/or Terms.  If You do not accept Our changes, please delete Your account and stop Using Sonim’s Services.

Contact Information

Should You have any questions, concerns or complaints regarding this Privacy Policy, Agreement or Our Terms, or wish to exercise any of Your rights, please contact Sonim at 1-833-MY-SONIM (1-833-697-6646), support@sonimtech.com, or via mail at 4445 Eastgate Mall, Suite 200, San Diego, CA 92121, USA.

Notice of Privacy Rights for California Residents

Updated Effective January 1, 2020

California Consumer Privacy Act (CCPA)

As a California Resident, Sonim is required to provide You with additional information about how We use and disclose Your personal information.  This Notice of Privacy Rights for California Residents (“California Privacy Notice”) is supplemental to the information contained in Our Privacy Policy, and only applies to visitors, Users and others who reside in the State of California (“You” or “Consumers”) who visit Our Sites, Services and other platforms where this California Privacy Notice is posted (Our “Online Presence”).  This supplement is adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Terms defined in the CCPA shall have the same meaning when used in this California Privacy Notice.

The Information We Collect

Sonim may collect 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 or device (”personal information”).  Specifically, Sonim may collect the following categories of personal information from You when visiting Our Online Presence within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Sonim may obtain the categories of personal information listed above from the following categories of sources:

• Directly from Our customers or Our partners. For example, a customer provides Sonim a personal address to ship one of Our Handsets.
• Indirectly from Our customers or partners as part of Our Services. For example, the payment method associated with a customer’s purchase of one of Our Handsets on Our online store.
• Directly and indirectly from activity on Our Sites. For example, from submissions through Our website portal or website Usage details collected automatically.

Use of Personal Information

Sonim may use the personal information collected for one or more of the following business purposes:

• To fulfill or meet the reason for which You provided Sonim the personal information.
• To provide You with information, Products or Services You requested from Sonim.
• To provide You with email alerts and other notices concerning Our Products, Services or news that may be of interest to You.
• To carry out Sonim’s obligations and enforce Sonim’s rights arising from any purchases or other transactions.
• To improve Our website and present its contents to You.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect Sonim’s rights, property or safety, or the safety of Sonim’s clients or others, as the case may be.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As Sonim has described when collecting Your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us is among the assets transferred.

Sonim will not collect additional categories of personal information or use the personal information We collect for materially different, unrelated, or incompatible purposes without providing You notice.

Sharing Personal Information

Sonim may disclose Your personal information to a third party for a business purpose. When Sonim discloses personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, We may have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category E: Biometric information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I:  Professional or employment-related information.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Category K: Inferences drawn from other personal information.

We disclose Your personal information for a business purpose to the following categories of third parties:

• Sonim affiliates and subsidiaries.
• Service providers.
• Third parties to whom You or Your agents authorize Us to disclose Your personal information in connection with Products or Services We provide to You.

Sonim does not sell Your personal information to third parties for their direct marketing purposes.

Your Rights and Choices

The CCPA provides Consumers (California residents) with specific rights regarding their 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 Sonim discloses certain information to You about Our collection and use of Your personal information over the past 12 months. Once We receive and confirm Your verifiable consumer request, We will disclose to You:

• The categories of personal information Sonim collected about You.
• The categories of sources for the personal information Sonim collected about You.
• Sonim’s business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom Sonim shared that personal information.
• The specific pieces of personal information Sonim collected about You (also called a data portability request).
• If Sonim sold or disclosed Your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Sonim deletes any of Your personal information that We collected from You and retained, subject to certain exceptions. Once Sonim receives and confirms Your verifiable consumer request, We will delete (and direct Our service providers to delete) Your personal information from Our records, unless an exception applies.

Sonim may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug Products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
• Enable solely internal Uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful Uses of that information that are compatible with the context in which You provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by either:

• Calling Us at 1-833-MY-SONIM (1-833-697-6646), or
• Emailing Us at support@sonimtech.com.

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 personal information. You may also make a verifiable consumer request on behalf of Your minor child.

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 personal information or an authorized representative.
• 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 personal information if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. Making a verifiable consumer request does not require You to create an account with Us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Sonim endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Sonim requires more time (up to 90 days), We will inform You of the reason and extension period in writing. Any disclosures Sonim provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Sonim provides will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, Sonim will select a format to provide Your personal information that is readily Useable and should allow You to transmit the information from one entity to another entity without hindrance.

Sonim does not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Sonim determines 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.

Non-Discrimination

Sonim 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 service.

Changes To Our California Privacy Notice

We reserve the right to amend this Notice at Our discretion and at any time. When We make changes to this Notice, We will indicate that the Notice has been updated on Our website. Your continued use of Sonim’s Site following the posting of changes constitutes Your consent to and acceptance of such changes.

Contact Information

You may have additional rights regarding how Sonim Uses and discloses Your information.  Please contact Sonim at 1-833-MY-SONIM (1-833-697-6646), support@sonimtech.com, or via mail to 4445 Eastgate Mall, Suite 200, San Diego, CA 92121 U.S.A  if You have questions or concerns about how We process Your data, or would like to exercise any of Your California privacy rights.

Please identify Yourself as a California resident, and provide Sonim with information sufficient to allow Us to perform the appropriate action(s). If You have a Sonim account, We may require You to complete Your request through Your account, to the extent such request is permitted by applicable law.

California Do Not Track California’s Online Privacy Protection Act requires Sonim to let You know how We respond to web browser Do Not Track signals. Some web browsers may allow You to enable a do-not-track feature that informs the website You visit that You do not want Your activities to be tracked.  At this time, Sonim’s website does not respond to Do Not Track browser settings or signals.  Sonim is not aware of a universally accepted standard for how to respond to a do-not-track requests.  Should a final and universally accepted method for responding to do-not-track requests be instituted, Sonim will take the method under advisement and provide an appropriate response.

California “Shine the Light” Law

If You are a California Resident, California Civil Code Section 1798.83 (the California “Shine the Light” law) permits You to request information regarding Sonim’s disclosure (if any) of Your personal information to third parties for the purposes of their direct marketing.  You may contact Sonim Using the information above to make such a request, but You must first identify Yourself as a California resident, and provide Sonim with sufficient information, including Your name, phone number and email address, and any other information as required, to allow Sonim to take the appropriate action.

Notice of Privacy Rights for EU Residents

Updated Effective January 1, 2020

Genera Data Protection Regulation (GDPR)

Where the processing of your Personal Information is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law.

• Access:  Request access to your personal data, as that term is defined in the GDPR;
• Rectification:  Request correction of your personal data;
• Erasure:  Request erasure of your personal data;
• Objection:  Object to some processing of your personal data;
• Restriction:  Request restriction of processing of your personal data;
• Portability:  Request the transfer of your personal data to you or to a third party;
• Withdrawal of Consent:  Withdraw your consent to processing your personal data; or
• Automated Decision-Making:  The right not to be subject to having a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.

In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law.

If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or to submit a Data Subject Access Request to exercise any other data subject right, please send a written request to support@sonimtech.com or via mail to 4445 Eastgate Mall, Suite 200, San Diego, CA 92121 U.S.A.  While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.