My kajeet

Introduction

Privacy Policy Version 2, Last updated 09/05/2007

Welcome to the kajeet privacy policy. This is serious stuff, and we hope you take the time to read it all. This is where we explain how personal information is and isn't used by kajeet. This policy applies to all aspects of kajeet, including the kajeet.com Web site, wireless Internet services, applications, our agreements with business partners and affiliates and wireless voice services.

kajeet adheres to applicable laws and regulations, including the Children's Online Privacy Protection Act of 1998 (COPPA). There's a lot more information about COPPA available on the following page hosted by the Federal Trade Commission:

http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/.

In addition, 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 than is reasonably necessary for them to participate in the services offered.
• When you set up an account with kajeet, we give you a choice to receive offers from us or from people we think you might be interested in. We let you choose separately which information is sent to a parent (or responsible adult) and which information is sent to a child. Even if you choose to receive offers, you can change your mind any time and stop receiving them later on.
• The kajeet policy is that you need to "opt in" to receive marketing offers. This means you must choose to receive the offers.

Please note. When we say "you" or "our customers" in this document, we're talking about both you as a user (including any role you may have as a parent or responsible guardian) as well as any minor who uses the kajeet service.

There's more important information about our privacy policy below. While there's a lot of legal language in there, we hope you'll take the time to read through it all. 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.

This policy also applies to our use of what our industry calls "Customer Proprietary Network Information" (CPNI). CPNI relates to the use of kajeet voice services. It 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.

In this policy, we also provide additional information concerning our collection and use of data from our customers who are under the age of 13. COPPA protects personally identifiable information such as name, address, e-mail address and phone number.

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 customer above the age of 18 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.
• When someone under age 18 attempts to register with kajeet, a parent or guardian must provide consent and create a "kid account." In addition, consistent with COPPA, we obtain verifiable parental consent for collection of personally identifiable information from children under the age of 13.
• If a customer registers a kid account, including accounts for a child under the age of 13, we collect the first name, gender, date of birth, e-mail address and a password for the child. Customers may again give us a response to a secret question to allow them to get their password if they forget it.

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.

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 do not opt in to marketing offers described herein, we will continue to send you this important account-related information. Customers will not be charged for receiving these messages if we send them to the kajeet phone.

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.

Customers who want to receive offers for such customized content will be provided the opportunity to opt in to such communications during the registration process. You do not have to opt in, and you can always opt out at any time by logging back into your account and changing your preferences accordingly. kajeet will not contact children under 13 about special offers or for marketing purposes without parental consent. Customers will not be charged for receiving these messages if we send them to the kajeet phone.

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 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.

Instant Messaging (IM) Services

If you enable IM services, you will need to set up an account with the IM service provider. IM services will be governed by that provider's terms of service and privacy policies. In order to access the IM service, you will need to input personally identifiable information (such as your screen name or e-mail address) through your kajeet handset.

Depending on how you use the IM services, your IM messages and information about your IM messages, IM alerts and the searches you perform through the IM network and how you use the results of those searches may be used or retained by the IM service provider and may be shared with the IM service provider's affiliated providers, all subject to that IM provider's policies.

Ability to Update or Delete Information

kajeet gives you the ability to update and delete personal information you have provided to us as follows:

• Parents can view and update their own information and information relating to their child's kajeet account using tools offered in the "My Account" area of our Web site (www.kajeet.com). If parents wish to delete information from their child's account or prevent future collection, they may contact customer care at 1-866-4kajeet.
• Children can view and update their name, username, password and associated secret question in their kajeet accounts as a registered user in My Account. This does not affect a parent's ability to view or manage the child's account.

Please note that any information that we have obtained may remain 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 the phone, cookies are also used by our suppliers and third-party vendors to facilitate the various services and information offered. Depending on the phone being used, cookies may be stored locally on the phone or 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 phone will allow you to clear cookies if you do not want these to be maintained (this depends on the browser used by the phone).
• When you log in to the web site or use your phone, kajeet recognizes your identity. Independently of cookies, kajeet may personalize your experience and suggestions on the web site or on your phone.
• 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 and phones, 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 a phone 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 phones receive temporary IP addresses when they use data services. These addresses are reassigned after each data session. IP addresses from kajeet phones are hidden from third parties you visit via the Mobile Web service. These third parties cannot collect kajeet IP addresses.

Customer Proprietary Network Information.

Customers have a right, and kajeet has a duty, under the law 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 employees 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 that comply with federal regulations 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.

Questions and Suggestions

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

kajeet, Inc.

P. O. Box 30804

Bethesda, MD 20824-0804

1-866-4kajeet

privacy@kajeet.com

Update/Effective Date:

This policy was last updated 09/05/2007

Copyright © 2007 kajeet Inc. All rights reserved.