PRIVACY AND CPNI POLICIES AFFINITY CELLULAR

(HEREAFTER REFERRED TO AS "AFFINITY CELLULAR")

Affinity Cellular is committed to maintaining your privacy. We believe that you are entitled to know how Affinity Cellular will collect, use and protect the information you give us. These policies describe how we collect and may disclose personal information, including the following: what personal information we collect from you, how we use your information, how long we maintain your information, when and to whom we disclose your information, how we restrict our use of your information for marketing purposes, and how we protect your rights concerning your information and its disclosure.

If you have any questions or concerns regarding these policies, please contact Affinity Cellular at 1-800-998-2355

PART I: OUR PRIVACY POLICY

SCOPE

This Privacy Policy notifies Affinity Cellular subscribers about the following:

  • What personal information we collect from you.
  • What personal information our vendors collect.
  • What organizations collect the information.
  • How the information is used.
  • With whom the information may be shared.
  • How long information is retained.
  • What choices are available to you regarding how we collect, use, and distribute the information.
  • What security procedures are in place to protect information under the control of Affinity Cellular.
  • How you can correct any inaccuracies in the information.

TREATMENT OF INFORMATION

Information Collected When We Provide Your Services

Affinity Cellular collects information from you in connection with your services.

Affinity Cellular is authorized to collect the personal information that we need to provide you services. We are prohibited from collecting your personal information for any other purpose without your consent. (See the next section for a list of authorized uses of your personal information.)

When you establish an account for services, we may collect information such as your name, address, and telephone number, as well as information used for credit checks, billing, and payment, and other information we may need to establish and service your account. When you first request your services, and when you request any changes or updates to your services, Affinity Cellular may collect information about the service options that you have chosen. Affinity Cellular may also collect your personal information when you communicate with us: for example, if you ask for support or maintenance, have questions about your bill, send us e-mails, respond to our surveys or e-mails, engage in chat sessions with us, register for information, or participate in promotions or contests.

In addition, Affinity Cellular may combine your personal information collected as part of our regular business operations with personal information obtained from third parties to use in marketing services. (Your right to limit or restrict us from making certain uses of information about you is described below in this Privacy Policy.)

How We Use and Disclose Your Information

Affinity Cellular considers the personal information contained in our business records to be confidential. However, Affinity Cellular is authorized to disclose your personal information for three general purposes:

  1. We may be required by law or legal process to disclose information to law enforcement personnel or to other parties in connection with litigation (as described below in this Privacy Policy).
  2. We may disclose the names and addresses of subscribers for business related purposes.
  3. We may disclose information necessary to provide your services.

For example, Affinity Cellular may use your personal information in order to install, configure, operate, support, and maintain your services, including but not limited to these purposes:

  • provide your services;
  • customize your services;
  • configure service-related devices;
  • account security;
  • bill for your services;
  • to provide customer service and support;
  • manage the network supporting your services;
  • make you aware of new products or services that may be of interest to you;
  • service improvements;
  • detect use or abuse of your services; and
  • compliance with policies or terms of service.

Affinity Cellular may use your information for any of the above purposes, for business activities and needs.

Additionally, Affinity Cellular may disclose personal information in connection with Caller ID, 911/E911, and directory services:

  • We may transmit your name and/or telephone number to be displayed on a Caller ID device unless you have elected to block such information.
  • We may provide your name, address, and telephone number to public safety authorities and their vendors for inclusion in E911 databases and records.
  • We may provide subscribers’ names, addresses, and telephone numbers to unaffiliated directory publishers and directory assistance providers for their use in creating directories and offering directory assistance services.

We sometimes disclose your personal information to our affiliates, to our employees for Affinity Cellular’s internal business purposes, as well as to outside auditors, professional advisors and service providers, potential business transition partners, and regulators. Typically, we make these disclosures only when the disclosure is necessary to provide your services or other services to you or to conduct a legitimate business activity related to them.

Information Collected on Use of Your Services

When you use your services, Affinity Cellular may transmit information about you over our network. We transmit this information in order to provide your services.

We will not listen to your outgoing or incoming calls or to your voicemail, but we may store information about the date and time of your calls for billing purposes. We could be required to disclose this information and messages along with other personal information about you to comply with law enforcement. We may also monitor and/or record the performance of our Services in order to manage, maintain, repair, and improve your services. For the purposes of training and/or quality assurance we may monitor and record your communications with Affinity Cellular employees.

Third-Party Service Providers

We may contract with third parties to provide specific services and features for your services. If these third parties provide services to you, they will collect, disclose, and protect your personal information in accordance with the policies stated herein. If, however, you become a direct customer of these third parties, then you will be subject to their terms of service and privacy policies. Affinity Cellular recommends that you carefully read their terms of service and policies to understand how they may use personal information about you.

Business Transitions

In the event Affinity Cellular (or its parent company) enters into a merger, acquisition, or sale of all or a portion of our assets, we may transfer information as part of the transaction. If, as a result of the business transition, the Privacy Policy and the accompanying CPNI Policy are changed, you can find those changes in the places indicated in the "Notification of Changes to this Policy" section below.

Software and Configuration

Affinity Cellular may use information that you provide to assist you with technical support, by collecting and maintaining your information in support software tools. The information collected in the support software is available only to authorized personnel for maintaining and supporting the use of your services. Affinity Cellular may also provide customer contact and support pages that you can use to communicate with Affinity Cellular about technical support. Affinity Cellular uses the information provided by you on these pages to support your use of your services.

Affinity Cellular may also provide software directly or through third parties for your use in connection with your services. These programs may be subject to their own terms of service and other policies. Affinity Cellular recommends that you carefully read their terms and policies to understand how they may use your personal information.

In certain cases, Affinity Cellular may configure your Service or Service-related equipment to resolve a technical support issue or otherwise render or deliver your service. Affinity Cellular may perform these configurations at your request.

Preferences

We may store information that you provide to personalize your settings so that you do not have to change these settings each time you use your services. We do not share your preferences with third parties except for service providers or other third parties who may provide certain components of your services.

Cookies

Affinity Cellular may use cookies to customize its services. Cookies are small files stored on your computer's hard drive to simplify and improve your experience. Cookies may be used to remember some of your personalization preferences and Service plan features, to remember your username and password (if you choose to store them). This Policy covers the use of cookies by Affinity Cellular on the Affinity Cellular website only; it does not cover the use of cookies by any other party or website unless stated otherwise.

Legal Disclaimer

We make every reasonable effort to protect subscriber privacy as described in this Privacy Policy. Nevertheless, we may be required by law to disclose personal information about a subscriber without his or her consent and without notice in order to comply with a valid legal process such as a subpoena, court order, or search warrant. We may also use or disclose personal information about you without your consent to protect our customers, employees, or property, in emergency situations, to enforce our rights in court or elsewhere, or directly with you, and for violations of the Service's terms of service and policies.

COMMUNICATIONS FROM AFFINITY CELLULAR

Special Offers and Updates

We may send new subscribers a welcome message and sometimes other information by e-mail or another means such as the U.S. mail. Subscribers who would like to receive information from us about other products, services, features, special offers, and promotions may do so. See the Do Not Call and Do Not Mail Lists section of this Policy, as well as the CPNI Policy which follows, to learn how to opt in or opt out of receiving these types of promotional communications.

Service Announcements

We send subscribers service-related announcements from time to time. For example, we may send you an e-mail announcement about a pricing change, a change in operating policies, or new features of your service. You may not opt out of these service-related communications.

Customer Service

We communicate with you to provide requested services and support for questions and issues relating to your account. We will reply to your requests for customer service by e-mail, phone, discussion forum, or through any other reasonable means.

Do Not Call and Do Not Mail Lists

Affinity Cellular is permitted to use your contact information to place or have others place telephone calls or to send printed mail to you for marketing or promotional purposes. You have the right to ask Affinity Cellular at any time to put your name on our "do not call" and "do not mail" lists so that you will not receive these calls or mail.

The use of your account information by Affinity Cellular for marketing and promotional activities is subject to your right to limit or restrict us from making those offers as described below.

LINKS

The Affinity Cellular website may contain links to other websites. Some of these websites may be co-branded with Affinity Cellular and may look like part of the Affinity Cellular website, but Affinity Cellular is not responsible for the privacy practices of these other sites. We encourage you to be aware that the privacy policies described here do not apply when you leave your service and we recommend that you read the privacy policies of every website that collects personal information about you, whether the site is co-branded with Affinity Cellular or not.

SECURITY

Affinity Cellular takes the security of our subscribers' personal information seriously. We follow industry-standard practices to protect your personal information from unauthorized access to it. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personal information.

CORRECTING AND ACCESSING INFORMATION

If your personal information changes, you may update our records by contacting us at 1-800-998-2355.

To ensure that our records are accurate, you may examine and copy personal information we collect and maintain relating to you upon reasonable notice during regular business hours. If you wish to inspect those records, please contact us by telephone at 1-800-998-2355, to arrange an appointment. We will need a reasonable period of time to locate and, if necessary, prepare the information for your review. You will only be permitted to examine records that contain information about you and no one else. Please note that we may be unable to provide you with records without a subpoena, court order, or search warrant. Affinity Cellular reserves the right to charge a fee for the production of any documents that you request.

We will correct our records on a going-forward basis when the personal information we have collected about you is inaccurate. Please note, it is not possible for us to correct information appearing in our or our vendors’ directory lists until the next available publication of those directory lists. Further, we may have no control over information appearing in the directory lists or directory assistance services of directory publishers or directory assistance providers not affiliated with Affinity Cellular.

RETENTION OF INFORMATION

Affinity Cellular maintains your personal information in our regular business records while you are a subscriber of your services. We may also maintain this information for a period of time after you are no longer a subscriber if the information is necessary for the purposes for which it was collected or to satisfy legal requirements. These purposes typically include business, legal, or tax purposes. If there are no pending requests, orders, or court orders for access to this personal information, we may destroy the information after it is no longer necessary for the purposes for which it was collected.

NOTIFICATION OF CHANGES TO THIS POLICY

If we change this Privacy Policy or the CPNI Policy below, we will post those changes on www.affinitycellular.com/phone_privacy/ or in other places we deem appropriate and notify customers of policy changes, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If you decide to continue receiving your services after we make any changes to this Privacy Policy or the CPNI Policy, you shall be deemed to have given express consent to the changes in the revised policy.

PART II: OUR CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI) POLICY

Affinity Cellular is committed to maintaining your privacy as one of our customers. In addition to protecting your personal information, as described above, we are obliged to give additional protections to certain information about how you use your services. However, that information can help us customize and improve services we offer you.

In this section, we first describe what information we protect and how we protect it. AS WE EXPLAIN IN THE "APPROVAL" SECTION BELOW, WE WILL ASSUME THAT YOU APPROVE OUR USE OF THIS INFORMATION, UNLESS YOU CONTACT US TO DENY OR RESTRICT YOUR APPROVAL.

CPNI PROTECTIONS

We protect personal information related to your services: (1) information about the quantity, technical configuration, type, destination, location, and amount of your use of your services, and (2) information contained on your telephone bill concerning your services you receive. That information, when matched to your name, address, and telephone number is known as "Customer Proprietary Network Information," or "CPNI" for short. Examples of CPNI include information typically available from telephone-related details on your monthly bill - technical information, type of service, current telephone charges, long distance and local service billing records, directory assistance charges, usage data and calling patterns.

As a customer of our services, you have the right, and Affinity Cellular has a duty, under federal law, to protect the confidentiality of your CPNI. Unless we obtain your approval, Affinity Cellular may not use this CPNI to market products and services to you other than for services you currently purchase.

APPROVAL

In this section, we first describe what information we protect and how we protect it. AS WE EXPLAIN IN THE "APPROVAL" SECTION BELOW, WE WILL ASSUME THAT YOU APPROVE OUR USE OF THIS INFORMATION, UNLESS YOU CONTACT US WITHIN 30 DAYS OF RECEIVING THIS CPNI POLICY TO DENY OR RESTRICT YOUR APPROVAL.

From time to time we would like to use the CPNI information we have on file to provide you with information about our communications‐related products and services or special promotions. Our use of CPNI may also enhance our ability to offer products and services tailored to your specific needs. We would like you approval so that we, our agents and affiliates may use this CPNI to let you know about communications‐related services other than those to which you currently subscribe that we believe may be of interest to you. IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION. IF YOU DO NOT WANT TO APPROVE OUR USE OF THIS INFORMATION, YOU MUST NOTIFY US WITHIN 30 DAYS OF RECEIVING THIS CPNI POLICY.

DISCLAIMER

Affinity Cellular also offers various other services that are not related to the services to which you subscribe. Under CPNI rules, some of those services are considered to be non-communications related products and services. Occasionally, you may be asked during a telephone call with one of our representatives for your oral consent to Affinity Cellular use of your CPNI for the purpose of providing you with an offer for non-communications related products and services. If you provide your oral consent for Affinity Cellular to do so, Affinity Cellular may use your CPNI only for the duration of such telephone call in order to offer you additional services.

If you deny or restrict your approval for us to use your CPNI, you will suffer no effect, now or in the future, on how we provide any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

Revised and Effective: June 1, 2012

Affinity Cellular