KAJEET PRIVACY POLICY

Introduction

Privacy Policy Version 4, Last updated 08/08/2012

Welcome to the Kajeet privacy policy. This is where we explain how personal information is and isn't used by Kajeet. This policy applies to the Kajeet.com Web site, the Arterramobility.com Web site, and any other Web site of Kajeet that indicates it is subject to this privacy policy.

This privacy policy applies to information collected from and after the date when this policy was last updated.  If information collected from you was subject to an earlier privacy policy, we will continue to treat previously collected information in accordance with the applicable earlier privacy policy.  Earlier privacy policies may be found here.

Kajeet applies its own policies for the safety and security of the data of users of the Kajeet service. Here are some other important things you should know:

  • Kajeet does not collect more personally identifiable information from children under the age of 13 than is reasonably necessary for them to participate in the services offered.
  • Though an adult customer may authorize a minor to utilize the adult’s account or an adult’s devices (e.g., mobile phones) that access his or her account, only an adult is authorized to establish and manage an account.  When you set up an account with Kajeet, we therefore require an email address from an adult 18 years old or older to establish service and may send you marketing emails of new Kajeet products or promotions.  Though we hope that you find these messages useful, we provide the option to opt out from receiving them by unsubscribing directly from the email delivery system or changing one's logged-in profile settings at Kajeet.com.  
  • When you set up an account with Kajeet, we also give you a choice to receive offers from companies we think may interest you (you must "opt in" to receive these particular offers). We let you choose separately which information is sent to an adult account holder and which information is sent to a minor authorized by the adult to use that account. Even if you choose to receive offers, you can change your mind any time and stop receiving them later on.

Please note. When we say "you" or "our customers" in this document, we're talking about both you as a user of our website or services (including any role you may have as a parent or legal guardian) as well as any minor who uses Kajeet’s websites or service with your permission.

There's more important information about our privacy policy below. We take the privacy of your information very seriously, but no one should take it more seriously than you. If you have any questions, there's a way to contact us at the end of this document.

What this Privacy Policy Covers

This privacy policy explains how Kajeet treats personally identifiable information that Kajeet collects and receives. Personally identifiable information is information about our customers that can identify them, such as name, address, e-mail address or phone number.

For customers who subscribe to our voice telephone services, this policy also applies to our use of what our industry calls "Customer Proprietary Network Information" (CPNI).  CPNI includes the length of calls, the phone numbers that customers call and similar information. CPNI does not include personally identifiable information, such as name, telephone number and e-mail address.

This policy does not apply to the practices of companies that Kajeet does not own or control, or to people Kajeet does not employ or manage. However, when Kajeet uses companies, agents, contractors or other third parties to perform services on its behalf, Kajeet requires that they protect CPNI and personally identifiable information consistent with this policy.

Why We Collect Information

We collect information that helps Kajeet provide services to our customers. These include services from third-party software developers and publishers and service providers with whom we have partnered. We may also use this information to protect customers, employees and property against fraud, theft or abuse, to conduct surveys and to maintain good customer relations. The information we collect helps us improve and keep you informed of new services and products.

Information We Collect

Kajeet collects personally identifiable information and CPNI when customers register with Kajeet, when customers use Kajeet products or services, when customers visit Kajeet Web pages or the Web pages of certain Kajeet partners and when customers choose to enter promotions or sweepstakes or participate in a survey.  Kajeet collects the following important information:

  • When a consumer who is 18 or older registers for a Kajeet account, we require name, gender, address, contact number, e-mail address and a password. Customers may also give us a response to a secret question to allow them to get their password if they forget it. We may not require some of this information from individual end users of Kajeet Services who are using a corporate account.
  • If a parent or legal guardian creates a Kajeet account to be used by his or her child under the age of 13, we collect information from the adult customer about the child, including either a name or nickname for the child, and, at the parent’s or guardian’s option, the child’s gender and date of birth.  We do not collect personally identifying information directly from children under the age of 13. 

Customers may also provide information in response to surveys conducted by Kajeet either online or offline. If this information is connected directly to your personally identifiable information, it is personally identifiable information under this policy. In addition, customers may provide Kajeet with personal information when they interact with us. For example, customers may provide such information when requesting or using Kajeet customer service.

In order to better personalize your service and to provide you offers tailored to your needs, Kajeet also collects information about customer transactions with us and with some of our business partners.

Collection of GPS

Kajeet devices may have the ability to collect and store GPS location data, include time-stamped GPS data capable of identifying the location of the device at various times.  You understand that this data may be disclosed to the account holder for the device (e.g., a parent desiring to find the location of a child’s Kajeet mobile device, or an employer ascertaining the location of a mobile device issued to an employee).  Other than to account holders as described above, Kajeet does not provide GPS location collected by Kajeet devices to third parties.

Use of Information

Administrative Messages

Kajeet uses personally identifiable information to create and maintain accounts, including the delivery of important administrative messages such as service announcements, privacy policy updates, terms of service updates, rate plan changes, balance notifications and account status notifications regarding that particular account (by e-mail, text message, call from customer service or any combination). Please note that when you unsubscribe from receiving marketing offers described herein, we will continue to send you this important account-related information. Customers will not be charged by Kajeet for receiving these messages if we send them to a mobile device. 

Customized Services

Kajeet may also use personal information to make offers for customized services, promotions and content offerings. For example, we may:

  • Send birthday messages
  • Alert customers to new games or contests
  • Alert customers to additional product and service opportunities (e.g., new accessories, ringtones, wallpapers or handsets)
  • Convey public service announcements

If you are an adult parent or legal guardian who has created a sub-account for a minor, during the registration process the adult will be provided the opportunity to opt in so that the minor may receive offers for such customized content. You can also opt out from receiving these messages by logging into your account and changing your preferences accordingly. Kajeet will not contact children under 13 about special offers or for marketing purposes without consent from the child’s parent or legal guardian. Customers will not be charged by Kajeet for receiving these messages if we send them to a mobile device.

Kajeet also uses and processes customer data to better understand our customers through the analysis of aggregate data related to those customers and their use of the Kajeet service.

Information Sharing and Disclosure

  • We may share information related to a Kajeet account with the account holder, even if the account holder and actual account user are different.  This may include sharing information about usage of a particular device, like a mobile phone, with the person or entity that holds the Kajeet account related to that device.  For example, if a parent creates a Kajeet account for a minor child and provides a mobile phone to that child, we may disclose information about that account, including usage information, to the parent.  Similarly, information about account usage by an employee (e.g., websites visiting using a mobile device issued to the employee and associated with the employer’s account) may be disclosed to the employer who holds the account.
  • We may share information with companies that work on behalf of Kajeet to provide a product or service that has been requested. We share this information only when it is required to deliver the service in question, and any company working with Kajeet to deliver such a service does not have a right to use the information we provide to them beyond what is necessary to assist us in delivering that product or service. 
  • You may elect to participate in Kajeet-sponsored contests, giveaways, sweepstakes or other promotions and product or service opportunities that Kajeet may sponsor. If Kajeet should use third parties to deliver these promotions, Kajeet will share only the information required to allow them to do their job and will not allow the third party to use information for any other purposes without appropriate permission. 
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise legal rights or defend against legal claims.
  • We share information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Kajeet terms of use or as otherwise required or permitted by law or consistent with legal requirements. 
  • We will transfer information about our customers if Kajeet is acquired by or merged with another company.

You may also want to take advantage of services and products offered by other companies through our wireless services, such as third-party network-aware applications or Web sites accessed through Kajeet Mobile Web. In those cases, you will be providing information to those companies directly, and information about you received by those third parties will be governed by their privacy policies, not this policy.

Ability to Update or Delete Information

If you have registered an account with us, you may view, update and request deletion of personally identifying information that we have collected by logging into your account within our website and using the online tools we provide.

If you are an adult parent or legal guardian who has created as sub-account on behalf of a minor, you may likewise view, update, and request deletion of information about the minor by using those online tools that are accessible by logging into your account.  

You may also change your preference settings related to our collection of information by using those same online tools, or you may contact us directly by clicking here.  

Please note that any information that we have obtained may remain in permanent archives or in backup storage for some period of time after a deletion request. This may be the case even though we will not use such information. Further, we retain call and other records consistent with legal requirements.

Personalization, Cookies, Web Beacons and Aggregate Data

This section identifies how Kajeet and third parties use Web technologies such as cookies and Web beacons, and identifies how your IP address may be seen or used as you use the Kajeet service. These technologies are generally used to improve or personalize a service in some way so that it is easier to use.

Cookies are small text files placed on a computer's hard drive by a Web site when a customer visits that site. Cookies are used within the Kajeet service as follows:

  • Cookies identify a customer's computer and record customer preferences and other data about the visit. When customers return to the site, the site knows who they are and can personalize the visit to that site. Kajeet uses cookies to collect information to improve and personalize our services and make suggestions to customers. In most cases your computer will provide you with the ability to clear cookies and to disable cookies (this depends on the browser you are using).
  • With Kajeet Mobile Web accessed from a mobile device, cookies are also used by our suppliers and third-party vendors to facilitate the various services and information offered. Depending on the type of device being used, cookies may be stored locally on the device or on servers operated by Kajeet or our vendors/licensors. This Internet cookie-like functionality is used for the same purposes as cookies placed on a customer's computer when interacting with Internet Web sites. In many cases, your device will allow you to clear cookies if you do not want these to be maintained (this depends on the browser used by the device).
  • When you log in to the web site or use your mobile device, Kajeet recognizes your identity. Independently of cookies, Kajeet may personalize your experience and suggestions on the web site or on your mobile device.
  • Sites that customers visit while using Kajeet Mobile Web are controlled by separate companies, and their individual privacy policies will govern the information they receive from the cookie.

Kajeet may also place Web beacons on its site in conjunction with cookies to monitor how visitors are navigating and/or interacting with the site. A Web beacon is a small, sometimes transparent graphic image on a Web page, Web-based document or in an e-mail message that is designed to allow the site owner or a third party to monitor the address and other information of the user visiting the Web site or sending or responding to the e-mail. Web beacons are used within the Kajeet service as follows:

  • When the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer, the time the Web beacon was viewed and for how long and the type of browser that retrieved the image.
  • Kajeet uses Web beacons to improve its site design and operational and business practices over time. Such beacons may also be used by third parties that provide Internet services for Kajeet users over the Mobile Web.
  • In some, but not all, computers, phones and other mobile devices, turning off the browser's cookies will prevent Web beacons from tracking the user's activity. The Web beacon will still account for an anonymous visit, but the information unique to the user will not be recorded.

IP addresses are used in the Kajeet service as follows:

  • An IP address allows information to be sent to and from a computer or other device on the Internet. IP addresses are often temporarily assigned. Temporarily assigned addresses are assigned to a user for a period of time so the user typically does not have the same address each time they use the service. If a user is using a permanent IP address (more common with servers than mobile, dial-up, DSL or cable Internet users), they will have the same address each time they use the service. Kajeet collects IP addresses when people access our Web site.

Kajeet mobile devices receive temporary IP addresses when they use data services. These addresses are reassigned after each data session. IP addresses from Kajeet mobile devices are hidden from third parties you visit via the Mobile Web service to prevent these third parties from collecting Kajeet IP addresses.

Customer Proprietary Network Information

Kajeet exercises reasonable efforts to ensure the confidentiality of CPNI. Kajeet may use customer CPNI to market additional communications and data products and services similar to the types currently purchased from us. For example, subject to your permission, Kajeet may market: 

  • Wireless Internet access
  • New messaging products
  • Interactive service
  • Ringtones, wallpapers, or games
  • Handsets or related equipment
  • Web-based services (for example, photo sharing on the Net)

Again subject to your permission, Kajeet may contact you to market additional products and services we and our partners sell.

Kajeet also discloses customer CPNI as required by law (see "Information Sharing and Disclosure" above).  And, to provide service, we may use and disclose CPNI to our agents and independent contractors, but we restrict their use and limit disclosure of CPNI for purposes of providing service or to market products and services as previously described. We will also prohibit the third party from further disclosing the CPNI except as required by law and will require the third party to implement safeguards to protect the confidentiality of the CPNI.

Confidentiality and Security

Kajeet works to safeguard your personally identifiable information. Kajeet limits access to personally identifiable information about our customers to personnel who we believe reasonably need to use that information to provide products or services to our customers or in order to do their jobs. 

We have physical, electronic, and procedural safeguards to protect personal information about our customers.

We use technologies to safeguard personal information including:

  • Secure Socket Layer (SSL) encryption
  • Firewalls and intrusion detection systems
  • Password protection of systems containing personally identifiable information.

As with any Web site, the security of information also depends on the safe computing practices of its customers. We strongly recommend that all Kajeet customers:

  • should use strong passwords that are not easily guessed for system access
  • should not share passwords with others
  • should not respond to e-mails or text messages asking for password information.

Changes to this Privacy Policy

Kajeet may update this policy from time to time if our practices change or if changes in the law require us to do so. We will notify customers about significant changes in the policy by sending a notice to the primary e-mail address specified in the Kajeet account or by placing a prominent notice on our site. By continuing to utilize our websites and/or services, you are agreeing that we may use and disclose information in accordance with those updates policies, including information we have previously collected.  If you do not consent to those updated policies, you must cease use or our websites and/or services and must promptly notify us or, as appropriate, update your information preferences by logging in to your online account and using the tools we provide.

Questions and Suggestions

If you have questions or suggestions about this policy, you can contact us at:

Kajeet, Inc.

7901 Jones Branch Drive, Suite 350

McLean VA 22102

1-866-4Kajeet

privacy@Kajeet.com

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