At INTELLETRACE INC., (“Intelletrace,” or “we,” “us,” “our”) we understand that privacy is important, and we are strongly committed to protecting the privacy of our customers and visitors to our website at (“our websites”).

The following information is designed to help you better understand the information that we gather, how we handle the information once we gather it, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct the information we gather. Please note that this Privacy Policy (“Policy”) applies to only our products, services, and websites (collectively, “Services”), and not to other companies’ or organizations’ services or websites to which we may link even if they market our products or use the Intelletrace name. By visiting our website(s) or using our Services, you accept the practices described in this Privacy Policy.

NOTE: Some of Services may involve features or practices not common to our other websites or services. You should carefully read this entire policy to understand the provisions applicable to our websites and services you are using.

What information do we collect?
Our primary goal in collecting personal information is to provide you with a smooth, efficient, and customized experience. This allows us to provide features that are most likely to meet your needs and to customize our service to make your experience easier and more pleasant.

Aggregate Data
Personal Information does not include information that is not used to identify you, such as aggregate or anonymous information. We gather certain usage information like the number and frequency of visitors to our websites. This information may include which URL you just came from, which URL you next visit, what browser you are using, and
your IP address. We use such data only in the aggregate. This collective data helps us determine how much our customers use parts of our websites, and conduct internal research on our customers’ demographics, interests, and behavior in order to better understand and serve you.

This type of aggregated, non-personally identifiable information may also be collected and/or used by third parties that support our services. In addition, we aggregate data and disclose such information in a non-personally identifiable manner to advertisers and other third parties for marketing and promotional purposes.

Personally Identifiable Information
Users are asked to provide certain information when they sign up for our Services such as name, address, phone number, birth date, gender, credit card information, and email address (collectively, “personally identifiable information” or “personal information”). The personally identifiable information collected from our customers during the registration process is used to manage each customer’s account. We also seek such information to provide products and/or services that more closely reflect your preferences. In addition, we may use such personally identifiable information to improve our marketing and promotional efforts, to analyze website usage, improve our content and product offerings, and customize our website’s content, layout, and services.

Usage Information
We automatically collect certain types of information when you use our Services. We may collect information about your device, including but not limited to the device type, operating system version, signal strength, whether it is on and how it is functioning, and device identifiers. We may also collect information related to your use of the device and the services you access through it, including but not limited to your call and data usage and history, your geolocation, the websites you visit, the applications purchased, downloaded, or used, and information about devices you tether to your device. We may link information we automatically collect from you with Personal Information, including information you provide to us and information we gather from other sources. We may use software to follow your use of our Services and other applications, including the use of cookies, web beacons, and other mechanisms, in addition to analysis of network and device information. In accordance with federal law, we are required to obtain approval for use of customer proprietary network information, that relates to the quantity, technical configuration, type, destination, location, and amount of use of our service, and that is made available to us solely by virtue of the carrier-customer relationship, through methods described herein.

Personal Identification Number for Your Account
To activate and manage your account and obtain access to certain services, we may require you to provide a secret code (your “Service Passcode”). When using your account or providing your Service Passcode, to the extent required, you must provide accurate and complete information to Intelletrace. You are entirely responsible for
maintaining the confidentiality of your Service Passcode and are solely responsible for any activity conducted using your Service Passcode. You agree not to use the account, customer name, or Service Passcode of any other customer at any time unless that customer is under 18 and you are the parent or guardian of that customer. Prior to
disclosing or releasing any personally identifiable, protectable information to you, we may require entry of your Service Passcode for all phone or online requests and presentation of a valid photo ID for requests made in person.

Voluntary Surveys
We may periodically conduct surveys of our customers and/or users of our websites (“survey participants”). We encourage you to participate in these voluntary surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and
responses will remain confidential, even if the survey is conducted by a third-party. We take the information we receive from individuals responding to our surveys and combine (or aggregate) it with the responses of other survey participants to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. You agree that this aggregated, non-personally identifying information may be shared with third-party affiliates.

How Do We Use Your Information?
As our customer, you have a right, and we—as your carrier—have a duty to protect the confidentiality of your customer proprietary network information. However, unless you specifically decline by opting-out, we may use personally identifiable information to contact you and deliver information to you via your home phone, address, email, voice, or text messages on your mobile device if you are an Intelletrace customer. Unless you opt-out or otherwise object, we may also share personally identifiable information with certain third parties so that these third parties can share information with you about new products, services and promotions that we believe will interest you. By accepting this Privacy Policy or by purchasing or using our products or our jointly-branded products, you expressly agree to such usage and sharing of information. In addition, Intelletrace may use non-personally identifiable information in aggregate form for demographic marketing purposes, and may disclose this information to third parties, including advertisers.

If you are an Intelletrace customer, in certain special circumstances, we may contact you to deliver service-oriented messages, even if you have asked that we not contact you about special airtime events or promotions. These messages will be limited and only for this purpose.

We may use third-party providers to facilitate our services, and therefore, we may provide some of your personally identifiable information directly to them. In addition, we employ other companies and individuals to perform functions on our behalf. Some examples include fulfilling orders, providing mobile content, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments and providing customer service.

These service providers have access to personally identifiable information and may use it as needed to perform their functions, but may not use it for any other purpose, except that they may aggregate your personally identifiable information with similar information from other customers in a manner that does not potentially identify you. Any third-party verification services are governed by those entities’ separate privacy policies and not
this policy.

We may share information with other third parties with your consent. For example, you may agree to our sharing your information with other third parties to hear about their products and services. Use of the information you agree to share will be subject to those third parties’ separate privacy policies.

Intelletrace cooperates with law enforcement inquiries, as well as other third parties, to enforce laws, such as protecting intellectual property rights and preventing fraud. We can (and you authorize us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, to respond to lawful claims or legal process, to respond to emergencies, to protect the property of Intelletrace or the safety of its employees or others, to investigate fraud, intellectual property infringements, or other activity that is or may be illegal or expose you to liability.

It is possible that Intelletrace or its partners could be acquired or merged with another business entity. Should such a combination occur, you should expect that Intelletrace or its partners will share some or all of your personally identifiable information to continue to provide service. You will receive notice of such event (to the extent that it occurs), and we will request that the new combined entity follow the practices disclosed in this Privacy Policy or notify you of any changes.

In accordance with federal law, we will maintain records of consumer consent to disclose or otherwise use customer proprietary network information for no less than one year.

We reserve the right to use, disclose, or permit access to your customer proprietary network information to protect our rights or property, or to protect users of our services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, services. We also reserve the right to use, disclose, or permit access to your customer proprietary network information without prior approval in our provisioning of inside wiring installation, maintenance, and repair services; and, for the purpose of conducting research on the health effects of CMRS.

What about Third Party Applications and Services?

Your Use of Third Party Applications. When using our Services, you may choose to use services and products offered by third parties, such as third-party applications. When you leave our network, you may also use mobile roaming services provided by third parties. Your use of such services and applications may result in these third parties collecting your Personal Information and obtaining information from Intelletrace, including location information (when applicable). You may also choose to give your Personal Information directly to third parties when using our wireless services or devices. Except as noted below in the section Preinstalled Third Party Applications, the Personal Information you give to a third party will be subject to that third party’s terms, conditions and policies—not this Privacy Policy. You should always review a third party’s privacy policy and terms of service before providing your Personal Information to them or using their services or products.

Pre-installed Third Party Applications. Intelletrace may partner with some third-party application developers to enhance your Intelletrace experience. Such applications maybe branded as Intelletrace applications and may be pre-installed on your device, to the extent provided in connection with our Services. These applications may require
Intelletrace to share certain Personal Information.

When you first subscribe to our Services, you will be given notice in compliance with all applicable federal rules of your choice to permit sharing Personal Information to facilitate the functioning of these applications. You may opt-out of sharing Personal Information with these applications at that time or later by contacting us using the means specified under “How to Contact Us” below. If you opt-out, certain features of these applications may no longer function.

Third Party Compliance with Intelletrace Privacy Policy. If we use third parties, including but not limited to those noted above, and those third parties require the use of CPNI or other Personal Information, we require that such third parties take reasonable steps to protect the confidentiality of that information.

How to Contact Us: If you would like to restrict the use or disclosure of your CPNI or other Personal Information for the marketing of certain products or services, you may contact us at (800) 618-5877 x2 or by e-mail by visiting our website:, or by notifying us in writing at Intelletrace, Attention: CPNI Officer, 936 B Seventh Street, #122, Novato, California, 94945 and provide your (1) Name, (2) Home Address, (3) Home telephone number (including area code), (4) Telephone number for your mobile phone (including area code), (5) Service billing address, and (6) Service account passcode.

What Are Your Choices About Your Privacy?
If you are an Intelletrace customer, you may change the information that you have elected to share with us. You also have choices in the types of communications you wish to receive from us. When you activated your device, your notification preferences were set to receive notices about special offers, events and promotions from Intelletrace and special offers from our partners.

What About Cookies?
“Cookies” are small files placed on your hard drive; each website can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features on our websites and you may be required to re-enter your Service Passcode more frequently during a session. In addition, a number of companies not related to Intelletrace offer utilities designed to help you visit websites anonymously.

Cookies assist us in providing customized services and can also help us provide information that is targeted to your interests. Intelletrace cookies, to the extent employed, do not combine information collected through cookies with other personally identifiable information. You may also encounter cookies or other similar devices that are placed by third parties. We do not control the use of cookies by third parties, including third-party websites to which we may link. Third-party cookies or tools are governed by the privacy policies of the entities placing the ads and not by this Privacy Policy.

What Is Our Policy Toward Children?
Intelletrace is concerned about the safety and privacy of children who use the Internet. Consistent with the Children’s Online Privacy Protection Act of 1998, we will never knowingly collect personally identifiable information from anyone under the age of 13 without prior verifiable parental consent and may limit participation in certain services we provide to individuals over 13 years of age. If a child under the age of 13 responds to an age verification request, to the extent employed, we will direct him or her to have a parent or guardian call a live customer care agent, where a parent will be permitted to purchase an Intelletrace device, establish an account and activate on behalf of a child under 13. In these circumstances, activation can be made only by phone with a live customer care agent and the account must be in the parent’s name. A customer must be 18 in order to establish an account for a contract phone.

If we become aware that a child under the age of 13 has or has attempted to provide us with personally identifiable information, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has done this, he or she should contact the following customer care agent to remove
this information:

Customer Resolutions
936 B Seventh Street, #122
Novato, CA 94945
Telephone: (415) 493-2200
Fax: (415) 598-2108

What Is Our Policy Regarding Location-Based Information?
Location-based information is information that indicates the location of your Intelletrace equipment, to the extent provided in connection with our Services. When you use any of our location-based services, your device—to the extent provided—automatically communicates with our network and relays its current location. The accuracy of location-based services may be affected by circumstances beyond our control, including atmospheric, geographic location, or topographic conditions. We do not warrant or guarantee that location services will be available at any specific time or geographic location, or that service will be provided without interruption.

By using our location-based services, you consent to have us electronically collect, monitor, and track your physical location and the location of your equipment, to the extent provided in association with our Services. We collect and disclose your location information only to provide you with the location-based services you have requested, or in emergency situations as prescribed by law. If you allow other users to your handset, you are responsible for informing these users that their location information may be collected or disclosed. We will not provide your location information to third parties other than as prescribed without your consent.

Any information that is collected, monitored or tracked regarding your physical location or the location of your handset will not be retained longer than necessary to provide the location-based services you have selected.

What About Other Information Collectors?
Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information that we, or our partners, collect from you. To the extent that you disclose your information to other parties, different rules may apply to their use or disclosure of your information. We encourage you to ask questions
before you disclose your personal information to others.

Is My Information Secure?
Intelletrace uses standard industry practices to safeguard the confidentiality of your personally identifiable information and comply with all applicable federal or otherwise applicable regulations. Intelletrace treats data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques
to protect such data from unauthorized access by users inside and outside the company.

Unfortunately, perfect security does not exist on the Internet, and therefore, Intelletrace makes no representations or warranties with regard to the sufficiency of our security measures. Intelletrace shall not be responsible for any damages that result from a lapse in compliance with this Privacy Policy because of a security breach, technical malfunction or similar problem. Always be careful and responsible regarding your personal information.

We are not responsible for, and cannot control, the use by others of any information, which you provide to them via our wireless services. Similarly, we cannot assume any responsibility for the content of any personal information or communication you receive from other customers through our wireless services.

What Law Applies?
Our collection, use, access, disclosure and safeguarding of your personally identifiable information is subject to U.S. law. If you are a non-U.S. customer, you acknowledge and agree that we may collect and use your personally identifiable information outside of your resident jurisdiction.

In addition, such personally identifiable information may be stored on servers located outside your resident jurisdiction. U.S. law may not provide the degree of protection for your information that is available in other countries. BY PROVIDING US WITH YOUR INFORMATION, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY, UNDERSTAND IT, AGREE TO ITS TERMS AND CONSENT TO THE TRANSFER OF SUCH INFORMATION OUTSIDE YOUR RESIDENT JURISDICTION. If you do not consent to the terms of this Privacy Policy, please do not use our Services.

Will This Privacy Policy Change?
Intelletrace may, from time to time, make changes to this Policy based on your comments and our need to accurately reflect our legal obligations and our data collection and disclosure practices. By continuing to use our Services or by calling Intelletrace, you agree to be bound by the latest version of this Policy, which may be viewed anytime by clicking on our website:

Want To Know More?
For questions or concerns about Intelletrace or our Services, please our support team at (800) 618-5877 x2. Calls to Intelletrace customer care may be monitored for quality assurance.