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Privacy Policy

Introduction

At Spot Mobile Corp. (“SPOT MOBILE”) we are committed to your privacy. This means we do not distribute, rent or sell any of your Personally Identifiable Information to third parties except as provided for in this Policy or as specifically consented to by you. For example, SPOT MOBILE may provide your Personally Identifiable Information, as defined below to third party carriers for the provision of services, for billing and/or collection purposes. All such provision of Personally Identifiable Information to third party providers shall only be done in accordance with this Policy.

DISCLAIMER: THIS PRIVACY POLICY (“POLICY”) COVERS SPOT MOBILE CORP. AND IS ONLY APPLICABLE TO CUSTOMERS, USERS AND EMPLYOYEES LOCATED IN, OR GOVERNED BY APPLICABLE LAWS OF THE UNITED STATES. FOR CUSTOMERS PURCHASING SERVICES FROM ANY OF SPOT MOBILE’S AFFILIATES.

Scope

This Policy applies to Personally Identifiable Information about identifiable SPOT MOBILE Customers and Users and SPOT MOBILE Employees that is collected, used or disclosed by SPOT MOBILE. This Policy will apply to and protect all Personally Identifiable Information collected, used or disclosed by SPOT MOBILE, except information that is aggregated in such a manner that it cannot be connected to a person and/or information which is publicly listed in a written or online directory or typically made available through directory assistance as permitted by law. For example, SPOT MOBILE may share non-personal, non-individual information with our partners in aggregate form for research analysis. The information will not show that a Customer called a specific destination but rather, how many customers called that destination.

The policy will apply to and protect all personal information collected, used or disclosed by SPOT MOBILE, except information that is aggregated in such a manner that it cannot be connected to a person and/or information which is publicly listed in a written or online directory or typically made available through directory assistance as permitted by law. For example, SPOT MOBILE may share non-personal, non-individual information with our partners in aggregate form for research analysis. The information will not show that you called a specific destination but rather, how many customers called that destination.

Personally Identifiable Information subject to this Policy may include but is not limited to:

  1. Details of calls/usage as contained in invoices or a Customer’s Call History website account;
  2. Account information from other telephone companies;
  3. Internet user names and activity reports;
  4. Customer names and passwords;
  5. Technical support records;
  6. Customer Call data records;
  7. Credit card information;
  8. Payment and banking information;
  9. Personally Identifiable Information provided by a User visiting SPOT MOBILE’s website
  10. Personally Identifiable Information provided to SPOT MOBILE by its Employees

Definitions

To better understand our Policy, SPOT MOBILE provides below some basic definitions to use when reading and interpreting this Policy. All capitalized terms in this Policy shall have the meaning set forth below.

Collection: the act of gathering, acquiring, recording, or obtaining Personally Identifiable Information from any source, including third parties, by any means.

Consent: voluntary agreement to the collection, use and disclosure of Personally Identifiable Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of SPOT MOBILE. Implied consent is consent that reasonably can be inferred from the circumstances or from an individual's action or inaction.

Customer: an individual who subscribes to SPOT MOBILE’s telecommunications services.

Disclosure: making Personal Identifiable Information available to a third party.

States of America. User: an individuals who uses SPOT MOBILE's website but who is not a Customer because he or she has not subscribed to SPOT MOBILE services.

Privacy Principles

SPOT MOBILE will abide by the following Privacy Principles with respect to Personally Identifiable Information under its control about its Customers, Users and Employees.

Principle #1

SPOT MOBILE is responsible for Personally Identifiable Information under its control and abides by the following principles.

  1. SPOT MOBILE’s Privacy Officer is accountable for SPOT MOBILE's compliance with this Policy. Other individuals within SPOT MOBILE may be delegated to act on behalf of SPOT MOBILE’s Privacy Officer to take responsibility for the day-to-day collection and processing of Personally Identifiable Information. The position of Privacy Officer has been created to ensure Customers, Users and Employee have a designated avenue to answer their privacy-related inquiries.
  2. Developing information to explain the organization's policies and procedures.

Principle #2 - Identifying Purposes

Where appropriate and feasible, SPOT MOBILE will identify the purposes for which Personally Identifiable Information is collected at or before the time the information is collected.

  1. SPOT MOBILE collects personal Identifiable information for the following purposes:
    1. To provide service(s) and/or products to its Customers and Users;
    2. To establish and maintain responsible commercial relations with Customers and to communicate with its Customers in order to provide service. This includes, but is not limited to communications related to billing, collection, advertising, promotion and account verification;
    3. To understand Customer and User needs and preferences;
    4. To afford promotional or other opportunities to our Customers and Users, such as contests;
    5. To meet legal and regulatory requirements; and
    6. To administer and manage SPOT MOBILE’s business operations, including personnel and employment matters.
    7. To respond to Users’ questions and/or comments.
  2. SPOT MOBILE may collect and uses anonymous web browsing information about its Customers and Users to gather broad demographic information used in marketing, promotion or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about Customers and Users who utilize SPOT MOBILE’s Site. SPOT MOBILE also may use this data to monitor Site performance and to make the Site easier and more convenient to us except where the collection of personal information is reasonably necessary in order to carry out the express wishes of the customer or employee, SPOT MOBILE shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected.

Principle #3 - Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personally Identifiable Information, except in certain circumstances as described below:

  1. Personally Identifiable Information can be collected, used, or disclosed without the knowledge and consent of the individual in the following circumstances:
    1. If legal, medical or security reasons may make it impossible or impractical to seek consent;
    2. When information is being collected for the detection and prevention of fraud, as required or permitted by law or seeking the consent of the individual might defeat the purpose of collecting the information;
    3. Where seeking consent may be impossible or inappropriate if there is an emergency threatening the individual's or other’s life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated;
    4. If the Personally Identifiable Information is publicly available;
    5. In the event that SPOT MOBILE decides to sell all or part or its assets, SPOT MOBILE reserves the right to include Personally Identifiable Information among the assets transferred to the acquiring company;
    6. In the event that SPOT MOBILE uses Personally Identifiable Information in order to market products or services of the type that Customers already purchase from SPOT MOBILE;
    7. In the event that SPOT MOBILE utilizes other companies and individuals to perform functions on its behalf such as sending postal and e-mail to Customers and/or Users, processing credit card payments, fulfilling orders, delivering products and services, and providing customer service;
  2. Where appropriate, SPOT MOBILE generally will seek consent for the use or disclosure of the Personally Identifiable Information at the time of collection. In certain circumstances, consent may be sought after the Personally Identifiable Information has been collected but before use (for example, when SPOT MOBILE wants to use information for a purpose other than those identified above).
  3. In obtaining consent, SPOT MOBILE will use reasonable efforts to ensure that a Customer, User or Employee is advised of the identified purposes for which Personally Identifiable Information collected will be used or disclosed.
  4. The form of consent sought by SPOT MOBILE may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, SPOT MOBILE shall take into account the sensitivity of the Personally Identifiable Information and the reasonable expectations of its Customers, Users and employees.
  5. SPOT MOBILE will seek consent when the information is likely to be considered sensitive. Implied consent generally will be appropriate where the information is less sensitive. The use of services or products by a Customer, use of SPOT MOBILE’s website by a User or the acceptance of employment by an Employee will be considered implied consent to collect, use and disclose Personally Identifiable Information for all identified purposes.
  6. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. SPOT MOBILE will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to SPOT MOBILE in writing.
  7. With respect to Personally Identifiable Information already collected by SPOT MOBILE prior to the publication of this Policy, this Policy will constitute reasonable notice to SPOT MOBILE's current Customers, Users and Employees of the purposes and uses for which such Personally Identifiable Information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to SPOT MOBILE in writing.

Principle #4 - Limiting Collection

The collection of Personally Identifiable Information will be limited to that which is necessary for the purposes identified by SPOT MOBILE. Information will be collected by fair and lawful means.

  1. SPOT MOBILE collects Personally Identifiable Information from its Customers, Users and Employees for the purposes described under Principle #2.
  2. SPOT MOBILE also may collect Personally Identifiable Information from such third parties as credit bureaus, employers, personal references or other third parties that represent they have the right to disclose the information.

Principle #5 - Limiting Use, Disclosure and Retention

Personally Identifiable Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.

  1. SPOT MOBILE may collect, use or disclose Personally Identifiable Information without the individual's knowledge or consent in certain circumstances as described in Principle #3.
  2. SPOT MOBILE may disclose a Customer's Personally Identifiable Information to:
    1. Another telecommunications company for the provision of telecommunications services to that customer;
    2. A company involved in providing communications directory services;
    3. A company involving in providing billing services;
    4. A person involved in the development, promotion, marketing or enhancement of SPOT MOBILE's services;
    5. A credit collections agency;
    6. Emergency services in an emergency situation;
    7. SPOT MOBILE's agents and affiliates;
    8. A person who, in the reasonable estimation of SPOT MOBILE, is an agent of the customer; and
    9. Any other third party, upon receiving the consent of the customer or as required by law.
  3. SPOT MOBILE may disclose an employee's personal information in the following circumstances:
    1. In the administration of that employee's benefits;
    2. In providing references to prospective employers, upon receiving the consent of the employee; and
    3. As may be required by law.
    4. Only SPOT MOBILE's employees with a business need to know, or whose duties reasonably so require, are granted access to personal information about customers.
    5. SPOT MOBILE will retain personal information for only as long as required to fulfill the identified purposes or as required by law.
    6. Personal information that is longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by SPOT MOBILE.

Principle #6 - Accuracy

Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

  1. SPOT MOBILE will update Personally Identifiable Information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle #7 - Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. SPOT MOBILE has implemented commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of the Personally Identifiable Information that is submitted to SPOT MOBILE and is under its control. SPOT MOBILE will use reasonable efforts to protect Personally Identifiable Information it discloses to third parties through contractual agreements; however, SPOT MOBILE is not ultimately responsible for the actions of any third party in misusing Personal Identifiable Information. SPOT MOBILE makes no representations or warranties with regard to the sufficiency of these security measures. SPOT MOBILE shall not be responsible for any actual or consequential damages that result from a lapse in compliance with this Policy as a result of a security breach or technical malfunction.
Principle #8 - Challenging Compliance
All inquiries or complaints involving this Policy should be directed to: SPOT MOBILE's Privacy Officer; Email: privacy@spotmobile.com.

Principle #9 - Children’s Privacy Protection

Children under 13 years of age are not permitted to be account holders for SPOT MOBILE’s products or services. SPOT MOBILE does not knowingly collect any information from children under 13 years of age. If you are under 13 years of age, you are not permitted to submit Personally Identifiable Information to SPOT MOBILE.

Principle #10 - Linked Internet Websites

The Site provides hyperlinks, which are highlighted words or pictures within a hypertext document that, when clicked, take you to another place within the document, to another document altogether, or to other Web sites not controlled by SPOT MOBILE. These hyperlinked Web sites may contain privacy provisions that are different from those provided herein. SPOT MOBILE is not responsible for the collection, use, or disclosure of information collected through these Web sites, and SPOT MOBILE Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. SPOT MOBILE has implemented commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of the Personally Identifiable Information that is submitted to SPOT MOBILE and is under its control. SPOT MOBILE will use reasonable efforts to protect Personally Identifiable Information it discloses to third parties through contractual agreements; however, SPOT MOBILE is not ultimately responsible for the actions of any third party in misusing Personal Identifiable Information. SPOT MOBILE makes no representations or warranties with regard to the sufficiency of these security measures. SPOT MOBILE shall not be responsible for any actual or consequential damages that result from a lapse in compliance with this Policy as a result of a security breach or technical malfunction.

Principle #8 - Challenging Compliance - Spot Mobile Cell Phones & Spot Mobile Plans

All inquiries or complaints involving All inquiries or complaints involving this Policy should be directed to: SPOT MOBILE's Privacy Officer; Email: privacy@spotmobile.com.

Principle #9 - Children’s Privacy Protection

Children under 13 years of age are not permitted to be account holders for SPOT MOBILE’s products or services. SPOT MOBILE does not knowingly collect any information from children under 13 years of age. If you are under 13 years of age, you are not permitted to submit Personally Identifiable Information to SPOT MOBILE.

Principle #10 - Linked Internet Websites

The Site provides hyperlinks, which are highlighted words or pictures within a hypertext document that, when clicked, take you to another place within the document, to another document altogether, or to other Web sites not controlled by SPOT MOBILE. These hyperlinked Web sites may contain privacy provisions that are different from those provided herein. SPOT MOBILE is not responsible for the collection, use, or disclosure of information collected through these Web sites, and SPOT MOBILE expressly disclaims any and all liabilities related to such collection, use, or disclosure.

Principle # 11 – Cookies

When our Customers use our web-based services, which include access to a Customer’s account on SPOT MOBILE’s Site, our servers may use session cookies to help identify each Customer and make using the service more efficient. Our session cookies do not collect any Personal Information. Our Site does not use any cookies when Users are using the Site.