ZERO11 wireless^®

Americatel Corporation d/b/a ZERO11 wireless^® (hereinafter "ZERO11 wireless^®") is committed to protecting the privacy and security of your personal information. This Privacy 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. By subscribing to or using our services, you indicate your agreement with the terms of this policy. 

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 voice 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 or 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. For example, our systems capture details about the type and location of wireless device(s) you use, calls and text messages you send and receive, and other data services you use (for example your ringtone purchases). When your computer Web browser or other communication device (including phone, PDA, etc.) accesses our Web sites or wireless web pages (ZERO11 wireless^® web pages designed for access by wireless device browsers), we automatically receive certain information, such as your IP address, browser type, date and time, and the Web page you visited before visiting our site. If the service is available, o+ur network also automatically captures necessary routing information when you use our services to access the Internet at a ZERO11 wireless^® HotSpot or from your wireless device.
• Information from other sources. We may also obtain personal information about you from other sources. For example, we may receive credit information from third-party sources before initiating your service or in connection with your service and we may obtain updated address information from our shippers or other vendors. We may also purchase personal information (for example, e-mail lists, postal mail lists, demographic and marketing data) from others.

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; collect for our services; make internal business decisions about current and future offers; provide personalized service and user experiences;  protect our rights and property; and contact you other about other services offered by ZERO11 Wireless. We may disclose personal information to personnel employed by our parent or affiliated companies in order to further any business purposes, including those described in this policy.

Third-parties may also use personal information to contact you about their 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. You may opt-out of receiving marketing communications from us at any time as outlined below in the section titled Customer Control.

Disclosure of Personal Information
We do not sell, rent, or otherwise provide your personal information without your consent, to unaffiliated third-parties (parties outside the ZERO11 wireless^® corporate family) 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 the direction of the account holder. 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.
• Third-parties Performing Services on Our Behalf; Transaction Processing. We may disclose personal information to third-parties performing services on our behalf (for example, companies who complete transactions and perform credit checks, billing, credit and debit card payment processing, shipping, customer service, and marketing), or that perform transactions on your behalf (for example, verification of your account information at your request to some third-party business, processing of debit/credit card transactions, ) or transfers related to your service (for example, number portability).  Your wireless telephone number, the numbers you dial, and other information about your usage will be available to companies that perform underlying telecommunications services on our behalf to facilitate the origination, transport and termination of your ZERO11 wireless^® calls. 
• 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 ZERO11 wireless^® 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, the Terms and Conditions or this policy; 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. Although we cannot guarantee that loss, misuse, or alteration of your personal information will not occur, we undertake commercially reasonable measures to prevent such occurrences.

Our practices and procedures are designed to limit personal information access to those ZERO11 wireless^® employees and agents with a legitimate need to access such information. The employees of ZERO11 wireless^® and our parent and affiliated companies are bound by confidentiality obligations and a 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 contractually require third-parties acting on our behalf to protect our customers’ personal information in a manner consistent with this policy.

We retain personal information for as long as we have a business need or as applicable laws, regulations, or government orders require. As required by law, we will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred.

Access and Choice

Access to Your Information  
You may access and modify your contact information by contacting us at www.zero11wireless.com or our Customer Service Department. 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.

Customer Control  
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 ZERO11 wireless^® 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. You can stop email marketing messages by “unsubscribing” as instructed in the email. You can stop telemarketing calls by asking that your telephone number be removed from our telemarketing lists when we call you. You can also change your marketing preference by contacting us at www.zero11wireless.com or at our Customer Service Department at 1-877-724-8325.

Not all marketing communications you receive on your device are sent or authorized by ZERO11 Wireless. When you provide your cell phone number or other contact information to others, you may receive unwanted calls, text messages, or e-mails on your device.

OTHER PRIVACY INFORMATION

Caller ID
When you use ZERO11 wireless^® communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill.

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 ZERO11 wireless^® 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. 

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 invisible graphic images on a Web page or an HTML e-mail) to monitor interaction with our Web sites or e-mails. 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 Proprietary Network Information (CPNI)  
Customer Proprietary Network Information, or "CPNI", is a form of personal information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted policies and procedures designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under FCC rules, applicable law, or explained in this policy. However, you may designate other “authorized users” (for example, a spouse) to access and manage your account information, including CPNI.

We provide password protected online access to your account information through www.ZERO11 Wireless.com. For multi-line accounts, the primary account holder is authorized to access online account information for all the devices on the account.

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.

Directories  
We do not publish directories of our customers’ wireless numbers. Nor will we provide or make such numbers available to third-parties for listing in their public directories, without the customer’s prior consent.

Forums and Chat Rooms  
If you use or link to a public forum, bulletin board, chat room, or social network on or from a ZERO11 wireless^® web site, be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of personal information you choose to submit or share with others.

Location Information  
Our network may detect your device's approximate location whenever it is turned on (subject to coverage limitations). This location technology makes the routing of wireless communications possible and is also the basis for providing enhanced emergency 9-1-1 service (if applicable to your Zero11 wireless^® service), which permits us to provide your general location to a public safety answering point, emergency medical service provider, or emergency dispatch provider. We may also use this technology to disclose, without a user’s consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm.

Network Information Storage  
Some devices may automatically upload to ZERO11 wireless^® network servers information you have stored on the device and/or SIM card in order to facilitate specific functions. For instance, some devices back-up your address book. If possible, you may choose to disable such uploads but this may affect functionality of the device or your services. Refer to instructions for your device and service or for details or contact Customer Service for more information. We may also provide you the ability to upload other information from your device to ZERO11 wireless^® network servers. For instance, you may have the option to upload pictures, recordings, calendars, tasks, or notes. Uploaded information will not be used by ZERO11 wireless^® for purposes other than as disclosed in connection with those services, this policy, or applicable Terms and Conditions.

You may use your Zero11 wireless^® service in conjunction with Hand-sets or devices sold by other companies.  As a result, personal information from your devices may be uploaded and stored on the servers of those other companies. As a result, these companies’ specific terms and conditions, terms of use, and privacy polices apply to the use of the equipment and services provided by these other companies.

Other Governing Terms  
This policy does not modify or alter any applicable agreement you have with ZERO11 Wireless. If you use or subscribe to our products and services, our ZERO11 wireless^® Terms and Conditions 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  
Many devices store information both in the phone and on the SIM card. Therefore, before discarding, trading in, or giving away your device, be sure you remove and retain your SIM card and follow the manufacturer's instructions for deleting personal information or other data on the device. (This can be found in your owner's manual or on the manufacturer’s Web site.) If you provide a third-party access to your device, you should understand that personal information will remain on the device and may be accessible, deleted, altered, or transferred to another device or our network servers by the person using the device, and that we will treat that user as you for purposes of this policy.

We encourage you to use passwords to prevent unauthorized access to your device, your online account, and your voicemail. 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.

Third-Party Applications for Your Devices  
When you install third-party applications (for example, programs, widgets, etc.) on your device, you may give your consent for the third party to access certain information you have stored on your device (for example your contact list). You may also give your consent for the third party to access information stored on ZERO11 Wireless’s network to facilitate the application’s functions (for example, you may have given your consent to third-parties to access your location information). In either case, the manner in which such third-parties may use, share, or disclose such information is governed by their terms and conditions and their privacy policies – not this policy.

Wireless Communications Security  
We cannot guarantee that your communications using our services or devices will be private or secure. Although it is illegal for unauthorized persons to intercept or access your communications or information, such interceptions or access can occur.

POLICY UPDATES AND CONTACT INFORMATION

Changes to This Policy  
We may update this policy if we materially change our practices or if legal or regulatory changes require it. If we decide to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time the personal information was collected, we will notify you by posting notice of the change on our Web site's home page for at least 30 days before we implement that change. You should refer to this policy often for the latest information and the effective date of any changes.

How to Contact Us  
If you have any questions or comments about this policy or about ZERO11 Wireless' privacy practices, please contact us at www.zero11wireless.com or call us at 877-724-8325. You may also direct your privacy-related comments or questions to the address below:

ZERO11 Wireless
c/o Americatel Corporation
Attn: Privacy Officer
7361 Calhoun Place, Suite 520
Rockville, MD 20855