Effective Date: May 24, 2022

Introduction

TracFone Wireless, Inc. (“TracFone,” “we,” “us”) is committed to your privacy. The following is our Privacy Policy (“Policy”) to ensure that our customers, website visitors, and mobile application users (“Customers” or “you”) are informed of your rights and are given clear instructions on how to exercise your rights. The purpose of this Policy is to inform you of the types and categories of personal information that TracFone, including its brands, affiliates, vendors, and service providers collect, use, share, and retain. The Policy also provides instructions on how you can manage your personal information, and depending on where you reside, you may request the disclosure, deletion, or restriction of any sale or monetization activities of your personal information.

Your use of our websites and services is subject to this Policy and the terms and conditions of service associated with your brand (“Terms”) including the indemnification and limitations of liability provisions contained therein. By using our website and services, you acknowledge that you have read, understand, and agree to this Policy and Terms. We do not require you to provide your personal information to us to enjoy some of our services. However, if you do not provide certain personal information, you may not be able to use or access portions of our website, such as the account features or account information.

TracFone reserves the right to change this Policy by publishing new terms on its website at any time. When we do, we will revise the effective date above. Your continued use of our website and services after such changes means you accept the Policy as revised. Please periodically review this Policy to stay informed about how we collect, process, and share your personal information.

Categories and Types of Personal Information We Collect:

TracFone collects personal information, which is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect this information to offer services, complete transactions, and maintain the highest level of customer service for all of our customers and website visitors. The personal information we collect and process depends on how, where, and why you interact with us. Some of the personal information we collect or may collect include:

Identifiers – Identifiers are any personal information that can be associated with a specific individual, entity or device. Examples of these identifiers include customer name, alias, postal address, mobile and device numbers, device identifiers, e-mail address, partial or full social security number, and other similar identifiers.

Categories of Personal Information – These are other types of the personal information collected from the customer to facilitate business transactions. These include, for example, telephone numbers, signature, credit or debit card information, credit or debit card expiration dates, and other financial or medical or financial records.

Characteristics of Protected Classification – Other information that TracFone may receive and store is information viewed as characteristics of protected classification under state or federal law. Typically, this information is received as ancillary to other information, such as date of birth to reveal the customer’s age, or may be required as part of the Federal Lifeline program to determine a customer’s qualification for SafeLink. Information that may be included in this category includes age, gender, marital status, disability, medical information, and military or veteran status. For identification and verification purposes, TracFone may ask the customer to provide a copy of his/her driver’s license. By doing so, TracFone may see, but does not actively collect, other information about the customer including race, color, religion, or national origin.

Commercial or Transaction Information – In order to complete transactions and for the convenience of the customers, TracFone collects credit card information, including account numbers, card holder names, and addresses. Also, TracFone will have records of the phone or other devices’ purchases, airtime card purchases and redemptions, wireless plans and offers, activation and port-in history, and records of information of products or services purchased or placed into the customer’s online cart.

Customer Proprietary Network Information (CPNI) and other Electronic Activities – As a wireless services provider, TracFone is required to collect certain personal information in connection with your wireless services. CPNI, for example, is a subset of the personal information that is generated in connection with the telecommunications services we provide to our customers. CPNI includes, for example, call detail records, call location information, technical configuration, and information about your rate plans and features. We may de-identify your CPNI and, if we do so, we will maintain and use the data in a non-individually identifiable form and will not attempt to re-identify the data. If you use one of our branded cloud mobile applications and you grant us permission, we will access information from your mobile device to operate the service including geolocation, contact list, call records containing phone numbers you call and receive calls from, text records, text messages and your photo and video library, documents and music. Our cloud services cannot back up or restore your device information on your behalf if you do not grant us the required permissions. Additionally, TracFone maintains several internet webpages and mobile apps to inform customers about plans, services, and help complete transactions. As part of this, TracFone will collect certain information including browsing history, search history, interaction with website and apps, and interaction with advertisements.

Information collected when you use TracFone cloud apps - If you use one of our branded cloud mobile applications and you grant us permission, we will access information from your mobile device to operate the service and to store the types of content you wish to back up, including contact list, call records containing phone numbers you call and receive calls from, text records, text messages and your photo and video library, documents and music. In addition, depending on your mobile device operating system, we may obtain your permission to collect location information for scheduled backups or to locate printing vendors near you. Our cloud services cannot back up or restore your device information on your behalf if you do not grant us the required permissions.

Network, Device, and Geolocation Information – We may collect information about your use of your device and our network, how you use or access our service or website, Wi-Fi usage, geographic locations, and performance information. Some examples of this type of information include internet protocol (IP) addresses, the type of internet browser you are using, the type of operating system you have configured on your computer or phone, the domain name of the website and/or Internet Service Provider (ISP) from which you are linked to our website, the model of phone that you are using, device identifier (“UDID”), web browsing and wireless application use information, date and time stamp, and clickstream data to analyze trends in aggregate and administer our website. TracFone may also collect aggregated network strength data. This data may combine geolocation information, signal data, and other information to help TracFone monitor the strength and reliability of the services we provide to our customers.

Educational, Professional, and Employment Information – TracFone does not actively seek educational or employment information about our customers. However, this information may be submitted to TracFone as part of TracFone’s Lifeline program to verify eligibility. For example, customers may elect to verify their income levels by submitting paystubs. Once the information is verified, TracFone will delete such information as prescribed by law.

Inferences – TracFone always seeks to provide the best service, products, and selections to our customers. As part of this, we may develop profiles on our customers to determine which service, prices, and offers would best suit their needs. As such, TracFone may have inferential information on our customers including preferences, predispositions, and behavior to see what wireless plans or offerings would be competitive in the marketplace.

Health Information – For those customers who apply to qualify for the federal Lifeline Assistance Program, personal information may be appended with information obtained through third party sources, such as Health Maintenance Organizations (HMO), for the purpose of corroborating a potential customer’s enrollment eligibility. TracFone will share the mobile number with the HMO providers associated with those customers. If a child or other beneficiary is the qualifying recipient for the Lifeline Assistance Program, we will also collect the child’s or other beneficiary’s name, date of birth, and partial social security number to verify their eligibility in the program.

Note: TracFone does not have access to the content of private e-mail communications and text messages that are transmitted using TracFone services.

How Personal Information is Collected:

Personal Information Submitted to Us. We collect personal and non-personal information from you based upon our business relationship with you. You supply information to us when you use our products and services, when you visit our website, when you make a purchase from us, or when you establish or modify an online account. Additionally, you may also provide us with information when you interact with our customer service representatives, participate in online surveys, or collect and redeem reward points.

Preinstalled Applications. Your device may have pre-installed applications or portions of applications that, because of their limited utility, do not appear as separate icons on your device screen. These applications are used by us and our partners to collect network strengths, performance, coverage, and quality, as well as for marketing purposes. Additionally, these applications may collect information regarding your device, such as device identifiers, features, and software versions installed, for campaign management such as push notifications or to preinstall certain applications.

Automatically Collected Personal Information. We also automatically collect information associated with you through your use of your device and our products and services. When you visit our website, we may store information on your computer that allows us to identify you immediately. This process is often referred to as "cookie" technology. More specifically, a cookie is a commonly used Internet standard which stores, in a very small text file on the customer's hard disk, information specific to the customer. We and our partners use cookies or similar technologies to identify you as the user, analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our customer base as a whole. TracFone and its partners also use web beacons, widgets, and server log files to collect and store information about our users. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, you may limit your use of certain features or functions on our website or service.

How Personal Information is Used:

Business Relationship Purposes. TracFone uses your personal information for various purposes, including but not limited to, billing purposes such as the auto-refill program, to provide or change service, to anticipate and resolve problems with your service, for fraud prevention purposes, to comply with legal requirements, to communicate with you, to manage and administer our websites and services, for auditing and accounting purposes, to collect and process transactions, or to inform you of products and services that better meet your needs.

Interest Based Advertising. We and our authorized advertising partners use cookies and similar technologies to collect information to help tailor the ads you see on our sites and to help make decisions about ads you see on other sites. These companies employ cookies and action tags to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely non-identifiable. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note that by “opting out,” you will no longer receive targeted advertisements, but may continue to receive general advertisements.

Adobe Experience Cloud Device Co-op. All TracFone’s brands participate in the Adobe Experience Cloud Device Co-op to better understand how you use our website and apps across the various devices you use, to deliver tailored promotions, and to provide our customers with a better, more consistent cross-device experience. To learn more about Adobe and its Device Co-op Privacy Control, please click here.

Mobile Analytics Software. TracFone uses mobile analytics software to better understand the functionalities of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and location where the application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

How Personal Information is Shared:

Third Party Service Providers. Your wireless number may be shared for text messaging services operated by third party service providers. These vendors may directly contact you on our behalf by text messages with promotions, discounts, advertisements, reminders related to your services, or other information that may be helpful or informative to you. An opt-out mechanism is provided in these messages in compliance with applicable laws.

Third-Party Service Providers Obligations. When TracFone uses third party vendors to perform services on our behalf, such as marketing, fulfillment services, and shipping to customers, TracFone will require that such third parties protect and restrict use of your personal information consistent with the terms described in this Policy.

TracFone may further share customer personal information in the following situations:

• With affiliated and unaffiliated service providers who help us perform and deliver our website and services, subject to confidentiality agreements where reasonably feasible, including: service and sales fulfillment; form processing; website management and hosting providers; information technology and security providers; customer service; email and newsletter delivery services; background check providers; credit agencies; advertisement partners and corporate sponsors; and auditing providers;
• With third parties to investigate and help prevent fraud, other unlawful activity or activity that threatens a service network;
• With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to legal activity, such as to comply with a subpoena, request by public authorities for meeting national security or law enforcement requirements, or other similar legal process;
• With the appropriate government and law enforcement authorities, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• With persons or any third party of your choosing and at your discretion; and
• With necessary third parties in connection with, or during negotiations for, a merger, acquisition, or sale of all or a portion of TracFone’s assets.

Walmart Family Mobile Customers. If you are a Walmart Family Mobile customer, TracFone works with Walmart Stores, Inc. ("Walmart") to offer the Walmart Family Mobile service. Any information you provide directly to Walmart will be subject to Walmart's Privacy Policy, not this one. This includes information you provide to Walmart in connection with your device purchase, upgrade, return, or replacement, whether in its stores, by phone or online, including but not limited to, if you purchase a Family Mobile device or obtain technical support for the device at or from Walmart or its agents. In addition, if you activate Walmart Family Mobile communications services at a Walmart store, Walmart may request personal information from you that is passed to TracFone as part of the activation process, but which may also be retained by Walmart. For information on Walmart's privacy policy and practices, see Walmart Privacy Policy by clicking here.

Software Application for Our Websites. TracFone also works with other companies who supply software applications for use on our websites. The software is used to collect survey or feedback information or support real-time chat sessions from customers who visit our website and utilize these tools. Information from your web session, including your device serial number, phone number, and account email may be associated with your responses when utilizing these tools. This information is used by TracFone exclusively for analysis of survey or feedback results and will not be shared with any third party for any other purposes.

How Long Your Personal Information is Retained:

We will retain your personal information as long as it is needed for business, tax, retention, and legal purposes. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You information will be deleted when all of the following conditions are met:

• once it is no longer needed;
• when there is no legal obligation to retain it;
• at the end of TracFone’s information retention period; and
• upon receipt of a verified request and can be deleted without affecting TracFone’s legal obligations or ongoing business needs.

Absent a specific request to delete your personal information, as permitted by law, TracFone will delete your information per its normal business processes and procedures.

How Customers Can Restrict the Sharing of Personal Information Used in E-Mail Marketing:

Declining E-mail Offers. TracFone will only send our customers e-mails regarding promotional offers or other news if a customer grants us permission to do so by providing an email address. If a customer does provide us an email address, we may use it to communicate with the customer including sending promotional offers or other information.

Opting-Out of E-Mail Offers. A customer always has the right to choose not to receive TracFone e-mail direct marketing communications by opting-out or unsubscribing. A customer can opt-out or unsubscribe from our e-mail list by clicking on the unsubscribe link found at the bottom of every message or promotion delivered electronically to our customers. Upon such election and within a reasonable time thereafter, TracFone (a) will not contact that customer directly with TracFone promotional messages, and (b) will not use personal information obtained from that customer's registration to contact that customer with TracFone product messages.

How Personal Information is Secured:

TracFone uses administrative, organizational, technical, and physical safeguards to protect the personal information it collects and processes. Nonetheless, TracFone cannot guarantee your personal information will be perfectly secure at all times. Our security controls are designed to maintain data confidentiality, maintain data integrity, and give us an appropriate level of access to your data. For example, when you enter sensitive personal information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). TracFone, based on its reasonable judgment, will continue to enhance its security procedures as new technology becomes readily available. If you have any questions about security on our website, you can contact us at privacy@tracfone.com.

Links to Other Websites:

Third Party Links. TracFone's websites may contain links to other websites that are not owned, operated, or controlled by TracFone. Any personal information collected by such third-party websites is not governed by this Policy. We recommend that you examine the privacy policies of such third-party websites prior to submitting any personal information.

Third-Party Websites. In some instances, our website content is also featured on other websites with differing or non-existent privacy policies. These websites may collect personal information from website visitors that may or may not be used in conjunction with our website information. Prior to supplying personal information to any third-party company linking to our website, please read and understand their privacy policies.

Policy Regarding Information Obtained from Children:

TracFone’s websites are not structured to attract children under the age of 13. TracFone does not knowingly, directly, or passively collect information from children under the age of 18. Ordering online products and services from TracFone is limited to adults (ages 18+). Of course, wireless devices and services purchased for family use may be used by minors without the knowledge of TracFone. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.

Advertisements:

Advertisements may appear on pages throughout our website. Some advertisements may request information directly from our customers or take our customers to websites that may request personal information. TracFone has no control over its advertisers' privacy policies, so please examine the privacy policy of any company advertising on our website prior to submitting any personal information.

Public Forums/Blogs:

Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You should not provide personally identifiable information in any publicly accessible blog or community forum.

To request removal of your personal information from our blogs and forums, contact us at privacy@tracfone.com, and we will do our best to comply with the request. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Refer-A-Friend:

If you choose to use our referral service to tell a friend about our site, we will ask you for your friend's name and email address and automatically generate a one-time email to send your friend inviting them to visit the site. If you use the “Import Contacts” feature, we may collect your friends’ names and addresses in order to administer TracFone’s Refer-A-Friend program. TracFone does not store your friend's information or use it for any other purpose.

Gift Purchases:

If you purchase a gift, we will ask you for the recipient’s name and mailing address in order to ship product to the individual. TracFone does not retain the recipient’s information or use it for any other purpose.

Social Media Features:

Our website includes social media features and widgets, such as the "Share This" button or other interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the feature or widget.

Surveys:

Occasionally, we may conduct surveys on our website. Surveys are conducted at random and are completely voluntary to our website visitors. The survey may require a customer to provide personal information in exchange for the information or services provided by the survey. We may use this information in an aggregate manner to better tailor the types of services, information, and advertising that are provided on our website.

Mobile Applications:

The My Account app may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you do not wish to receive these types of communications, you may turn them off at the device level.

Geolocation:

You may opt-out of location-based services at any time by editing the location services setting at the device level.

How Customers and Visitors Can Access and Update Personal Information:

You can verify your account and manage your personal information by logging into the “My Account” portal or by contacting Customer Service. To manage your personal account online, log into the “my Account” portal and select the “Update Your Profile” link. Delete or change your personal information from the form and select “Submit” at the bottom of the page.

If you do not remember or are unable to use your information to log onto the “My Account” portal, please contact a customer care agent by calling 1-800-867-7183. All requests for changes or deletion of account information require account verification by answering security questions or providing the Personal Identification Number (PIN) you set when you first activated your account.

In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Nevada Privacy Rights

Nevada consumers have a right to submit a request to opt-out of sale of personal information, referred to under the Nevada Privacy Law as “covered information.” Upon receipt of a verified request, both as to the submission and the identity of the consumer, TracFone will ensure that no covered information, as defined under the Nevada Privacy Law, is sold. TracFone will further notify the customer within 60 days after receipt that the request has been processed. At this time, Nevada residents can only submit this request by calling 1-877-799-1999.

How to Contact Us:

Please direct any questions or comments regarding our privacy policy to:

Email: privacy@tracfone.com

Address: TracFone Wireless, Inc.

Attn: Privacy Policy Compliance

9700 NW 112th Avenue

Miami, Florida 33178

If you have any unresolved privacy or data use concerns that we have not addressed to your satisfaction, please contact our U.S. based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.