Privacy Statement

OnePIN’s Privacy Statement

Effective: June 19, 2024

OnePIN, Inc. and its subsidiaries, OnePIN International, Inc., Life Technologies, Inc. and Zillions Technologies, Inc. (hereafter referred as “OnePIN, Inc.” or “OnePIN”) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. OnePIN has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF. OnePIN has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

OnePIN is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. OnePIN complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over OnePIN’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, OnePIN may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, OnePIN commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2

1 About OnePIN

OnePIN has a decade of experience connecting people to each other and the brands they care about. Its simple – OnePIN’s SIMplicity Cloud connects the world. With over one quarter of a billion connected people, OnePIN has demonstrated its innovation excellence within the mobile marketplace.

OnePIN’s SIMplicity cloud service platform offers the following distinct services:

Person to Person mobile communication services:

CallerXchange®
MsgXpress™
CelebraXion™
CelebraXion™

User engagement channel for Mobile Network Operators:

BoosterX™
ZeroX™
AuthentiXator™
Zillions™

User engagement channel for Content Providers:

MediaX™

Mobile Marketing Services for Brands:

AdXecutive™
SocialLinX™
SurveyXpert™
MaXapp™

Realizing that relationships between people and entities span multiple countries, mobile network operators, and even handsets, OnePIN has developed patented technologies on a unique mobile platform that enables the service to work on every handset and network.

OnePIN’s CallerXchange® service transforms mobile phonebooks into dynamic social address books subscribers use to stay in touch with their growing social network of friends, family and business associates. CallerXchange is a person-to-person contact exchange service that connects people and enhances social networks, enabling subscribers to share their mobile, home and work numbers, e-mail address, blogs, social networking sites, etc. with just one click.

MsgXpress™ is a missed call “quick message” service for subscribers. Subscribers can quickly send a personalized message with 1-click after missed calls.

Xpression™ enables users to share content with friends, family, and colleagues at socially relevant times using only a few clicks. The service automatically detects when a new connection is made with another individual, and prompts users to enhance that connection by sharing content.

CelebraXion™ is a mobile subscriber service that allows subscribers to conveniently send messages to their networks on special days. Based on the subscriber’s use of MsgXpress and CallerXchange, as well as the subscriber’s location, subscribers can send their friends and family a message on holidays and other special days.

MediaX™ is a user engagement service for Content and Media providers. The service enables the promotion of content and media to mobile customers via an interactive channel, helping customers choose, purchase and renew content subscriptions.

ZeroX™ is a personalized call back service subscribers can use when they are not able to top-up their zero balance cards.

Zillions™ provides all the fun and excitement of lottery, gaming and betting marketing platforms to Mobile Network Operators’ subscribers. By utilizing subscription billing, SMS, USSD, WAP and mobile wallets for gameplay, Mobile Network Operators can drive significant incremental revenue from their subscribers whilst also providing exciting and innovative content for them to enjoy.

AuthentiXator™ is a multi-factor authentication service which provides both the Mobile Operator and subscribers with additional security. AuthentiXator allows the mobile operator to add layers of protection for their customers with a simple press of a button on the user’s selected device.

The Mobile Marketing Services for Brands (AdXecutive™, MaXapp™, SocialLinX™, SurveyXpert™) provide a unique advertising opportunity for brands where Mobile Network Operators can offer subscribers a convenient way to interface with brands.

OnePIN Inc. is a privately held company, headquartered in Boston Massachusetts. OnePIN SIMplicity Services are commercially deployed in 30 Mobile Network Operators and servicing over 240 million mobile subscribers.

2 Statement of Privacy

This Statement of Privacy applies to OnePIN’s Mobile Network Operator Services (MNO), https://www.onepin.com, owned and operated by OnePIN, Inc. (collectively known as “OnePIN”, “we”, “us”, “our”). This Privacy Statement governs the collection, display and usage of all personal data and information collected through OnePIN’s Mobile Network Operator Services as well as all personal data and information collected through OnePIN’s business activities. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

OnePIN is committed to your privacy and hereby discloses OnePIN’s information practices and its privacy procedures in this document.

This privacy statement notifies you of the following:

What personal information is collected from you
What choices are available to you regarding display of and access to your information
How to cancel your account
How the information is used
Communication between OnePIN and Users
The security procedures in place to protect the loss, misuse or alteration of information
How to contact OnePIN

OnePIN, Inc. and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@onepin.com.

3 Data and Privacy Policies for each Service

3.1 CALLERXCHANGE®

3.1.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the CallerXchange Service to their mobile subscribers in their network. Subscribers are given opportunities to opt-in (register) to the service during normal mobile phone use (e.g. at handset start-up, after phone calls are ended, etc.). If the mobile subscriber does not wish to opt-in at the time of these offers, the service will not be available to them.

When opting-in with OnePIN’s CallerXchange service the mobile subscriber is asked for your first name, last name (optional), mobile number (MSISDN obtained from the network), telephone number (optional), e-mail address (optional) and your social media addresses (optional) as part of the service activation process. Once this minimum information has been received, mobile subscribers may then elect to use OnePIN’s CallerXchange service after phone calls.

OnePIN will only collect and display contact information exactly as it is entered and saved by subscribers. OnePIN does not collect or display other personal information (such as race, religion, political affiliation or sexual orientation). OnePIN does not knowingly collect personal information on children.

Subscribers are given the opportunity to send their CallerXchange business card to another mobile subscriber after the first call is dialed and has ended with the other subscriber. The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the CallerXchange service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.1.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

OnePIN operates on a permission-only basis with respect to the publication of members’ personal information.

For the CallerXchange service, if your contact information (business card) changes, or if you no longer desire our service, you may correct, update, delete or deactivate it by accessing the services menu.

A mobile subscriber’s CallerXchange business card is accessible within the Operator SIM Services Menu under the related service sub menu. The contact information in the CallerXchange business card (stored on the subscriber’s SIM card) can only be accessed and distributed by the subscriber (owner) by using the application on the subscriber’s SIM card. When mobile subscribers use the CallerXchange service and choose to share their business card within another person, the sender’s contact information may be stored in a secure cloud server environment. This cloud server is not accessible to the general internet.

Members can send their contact information to any mobile subscriber. If a member chooses to send his or her contact information to another subscriber, non-members will receive the contact information in SMS (text) format. Mobile subscribers with the CallerXchange service can receive the contact information of other members (when sent) in the same format, which matches the phonebook format of the operating system of the recipient’s mobile device.

Members can choose to whom they send their contact information, one at a time, at the end of the first call to each unique mobile number. In this way, members have complete control over how much of their contact information is shared, and with whom this information is shared.

Upon request OnePIN will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at privacy@onepin.com. We will respond to your request within a reasonable timeframe.

3.1.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the CallerXchange service, he/she may cancel the service via any of the following methods:

By selecting the related OnePIN services submenu from Mobile Network Operator SIM services Menu, then selecting “turn off”;
By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS, within the About screen of the SIM menu, and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times).

Under these circumstances, the CallerXchange service will no longer present itself when the subscriber makes phone calls. At any time, a subscriber can re-activate the account by visiting the services menu and selecting “turn on”. OnePIN will retain the contact information in the deactivated account until OnePIN’s contract with the Mobile Network Operator expires or is terminated.

OnePIN will retain and use subscriber information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.1.4 HOW THE INFORMATION IS USED

The contact information collected by the CallerXchange service belongs at all times to the individuals and organizations that entered the information. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the OnePIN services.

If you directly, or through OnePIN services, disclose your contact information to others, then your information may be collected and used by others.

3.1.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

In certain situations, OnePIN may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, 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.

If OnePIN is involved in a merger, acquisition, or sale of all or a portion of its assets, your Mobile Network Operator will be notified via email and we will post a prominent notice on our Web site detailing any change in ownership.

Third Party Intermediaries:

We may share aggregated information with companies that provide services such as hosting and IP routing for us to provide you service. These companies do not retain, share, store or use personal information gathered from OnePIN services for any secondary purposes. They are only authorized to use aggregated information only as necessary to provide the specified service.

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the information from one mobile subscriber to another. Mobile subscribers are protected under the terms of use of their Mobile Network Operator. The Mobile Network Operators do not retain, share, store or use personal information gathered from OnePIN services for any secondary purposes.

Cookies and Other Tracking Technologies

Technologies such as cookies, tags and scripts are not used by OnePIN’s mobile services. Other technologies are used in analyzing trends, administering the site, tracking subscribers’ usage behaviors and to gather demographic information about our subscriber base as a whole. We may generate reports based on the use of these technologies on an individual as well as aggregated basis. We use technologies to remember subscribers’ settings (e.g. language preference).

Log files

Like most standard technology companies, OnePIN uses log files. Data collected includes MSISDN, mobile device type, platform and mobile OS type, date/time stamp, and number of clicks in order to analyze trends, administer the site, track subscribers’ user behavior in the aggregate, and gather broad demographic information for aggregate use. OnePIN does not share this collected information with any third parties. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the information from one mobile subscriber to another. Mobile operators use log files, mandated by Telecommunications Regulations of the country (i.e. billing logs). Mobile subscribers are protected under the terms of use of their Mobile Network Operator. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

3.1.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Special Offers and Updates

After the provisioning of your SIM card for the first time, OnePIN sends all new subscribers a welcome communication via SMS (text) message or in the form of a mobile application notification on the screen. This communication will include service pricing, opt-in and opt-out information. Established subscribers will occasionally receive information on products, services, and special deals.

Service Announcements

On occasion it is necessary for OnePIN to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance we might send a communication via SMS (text) message or in the form of a mobile application notification on the screen. Typically, the Mobile Network Operator will communicate service announcements directly to the mobile subscriber.

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.2 MSGXPRESS™

MsgXpress™ is a missed call “quick message” service for subscribers. Subscribers can quickly send a personalized message with 1-click after missed calls. With MsgXpress, Operators generate premium VAS revenue with each message, and the service also increases operator’s “return call” volume and revenue. Subscribers pay an out-of-bundle SMS price per message.

3.2.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the MsgXpress Service to their mobile subscribers in their network. Subscribers are given opportunities to opt-in (register) to the service during normal mobile phone use (e.g. after non-answered phone calls are ended). If the mobile subscriber does not wish to opt-in at the time of these offers, the service will not be available to them.

When opting-in with OnePIN’s MsgXpress service, the mobile subscriber is asked to accept service registration via a two-step process after a phone call is dialed to another mobile subscriber, but not answered (a missed call). First, the mobile subscriber must confirm they would like to use the service by clicking OK/Accept to the MsgXpress welcome screen(s) displayed to the user. Secondly, the mobile subscriber must navigate through a menu to select the specific message they would like to send to the other mobile subscriber.

Subscribers are given the opportunity to send a MsgXpress message to another mobile subscriber after a phone call is dialed but not answered. The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the MsgXpress service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.2.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

OnePIN operates on a permission-only basis with respect to the publication of members’ personal communications.

For the MsgXpress service, the mobile subscriber determines what information they would like to send to the other mobile subscriber after a missed call.

Mobile subscribers can send their contact information to any mobile subscriber. If a Mobile subscriber chooses to send a MsgXpress message, the other mobile subscriber will receive the SMS message if they are not a member of the MsgXpress service, otherwise the other member will be notified and receive the message within their MsgXpress application and will be able to read and reply to the message in the same manner in which it was originally sent.

For the OnePIN MsgXpress service, Members can choose to whom they send a predefined message, one at a time, at the end of a missed call to each unique mobile number. In this way, members have complete control over what information is shared, and with whom this information is shared.

3.2.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the MsgXpress service, he/she may cancel the service via any of the following methods:

By selecting the related OnePIN services submenu from Mobile Network Operator SIM services Menu, then selecting “turn off”;
By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS, within the About screen of the SIM menu, and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times).

Under these circumstances, the MsgXpress service will no longer present itself when the subscriber makes phone calls. At any time, a subscriber can re-activate the account by visiting the services menu and selecting “turn on”. OnePIN will retain the subscriber’s account until OnePIN’s contract with the Mobile Network Operator expires or is terminated.

OnePIN will retain and use subscriber information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.2.4 HOW THE INFORMATION IS USED

The communications collected by the MsgXpress service belongs at all times to the individuals and organizations that selected the predefined MsgXpress messages.

If you directly, or through OnePIN services, send communications to others, then your communication may be collected and used by others.

3.2.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

We may share aggregated information with companies that provide services such as hosting and IP routing for us to provide you service. These companies do not retain, share, store or use MsgXpress messages gathered from OnePIN services for any secondary purposes. They are only authorized to use aggregated information only as necessary to provide the specified service.

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the MsgXpress messages from one mobile subscriber to another. Mobile subscribers are protected under the terms of use of their Mobile Network Operator. The Mobile Network Operators do not retain, share, store or use MsgXpress messages gathered from OnePIN services for any secondary purposes.

Cookies and Other Tracking Technologies

Log files

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the MsgXpress messages from one mobile subscriber to another. Mobile operators use log files, mandated by Telecommunications Regulations of the country (i.e. billing logs). Mobile subscribers are protected under the terms of use of their Mobile Network Operator. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

3.2.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Special Offers and Updates

Service Announcements

On occasion it is necessary for OnePIN to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send a communication via SMS (text) message or in the form of a mobile application notification on the screen. Typically, the Mobile Network Operator will communicate service announcements directly to the mobile subscriber.

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.3 BOOSTERX™

BoosterX™ is an interactive user engagement channel for Mobile Network Operators to communicate with their mobile subscribers. Mobile Network Operators use the BoosterX service as a convenient, universal channel to promote and fulfill: tariff plans, new services, account top-ups, etc. Subscribers easily upgrade their voice or data package using a simple subscriber interface prior to their plans expire. Operators increase their revenue by upgrading subscribers to higher capacity data plans and by eliminating down-time between data plan refills. This BoosterX service itself is offered for free to subscribers.

3.3.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the BoosterX Service to their mobile subscribers in their network who have opted-in to Mobile Network Operator marketing communications.

OnePIN will only collect and display information exactly as it is entered by subscribers as a response from the communication from the Mobile Network Operator. The information that is collected from subscribers is governed by the Mobile Network Operator’s terms of use agreement with its subscribers and is regulated by the Telecommunications Authority in the country.

The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the BoosterX service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.3.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

Since OnePIN’s BoosterX service is used as a channel to pass communications between the subscriber and Mobile Network Operator, OnePIN does not provide the subscriber access to their information. Mobile Subscribers must contact the Mobile Network Operator directly to find out the choices available to them regarding the display and access of their information.

3.3.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the BoosterX service, he/she may cancel the service via any of the following methods:

By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times);
By calling the Mobile Network Operator’s customer service department and requesting opt-out from all Mobile Network Operator communications.

Under these circumstances, the BoosterX service will no longer present itself. At any time, a subscriber can re-activate the account by calling the Mobile Network Operator’s customer service department. OnePIN will retain and use account information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.3.4 HOW THE INFORMATION IS USED

Mobile Network Operator uses the information that is collected by the BoosterX service to manage your account with the Mobile Network Operator. OnePIN’s BoosterX service is used as a channel to pass communications between the subscriber and Mobile Network Operator.

The information collected by the BoosterX service belongs at all times to the individuals, organizations that entered the information and the Mobile Network Operator. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the BoosterX service.

3.3.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the information from one mobile subscriber to the Mobile Network Operator systems. Mobile subscribers are protected under the terms of use of their Mobile Network Operator.

Cookies and Other Tracking Technologies

Log files

3.3.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.4 MEDIAX™

MediaX is a user engagement service for Content and Media providers. The service enables the promotion of content and media to mobile customers via an interactive channel, helping customers choose, purchase and renew content subscriptions. The service is available to any mobile customer within a specific Mobile Operator’s network who has OnePIN’s application.

OnePIN’s MediaX provides value to content providers, mobile operators, and subscribers. It is seamless, user friendly, and allows subscribers to access digital content with a simple opt-in process. Through OnePIN’s digital screens, operators are able to advertise effectively for the content providers as well as give the providers a platform to increase subscriptions. This MediaX service itself is offered for free to subscribers.

3.4.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the MediaX Service to their mobile subscribers in their network who have opted-in to Mobile Network Operator marketing communications.

The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the MediaX service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.4.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

Since OnePIN’s MediaX service is used as a channel to pass communications between the subscriber, the Content Provider, and the Mobile Network Operator, OnePIN does not provide the subscriber access to their information. Mobile Subscribers must contact the Mobile Network Operator directly to find out the choices available to them regarding the display and access of their information.

3.4.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the MediaX service, he/she may cancel the service via any of the following methods:

By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times);
By calling the Mobile Network Operator’s customer service department and requesting opt-out from all Mobile Network Operator communications.

Under these circumstances, the MediaX service will no longer present itself. At any time, a subscriber can re-activate the account by calling the Mobile Network Operator’s customer service department. OnePIN will retain and use account information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.4.4 HOW THE INFORMATION IS USED

Content Providers use the information that is collected by the MediaX service to manage your subscription. OnePIN’s MediaX service is used as a channel to pass communications between the subscriber, the Content Provider, and Mobile Network Operator.

The information collected by the MediaX service belongs at all times to the individuals, organizations that entered the information, the Mobile Network Operator, and the Content Provider. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the MediaX service.

3.4.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.4.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.5 MOBILE MARKETING AND AUTHENTICATION SERVICES

OnePIN’s The AdXecutive™, MaXapp™, SocialLinX™, and SurveyXpert™ and AuthentiXator services provide a unique opportunity for brands to engage with Mobile Subscribers via the Mobile Network Operator.

AdXecutive™ is a phonebook advertising service for brands. The service provides a unique advertising opportunity for Brands where Mobile Operators can offer subscribers a convenient way to add valued brands into their phonebooks.

SurveyXpert™ is an mobile phone-based survey service for brands. The service allows brands to collect immediate survey feedback.

With SocialLinX, brands have the opportunity to increase the effectiveness of their Social Networking communication channels with customers.

MaXapp is an application download boosting service. It allows brands to promote the download of their mobile applications.

AuthentiXator is a multi-factor authentication service which provides both the Mobile Operator and subscribers with additional security. AuthentiXator allows the mobile operator to add layers of protection for their customers with a simple press of a button on the user’s selected device.

3.5.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

OnePIN offers Mobile Marketing Services to brands through the Mobile Network Operator. Mobile Network Operators offers OnePIN’s Mobile Marketing Services to their mobile subscribers in their network who have opted-in to the service. These services may be offered after a mobile subscriber ends a phone call with a brand, or the service may also be offered at any time during normal mobile phone use.

AdXecutive collects the MSISDN of the mobile subscriber and the phone number and the name of the brands whom they have added to their phonebook.

SurveyXpert collects the MSIDSN and the response of a brand survey from the mobile subscriber.

SocialLinX collects the MSISDN and the brand with whom the subscriber has connected on social media.

MaXapp collects the MSISDN and the brand with whom the subscriber has downloaded the Brand’s mobile application.

AuthentiXator collects the MSISDN and the brand name, where the Brand is an entity where the user requested with whom the subscriber requested toa log- in to the Brand’s mobile application or website.

3.5.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

None of your information is provided to third parties or brands without prior consent. All data is aggregated and cannot be linked to a specific mobile subscriber.

3.5.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the service, he/she may cancel the service via any of the following methods:

By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times);
By calling the Mobile Network Operator’s customer service department and requesting opt-out from these communications.

Under these circumstances, the Mobile Marketing Service will no longer present itself. At any time, a subscriber can re-activate the account by calling the Mobile Network Operator’s customer service department. OnePIN will retain and use account information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.5.4 HOW THE INFORMATION IS USED

OnePIN will share aggregated information submitted by the mobile subscriber to each corresponding brand. OnePIN does not share personal information gathered from OnePIN Mobile Marketing Services with the brands and third-parties.

In order to provide the OnePIN services, the Mobile Network Operator network is used to transmit the information from one mobile subscriber to OnePIN systems. Mobile subscribers are protected under the terms of use of their Mobile Network Operator.

The information collected by the Mobile Marketing Service belongs at all times to the individuals, organizations that entered the information. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the Mobile Marketing Services.

3.5.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.5.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Communication to mobile subscribers only occurs when the mobile subscriber uses the service. OnePIN’s Mobile Marketing Services are used as a channel to pass communications and interaction between the mobile subscriber and Brand. Otherwise, OnePIN does not communicate directly with mobile subscribers in regards to Mobile Marketing Services.

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.6 ZEROX™

ZeroX™ is a personalized call back service that enables subscribers with a zero airtime balance to request a call back or airtime transfer from another mobile subscriber. ZeroX™ is a service powered by the OnePIN SIMplicity user engagement channel, enabling Mobile Network Operators to offer their subscribers a convenient, universal channel to increase the use of the Mobile Operator’s existing airtime transfer services. ZeroX helps Mobile Operators reduces subscriber churn and generates more voice, messaging, and data traffic. ZeroX™ service is offered for free to subscribers.

3.6.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the ZeroX™ Service to their mobile subscribers in their network who have opted-in to Mobile Network Operator marketing communications.

The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the ZeroX™ service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.6.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

Since OnePIN’s ZeroX™ service is used as a channel to pass communications between the subscriber and Mobile Network Operator, OnePIN does not provide the subscriber access to their information. Mobile Subscribers must contact the Mobile Network Operator directly to find out the choices available to them regarding the display and access of their information.

3.6.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the ZeroX™ service, he/she may cancel the service via any of the following methods:

By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS and on the Mobile Network Operator’s website);
• By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times);
• By calling the Mobile Network Operator’s customer service department and requesting opt-out from all Mobile Network Operator communications.

Under these circumstances, the ZeroX™ service will no longer present itself. At any time, a subscriber can re-activate the account by calling the Mobile Network Operator’s customer service department. OnePIN will retain and use account information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.6.4 HOW THE INFORMATION IS USED

Mobile Network Operator uses the information that is collected by the ZeroX™ service to manage your account with the Mobile Network Operator. OnePIN’s ZeroX™ service is used as a channel to pass communications between the subscriber and Mobile Network Operator.

The information collected by the ZeroX™ service belongs at all times to the individuals, organizations that entered the information and the Mobile Network Operator. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the ZeroX™ service.

3.6.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.6.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Mobile Network Operator uses the information that is collected by the ZeroX™ service to manage your account with the Mobile Network Operator. OnePIN’s ZeroX service is used as a channel to pass communications between the subscriber and Mobile Network Operator. Otherwise, OnePIN does not communicate directly with mobile subscribers in regards to ZeroX services.

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.7 ZILLIONS™

Zillions™ is a leading lottery, gaming and betting platform and service solution. Zillions builds innovative end-to-end gaming solutions in partnership with the world’s biggest mobile network operators. The Zillions service is tailor-made in each local market and comes with a wide range of customizable games and digital subscription models. Mobile Network Operators can drive incremental revenue from their subscribers while also providing exciting and innovative content for them to enjoy. All Zillions games are customizable allowing Mobile Network Operators to set their own jackpot prize levels and ticket prices and with Zillions’ insured jackpot payouts Mobile Network Operators have the freedom to launch truly exciting games and promotions. The Zillions service is offered at different price levels in each local market to subscribers.

3.7.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

Zillions™ is offered to mobile subscribers through two different channels:

The Mobile Network Operator offers the Zillions™ Service to their mobile subscribers in their network who have opted-in to Mobile Network Operator marketing communications. In this case, OnePIN will only collect and display information exactly as it is entered by subscribers as a response from the communication from the Mobile Network Operator. The information that is collected from subscribers is governed by the Mobile Network Operator’s terms of use agreement with its subscribers and is regulated by the Telecommunications Authority in the country. The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the Zillions™ service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.
Zillions is offered through a localized website. In this case, OnePIN will only collect and display information exactly as it is entered by subscribers into their secure online accounts.This private information is stored on secure servers. OnePIN server is used only by the individual to access their information when needed, no other individual can access the information. The user has full access to his or her information within their online accounts. The user can always keep their information up to date and make necessary edits as needed. OnePIN cannot make changes to the user’s information. Users have the responsibility to keep their information up-to-date. When an individual wins, OnePIN informs the individual to update their contact information and provide further details as required by regulation. The information that is collected from subscribers is governed by the terms of use agreement with Zillions subscribers and is regulated by the local Privacy Authority in the country. The service adheres to all local regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the Zillions™ service is confirmed by the applicable Gaming Board or Regulator prior to the commercial deployment of the service in the country.

3.7.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

When the Zillions™ service is used as a channel to pass communications between the subscriber and Mobile Network Operator, OnePIN does not provide the subscriber access to their information. Mobile Subscribers must contact the Mobile Network Operator directly to find out the choices available to them regarding the display and access of their information. Upon request OnePIN will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at privacy@onepin.com. We will respond to your request within a reasonable timeframe.

On the other hand, when the Zillions™ service is used via a designated Zillions website, OnePIN provides the subscriber a secure password protected access to their account and information. Players can login to their online account and access their information at any time. Upon request, if needed, OnePIN will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at privacy@onepin.com. We will respond to your request within a reasonable timeframe.

3.7.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the Zillions™ service, he/she may cancel the service via any of the following methods:

By sending an SMS with a keyword (e.g. STOP) to a specific number (number provided to the mobile subscriber via SMS and on the Mobile Network Operator’s website);
By selecting and confirming an “automatic opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service after a period of time defined by the Mobile Network Operator (e.g. after choosing not to use the service after 5 consecutive times);
By calling the Mobile Network Operator’s customer service department and requesting opt-out from all Mobile Network Operator communications.
By accessing the account directly at the website where the account has been created and by following the directions on how to cancel the account.

Under these circumstances, the Zillions™ service will no longer present itself. At any time, a subscriber can re-activate the account by calling the Mobile Network Operator’s customer service department or by creating a new online account. OnePIN will retain and use account information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.7.4 HOW THE INFORMATION IS USED

Mobile Network Operator uses the information that is collected by the Zillions™ service to manage your account with the Mobile Network Operator. OnePIN’s Zillions™ service is used as a channel to pass communications between the subscriber and Mobile Network Operator.

OnePIN’s Zillions service collects personal information to be used by the end user to play games and collect winnings. This private information is stored in a secure website. Subscribers have full access to their information within dedicated online accounts. Subscribers have the responsibility to keep their information up-to-date. When an individual wins, OnePIN informs the individual to update their contact information and provide further personal details as required by the local regulation and tax authorities.

The information collected by the Zillions™ service belongs at all times to the individuals, organizations that entered the information and the Mobile Network Operator. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the Zillions™ service.

3.7.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.7.6 COMMUNICATION BETWEEN ONEPIN AND USERS

The Mobile Network Operator uses the information that is collected by the Zillions™ service to manage your account with the Mobile Network Operator. OnePIN’s Zillions service is used as a channel to pass communications between the subscriber and Mobile Network Operator. Otherwise, OnePIN does not communicate directly with mobile subscribers in regards to Zillions services.

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber if the Service is delivered within a Mobile Operator network.

OnePIN provides customer service directly with the mobile subscriber if Zillions Service is delivered online at a Zillions website.

3.8 XPRESSION®

OnePIN’s Xpression™ service enables users to share content with friends, family, and colleagues at socially relevant times using only a few clicks. The service automatically detects when a new connection is made with another individual, and prompts users to enhance that connection by sharing content. Xpression also has the intelligence to recognize when calls are made or quick messages are sent with familiar contacts. The service suggests meaningful content to share in these scenarios to help brighten the day and put a smile on someone’s face.

3.8.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the Xpression™ Service to their mobile subscribers in their network. Subscribers are given opportunities to opt-in to the service during normal mobile phone use. If the mobile subscriber does not wish to opt-in at the time of these offers, the service will not be available to them.

OnePIN will only collect and display information exactly as it is chosen by subscribers. OnePIN does not collect or display other personal information (such as race, religion, political affiliation or sexual orientation). OnePIN does not knowingly collect personal information on children.

Subscribers are given the opportunity to send content to another mobile subscriber after they exchange business cards or messages with the other subscriber. The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the Xpression service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.8.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

OnePIN operates on a permission-only basis with respect to the sharing of member’s content.

The Xpression content can only be accessed and distributed by the subscriber (owner) by using the OnePIN application on the subscriber’s SIM card. When mobile subscribers use the Xpression service and choose to share content with another person, the sender’s content may be stored in a secure cloud server environment. This cloud server is not accessible to the general internet.

Members can send their content to any mobile subscriber after calls, business card exchanges or quick message exchanges. If a member chooses to send his or her content to another mobile subscriber, other subscribers will receive the content in SMS (text) format.

Members can choose to whom they send their content, one at a time, after they make a connection (CallerXchange or MsgXpress service use) with other mobile users. In this way, members have complete control over how their content is shared, and with whom this information is shared.

Upon request OnePIN will provide you with information about whether we hold any of your content. You may access, correct, or request deletion of your content by contacting us at privacy@onepin.com. We will respond to your request within a reasonable timeframe.

3.8.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the Xpression service, he/she may cancel the service via any of the following methods:

By selecting “opt out” within the related submenu when Xpression services Menu prompts the user to select their content to share with others;
By selecting and confirming an “opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service.

Under these circumstances, the Xpression service will no longer present itself when the subscriber uses CallerXchange or MsgXpress service. OnePIN will retain the contact information in the deactivated account until OnePIN’s contract with the Mobile Network Operator expires or is terminated.

OnePIN will retain and use subscriber information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.8.4 HOW THE INFORMATION IS USED

The content collected by the Xpression service belongs at all times to the individuals and organizations that entered the information. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the OnePIN services.

If you directly, or through OnePIN services, disclose your contact information to others, then your information may be collected and used by others.

3.8.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.8.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Special Offers and Updates

Service Announcements

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.9 CELEBRAXION

CelebraXion is a mobile subscriber service that allows subscribers to conveniently send messages to their networks on special days. Based on the subscriber’s use of MsgXpress and CallerXchange, as well as the subscriber’s location, subscribers can send their friends and family a message on holidays and other special days. The customer receives the option to subscribe to CelebraXion, and is able to pay a small premium fee to send their friends holiday messages. Subscribers select the types of messages they want to share with their friends and family via an easy, convenient, and dynamic interface.

3.9.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

The Mobile Network Operator offers the CelebraXion™ Service to their mobile subscribers in their network. Subscribers are given opportunities to opt-in to the service during normal mobile phone use. If the mobile subscriber does not wish to opt-in at the time of these offers, the service will not be available to them.

Subscribers are given the opportunity to send content to another mobile subscriber after they exchange business cards or messages with the other subscriber. The service adheres to mobile telecommunications regulatory requirements for pricing transparency and opt-in business rules for the country in which the service is offered. The user experience of the CelebraXion service is confirmed by the Mobile Network Operator with the applicable Telecommunications Regulator prior to the commercial deployment of the service in the country.

3.9.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

OnePIN operates on a permission-only basis with respect to the sharing of member’s content.

The CelebraXion content can only be accessed and distributed by the subscriber (owner) by using the application on the subscriber’s SIM card. When mobile subscribers use the CelebraXion service and choose to share content with another person, the sender’s content may be stored in a secure cloud server environment. This cloud server is not accessible to the general internet.

Members can send their content to any mobile subscriber after calls, business card exchange or quick message exchanges. If a member chooses to send his or her content to another subscriber, other subscribers will receive the content in SMS (text) format.

Members can choose to whom they send their content, one at a time, after they make a connection (CallerXchange or MsgXpress service use) with other mobile user. In this way, members have complete control over how their content is shared, and with whom this information is shared.

3.9.3 HOW TO CANCEL YOUR ACCOUNT

If a subscriber wishes to stop using the CelebraXion service, he/she may cancel the service via any of the following methods:

By selecting “opt out” within the related submenu when CelebraXion services Menu prompts the user to select their content to share with others;
By selecting and confirming an “opt-out” notification displayed by the service if the mobile subscriber has chosen not to use the service.

Under these circumstances, the CelebraXion service will no longer present itself when the subscriber uses CallerXchange or MsgXpress service. OnePIN will retain the contact information in the deactivated account until OnePIN’s contract with the Mobile Network Operator expires or is terminated.

OnePIN will retain and use subscriber information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator.

3.9.4 HOW THE INFORMATION IS USED

The content collected by the CelebraXion service belongs at all times to the individuals and organizations that entered the information. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of operating the OnePIN services.

If you directly, or through OnePIN services, disclose your contact information to others, then your information may be collected and used by others.

3.9.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

Third Party Intermediaries:

Cookies and Other Tracking Technologies

Log files

3.9.6 COMMUNICATION BETWEEN ONEPIN AND USERS

Special Offers and Updates

Service Announcements

Customer Service

The Mobile Network Operator performs customer service communications directly with the mobile subscriber.

3.3.108 BUSINESS CONTACTS AND COMMUNICATION

During the course of doing normal business, OnePIN employees collect business cards and other contact information from the employees of other companies, partners and alliances. This information is used only for communication with these people for the purpose of completing business transactions.

3.3.108.1 WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU

OnePIN employees collect business cards and other contact information from the employees of other companies, partners and alliances during the course of doing normal business transaction. This information may include name, mobile and office numbers, email address and office address in addition to other information printed on business cards or send to OnePIN employees via email signature. The information collected is not shared with any entity outside of OnePIN unless required to complete a business transaction. Otherwise, the information is used only by OnePIN employees to complete the business communications.

3.3.108.2 CHOICES AVAILABLE TO YOU REGARDING DISPLAY OF AND ACCESS TO YOUR INFORMATION

The contact information provided to OnePIN may be stored in email systems and OnePIN mobile phonebooks. Additionally, the paper based business cards are stored on premise in the OnePIN corporate offices. This data is not displayed publicly and these systems are protected by employee passwords. Since your data is part of OnePIN’s confidential and internal network, the access to this information is only available to the employees of OnePIN.

3.3.108.3 HOW TO CANCEL OUR RELATIONSHIP

If you have provided your contact information to OnePIN employees and wish to stop any type of communication, you may cancel the relationship via any of the following methods:

By sending an email to the privacy@OnePIN.com and requesting the deletion of your information

Under these circumstances, this customer will no longer receive any communication from OnePIN. OnePIN will retain and use contact information as necessary to comply with its legal obligations and in support of the agreement with the Mobile Network Operator and/or Partnership agreements in place.

If access or correction has been refused, OnePIN will communicate with you why it has been denied and whom to contact for further information.

3.3.108.4 HOW THE INFORMATION IS USED

OnePIN employees use customer’s contact information only for communication with these people for the purpose of completing business transactions.

The information collected belongs at all times to the individuals and organizations. OnePIN claims no proprietary right whatsoever in the information and as such claims no right to use the information in any way other than for the purpose of communicating with the customers.

3.3.108.5 WHEN PERSONAL INFORMATION MAY BE DISCLOSED

If OnePIN is involved in a merger, acquisition, or sale of all or a portion of its assets we will post a prominent notice on our Web site detailing any change in ownership.

4 Limiting the Use and Disclosure of Personal Data

Individuals may have the right to limit the use and disclosure of their personal information as required by the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, such as whether your personal information is disclosed to a third party or used for purposes materially different from the purpose for which the personal information was originally collected or subsequently authorized by you.

If you wish to limit the use and disclosure of personal information in accordance with the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, please contact us at privacy@onepin.com.

5 Security

OnePIN takes precautions to protect the subscribers’ information. For your own protection, however, OnePIN strongly recommends that you do not enter any information of a sensitive nature (such as passwords or financial account numbers) into the data fields of OnePIN’s Services. OnePIN Services are designed for data that is to be shared with others. Data of a sensitive nature should not be entered into OnePIN Services.

If you directly, or through OnePIN, disclose your contact information to others, then your information may be collected and used by others.

Online Security

When a OnePIN subscriber sends their response to a OnePIN service, the information is transmitted within the Mobile Operator Network. Information exchange between the Mobile Operator Network and the OnePIN Cloud is encrypted during transmission and is protected using IPSEC VPN tunnel which is an industry security standard.

Off-Line Security

OnePIN also protects subscriber-information off-line. All information about OnePIN subscribers, except for information provided by the subscribers for the express purpose of communicating that information to other subscribers through the OnePIN system is restricted in OnePIN’s offices. Only employees who need the information to perform a specific job (for example, billing clerk or a customer service representative) are granted access to personal information. OnePIN employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to subscriber information. Furthermore, ALL employees are kept up-to-date on OnePIN security and privacy practices. Any time new policies are added, OnePIN employees are notified and/or reminded about the importance OnePIN places on privacy, and what they can do to ensure OnePIN’s subscribers’ information is protected. Finally, the servers that store personal information are in a secure environment.

Changes to This Privacy Statement

OnePIN may update this Privacy Notice to reflect changes to its data governance practices. If OnePIN proposes to make any material changes, OnePIN will notify you by means of a notice on this page. OnePIN encourage you to periodically review this page for the latest information on OnePIN’s privacy practices.

Should OnePIN change its privacy policy, OnePIN will also notify the Mobile Network Operator about any changes prior the change becoming effective. The Mobile Network Operators shall always be aware of what information is collected, used, and under what circumstances, if any, disclosed.

If, however, OnePIN is going to make any material changes or use subscribers’ personal information in a manner different from that stated at the time of collection, OnePIN will notify Mobile Network Operator via email or by means of a notice on our website and obtain approval prior to the change becoming effective.

6.0 How to Contact OnePIN

If Mobile Network Operators or users of any of OnePIN’s services have any questions or suggestions regarding OnePIN’s privacy statement, please contact us OnePIN at:

By Email:

privacy@onepin.com

By Postal Address:

2200 West Park Drive

Westborough, MA 01581

USA

By Web Site:
www.onepin.com