PRIVACY POLICY

For Mobile Enablement and Payment Services BY MCLOUDNETWORX

At mCloudNetworx (“we,” “us,” or “our”) we understand that privacy is important, and we are strongly committed to protecting our customers’ privacy and visitors to our website at https://mcloudnetworx.com and any other subdomains used in conjunction with the mcloudnetworx.com domain; including our online store and payment services provided to our reseller customers under dba Telecom Provider (collectively, “our websites”).

The following information is designed to help you better understand the information we gather from our websites, how we protect the information once we obtain it, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct the information gathered on our websites. This Privacy Policy applies only to our websites and not to other companies’ or organizations’ services or websites to which we may link, even if they market our products or use the mCloudNetworx name or logo. By visiting our websites or using the services provided there, you accept the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

Our primary goal in collecting personal information is to provide you with a smooth, efficient and customized experience. This allows us to provide features that are most likely to meet your needs, and to customize our service to make your experience easier.

  1. General Data. We gather certain usage information like the number and frequency of visitors to our websites. This information may include which URL you just came from, which URL you next go to, what browser you are using, and your IP address. We use such data only in general meaning no specific tracking to your personal information. This collective data helps us determine how much our customers use parts of our websites, and do internal research on our customer demographics, interests, and behavior to better understand and serve you.

    This type of general, non-personal information may also be collected and/or used by third parties that support our services. In addition, we aggregate data and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes.

  2. Personal Information. Users are asked to disclose information when they sign up for our services such as name, address, phone number, birth date, gender, credit card information, and email address (collectively “Personal Information”). The Personal Information collected from our customers during the registration process is used to manage each customer account. We also gather such information to provide products and/or services that more closely reflect your preferences. Additionally, we may use such Personal Information to enhance our marketing and promotion efforts, analyze website usage, improve content and product offerings, and customize our website’s content, design layout, and services.

  3. Account Password. To activate and manage your account and to access certain services, we require you to provide a password (your “Password”). When accessing your account or providing your Password, you must provide accurate and complete information to mCloudNetworx. You are solely responsible for maintaining the confidentiality of your Password and are individually responsible for any activity conducted using your Password. You agree not to use the account, customer name, or password of another customer at any time unless that customer is under 18 and you are the parent or guardian of that customer.

  4. Volunteer Surveys. We may, at times, conductsurveys of our customers and/or users of our websites ("SurveyParticipants"). We encourage you to participate in these voluntary surveysbecause they provide us with important information that aids us in improvinghow we provide service and the types of services we offer. Your personalinformation and responses will remain confidential, even if the survey isconducted by a third-party.

  5. We may take the information we collect from individuals responding to surveys andcombine (or aggregate) it with responses of other Survey Participants to createbroader, generic responses to the survey questions (such as gender, age,residence, interests, education level, employment, industry, or otherdemographic information). We then use the combined information to increase thequality of our services to you, and to develop new services and products. This combined, non-personally identifiable, information may be shared with third- partyaffiliates.

2. HOW WE USE YOUR INFORMATION

We may use personal information to contact you and distributeinformation to you via your home phone, address, email, voice or text messageson your mobile phone if you are a mCloudNetworx customer. We may also share personalinformation with certain third parties so that these third parties can shareinformation with you about new products, services and promotions that webelieve will interest you unless you decline. By accepting this Privacy Policyor by purchasing or using our products or our jointly-branded products, youexpressly agree to such usage and sharing of information. Additionally, mCloudNetworx may use non- personal information in aggregate form for demographic marketing purposes, and may disclose this information to third parties, includingadvertisers.

In certain special circumstances, we maycontact mCloudNetworx customers to deliver service- oriented messages, even if you have asked thatwe not contact you about special airtime events or promotions. These messageswill be limited and only for this purpose.

We may use third party service providers to facilitate our services, andtherefore, we may provide some of your personal information directly to them. In addition, we employ other companies and individuals to perform functions onour behalf. Some examples may include fulfilling orders, providing mobilecontent, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketingassistance, processing credit card payments and providing customer service. These service providers may have access to personal information and may use itas needed to perform their functions, but may not use it for any other purpose,except that they may aggregate your personal information with simi-larinformation from other customers in a manner that does not personally identifyyou.

mCloudNetworx cooperates with law enforcement inquiries, as well as other thirdparties, to enforce laws, such as protecting intellectual property rights andpreventing fraud. We can (and you authorize us to) disclose any informationabout you to law enforcement or other government officials as we, in our solediscretion, believe necessary or appropriate, to respond to claims or legalprocess, to protect the property of mCloudNetworx or the safety of its employeesor others, to investigate fraud, intellectual property infringement, or otheractivity that is or may be illegal or expose us or you to liability.

In the event that mCloudNetworx or its partners be acquired by or merged withanother business entity, you should expect that mCloudNetworx or its partners toshare some or all of your personal information to continue to provide service.You will receive notice of such event (to the extent that it occurs), and wewill request that the new combined entity follow the practices disclosed inthis Privacy Policy or notify you of any changes.

Third party vendors, including Google, show your ads on sites on the Internet. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page. Alternatively you can point users to opt out of a third party vendor’s use of cookies by visiting the Network Advertising Initiative opt out page.

3. CHOICES ABOUT YOUR PRIVACY

mCloudNetworx customers may change the personal information you have elected to sharewith us. You also have choices in the types of communications you wish toreceive from us. To change your notificationsettings, or to change any of your personal information, log in to your account whereyou can manage your account information.

4. COOKIES

"Cookies" aresmall files placed on your hard drive; each website can send its own cookie toyour browser if your browser preferences allow it. You can configure yourbrowser to accept all cookies, reject all cookies, or notify you when a cookieis sent. [Because each browser is different you can click the "Help"menu of your browser to learn how to change your cookie preferences.] You arefree to decline our cookies if your browser permits, although in that case youmay not be able to use certain features on our websites and you may be requiredto re- enter your Password more frequently during a session. Additionally, anumber of companies not related to mCloudNetworx provide services designed to helpyou visit websites anonymously.

Cookies help us provide customized services and can also help us directinformation that is targeted to your interests. mCloudNetworx uses cookies to informus how and when pages in our websites are viewed, and by how many people. mCloudNetworx also uses cookies to remember you when you "sign in" to our websites, so that we can provide you with relevant content, such as your accountinformation and other important information you may want to access frequently. mCloudNetworx cookies do not combine information collected through cookies with other personalinformation. mCloudNetworx uses two kinds of cookies. Each time you log on to anyof our websites, mCloudNetworx uses a "session cookie" to remember youuntil approximately 30 minutes has expired or the closing of your browser,whichever occurs first and to help make sure that you remain logged in to ourwebsite. Session cookies are automatically deleted from your hard drive at theend of a session. We also use "persistent cookies," which allow us toremember what is in your shopping cart to aggregate certain non- personallyidentifiable usage data in ways that help us improve our services. In addition, you may encounter cookies or other similar devices on our websites that areplaced by third parties. We do not control the use of cookies by third parties, including third party websites to which we may link.

We use Google Analytics and other services to help analyze how customers useour websites through the use of cookies. The information generated by thecookie about your use of our website (including your IP address) is transmittedto and stored by these analytics partners. This information is used for the purposeof evaluating your use of our websites, assembling reports on website activityfor website developers and providing other services relating to websiteactivity and Internet usage. These analytics partners may transfer thisinformation to third parties where required to do so by law, or to thirdparties that process information on its behalf. Neither partner will associateyour IP address with any other data held regarding you.

5. POLICY TOWARD CHILDREN

mCloudNetworx is concernedabout the safety and privacy of children who use the Internet. In adhering tothe Children’s Online Privacy Protection Act of 1998, we will never deliberatelycollect personal information from anyone under the age of 13 without priorverifiable parental consent and may limit participation in certain services weprovide to individuals over 13 years of age. At various places on our websites,we may request that customers provide a year of birth. If a child under 13responds to that request, we will direct him or her to have a parent orguardian call a live customer care agent at 1855-678-9123, where a parent willbe permitted to purchase a mCloudNetworx device, establish an account and activatethe on behalf of a child under 13. In these circumstances, activation can bemade only by phone with a live customer care agent, and the account must be inthe parent’s name. If we become aware that a child under 13 has or has attempted to provide uswith personal information, we will use our best efforts to remove suchinformation from our files. If a parent or guardian becomes aware that his orher child has done this, he or she should contact our customer careagent to remove this information:

Email: support@mcloudnetworx.com
Call: 858-205-9381.

6. LOCATION-BASED INFORMATION

Location-based informationis information that indicates the location of usage of your mCloudNetworx device.When you plug in your device, your device automatically communicates with ournetwork and relays its current location. The accuracy of location services maybe affected by many circumstances beyond our control, including atmospheric,geographic or topographic conditions. We do not guarantee that service will beprovided without interruption. By using our services, you consent to allow us or our partners toelectronically collect, monitor and track your physical location. We collectand disclose your location information only to anonymously analyze geographicusage, improve the quality of our service, and aid in emergency situations asprescribed by law. If you allow other users to use your device, you areresponsible for informing these users that their location information may becollected and/or disclosed. We will not provide your location information tothird parties other than as prescribed by law without your consent. Any information that iscollected, monitored, or tracked regarding your physical location or thelocation of your device will not be retained longer than is necessary toprovide the necessary information to improve our services to customers.

7. OTHER INFORMATION COLLECTORS

Except as otherwise explicitlyincluded in this Privacy Policy, this document addresses only the use anddisclosure of information that we or our partners collect from you. To theextent that you disclose your information to other parties, different rules mayapply as to their use or disclosure of your information. We encourage you toask questions before you disclose your personal information to other entities.

8. INFORMATION SECURITY

mCloudNetworx uses standardindustry practices to safeguard the confidentiality of your personal information. mCloudNetworx treats data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protectsuch data from unauthorized access by users inside and outside the company.

Unfortunately, perfect security does not exist on the Internet, and therefore, mCloudNetworx makes no representations or warranties regarding the sufficiency of oursecurity safeguards. mCloudNetworx shall not be responsible for any damages thatresult from a lapse in compliance with this Privacy Policy because of asecurity breach, technical malfunction or similar problem. Always be carefuland responsible regarding your personal information.

We are not responsible for, and cannot control, the use by others of anyinformation which you provide to them via our wireless services. Similarly, we willnot assume any responsibility for the content of any personal information orcommunication you receive from other customers through our wireless services.

9. APPLICABLE LAW

Personal information thatis submitted to our websites will be collected, processed, stored, disclosedand disposed of in accordance with applicable U.S. law. If you are a non- U.S.customer, you acknowledge and agree that we may collect and use your personalinformation outside your resident jurisdiction.

In addition, such personal information may be stored on servers located outsideyour resident jurisdiction. U.S. law may not provide the degree of protectionfor your information that is avail-able in other countries. BY PROVIDING US WITHYOUR INFORMATION, YOU ACKNOWLEDGE THAT YOUR HAVE READ THIS PRIVACY POLICY, UNDERSTAND IT, AGREE TO ITS TERMS AND CONSENT TO THE TRANSFER OF SUCHINFORMATION OUTSIDE YOUR RESIDENT JURISDICTION. If you do not consent to theterms of this Privacy Policy, please do not use our websites.

10. CHANGES TO THE PRIVACY POLICY

mCloudNetworx may, from timeto time, make changes to this policy based on your comments and our need toaccurately reflect our legal obligations and our data collection and disclosurepractices. By continuing to use our websites and services or by calling mCloudNetworx customer service at 11-858-205-9381, you agree to be bound by the latest versionof this policy, which may be viewed anytime by clicking on the "PrivacyPolicy" link at the foot of the each of our websites.

11. MORE INFORMATION

For questions or concerns about mCloudNetworx or our websites, please contact us by visiting http://mcloudnetworx.com/#contact-section or email us at support@mcloudnetworx.com.

Rev. July 2022