Fonex Inc. limits the information collected about you to what is needed for conducting business, including the offering of products and services that might be of interest to you. You may choose to provide “personally identifiable information” (PERSONAL INFORMATION) to Fonex Inc. in a number of ways either in person, telephonically or via our websites or mobile apps. Examples of how you may share PERSONAL INFORMATION with us include: ordering a service or equipment from us, sending us e-mail, responding to Fonex Inc. surveys, entering Fonex Inc.-sponsored contests or sweepstakes, registering to receive news or public information or applying for a job. We may also obtain PERSONAL INFORMATION from third parties (for example, credit agencies) with your permission.

Examples of PERSONAL INFORMATION are:

Name (including company name for business customers)

Unlisted or restricted mailing address

Unlisted or restricted telephone number

E-mail address

Credit card number or financial/bank account number or information, including routing numbers

Passwords or personal identification codes (PINs)

Date of birth

Social Security number

Driver’s license number or government issued identification number

Company contact information for business customers

Information obtained by Fonex Inc. through customer referral programs

The following information is not PERSONAL INFORMATION:

Mailing address, unless unlisted or restricted at your request

Telephone number, unless unlisted or restricted at your request

IP Address allowing you to use our internet service

Fonex Inc. may compile or aggregate PERSONAL INFORMATION from numerous customers or Web visitors or mobile app users to collect data about groups of customers or potential customers or categories of service. Fonex Inc. does not consider this “aggregate” information as PERSONAL INFORMATION because the aggregate information does not contain the PERSONAL INFORMATION of any individual customer, Web visitor, or mobile app user.

  1. Use of Personally Identifiable Information

Fonex Inc. uses PERSONAL INFORMATION to provide products and services to meet customers’ needs, including new products or services. Fonex Inc. may share PERSONAL INFORMATION with any Fonex Inc.-affiliated company, and these companies are subject to the terms of this Statement.

Fonex Inc. retains PERSONAL INFORMATION only as long as is necessary for Fonex Inc. to comply with business, tax and legal requirements. This retention period could be the entire time you are our customer depending on the type of PERSONAL INFORMATION.

Fonex Inc. does not:

Sell any customer data, whether it be defined as PERSONAL INFORMATION or otherwise, to third parties.

Collect PERSONAL INFORMATION from you unless you provide it to us in person, telephonically or electronically by visiting our websites or using our mobile apps, including information you provide in order to use our services.

Sell the names and addresses of Fonex Inc. Web visitors or mobile app users to unaffiliated suppliers, without your prior approval.

Allow third parties to change your service provider or otherwise access your account information, at your request, without complying with our security policies, including our Customer Account Protection Plan that protects your account from changes not authorized by you.

Information about our customers and users, including PERSONAL INFORMATION, may be shared and transferred as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which customer and user records would be transferred to another entity as a result of such a proceeding.

  1. SMS/Text Messaging

If you create an account and provide your cellular telephone number, Fonex Inc. may send you administrative text messages. If you opt in to receive promotional/marketing text messages, Fonex Inc. may also send you promotional/marketing text messages. If you wish to opt out of any type of text messaging sent to you by Fonex Inc., you may do so by following the “opt-out" instructions in the text message, or by editing your account settings.

  1. Customer Proprietary Network Information (CPNI)

CPNI is information that relates to the quantity, technical configuration, type, destination, location and amount of use of the telecommunications services purchased by you from Fonex Inc. CPNI is available to Fonex Inc. solely through its relationship with you and information contained in your bill for telecommunication services. CPNI does not include information that is typically classified as PERSONAL INFORMATION, such as your name or e-mail address and does not include compiled or aggregated PERSONAL INFORMATION. U.S. federal law requires Fonex Inc. to protect the confidentiality of CPNI. Unless you opt-out from the use of CPNI, Fonex Inc. may use CPNI to market service offerings to you to which you do not already subscribe. To opt-out, just contact us. Fonex Inc. may, without prior approval from you, use CPNI to provide or market service offerings to you, if the service offerings are within the same categories of service to which you already subscribe, regardless of your CPNI selection.

If you order Fonex Inc. services from a Fonex Inc. dealer, Fonex Inc.’s dealers are prohibited from accessing or using your CPNI unless you sign a consent form authorizing Fonex Inc. to release your CPNI to the dealers. Dealers are required by Fonex Inc. to take all necessary measures to protect the confidentiality of your CPNI. As part of the dealers’ agreements with Fonex Inc., dealers agree that, upon termination of your Fonex Inc. services, the dealers will promptly return all of your CPNI to Fonex Inc. and will not retain any CPNI in any form.

  1. Value-Added Services

Because we appreciate the trust you have placed in us, we continually look for ways to enhance your customer experience. From time to time, we may notify you about a Fonex Inc. product or service using the information you have provided to us either in person, telephonically or electronically by visiting our websites or using our mobile apps, including information you provide to use our services. We strive to limit our offers to those we think you would benefit from and appreciate receiving. We want every contact you have with us to be a positive experience. If you prefer not to receive these Fonex Inc. value-added services, offers and opportunities, just contact us.

Fonex Inc. complies with all applicable laws and regulations regarding “Do Not Call” Lists. Generally, Fonex Inc. is allowed to contact its customers, even if the customers are registered with federal or state Do Not Call Lists, because of our relationship with you. Fonex Inc. will, of course, honor any request to remove your name from our telephone, mail or e-mail solicitation lists and will delete your information from existing files within a reasonable time period. Just contact us.

  1. Information Disclosed to Third Parties

Fonex Inc. does not sell PERSONAL INFORMATION of its customers. In limited circumstances, Fonex Inc. may provide PERSONAL INFORMATION to third parties:

To assist us in developing, promoting, establishing, maintaining, and/or providing Fonex Inc.-related products and services to you, including joint marketing efforts or promotions, but PERSONAL INFORMATION may not be used by the third parties for any other purpose;

To assist us in establishing accounts, billing, collecting payment (i.e. credit bureaus and collection agencies), enforcing the Terms and Conditions or the Acceptable Use Policy of our Fonex Inc. services where permitted by law, and protecting or enforcing our rights or property, or the services of our other customers, from fraudulent, abusive, or unlawful use by you of our services;

To comply, when required by law, with court or administrative orders, civil or criminal subpoenas, warrants from law enforcement agencies, federal or state regulatory requirements, mandatory governmental audits, E911 reporting requirements, grand jury investigations, civil or criminal governmental investigations, or reporting required by the National Center for Missing and Exploited Children, designated by federal law as a reporting mechanism for child pornography; and

To appropriate law enforcement, 911 centers, or emergency services when Fonex Inc., in good faith, believes the disclosure is necessary to protect a person, Fonex Inc. property, or the public from an immediate threat of serious harm.

  1. Data Collection Technologies

In addition to PERSONAL INFORMATION identified in Section A of this Statement, we, or our third-party partners, may collect non-personal information automatically when you enter Fonex Inc. websites or use Fonex Inc. mobile apps, such as domain name, browser, your computer operating system, information about the Web page from which you linked to the website, and time spent on different parts of our websites or mobile apps. We or our partners may use this information to evaluate and improve the websites and mobile apps, and may share the information with third parties on an aggregated basis to enhance our products and services offered. This on-line information is typically collected via cookies, web beacons (see Section N for definitions), and/or other data collection technologies. Like virtually all other websites that you visit, we use cookies to deliver Web content specific to your interests and to control access to your personal shopping cart after your initial entry. The cookie permits the server to recall information from your previous shopping trip, should you decide to think about your purchase. A cookie is not used to access or otherwise compromise the data on your hard drive. With most browsers, you can choose to change your browser settings to disable cookies. Please be aware that cookies may be required to complete certain functions on Fonex Inc. websites and other websites you may link to from Fonex Inc. websites, including making purchases or payments on your Fonex Inc. account.

  1. Security Measures

Fonex Inc. wants you to use our services with confidence, and therefore we use a number of security techniques designed to protect your information from unauthorized access, including firewalls and access control procedures. Fonex Inc. has physical, electronic, contractual, and managerial security measures in place to protect against the loss, misuse and alteration of information under our control. For example, when you place an order on a Fonex Inc. Website, the information you submit is encrypted using the Secure Sockets Layer (SSL) protocol.

Fonex Inc. employees are bound non-disclosure agreements that prevent them from disclosing any PERSONAL INFORMATION or CPNI. Further, Fonex Inc.’s working with Integrity Guidelines state that Fonex Inc. employees must abide by all state and federal laws and regulations in the performance of their job duties.

Our policies also limit access to PERSONAL INFORMATION to only those employees, contractors, agents, or representatives that require the information to perform their jobs or assist Fonex Inc. with providing products and services to you.

  1. Children

Children under the age of majority should consult with their parents or guardian before furnishing any data to us. Parents should consider using one of a number of available parental control tools that provide a child-friendly, on-line environment and can prevent children from disclosing PERSONAL INFORMATION without parental consent. If a child has provided personal information without the consent of a parent or guardian, that parent or guardian should contact us to request that the information be deleted from our records. More information about parental controls may be found on Fonex Inc. websites or by contacting a Fonex Inc. customer care representative.

Fonex Inc. does not knowingly collect PERSONAL INFORMATION from children under the age of 13 in connection with providing products and services, and it strives to comply with all provisions of the Children’s Online Privacy Protection Act (COPPA). If Fonex Inc. inadvertently collects information from minors below the age of 13, the information will be treated as PERSONAL INFORMATION of the adult customer.

  1. Links

Fonex Inc. is not responsible for the content or privacy policies of other non-Fonex Inc. websites or non-Fonex Inc. mobile apps. You should keep this in mind when accessing websites through links on Fonex Inc. websites or mobile apps, or through third party advertisements appearing on Fonex Inc. websites or mobile apps. Further, Fonex Inc. may advertise on other websites or mobile apps. The advertising companies placing our ads may use cookies or web beacons to track the effectiveness of our ads. The use of such technology is subject to the privacy policies of the advertising companies, and not this Statement.

  1. Statement Updates

We may update this Privacy Statement at any time in connection with our constant efforts to improve our products and services. We strongly encourage you to periodically review this Statement. We reserve the right to expand our capabilities for information collection and use and change this Statement in this regard. If any change constitutes a material change to this Statement, we will post a notice on our websites in a prominent position. If Fonex Inc. decides to use PERSONAL INFORMATION in a manner that is materially different from what is contained herein, we will post the change on this page for 30 days before making the change.

  1. Security Breaches

While our goal is to prevent any unauthorized disclosure of PERSONAL INFORMATION, Fonex Inc. cannot guarantee that a disclosure will not occur. We will make reasonable efforts to contact you if we determine that a security breach has occurred and that there is a reasonable risk of identity theft or as otherwise required by law.

  1. Definitions

Cookies are small, encrypted data strings our server writes to your hard drive that contains your unique Fonex Inc. User ID.

Web beacons are small graphic images imbedded in a webpage or email.

  1. Internet Information

Fonex Inc.’s network management practices are designed to provide the best possible online experience to its customers. To that end, Fonex Inc. monitors traffic flows between points within its network and between its network and locations on the Internet for purposes of reasonable network management. Fonex Inc. uses this information to manage its network, provide security for its customers, plan for future needs, and ensure its network runs efficiently. Monitored information includes the amount of data sent to and from your connection, the source and destination of the data, and the type of information sent and received. In limited circumstances, Fonex Inc. may also look into the contents of the information to determine whether it is malicious in nature (such as a virus, spam, worm, etc) or when required by law to comply with judicial orders or regulations.

  1. US-EU Privacy Principles

For individually identifiable information received by Fonex Inc. in the United States from Users in the European Union, Fonex Inc. adheres to the following principles:

Notice: Fonex Inc. will inform Users about the purposes for which it collects and uses PERSONAL INFORMATION, the types of non-agent third parties to which Fonex Inc. discloses PERSONAL INFORMATION, and the choices and means, if any, Fonex Inc. offers for limiting use and disclosure of PERSONAL INFORMATION.

Choice: Fonex Inc. will offer Users the opportunity to choose (opt-out) whether their PERSONAL INFORMATION is (a) to be disclosed to a third party who is not an agent, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized. For sensitive PERSONAL INFORMATION, Fonex Inc. will give Users the opportunity to affirmatively and explicitly (opt-in) consent to such disclosure or use.

Access: Upon request, Fonex Inc. will provide Users with the PERSONAL INFORMATION that it holds about them and will take reasonable steps to provide individuals with a means to correct, amend or delete PERSONAL INFORMATION that is inaccurate or incomplete.

Dispute Resolution: For complaints that cannot be resolved between Fonex Inc. and the User, such disputes will be governed by the current provisions of Fonex Inc.’s Terms and Conditions, or the terms of your written agreement with Fonex Inc., if applicable.