Privacy Statement

Infinite Wireless, Inc. Privacy Statement
Last Updated: February 2024

This Privacy Statement describes the types of information the Infinite Wireless, Inc. group of companies which includes Infinite Wireless, and subsidiaries and affiliates, (collectively, Infinite Wireless, “we,” “our,” or “us”) collect through our websites, including the website at www.infinite-wireless.com (our “Sites”), as well as all related websites, networks, applications, and other services provided by us (the “Services”). This Privacy Statement describes the information that we gather from you, how we use and disclose such information, the steps we take to protect such information, and how you can exercise your data protection rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided under the “Contacting Infinite Wireless” section below.

Accessibility

If you are unable to access this Privacy Statement due to a disability or any physical or mental impairment, please contact us using the contact details provided under the “Contacting Infinite Wireless,” section and we will arrange to supply you with the information you need in an alternative format that you can access.

What Personal Information Do We Collect And Process?

Personal Information You Provide

When you use our Services, you voluntarily provide us with information about you. We use this information for the following business and commercial purposes:

  • Account Registration. We collect information that is necessary for you to register an account with us, log in to your account, and use features of our Services, such as your name, contact details, company, geographic area, preferences, job title, and password. This information also allows us to manage your account.
  • Order and purchase. We collect information that is necessary to fulfill your order features of our Services or the purchases you make through our Services, such as your name, contact details, job title, company, credit card or other billing information.
  • Customer communications and support: We collect information that is necessary to respond to enquiries, support requests or any other communications you submit through our Services, such as your name, contact details and the content of your communications. We also use that information to communicate with you via technical notices, updates, security alerts and support and administrative messages.
  • Promotions: We collect information that is necessary to process and deliver entries and rewards in connection with promotions that we may offer from time to time, such as your name, contact details, job title and company.
  • Operate and enhance our Services. We collect information that is necessary to operate, maintain, enhance and provide all features of our Services, such as your feedback or any other information related to your utilization of our Services that you provide us with. We also use that information to develop new products, services, features, and functionality.
  • Direct marketing: We collect information to send you direct marketing, in accordance with your marketing preferences. We use your name, contact details and account information to email you with marketing offers and resources, events, newsletters, whitepapers and other company updates about Infinite Wireless and other third parties.
  • Other purposes. We may use the personal information you voluntarily disclose to us for any other purposes disclosed to you and with your consent.

Automatically Collected Personal Information

When you use our Services, we may collect certain information automatically from your device, including information like your IP address, operating system, device type, unique device identification numbers, browser-type, broad geographic location (by use of GPS or other geolocation features of your device) and other technical information. We also collect information about how you use our Services for purposes of facilitating your use of our Services, including securing, managing, measuring, improving, and/or supporting our Services as well as to enable us to develop and market additional products and Services. We may also collect information about how your device has interacted with our Services including our Sites, including the pages accessed and links clicked. Some of this information may be collected using cookies and similar tracking technology. We use these cookies or similar technologies to understand and analyze the usage trends and preferences of our users, enhance and develop new products, Services, features, and functionality, administer our Services, track user’s movements around our Services, store preference information in our Services, serve targeted advertisements, and gather demographic information about our user community as a whole.

Information from Other Sources

From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent (where required by law) or are otherwise legally permitted or required to disclose your personal information to us. For instance, we may obtain information such as your contact details, job title, company and interest from third parties, such as our partners and advertisers, and from other sources outside of our Services, including from certain offline sources such as trade shows or publicly available sources, to market our Services and products offered by third parties, in accordance with your marketing preferences.

Log Files, IP Addresses, URLs and Other Data

Infinite Wireless like most websites, gathers certain information automatically to analyze trends in the aggregate and administer our Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Offering. This information is used to analyze overall trends, to help us improve our Services, to track and aggregate non-personal information, and to provide the Services.

Social Media Features and Single Sign-on

Infinite Wireless websites or other Services may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on our website and may set a cookie or other similar technologies to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Offering to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by a third-party or hosted directly on our Services. Information collected in the context of the Social Media Features is subject to the relevant social media platforms’ own data collection, use, and disclosure policies. Infinite Wireless also allows you to log in to certain of our Services using sign-in services provided by social media platforms. These Services authenticate your identity and may provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

Hosted Data

Infinite Wireless’ obligations with respect to data that may be accessed as a function of Infinite Wireless’ role as a cloud service and Infrastructure-as-a-Service (IaaS) provider, such as data stored or transferred by Infinite Wireless customers through Infinite Wireless’ hosted Services are defined in our agreements with our customers and are not governed by this Privacy Statement.

Your Rights and Choices

Depending on your location and applicable data protection laws, you may have the right to request access to, or correction, deletion or removal of, information about you, by contacting us at privacy@infinite-wireless.com by using the contact details provided under the “Contact Us” heading. To protect your privacy and security, we may take steps to verify your identity before granting access, deleting, or making changes to information you have provided us, including by requesting your name and email address. While we will make reasonable efforts to accommodate your request, we also reserve the right to reject such access requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law.

If you receive marketing communications from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at unsubscribe@inifinte-wireless.com or by writing to us at the address given at the end of this Privacy Statement. Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We do not discriminate against any individual based on the exercise of their data protection rights.

Sharing Information

Except as described in this Privacy Statement, we will not disclose information about you that we collect on or through our Services to third parties without your consent, unless legally required or permitted to do so. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Any information that you voluntarily choose to include in a publicly accessible area of the Sites or any of our Services will be available to anyone who has access to that content, including other users.

We work with third-party service providers to provide you with our Services and website and assist us with our marketing and sales activities. Examples include customer relationship management providers, communications providers, maintenance and technical support providers, cloud hosting providers, analytics companies, payment providers, security and fraud detection providers. These third parties may have access to or process information about you for the purpose of providing the Services mentioned above. For example, our customer relationship management providers host our customers and prospects employees’ contact details and information about our interactions and relationship with them for the purpose of allowing us to better manage our relationships with our customers and prospective customers. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to only use the information shared to provide us with the Services they have been hired to provide.

We may share your information with our partners in connection with, selling or distributing our Services, or engaging in joint marketing activities, in accordance with your marketing preferences.

We may disclose your information if required to do so by any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary to comply with applicable law or regulation, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Services and any facilities or equipment used to make our Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third-parties as one of our business assets in which case the acquirer, successor or assignee will use your personal information in line with this Privacy Statement.

We may make certain aggregated, automatically collected, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, Services, advertisements, promotions, and/or functionality available through our Services.

 

 

Security

At Infinite Wireless, security is a priority. We use physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect, process and maintain. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Security is an evolving area and Infinite Wireless, is constantly working to not only raise the level of security it deploys but also the security training of its employees.

Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Third-Party Services

Our Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

International Transfer of Information and International Visitors

We may transfer and process your personal information in countries other than the country in which you are resident in connection with storage and processing of data, fulfilling your requests, and operating and providing our Services. These countries may have data protection laws that are different from the laws of your country. Specifically, our Services are hosted in the United States and United Kingdom, and our subsidiaries and third-party service providers and partners operate around the world. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Statement.

In the event that we transfer personal information from the European Economic Area (“EEA”), UK and Switzerland (collectively “Europe”) to countries which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms to ensure adequate level of protection, including entering into the standard contractual clauses for the transfer of European data approved by the European Commission or, where required, asking you for your prior consent to such international data transfers.

 

 

EU-US and Swiss-US Privacy Shield

While no longer relying on these frameworks, Infinite Wireless continues to comply with the EU-US Privacy Shield and the Swiss-US Privacy Shield regarding the collection, use, and retention of personal information transferred from Europe to the United States.

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

EEA and UK Rights

If you are a visitor/customer located in the EEA and the UK, Infinite Wireless is the data controller of your personal information. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

You have the following rights:

  • If you wish to access, correct, update or request deletion of your personal information, see “Your Rights and Choices” above.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights contact us or by email: privacy (at) privacy @infinite-wireless.com.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • To exercise these rights contact us via email privacy@infinite-wireless.com.

California Rights

  • Shine the Light Customer Rights

Residents of California have the right to request a disclosure describing what types of personal information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us.

  • California Consumer Rights Under The CCPA

The following disclosures apply only to California residents covered under the California Consumer Privacy Act (“CCPA”).

Personal information collected for business purpose and commercial purpose

The purposes for which we collect your personal information are described under the heading “Information We Collect and How We Use It” above. This section describes the business purposes and commercial purposes for which we collect personal information.

Personal information disclosed for a business purpose

This Privacy Notice describes the categories of personal information that we have, disclosed for a business purpose and sold over the preceding twelve (12) months. Please refer to the sections titled “Information We Collect and How We Use It” and “Sharing Information” above for more information.

Personal information sold

We do not and will not sell your personal information to any other business or third party.  Infinite Wireless will always seek your affirmative direction/consent to intentionally disclose personal information to third parties in ways that might otherwise be construed to be a “sale” under the CCPA.

Right to know and right to delete

You have the right to request that we disclose the personal information we collect, use, disclose and sell. To exercise this right, please follow the instructions described to access your information in the “Your Rights and Choices” section above.

Children’s Privacy

Protecting the privacy of young children is especially important to Infinite Wireless. Our Sites are general audience websites not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you believe we have collected information belonging to an individual under the age of 16, please let us know by email at privacy@infinite-wireless.com.

Changes and Updates

Please revisit this page periodically to stay aware of any changes to this Privacy Statement, which we may update from time to time. If we modify this Privacy Statement, we will make it available through our Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change and obtain your consent where legally required. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access one of our Services for the first time after such material changes are made.

Contacting [Company Name Here]

If you have any questions or comments about this Privacy Statement, your Information, our use, and disclosure practices, or your consent choices, please contact us, by email to privacy@infinite-wireless.com or you can contact us using the information provided https://infinite-wireless.com/contact/.

Infinite Wireless, Inc Privacy

 

 

EXHIBIT A

COOKIE NOTICE

Infinite Wireless aims to make your experience and interaction with us as informative and relevant as possible. To achieve this, we use cookies or similar technologies. This Cookie Notice provides information about how and when we use cookies for these purposes in our Services. Capitalized terms used in this Cookie Notice have the meaning described in our Privacy Statement unless we provide a definition here in the Cookie Notice. Our Privacy Statement also includes additional information about the collection and use of data and information at Infinite Wireless.

What is a Cookie?

A cookie is a small text file that stores Internet settings. Almost every website uses cookie technology. The cookie is downloaded by your Internet browser the first time you visit a website. The next time you visit this website from the same device, the cookie and the information in it are either sent back to the originating website (first-party cookies) or to another website to which it belongs (third-party cookies). By that, the website can detect that it has already been opened using this browser, and in some cases it will then vary the content it shows.

Some cookies are extremely useful because they can improve your user experience when you return to a website you have already visited. This assumes that you are using the same device and the same browser as before; if so, cookies will remember your preferences, will know how you use the website, and will adapt the content you are shown so that it is more relevant to your personal interests and needs.

Why are Cookies Used?

Cookies may be used for many different purposes. In the first place, cookies can be required to make the website function properly. For example, without cookies it would be difficult to make a website remember that you have logged in, or which products you have put in your shopping cart. These are called required cookies.

Cookies can also be used to analyze how a website is used, to count the number of visitors, to learn how the website may be improved. We do not link the website usage statistics and other reports to individual people. These cookies are called analytics cookies.

Third, social media cookies are used to enable integration of social media into the website, so that you can immediately like or share a page or product on your favorite social media service.

Another important use of cookies is to enable online advertising, which may be personalized to show ads that are more relevant and interesting to you, both within and beyond Infinite Wireless websites. This is done by (targeted) advertising cookies.

Types of Cookies

Based on what function cookies have and the purpose for which cookies are used, there are four categories of cookies: strictly necessary cookies, performance cookies, functional cookies and marketing cookies.

Strictly necessary cookies Strictly necessary cookies, such as Critical Cookies, are essential in order to enable you to move around the website and use its features. Without these cookies, some services cannot be provided – for example, remembering previous actions (e.g., entered text and vehicle configurations) when navigating back to a page in the same session.

Performance cookies Performance cookies gather information about how a website is used – for example, which pages a visitor opens most often, and whether the user receives error messages from some pages. These cookies do not save information that would allow the user to be identified. The collected information is aggregated, and therefore anonymous. These cookies are used exclusively to improve the performance of the website, and with it the user experience.

Functional cookies Functional cookies enable a website to save information which has already been entered (such as usernames, languages choices, and your location), so that it can offer you improved and more personalized functions. For example, a website can offer you local, price-relevant information if it uses a cookie to remember the region in which you are currently located. Functional cookies are also used to enable features you request such as playing videos. These cookies collect anonymous information and cannot track your movements on other websites.

Miscellaneous cookies (e.g., Advertising, Surveys, Social Sharing) Miscellaneous cookies such as advertising, surveys, and social media cookies, are used to deliver advertisements and other communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. They remember whether you have visited a website or not, and this information can be shared with other organizations such as advertisers. Cookies for improving group targeting and advertising will often be linked to site functionality provided by other organizations.

Type of Cookies Infinite Wireless Uses

Infinite Wireless uses Strictly necessary cookies, Performance cookies, Functional cookies, and Miscellaneous cookies. Specifically, Infinite Wireless uses Critical cookies that contain information critical to your experience with our Services, or that assist with certain personalization actions that are essential to the use of our services. Process cookies help make the websites work and deliver the expected services. Analytics cookies are used to collect information and report website usage statistics without personally identifying visitors. Infinite Wireless uses security cookies to authenticate users, prevent fraudulent use of login credentials, and protect information from unauthorized entities.

Infinite Wireless uses preference cookies that contain information important to your experience but not strictly necessary or essential, such as configurations. Lastly, Infinite Wireless uses Advertising, Survey and Social Sharing cookies that allow you to utilize sharing features for third-party social media services from our Services.

Cookies and Advertising Uses

Cookies and other ad technology such as beacons, pixels, and tags help us market more effectively to users that we and our partners believe may be interested in Infinite Wireless. They also help provide us with aggregated auditing, research, and reporting, and help us know when content has been shown to you.

Managing your Cookie Options

From Your Browser

Information on changing your browser settings to opt out of Cookies can be found in your browser settings. You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

For other browsers, please consult the documentation that your browser manufacturer provides.

Resources to Manage Third-Party Advertising Cookies:

If you wish to opt out of interest-based advertising, click here, or if located in the European Union, click here.

The following websites provide choices to opt-out of tracking through certain third-party advertising Cookies:

Resources to Manage Third-Party Analytics Cookies

You can opt out of data collection or use by the following analytics providers by clicking the following links:

Infinite Wireless and Do Not Track (“DNT”)

Currently, various web browsers offer a “do not track” or “DNT” setting that relies on technology known as a “DNT header.” A DNT header sends a signal to websites visited by the user about the user’s browser DNT preference setting. Infinite Wireless websites do not currently respond to a browser’s DNT setting, largely since there is no common industry standard for DNT and industry groups, technology companies and regulators have not established any consistent standards for interpreting the intent of the user. Infinite Wireless takes privacy seriously and will continue to monitor efforts to develop standards around the browser use of DNT and technology industry responses to such settings.

Updates to this Cookie Notice

Infinite Wireless may amend this Cookie Notice from time to time, for example, because our website or the regulations relating to cookies change. We reserve the right to amend the content of the Cookie Notice and the cookies included in the lists at any time and without notice. The new Cookie Notice will be effective upon posting. If you do not agree to the revised notice, you should alter your preferences, or consider stopping using the Infinite Wireless websites. By continuing to access or make use of our services after the changes become effective, you agree to be bound by the revised Cookie Notice. You can consult this web page for the latest version.

 

EXHIBIT B

ONLINE FORM

 

Privacy Rights Request

Individuals in several countries have certain rights to request information about their personal data. You may submit your privacy requests and questions by completing the below form or by sending us an email at privacy@infinite-wireless.

If you would like to unsubscribe from Infinite Wireless email communications, please email your request to privacy@infinite-wireless.com.

Residents of certain US states have additional privacy rights under state privacy laws and regulations. To exercise such state privacy rights, please send an email to privacy@infinite-wireless.com and include the below information in the body of the email.  By submitting your email, you affirm that the information you provide is accurate and acknowledge that your information will be processed for the purpose of responding to this request, and in accordance with the Infinite Wireless Privacy Statement.

Email Address

Indicate which state you are a resident.

  • California
  • Colorado
  • Connecticut
  • Utah
  • Virginia

I would like to opt out of (include all that apply)

  • The “sale” of my personal information
  • The use or “sharing” of my personal information for interest-based advertising.

Privacy is important to Infinite Wireless and we have processes in place to respond to and act on all legitimate requests consistent with applicable law. For your protection, we may need to verify your identity before acting on your request. We will try to comply with your request as soon as reasonably practicable.

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