Privacy Policy

At TruConnect Mobile, LLC (“TruConnect,” “we,” “us,” or “our”) we understand that privacy is important, and we are strongly committed to protecting our customers’ privacy and visitors to our websites at http://www.truconnect.com and any other subdomains used in conjunction with the http://www.truconnect.com domain (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 TruConnect name or logo. By visiting our websites or using the services provided there, you accept the practices described in this Privacy Policy.

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.

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.

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.

Password For Your Account

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 TruConnect. 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.

Volunteer Surveys

We may, at times, conduct
surveys of our customers and/or users of our websites ("survey
participants"). We encourage you to participate in these voluntary surveys
because they provide us with important information that aids us in improving
how we provide service and the types of services we offer. Your personal
information and responses will remain confidential, even if the survey is
conducted by a third-party.

We may take the information we collect from individuals responding to surveys and
combine (or aggregate) it with responses of other survey participants to create
broader, generic responses to the survey questions (such as gender, age,
residence, interests, education level, employment, industry, or other
demographic information). We then use the combined information to increase the
quality of our services to you, and to develop new services and products. This combined,
non-personally identifiable, information may be shared with third-party
affiliates.

How We Use Your Information

We may use personal information to contact you and distribute
information to you via your home phone, address, email, voice or text messages
on your mobile phone if you are a TruConnect customer. We may also share personal
information with certain third parties so that these third parties can share
information with you about new products, services and promotions that we
believe will interest you unless you decline. By accepting this Privacy Policy
or by purchasing or using our products or our jointly-branded products, you
expressly agree to such usage and sharing of information. Additionally, TruConnect
may use non-personal information in aggregate form for demographic marketing
purposes, and may disclose this information to third parties, including
advertisers.

If you are a TruConnect customer, in certain special circumstances, we may
contact you to deliver service-oriented messages, even if you have asked that
we not contact you about special airtime events or promotions. These messages
will be limited and only for this purpose.

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

TruConnect cooperates with law enforcement inquiries, as well as other third
parties, to enforce laws, such as protecting intellectual property rights and
preventing fraud. We can (and you authorize us to) disclose any information
about you to law enforcement or other government officials as we, in our sole
discretion, believe necessary or appropriate, to respond to claims or legal
process, to protect the property of TruConnect or the safety of its employees
or others, to investigate fraud, intellectual property infringement, or other
activity that is or may be illegal or expose us or you to liability.

In the event that TruConnect or its partners be acquired by or merged with
another business entity, you should expect that TruConnect or its partners to
share 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 we
will request that the new combined entity follow the practices disclosed in
this 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.)

TruConnect.com uses a Teracent cookie in order to display ads to visitors of Truconnect.com on other websites via Google and Google’s partners. You may opt-out of Teracenter cookies here: Teracent opt-out page.

Choices About Your Privacy

If you are a TruConnect
customer, you may change the personal information you have elected to share
with us. You also have choices in the types of communications you wish to
receive from us.

To change your notification
settings, or to change any of your personal information, visit https://manage.truconnect.com to log in to your TruConnect account where
you can manage your account information.

Cookies

"Cookies" are
small files placed on your hard drive; each website can send its own cookie to
your browser if your browser preferences allow it. You can configure your
browser to accept all cookies, reject all cookies, or notify you when a cookie
is sent. (Because each browser is different you can click the "Help"
menu of your browser to learn how to change your cookie preferences.) You are
free to decline our cookies if your browser permits, although in that case you
may not be able to use certain features on our websites and you may be required
to re-enter your Password more frequently during a session. Additionally, a
number of companies not related to TruConnect provide services designed to help
you visit websites anonymously.

Cookies help us provide customized services and can also help us direct
information that is targeted to your interests. TruConnect uses cookies to inform
us how and when pages in our websites are viewed, and by how many people. TruConnect
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 account
information and other important information you may want to access frequently. TruConnect
cookies do not combine information collected through cookies with other personal
information. TruConnect uses two kinds of cookies. Each time you log on to any
of our websites, TruConnect uses a "session cookie," to remember you
until 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 our
website. Session cookies are automatically deleted from your hard drive at the
end of a session. We also use "persistent cookies," which allow us to
remember what is in your shopping cart to aggregate certain non-personally
identifiable usage data in ways that help us improve our services. In addition,
you may encounter cookies or other similar devices on our websites that are
placed 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 use
our websites through the use of cookies. The information generated by the
cookie about your use of our website (including your IP address) is transmitted
to and stored by these analytics partners. This information is used for the purpose
of evaluating your use of our websites, assembling reports on website activity
for website developers and providing other services relating to website
activity and Internet usage. These analytics partners may transfer this
information to third parties where required to do so by law, or to third
parties that process information on its behalf. Neither partner will associate
your IP address with any other data held regarding you.

Policy Toward Children

TruConnect is concerned
about the safety and privacy of children who use the Internet. In adhering to
the Children’s Online Privacy Protection Act of 1998, we will never deliberately
collect personal information from anyone under the age of 13 without prior
verifiable parental consent and may limit participation in certain services we
provide 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 13
responds to that request, we will direct him or her to have a parent or
guardian call a live customer care agent at 1-855-878-2666, where a parent will
be permitted to purchase a TruConnect device, establish an account and activate
the on behalf of a child under 13. In these circumstances, activation can be
made only by phone with a live customer care agent, and the account must be in
the parent’s name.

If we become aware that a child under 13 has or has attempted to provide us
with personal information, we will use our best efforts to remove such
information from our files. If a parent or guardian becomes aware that his or
her child has done this, he or she should contact the following customer care
agent to remove this information:

Customer Service

TruConnect Mobile, LLC

355 S Grand Ave # 3100

Los Angeles, CA 90071

Telephone: (855) 878-2666 (toll-free)

href="http://support.truconnect.com">http://support.truconnect.com

Location-Based Information

Location-based information
is information that indicates the location of usage of your TruConnect device.
When you plug in your device, your device automatically communicates with our
network and relays its current location. The accuracy of location services may
be affected by many circumstances beyond our control, including atmospheric,
geographic or topographic conditions. We do not guarantee that service will be
provided without interruption.

By using our services, you consent to allow us or our partners to
electronically collect, monitor and track your physical location. We collect
and disclose your location information only to anonymously analyze geographic
usage, improve the quality of our service, and aid in emergency situations as
prescribed by law. If you allow other users to use your device, you are
responsible for informing these users that their location information may be
collected and/or disclosed. We will not provide your location information to
third parties other than as prescribed by law without your consent.

Any information that is
collected, monitored, or tracked regarding your physical location or the
location of your device will not be retained longer than is necessary to
provide the necessary information to improve our services to customers.

Other Information Collectors

Except as otherwise explicitly
included in this Privacy Policy, this document addresses only the use and
disclosure of information that we or our partners collect from you. To the
extent that you disclose your information to other parties, different rules may
apply as to their use or disclosure of your information. We encourage you to
ask questions before you disclose your personal information to other entities.

Information Security

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

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

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

Applicable Law

Personal information that
is submitted to our websites will be collected, processed, stored, disclosed
and 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 personal
information outside your resident jurisdiction.

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

Changes To The Privacy Policy

TruConnect may, from time
to time, make changes to this policy based on your comments and our need to
accurately reflect our legal obligations and our data collection and disclosure
practices. By continuing to use our websites and services or by calling TruConnect
customer service at 1-855-878-2666, you agree to be bound by the latest version
of this policy, which may be viewed anytime by clicking on the "Privacy
Policy" link at the foot of the each of our websites.

More Information

For questions or concerns
about TruConnect or our websites, please contact customer care by visiting http://support.truconnect.com or call TruConnect customer service at 1-855-878-2666.
Calls to TruConnect customer service may be monitored for quality assurance.

Effective
05/05/2011