Privacy Policy

Last Revised: August 27, 2012

This Privacy Policy ("Policy") explains how information about you is collected, used and disclosed by FreedomPop and its subsidiaries and affiliates ("FreedomPop," "we" or "us"). This Policy applies to all of the websites (including www.freedompop.com) (the "Site"), subdomains, products, applications (including mobile applications and applications and pages operated by FreedomPop and available on social networking sites and other platforms and our downloadable products) and services offered by FreedomPop (collectively, the "Services"). We value your privacy.

By using our Site and our Services you agree to this Policy. Please read this Policy carefully. If you disagree with the way we collect, use, disclose, or transfer your personal information, or any other practice described in this Policy, please do not use this Site or our Services.

  1. INFORMATION WE COLLECT

    We collect information, including personal information, about you when you visit our Site and use our Services, including, information that we collect directly from you, information that we collect about you from third parties, and information that we collect automatically as you visit our Site and use our Services.

    1. Information We Collect Directly From You. We request information directly from you when you interact with our Site and use our Services. Specifically, we request information from you when you register or subscribe to our services, including: your first and last name, contact information (e.g., email and postal address, mobile and home phone numbers), credit card and billing information, and demographic information. If you purchase a service from us, then certain of the above-listed information is required, but other information (e.g., demographic) is optional. From time to time, we may request that you provide us with additional demographic information, such as your birth date, salary, education, marital status, and employment. This information is not necessary for the provisioning of your service, but we may use it to identify other products and services that may be of interest to you and for the purposes described in the section "How We Use Your Information."
    2. Information We Collect About You From Third Parties. We also may obtain information about you from third parties, such as email appends services, social networking sites, and our Refer a Friend Program. We may combine this information with other information that we have collected about you.
      • Social Networking Sites. You may log into certain of our Services through a social networking site (e.g., Facebook). If you do so, then we will request certain permissions, which will vary based on the particular social networking site, but may include a request to access your basic information, post to your wall, or take other actions applicable to that particular social networking site. In addition, if you use any of our applications found on social networking sites, we also may collect information from you, including your profile information. For information about how the social networking site may disclose your information, including any information you make public, please consult its privacy policy. We have no control over how the social networking site uses or discloses the personal information that you provide to it. We store the information that you receive from the social networking sites along with other information that we collect from you or receive about you.
      • Refer a Friend. If you use our invitation service to tell a friend about our Site and our Services, we will ask you for information to send the invitation, such as your friend's email address, first name and last name. We will send your friend an email inviting him or her to visit the Site or one of our Services, as applicable. FreedomPop stores this information to send this invitation, to register a friend connection if your friend accepts our invitation, and to track the success of our referral program. Your friend may contact us at unsubscribe@freedompop.com to request that we remove this information from our database.
    3. Information We Collect Automatically. We use cookies, web beacons, and other automated devices to collect information about visitors to our Site and users of our Services. Specifically, when you access our Site and our Services, we automatically record information about you, such as your IP address, browser type, Internet service provider, platform type, the website from which you came, and the website to which you are going when you leave our Site, date and time stamp, and one or more cookies that may uniquely identify your browser or your account. When you access our Services using a mobile device, we may receive or collect your mobile device ID (often referred to as UDID), mobile carrier, device manufacturer and phone number. We also collect information about your usage of, and activity on, our Services. We and service providers acting on our behalf, such as Google Analytics, use this information to understand and analyze trends, to administer our Services, to gather demographic information about our user base and to deliver you a more personalized experience. We combine this information with other information that we maintain about you, including your personal information, and, for our registered users, we may associate this information with your username. Please see the section below entitled "Use of Cookies, Javascript, Web Beacons, and Other Tracking Devices."
  2. CHILDREN UNDER 13

    We do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, we will delete it from our database.

  3. USE OF YOUR INFORMATION WE COLLECT

    We use your information, including your personal (collectively, "information"), for the following purposes:

    1. To Provide Products & Services. We use your information to provide our Services to you and for the purposes described in this Policy, including the following:
      1. to operate, provide, maintain, develop, and deliver our Services;
      2. to maintain and administer your FreedomPop account;
      3. to maintain and display your FreedomPop profile;
      4. to respond to your comments and questions and to provide customer service;
      5. to provide you with confirmation of purchases, invoices, support and administrative messages;
      6. to perform other functions as otherwise described to you at the time of collection; and
      7. link or combine information about you with other information we obtain from third parties to help understand your needs and provide you with better service.
    2. Marketing. We use your information to offer you our products and services as well as third party products and services to you that may be of interest to you. This may include passing your information on to a third party. For additional information about how a third party might use your information, please see the section below entitled, "Sharing Information with Third Parties."
    3. Service Improvement and Development. We use your information to respond to your inquires; operate and improve our Services or emails, improve and create a positive user experience with our Services or emails; and deliver our Services to you. Our Services include the display of personalized products, content, and advertising relating to your experience and interests.
    4. To administer contests and promotions;
    5. To send you emails, including about products and services that we believe might be of interest to you; and, with your consent (and depending upon the particular product or service that you have ordered), to send you text messages;
    6. Where permitted by law, and if you have not opted out, for telemarketing purposes;
    7. To detect and prevent abusive, fraudulent, malicious or potentially illegal activities, and to protect the rights, safety or property of FreedomPop or our users; and
    8. To keep you posted on our latest product or service announcements, software updates, security alerts and any technical notices, and products and services that may be of interest to you.
  4. SHARING INFORMATION WITH THIRD PARTIES

    We share your information, including personal information, with the following entities and for the purposes described below.

    1. Affiliates and Third Parties. We share your information with third parties so that they can understand the kinds of visitors to our Site and users of our Services, how those visitors use our Services, and for research purposes. We also share your information with affiliates and third parties for their own marketing purposes. (For California residents, please see our special notice below.)
    2. Business Transfers/Bankruptcy. We may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, if we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court.
    3. Legal Process. We disclose information if legally required to do so, or at our discretion pursuant to a request from a governmental entity or if we believe in good faith that such action is appropriate to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
    4. Service Providers. We may share your information with third parties who perform function on our behalf, such as to process your order and to assist with order provisioning. These service providers also may help us perform technical functions, host our Services, analyze our data, provide marketing assistance, and provide customer service.
    5. Joint Venture/Promotional Partners. If we run a promotion or contest, we may share your information with the other sponsors of the contest for marketing and other purposes.
    6. To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Policy.
    7. Aggregate and Anonymized Information. We may share aggregate or anonymized information about you with third parties for marketing, advertising, research or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregate, demographic information with that third party about the users to whom we displayed the advertisements.

    In each of these situations, the recipients of your data may potentially be located in any country in the world.

  5. USE OF COOKIES, JAVASCRIPT, WEB BEACONS, AND OTHER TRACKING DEVICES

    1. Cookies. We and third parties use cookies on our Site and at our Services. "Cookies" are a feature in your browser software. We use cookies that may store small amounts of data on your computer about your visit to any of the pages of this Site or our emails. Cookies assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits. When you visit this Site again, cookies can enable us to customize our content according to your preferences. We may use cookies, for example, to keep track of the number of return visits to this site; accumulate and report aggregate, statistical information on website usage; deliver specific content to you based on your interests or past viewing history; and to save your password for ease of access to our Site. You can disable certain types of cookies, but portions of the Site (such as account creation, ordering, and account management) may not work properly if you disable cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. There are two types of cookies: session-based and persistent cookies. We also allow third parties to place cookies on our Site.
      • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
      • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information. We also use persistent cookies to enable us to recognize whether you have responded to a questionnaire or completed a registration.
      • Third Party Cookies. We also engage third parties to track and analyze non-personal and personal information and to serve advertisements. To do so, we may permit third parties to apply cookies to users of our Site, where permitted by law, and, subject to your right to opt-out through the Network Advertising Initiative (as discussed below). We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze site usage. Such third parties may combine the information that we provide about you with other information that they have collected.
    2. JavaScript. We may also use JavaScript within certain advertisements. JavaScript is a computer language that enhances the functionality of websites, particularly in respect to pictures. We do not collect any personal information via JavaScript but use it to analyze and improve the Site's functions. You may deactivate JavaScript via your browser settings or activate it the same way. If you disable JavaScript you will not be able to use some of the functions of our Site.
    3. Web Beacons. We also use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs or action tags) that allow us to collect certain information about your visit to these web pages (including the number of users who have visited those pages), measure and improve the effectiveness of advertisements, and deliver services. Web beacons collect information such as a cookie number, time and date of page view and a description of the page on which the web beacon resides. This information may be shared with one or more third parties so that they can understand the kinds of visitors to our Site and our Services, how those visitors use our Site, and the effectiveness of their advertisements. We may also use web beacons in email messages that we send to you, for example, to track whether recipients read our emails. Because web beacons are the same as any other content request, you cannot opt out or refuse them. web beacons can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.
  6. ADVERTISEMENTS

    We display advertisements on our Site. We use third parties such as network advertisers to serve these advertisements. Network advertisers are third parties that display advertisements based on your visits to our Sites and other websites you have visited. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third- party advertisers with information about your usage of our Site and our Services, both personal and non-personal information.

    We do not control these advertisers or advertising networks or any other third parties whose websites may be linked from our Services or their practices.

    We also do not control the data use practices of those persons or entities that may access your information on this Site for the purposes of providing the service or product you have requested or third party Ad Networks. We encourage you to review the privacy policies and opt-out choices of those third parties so you can understand how they collect, use and share your information.

    Some of the advertisements are based on the collection of personal information and others are based on the collection of aggregate information.

    You may opt-out of many third-party ad networks. The website http:// www.networkadvertising.org/optout_nonppii.asp provides information regarding this practice by Network Advertising Initiative ("NAI") members, and your choices regarding having this information used by these companies, including how to "opt-out" of third-party ad networks operated by NAI members. You also may contact the Digital Advertising Alliance ("DAA") at http:/ /www.aboutads.info/choices/ for information about opting out of targeted advertising and your choices regarding having information used by DAA, including how to "opt-out" of third-party ad networks operated by About Ads members. Opting out of one or more NAI members or DAA members (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you, but it does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites accessible by the above links.

  7. YOUR PREFERENCES/OPTING-OUT

    If you do not want to receive marketing or advertising from us via email, you may opt-out by following the instructions contained in the email. You also may exercise your email preferences by logging into your account and following the link to email preferences. It may take up to 10 days to process your request. Please note that we will continue to send you customer service related emails even if you have opted out of receiving marketing communications from us. If you subscribe to services from different affiliates, you may need to unsubscribe from each affiliate's marketing list.

    Under your email preferences, you also may opt-out of certain third party marketing. If, however, we already have shared your name with a particular third party, then you will need to contact that third party to opt-out of future communications.

  8. UPDATES TO THIS POLICY

    We reserve the right to modify this Policy from time to time. If we make any changes that materially affect the use of your personal information, we will endeavor to notify you by changing the "Last Revision" date and posting the updated Policy on this Site.

  9. SPECIAL NOTICE FOR CALIFORNIA RESIDENTS

    A California resident has the right to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. California customers may request a list of the entities with which we have shared your information for their direct marketing purposes and the categories of information that we have shared. If you would like to request this information, please provide proof of your California residency and a request via email to: privacy@FreedomPop.com. You may make one request per calendar year.

  10. SAFEGUARD AND PROTECTION OF INFORMATION MEASURES

    We take measures to protect your information. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through this site is at your own risk.

  11. LINKS TO THIRD PARTY WEBSITES

    FreedomPop Services and emails may also post links to other websites over which we have no control. As such, we are not responsible for the privacy policies or practices of other websites when you choose to link from this Site. We encourage you to review the privacy policies of those other web sites so you can understand how they collect, use and share your information.

  12. NOTICE TO NON U.S. USERS

    Our company is located in the United States. You may be located in a country that has laws that are more restrictive about the collection and use of your personal information. By using this Site and our Services, you agree that your personal information will be transferred to and stored in the United States.

  13. CONTACTING FREEDOMPOP

    If you have questions about this Policy, please contact us at privacy@FreedomPop.com or by writing to us at: FreedomPop, Inc., Attn: Privacy Matters, 11301 W Olympic Blvd Ste 112, Los Angeles, CA 90064-1652