TransferTo Privacy Policy

Effective: August 2014

TransferTo, Inc. ("TransferTo") is committed to protecting the privacy and security of your personal information. This Privacy Policy (“Policy”) describes the personal information we may collect about you, how we may use it, when we may disclose it, how we safeguard it, and how you may access it and control its use in connection with our marketing communications. The policy also provides other important privacy information and describes when and how we may change this policy and how to contact us with any questions or comments.

COLLECTION, USE, DISCLOSURE, AND SECURITY OF PERSONAL INFORMATION

Personal Information

This policy applies to personally identifiable information (“personal information”), which is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; social security number; call records; wireless device location). Personal information does not include “anonymous” or "aggregate" information – neither of which are associated with a specific person or entity.

Collection of Personal Information

We collect personal information about you when you use our services or otherwise interact with us. Such information includes:

* Information you provide. We collect personal information when you sign up for and use our services, and when you e-mail, call, or otherwise communicate with us. For example, we may collect personal contact, billing, and credit information when you sign up for data services or purchase other products or services. We may also collect personal information when you call or e-mail our customer service representatives, enter information on our Web sites, submit survey responses, pay for service. If you provide personal information to us in connection with a co-sponsored Web site, this policy will apply to our use of the information and the co-sponsor’s policy will apply to their use of the information.

* Information automatically collected. We automatically collect certain information, some of which may be associated with personal information, whenever you use our services or Web sites.

Use of Personal Information

We use personal information for a variety of business purposes, including for example, to complete transactions and bill for products and services; verify your identity; respond to your requests for service or assistance; anticipate and resolve actual and potential problems with our products and services; create and improve products and services; suggest additional or different products or services; make internal business decisions about current and future offers; provide personalized service and user experiences; and protect our rights and property. We may also use personal information to contact you about TransferTo or third-party products, services, and offers that we believe you will find of interest. We may contact you by telephone, postal mail, e-mail, or other methods.

Disclosure of Personal Information

We do not sell, rent, or otherwise provide your personal information to unaffiliated third-parties (parties outside the Transfer To Inc corporate families) to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows:

* With your consent. We may disclose personal information about you to third-parties with your consent. We may obtain your consent in several ways, such as in writing; online, through "click-through" agreements; orally, including through interactive voice response; or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.

* To the primary account holder. We may disclose personal information of an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you or your use of the service to them or others at their direction. When you are the primary account holder, but you receive special or discounted pricing, terms, or other benefits through another party’s agreement with us (for example, an employee discount), we may provide enough personal information to that party to verify your initial and continuing eligibility for benefits under their agreement with us and to calculate any associated discounts.

* Transaction processing. We may disclose personal information to third-parties who complete transactions or perform services on our behalf (for example, billing, shipping, customer service, and marketing), transactions on your behalf (for example, verification of your account information at your request to some third-party business), or transfers related to your service (for example, number portability). We typically restrict by contract the manner in which these third-parties may use and disclose personal information about you without your consent.

* Third-party services. Your personal information may be disclosed when the use of our services allow you to take advantage of services and products offered by other companies. For example, if you are roaming on the network of another carrier, your wireless telephone number, the numbers you dial, and other information about your usage will be available to that carrier to facilitate that service.

* Business transfers. We may disclose personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information could be transferred to third-parties as a business asset in the transaction.

* Legal process & protection of TransferTo and others. We may disclose personal information or communications where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (for example, lawful subpoena, court order, E-9-1-1 information); to enforce or apply agreements; to initiate, render, bill, and collect for services and products; to protect our rights or property; in connection with claims, disputes, or litigation; to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or if we determine disclosure is necessary in an emergency situation.

Security and Retention of Personal Information

We use a variety of physical, electronic, and procedural safeguards to protect personal information from unauthorized access, use, or disclosure while it is under our control. For instance, when you provide sensitive information (such as credit card numbers) to our Web sites, we use transmission encryption technologies like Secure Socket Layer (SSL). Although we cannot guarantee that loss, misuse, or alteration of your personal information will not occur, we strive to prevent such occurrences.

Our practices and procedures are designed to limit personal information access to those TransferTo employees and agents with a legitimate need to access such information. TransferTo employees are bound by confidentiality obligations and our Code of Conduct, which obligate them to protect the confidentiality of our customers’ personal information. Violations subject employees to disciplinary action, up to and including termination.

We retain personal information for as long as we have a business need or as applicable laws, regulations, or government orders require. When we dispose of personal information, we use reasonable procedures to erase or render it unreadable (for example, shredding documents and wiping electronic media). We will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred and creates a risk of identity theft or service disruption, or as otherwise required by law.

Access and Choice Access to Your Information

You may access and modify your contact information by contacting Customer Service. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.

Choices Regarding Use of Your Information

We want to provide you with meaningful choices regarding our marketing communications and you may choose to limit or opt-out of certain communications from TransferTo at any time. While you may elect not to receive marketing information from us, if you subscribe to our services or buy our products, you will continue to receive invoices, customer-service and transactional notices, and similar communications.

Not all marketing communications you receive on your device are sent or authorized by TransferTo. When you provide your mobile number or other contact information to others, you may receive unwanted calls, text messages, or e-mails on your device. We take steps to reduce unsolicited advertising, but we cannot block all such advertisements or unwanted communications.

OTHER PRIVACY INFORMATION

Children

We do not solicit children to purchase our services or products. If, however, you authorize a child to use our services or products by providing them a device associated with your TransferTo account, any personal information associated with such use will be treated as your information in accordance with this policy. Our Web sites are not designed to attract children under the age of 13 and we do not intentionally or knowingly collect personal information on our sites from anyone under the age of 13. We encourage parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission. We may offer Web Guard or similar security features designed to allow the customer to implement restrictions to adult orientated content, but such features are not foolproof.

Cookies, Web Beacons, and Similar Technologies

We may use cookies (small data text files placed on your computer or device) or similar technologies to identify the computer or device and record your preferences and other data so that our Web sites can personalize your visit(s). We may also use information collected from cookies to improve our sites, make recommendations, and complete transactions you request. You may be able to set your browser(s) to reject cookies or delete cookies, but that may result in the loss of some functionality on our sites. We may also use Web beacons (small graphic images on a Web page or an HTML e-mail) to monitor interaction with our Web sites or e-mails. Web beacons are generally invisible because they are very small (only 1-by-1 pixel) and the same color as the background of the Web page or e-mail message. If we combine or link cookie or Web beacon information with personal information, we will treat the combined or linked information as personal information under this policy. We may employ third-parties to place advertisements about our products and services on other Web sites. The use of cookies, Web beacons, or similar technologies by such third-parties is subject to their privacy policies – not this policy.

Customer Service Monitoring

We may monitor and record phone calls, e-mails, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests.

Other Governing Terms

This policy does not modify or alter any applicable agreement you have with TransferTo. For example, our Terms of Use govern your use of our Web sites. Additionally, if you use our products or use or subscribe to our services, our TransferTo Terms and Conditions, one or more applicable service agreements, and certain other terms may apply to your use, purchase, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency.

Protecting Your Own Personal Information

You play an important role in ensuring the security of personal information, including protecting against unauthorized access to your device. Many devices store information both in the phone and on the SIM card.

We encourage you to use passwords to prevent unauthorized access to your device. We recommend that you use unique, non-obvious passwords, that you periodically change your passwords, and that you not share your passwords with others. Notify us immediately if you believe your device has been lost or stolen or if you believe your personal information has been accessed without your consent.