PREMIO MOBILE · PUERTO RICO
Privacy Policy
Fecha de vigencia: October 1, 2026
Premio Mobile is a brand of The Trinity Link, LLC, a Puerto Rico limited liability company.
Este documento legal está disponible actualmente en inglés. Conforme a los Términos y condiciones, la versión en inglés prevalece en la medida permitida por la ley.
1. Introduction and Scope
Premio Mobile is a brand of The Trinity Link, LLC, a Puerto Rico limited liability company ("Premio Mobile", "we", "us", or "our"). We are committed to protecting the privacy and security of the personal information of our customers, prospective customers, website and app visitors, and other individuals who interact with our services (collectively, "you"). This Privacy Policy explains what information we collect, how we use and share it, the choices and rights available to you, and how to contact us. Premio Mobile is a mobile virtual network operator (MVNO) service. We do not own a wireless network. Your wireless connectivity is provided over the network of Liberty Puerto Rico. Your service is delivered with the help of the following partners, each of which handles personal information on our behalf only as needed to provide and support your service:
Liberty Puerto Rico, which provides the underlying wireless network connectivity for your service
MVNX Link, LLC, which provides the billing system, customer web and app portal, and related back-office technology platform that supports your account, and acts as our technology and billing service provider
Customer care, payment, and other service providers that help us support your account, as described in
Section 9 Together, these partners are referred to in this Policy as our "Network Partners." Each is bound by contractual data- use, security, and confidentiality restrictions. Premio Mobile is not owned by or affiliated with Liberty Puerto Rico. If you would like to know which companies currently serve in these roles, contact us using the information in Section 17. This Policy applies to personal information we collect through our website(s), mobile application(s), customer service channels (including phone, chat, email, and any AI-assisted support tools), retail or point-of-sale interactions, and any other means by which you interact with Premio Mobile. It does not apply to third-party websites, applications, or services that we do not own or control, even if linked from our services. This Policy is intended to comply with applicable United States federal law and the laws of the Commonwealth of Puerto Rico. Where a specific federal, Puerto Rico, or other state law grants you rights broader than those described in this Policy, that law governs to the extent it applies to you.
2. Definitions
For purposes of this Policy, the following terms have the meanings below. Some terms are drawn from specific laws and apply only to the extent those laws apply to you.
Personal Information Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Sensitive Personal Information A subset of personal information that deserves heightened protection, which may include precise geolocation, government identifiers (such as Social Security number, driver's license, or passport number), financial account information, biometric data used for identification, and health information.
CPNI (Customer Proprietary Network Information) Information collected by a telecommunications carrier relating to the quantity, technical configuration, type, destination, location, and amount of use of your telecommunications service, and information contained in your telephone bill, as defined under Section 222 of the Communications Act and FCC rules at 47 C.F.R. Part 64, Subpart U. CPNI is subject to specific federal use, disclosure, and security requirements described in Section 6.
Automated Decision-Making The use of a computational process, including one derived from artificial intelligence or machine learning, to process personal information and evaluate, analyze, or predict aspects of an individual's behavior, characteristics, or preferences, with or without human involvement.
Sale and Sharing "Sale" generally means the exchange of personal information for monetary or other valuable consideration to a third party. "Sharing" generally means disclosing personal information to a third party for cross-context behavioral advertising. Our practices are described in Section 9.
3. Information We Collect
We collect the following categories of information about you:
Identifiers and Account Information
Name, mailing address, email address, phone number
Account credentials and account or subscriber number
Government-issued identification or date of birth, where required for identity verification, number porting,
SIM activation, or fraud prevention
Payment and billing information, including payment card or bank account details (processed by our payment processor)
Network, Service, and CPNI
Call and messaging detail records, including numbers dialed or received, call duration, and timestamps
Data usage volumes and session information
Device identifiers (IMEI, SIM/ICCID, MAC address), device make and model, and network and roaming status
Precise or approximate location information generated by your device's use of the network, where enabled
Customer Service and Support Data
Records of your communications with us, including phone call recordings (with notice as required by law), chat transcripts, and email correspondence
Interactions with automated or AI-assisted support tools, as described in Section 5
Technical and Online Activity Data
IP address, browser type, operating system, and device type
Pages viewed, links clicked, referring and exit pages, and other usage data collected through our website and app
Information collected through cookies and similar technologies (see Section 10)
Information from Third Parties
Fraud-prevention databases and identity-verification services, used to confirm your identity and prevent fraud (such as unauthorized SIM swaps)
Retail partners, authorized dealers, or distributors through which you purchased service
Our Network Partners, in connection with provisioning and service delivery
4. How We Use Your Information
We use the categories of information described above for the following purposes:
Service delivery: to provision, activate, maintain, bill for, and support your wireless service, including functions performed by our Network Partners
Account and customer management: to create and manage your account, process payments, and respond to inquiries
Fraud prevention and security: to detect, investigate, and prevent fraud, unauthorized account access, SIM- swap fraud, and other misuse of our services
Network management: to monitor, maintain, and optimize network performance and capacity
Communications: to send service-related notices and, where you have provided consent or as otherwise permitted by law, marketing and promotional communications (see Section 6 regarding TCPA and CAN-
SPAM)
Legal and regulatory compliance: to comply with applicable law, respond to lawful requests from public authorities, and meet telecommunications regulatory obligations, including CPNI, E911, and law enforcement assistance obligations
Product improvement: to understand how our services are used and to develop, test, and improve our offerings
To operate and improve automated and AI-assisted tools used in providing service to you, as described in
Section 5
5. Our Use of Artificial Intelligence and Automated Decision-Making
We use, or may use, artificial intelligence (AI), machine learning, and other automated systems to help operate and improve our services. This section describes those uses and the choices available to you.
Where We Use AI and Automated Systems
Customer service: we may use AI-assisted chat and automated call-routing and response tools to answer questions, troubleshoot service issues, and route you to a live representative
Fraud and security: we use automated systems and machine-learning models to detect potentially fraudulent activity, such as SIM-swap attempts, or unauthorized account changes, and to flag accounts for further review
Account and service recommendations: we may use automated systems to recommend plans, add-ons, or offers based on your usage patterns
Network operations: we use automated and AI-based tools to monitor and optimize network performance; these tools do not make decisions about individual customers
Quality assurance: customer service interactions, including calls and chats, may be analyzed by automated tools (in addition to human review) for quality, training, and compliance purposes
Automated Decisions with Legal or Similarly Significant Effects Where we use automated decision-making to make a decision that produces a legal or similarly significant effect concerning you, such as a decision to deny or suspend service or restrict your account based solely on automated processing, we will, to the extent required by applicable law, give you notice that automated decision-making is being used, provide a meaningful explanation of the logic involved where feasible, and offer you the ability to request human review or appeal the decision.
How to Exercise AI-Related Rights To request human review of an automated decision that affected you, or to ask questions about our use of AI, contact us using the information in Section 17. We will verify your identity and respond within the time required by applicable law.
AI Assistants and Disclosure Our AI assistants include chat assistants, virtual agents, and voice assistants that help answer questions and handle routine account requests. When you chat or speak with one, we tell you it is an AI and not a person. You may ask at any time to speak with a person, and we will connect you to our customer care team as soon as reasonably possible during our support hours. Our AI assistants cannot change our Terms and Conditions, change your plan or price, or promise credits or refunds, as our Terms and Conditions explain.
Information You Share with AI Assistants We record and keep the transcripts and recordings of your conversations with AI assistants, together with the information they relate to, such as your account and plan details and the service issue you asked about. We ask you not to share your full Social Security number, full payment card number, bank account number, or password with an AI assistant, and we will never ask for your password through one. If you share information like that, we may take steps to limit or remove it from our records where we can. Identity verification for actions such as a SIM change or number transfer uses the secure methods described in Section 11 and not an AI conversation alone.
Human Review and Oversight People on our team, and service providers acting under contract, may review conversations with AI assistants to answer your request, to prevent fraud, to check quality and accuracy, to resolve complaints, and to train and improve our own tools. We test our AI tools and review their results, and we limit the information they can see and the actions they can take to what each task needs. We do not use an AI assistant to make a final decision to end your Service or deny a privacy request. A person makes or reviews those decisions.
AI-Generated Voices and Automated Messages If we contact you using an AI-generated voice, an artificial or prerecorded voice, or an automated system, we do so only with the consent the law requires, and we will tell you when you are speaking with an automated system or an AI-generated voice. You may opt out of marketing calls and texts at any time as described in Section 6.
Service Providers That Provide AI Tools We use service providers that supply AI technology, such as chat and voice platforms and fraud-detection tools. These providers may handle your information only to perform services for us and are bound by contract to protect it, to keep it confidential, and to use it only for our purposes. We do not allow them to use your personal information to train their own or third-party AI models that serve other customers, unless the information has been de-identified or aggregated as the next heading describes.
Accuracy and Limits AI tools can produce errors. We do not rely on an AI assistant alone to decide matters that significantly affect you, and you should check important information against your account, your plan details, and our Terms and Conditions. If you believe an AI assistant gave you wrong information or handled your information improperly, contact us using the information in Section 17.
Use of Personal Information to Train AI Models We do not use your personal information to train third-party or publicly available AI models. We may use de-identified or aggregated customer service interaction data, which does not identify you, to improve our own automated support tools. We do not use sensitive personal information, such as government identifiers or payment account numbers, to train AI tools.
6. Federal and Puerto Rico Regulatory Disclosures
Customer Proprietary Network Information (CPNI) As a provider of telecommunications service, Premio Mobile is required by Section 222 of the Communications Act and FCC rules (47 C.F.R. Part 64, Subpart U) to protect the confidentiality of your CPNI. We do not use, disclose, or permit access to your CPNI except as required or permitted by law, including to provide the service you have requested, to market additional communications-related services to you within the scope permitted by your approval status, to protect our rights or property, or to comply with legal process. These obligations extend to MVNX Link, LLC and our other Network Partners in their roles processing this data on our behalf, under contractual data-use restrictions. Where your approval is required before we use CPNI for certain marketing purposes, we will obtain that approval through the opt-in or opt-out method required by FCC rules. You may contact us at any time using the information in Section 17 to ask about, or change, your CPNI approval status.
Telephone Consumer Protection Act (TCPA) and CAN-SPAM We will only send you marketing calls, text messages, or emails in accordance with the consent requirements of the TCPA and the CAN-SPAM Act. You may opt out of marketing text messages by replying "STOP" and out of marketing emails using the unsubscribe link in those messages. Opting out of marketing communications does not affect service-related messages necessary to operate your account.
Communications Assistance for Law Enforcement Act (CALEA) and Lawful Process We may be required to assist law enforcement agencies in accordance with CALEA and to disclose information in response to a valid subpoena, court order, search warrant, or other lawful process, or in response to an emergency involving danger of death or serious physical injury.
Puerto Rico Law Premio Mobile is operated from Puerto Rico and serves customers in Puerto Rico. We handle personal information in accordance with the laws of the Commonwealth of Puerto Rico that apply to us, including its data security breach notification law, described in Section 12. You also have the right to file a complaint with the Puerto Rico Department of Consumer Affairs (Departamento de Asuntos del Consumidor, or DACO) or the Puerto Rico Telecommunications Bureau (Negociado de Telecomunicaciones de Puerto Rico).
7. Your Privacy Rights
Customers in Puerto Rico are protected by federal law and by Puerto Rico law. Some customers may also be residents of states with comprehensive consumer privacy laws. We extend the following core rights to all of our customers, regardless of where they live, except where noted or where the law requires us to keep the information:
Right to know and access: to confirm whether we process your personal information and to obtain a copy of it
Right to correct: to correct inaccurate personal information we maintain about you
Right to delete: to request deletion of personal information we have collected from or about you, subject to legal exceptions (for example, information we must retain for billing, tax, fraud-prevention, or regulatory purposes)
Right to portability: to receive a copy of certain personal information in a portable format
Right to opt out of targeted advertising and of the sale or sharing of personal information (we do not sell personal information or share it for cross-context behavioral advertising, as described in Section 9)
Right to request human review of automated decisions that have legal or similarly significant effects, as described in Section 5
Right to non-discrimination: we will not deny goods or services, charge different prices, or provide a different level of service because you exercised a privacy right
Right to appeal: if we decline to act on your request, you may appeal our decision using the process in Section 12 To exercise any of these rights, contact us using the information in Section 17. We will verify your identity before responding and will respond within the time required by applicable law, and in any event within 45 days, extendable by an additional 45 days when reasonably necessary. You may designate an authorized agent to submit a request on your behalf, subject to verification.
8. Children's Privacy
Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without verifiable parental consent, consistent with the Children's Online Privacy Protection Act (COPPA). Accounts are for adults 18 years of age or older. If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take steps to delete that information. A parent or guardian who believes we may have collected information from a child under 13 should contact us using the information in Section 17.
9. How We Share and Disclose Information
We disclose personal information to the following categories of recipients:
Liberty Puerto Rico, to provision, deliver, and support the wireless connectivity for your service and to meet regulatory obligations tied to it
MVNX Link, LLC, our billing, customer portal, and technology platform service provider, which processes your information to deliver account, billing, and support functionality on our behalf
Customer care providers and other service providers who perform functions on our behalf, such as payment processing, customer support platforms (including AI-assisted support tools), identity verification, and cloud hosting, under contracts that restrict their use of your information to the services they provide
Professional advisors, such as auditors, lawyers, and insurers, as needed
Law enforcement, government authorities, or other third parties where required by law, subpoena, court order, or other legal process, or to protect the rights, property, or safety of Premio Mobile, our customers, or the public
A successor entity in connection with a merger, acquisition, financing, or sale of assets
Other parties with your consent or at your direction MVNX Link, LLC and our other Network Partners are each contractually restricted from using your personal information for any purpose other than providing services to Premio Mobile and its subscribers, and from selling your personal information. We do not sell your personal information to third parties for monetary consideration, and we do not disclose it to advertising partners for cross-context behavioral advertising. We store personal information in the United States.
10. Cookies, Analytics, and Tracking Technologies
We and our service providers use cookies, web beacons, software development kits (SDKs), and similar technologies on our website and app to operate our services, remember your preferences, and analyze traffic and usage.
Types of Cookies We Use
Strictly necessary cookies, required for our website and app to function
Performance and analytics cookies, used to understand how visitors use our services
Functional cookies, used to remember your preferences
Your Choices You can control cookies through your browser settings and, where required by law, by responding to Global Privacy Control or other opt-out preference signals as described in Section 14.
11. Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction, including encryption of data in transit and at rest where appropriate, access controls, network monitoring, and vendor security requirements. Before we process a SIM change or a request to move your number to another provider, we use secure methods to verify your identity and notify you of the request, as required by FCC rules. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Data Breach Notification and Appeals
If we experience a security incident involving unauthorized access to personal information that triggers a notification obligation, we will notify affected individuals and, where required, regulators and consumer reporting agencies, in accordance with the Puerto Rico Citizens Information on Data Banks Security Act (Law 111 of 2005), which includes notice to the Puerto Rico Department of Consumer Affairs, any applicable breach notification law of another state or territory in which an affected person lives, and any applicable FCC telecommunications breach reporting requirements.
Appeal Rights If we decline to act on a privacy rights request described in Section 7, you may appeal by contacting us using the information in Section 17 and stating that you are submitting an appeal. We will respond to your appeal within the timeframe required by applicable law and will inform you of any further options, including the ability to contact the Puerto Rico Department of Consumer Affairs, the Federal Communications Commission, or your state attorney general, if we deny your appeal.
13. Data Retention
We retain personal information for as long as reasonably necessary to provide the services, fulfill the purposes described in this Policy, and comply with our legal obligations, including CPNI recordkeeping obligations, tax and accounting requirements, and fraud-prevention needs. Retention periods depend on the type of information and the reason we hold it. As examples, we generally keep account and billing records for the life of your account and for a period afterward that tax, accounting, and legal requirements call for, we generally keep AI assistant chat transcripts and call recordings for as long as we need them for support, quality, fraud prevention, and legal purposes, and then delete or de-identify them, and we keep call and messaging detail records for the period that applicable law and our carrier obligations require. When information is no longer needed, we securely delete or de-identify it.
14. Do Not Track and Global Privacy Control Signals
Some browsers transmit "Do Not Track" signals; because there is no accepted industry standard for responding to such signals, we do not currently respond to them. Where required by applicable law, we honor the Global Privacy Control (GPC) as a valid method to opt out of the sale or sharing of personal information and targeted advertising through participating browsers.
15. Third-Party Links and Services
Our website and app may contain links to third-party websites, applications, or services that we do not own or control. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing them with information.
16. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy with a new effective date and, where required by law, will provide additional notice of material changes (for example, by email or a prominent notice on our website) before the change takes effect.
17. Contact Us
If you have questions about this Policy or wish to exercise your privacy rights, please contact us: Premio Mobile, a brand of The Trinity Link, LLC