FreeMo Privacy Policy
Last Revised: August 2017

1. ABOUT THIS PRIVACY POLICY
Thank you for using FreeMo and its related tools and services, including, without limitation, our mobile application (the “Application”), our website at http://www.getFreeMo.com (the “Site”), and any all services provided through the Application and the Site (collectively, the “Services”). The Services are owned and operated by FreeMo, Inc., a Washington corporation (“FreeMo,” “we,” “us” or “our”). The Application permits businesses and advertisers (collectively, “Advertisers”) to deliver ads, coupons, deals, and other advertising content (collectively, “Ad Content”) to a user’s mobile lockscreen and within the Application. Users who have downloaded, installed, and registered the Application (collectively, “End Users”, and each, an “End User”) can earn reward credits (“Reward Credits”), which may be redeemed by select participating carriers (“Partners”) as a credit to reduce some or all of the End User’s monthly cell phone services. To effectively offer and manage these highly interactive products and services, FreeMo collects, stores and shares information about its users. This Privacy Policy summarizes FreeMo’s practices with regards to the collection, storing and sharing of information about its End Users. This Privacy Policy applies to information collected through the Services, as well as other information provided to us online or offline by End Users, Advertisers, Partners, and other customers or users of our Site or Application; however, it does not apply to information collected from our employees, contractors or vendors.

2. USER CONSENT
By using the Services, you agree to the terms of this Privacy Policy and expressly consent to the collection, use and disclosure of your Personal Information (as defined below) in accordance with this Privacy Policy. Information gathered through the Services may be transferred, used, and stored in the United States and in any foreign jurisdictions in which we, our agents, service providers, customers and other users of the Services are located. If you use the Services, you consent to the transfer, use and storage of your Personal Information to and in those jurisdictions. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You further agree that all transactions relating to the Services, the Site or the Application shall be deemed to have occurred in the United States.

3. COLLECTION OF PERSONAL AND NON-PERSONAL INFORMATION
We collect Personal Information in connection with our Services. “Personal Information” means information that can be used to identify or contact an individual and may include, but is not limited to, your first and last name, by itself or combined with your unique user ID, password, gender, date of birth, address, email address, interests, hobbies, photos, phone numbers, your brand preferences, your Facebook, Twitter or other social media handles, your geographic location if you are accessing the Services from a GPS-enabled mobile device, any other personal profile or account information you choose to submit through our Services, and (if applicable) your company name and business contact information. FreeMo or its third party payment transactions services provider may also collect credit, debit or other billing account information. You may always choose not to provide Personal Information, but this may prevent you from receiving certain Services or Rewards Credits. For example, in order to set up an End User account, you must provide a valid email address to log in and to receive important account activity information. If you do not complete the account registration process, you will not be able to collect or redeem Reward Credits. If you choose to use our Site’s social networking function to post information to Facebook, Twitter or another social networking site, we may collect your user ID and password information for that social networking site as necessary to make it easier for you to log in to the Services or to interact with your social networks in other ways (for example, to share Ad Content with your friends on those social networks). Specifically, and without limiting the generality of the foregoing, the Services may allow users to access “Facebook Connect” to interact with friends and to share on Facebook while using FreeMo. Should you choose to use the Facebook Connect feature, FreeMo may collect certain information about you from your Facebook account, which will be specified at the time you first agree to sign in using Facebook Connect. You can edit privacy settings for posts that appear on Facebook or disconnect the Facebook Connect service by using the privacy tools provided through Facebook. FreeMo may also collect your telephone number, which we may use to verify users and prevent duplicative accounts. FreeMo may also collect non-Personal Information (aggregate, non-individually identifiable or demographic information). An example of non-Personal Information is system-related information such as IP addresses, click-through and other Application and Site use information (for example, we typically track each time you click on Ad Content from your mobile device lockscreen), browser and browser speed, bandwidth of your Internet connectivity, general location of your server and the pages of our Site or Application that were viewed during a visit. We use this information to manage End User and Advertiser accounts as well as for internal purposes such as to diagnose problems, monitor traffic patterns and otherwise continually improve our Services. Please note that the Services may provide links to third party sites, such as links to the websites of Advertisers and other third-party organizations, businesses, and merchants who have agreed to make Ad Content and offers available to End Users through FreeMo (including, but not limited to Tapsense Inc). We are not responsible for the privacy policies, practices or the content of websites owned by others that you may link to or that may be linked from the Services. Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use and share any Personal Information.

4. USE OF PERSONAL AND NON-PERSONAL INFORMATION
FreeMo uses Personal Information to: market products and services to End Users through the FreeMo Application; set up and manage your End User or Advertiser account; improve online operations; process transactions (for example, any credit, debit or other billing account information collected from you will only be used to process transactions requested by you); send text messages and notifications to your cell phone to inform you about special offers; provide customer service; send End Users newsletters, RSS feeds, and/or other communications or services which you have signed up for or otherwise agreed to receive (for example, messages about special offers); display content customized to your interests or preferences (for example, we may target you with select custom ads, messages and offers, basing our selections on information, such as brand preferences, you provide to FreeMo); send account- or transaction-related communications such as welcome letters and transaction confirmations; perform research and analysis aimed at improving our products, services and technologies; and managing our systems. We will only use your Personal Information in the ways we specified when it was collected (including as described in this Privacy Policy). We may use your non-Personal Information (including but not limited to Personal Information that has been de-identified and/or aggregated) for any reason in FreeMo’s sole discretion. Any geolocation data collected from your mobile device will also be used for the purpose of delivering customized services, such as displaying Ad Content featuring offers only available to End Users in particular cities or regions, determining the number of Reward Credits to offer End Users, or identifying a segment of End Users which Advertisers have requested as an audience for viewing of particular Ad Content; however, Advertisers will not have direct access to your location and will not be able to view your location on a map.

5. DISCLOSURE OF PERSONAL AND NON-PERSONAL INFORMATION
If you are an End User, in order to effectively manage the Services, your non-Personal Information (including, without limitation, de-identified, aggregated Personal Information) will be disclosed to Partners, Advertisers, and other business partners to facilitate such account-related activities and to manage and improve our Services. We may also disclose your Personal Information to Advertisers where such sharing is required to deliver products or services you have requested (including but not limited to facilitating your receipt or acceptance of offers or fulfillment or redemption of offers). In addition, we may disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our Site, marketing of our products and services, conducting audits, and performing web analytics). We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues. We may also disclose non-Personal Information to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications. We do NOT sell, rent, share or trade your Personal Information to third parties for their own marketing purposes unless you have granted us permission to do so.We may, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and / or with certain interests). In the event that you interact with a certain Advertisement, the advertiser (or the company with which the advertiser works, for example, its ad agency or an advertising network) may determine certain characteristics about you.
Please note also that if you choose to use our social networking function to post information to Facebook, Twitter or another social networking site, anyone who has access to your information through that other site will be able to see your information. FreeMo reserves the right to sell or transfer information (including your Personal Information and non-Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company, or in the unlikely event of a bankruptcy, liquidation or receivership of our business, and you hereby consent to any such sale or transfer. If any such transfer is required, we will make reasonable efforts to notify you in writing in advance by posting a notice on the Site or Application and/or emailing you at your contact email address of record, and we will make reasonable efforts to ensure that the transferee will continue to use any Personal Information collected from you prior to the transfer in accordance with the terms of the then-current version of this Privacy Policy.

6. ACCESSING AND UPDATING PERSONAL INFORMATION
When you use our Services, we make good faith efforts to provide you with access to your Personal Information and to either correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Please e-mail us at info@getFreeMo.com if you need assistance accessing or changing your Personal Information or if you would like to have your Personal Information deleted. Please be aware that if you delete your Personal Information, you may not be able to continue to use the Services, Application or Site. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

7. COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES
We and our Advertisers, authorized service providers, advertising companies, and ad networks may use various activity tracking technologies, such as cookies, pixels and web beacons, to collect information from any computer or mobile device you use to access the Services about your activities on our Site or interaction with our advertisements (see “Information Collected by Third Parties” below). A cookie is a small amount of data stored on the hard drive of your computer that allows your computer’s browser to store your preferences and allows FreeMo, our Advertisers, authorized service providers, advertising companies and ad networks to identify you by a unique identifier and associate this with corresponding information in our or their database. Through the use of a cookie, we and these companies may store your non-personally identifiable registration information and user preferences and may also automatically collect information about your online activity on our Site, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on our Site. In addition, FreeMo may set a cookie on your computer when you view our advertisements delivered on or in connection with a third-party website you are visiting. After a cookie is set, FreeMo may track how you interact with the Ad Content (for example, registering, purchasing, clicking, browsing, etc.). Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Services. We do not tie tracking cookies used for behavioral or targeted advertising purposes to any Personal Information you submit while on our site; however, cookies may be tied to your Personal Information solely for purposes of effectuating transactions you have requested and similar purposes related to the operation of our Site (such as managing our relationships with Advertiser and tracking, processing, maintaining and redeeming your Rewards Credits). They do NOT, however, collect Personal Information. Although we may place or allow third parties to place their cookies when you visit our Site (as described more fully in the subsection below entitled “Targeted or Behavioral Advertising”), we do not have access or control over third party cookies nor does our privacy policy cover the use of cookies by third parties. We may use other standard Internet activity tracking technologies, such as web beacons and similar technologies, to track your use on our Site, Application or your interactions with Ad Content. A web beacon is a programming code used to display an image on a web page and can also transfer an individual’s user identification to a database and associate the individual with previously acquired information about the individual. Such information may be used in targeted or behavioral advertising, as well as for the other uses described in this paragraph. We may include web beacons in promotional e-mail messages or newsletters or online advertisements to determine whether messages have been opened or acted upon. We may use the information we obtain in this manner to customize the Services, Ad Content and offers we provide to users via our Site and Application, to deliver targeted advertisements through such vehicles, and to measure the overall effectiveness of our online advertising, content, programming or other activities. We do not tie web beacons to any Personal Information you submit while on our Site. Information Collected by Third Parties: Targeted or Behavioral Advertising. Targeted advertising (also known as behavioral advertising) uses information collected on an individual’s web browsing or mobile application behavior, such as the pages they have visited or the searches they have made to target advertising to the user based on this behavior. This information is then used to select which FreeMo advertising should be displayed to a particular individual on websites or mobile applications other than the Site or Application. For example, if you have shown a preference for a certain product while visiting the Site, you may be served an advertisement from or about the Site for the same or a similar product when you visit a site other than the FreeMo Site. The information used for targeted advertising either comes from the Site, the Application or through third party website publishers. In addition, we may place (or allow third parties to place) cookies and pixels on our Site or Application which enable our authorized service providers, advertising companies and advertising networks to collect information about our users who view or interact with their or our advertisements on our Site or Application or complete certain actions on our site, such as submitting an application or registration form. However, we do not tie these cookies and pixels to personal information that you submit on our Site or Application. The information collected by the cookies and pixels allows us and the companies mentioned above to deliver, and gauge the effectiveness of, targeted advertisements, both on our site and when you are browsing other websites. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative (www.networkadvertising.org), which offers a single location to opt out of ad targeting from member companies.

8. MINORS
We do not knowingly collect Personal Information from individuals under 13 years of age. Nor do we authorize users who are less than 13 years old to use the Services (including, without limitation, the Application and Site). If we learn from the individual or from the individual’s parent or legal guardian that we have collected Personal Information about a person under the age of 13, we will make efforts to delete their Personal Information from our systems within a commercially reasonable period of time.

9. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We utilize reasonable information security measures to safeguard your Personal Information. For example, industry-standard encryption (Hyper Text Transfer Protocol Secure a/k/a “https”) is used to protect communications between our servers and our users’ web browsers and mobile devices. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. You are responsible for keeping the user name and password you use for accessing our Services confidential. We ask you not to share it with anyone.
The information you provide and that we collect from you will be stored on our servers and/or other third party providers (e.g., AWS) in data centers located in the United States. When you use our Site on your computing device, your information may be stored locally on that device as well. We retain information collected about you indefinitely for business, legal, or tax purposes.

10. ANONYMOUS DATA COLLECTION
Airpush, Inc. collects data relating to your use of this and other apps and your device and use of the device, such as Bluetooth beacon data, hashed or encrypted values of your email or phone number, geolocation, and other permission-based user information. You will see the icon whenever data is being collected. Collected data will be shared with third parties for advertising, analytics and market research purposes. For further information, Airpush, Inc.’s data collection and use practices, please see Airpush, Inc.’s Technology Privacy Statement and Privacy Policy. You may opt-out of interest-based ads by clicking here.
A) Data Collection: Airpush collects data relating to your use of this and other apps, your device and use of the device, such as Bluetooth beacon data, hashed or encrypted values of your email or phone number, geolocation, and other permission-based user information. You will see the ê icon whenever data is being collected.
B) Data Use: Anonymous data is commercially shared by Airpush with third parties for marketing and research, user trends and adoption measurement, interest-based profiling, analytics, and optimization. Airpush will not serve ads through this app, but data may be used to deliver interest-based ads via other channels.
C) Privacy and Opt-Out Options: AirPush collects data in accordance with applicable privacy laws, including the EU-US Privacy Shield Framework, and its own Technology Privacy Statement. You may opt-out of interest-based ads by clicking here.

11. CALIFORNIA PRIVACY RIGHTS
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed. We will not share Personal Information about you with third parties for their own direct marketing purposes unless you affirmatively agree to such disclosure – typically by opting in to receive information from a third party through our Site. To prevent disclosure of your Personal Information for use in direct marketing by a third party for its own purposes, do not opt in to or authorize such use when you provide Personal Information on our Site. Please note that whenever you choose to share your Personal Information with a third party or allow your Personal Information to be shared with a third party to communicate with you (for example, if you are an End User, to facilitate your acceptance and/or receipt of special offers from an Advertiser), your information will be subject to the third party’s privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information. California Customers may request further information about our compliance with California’s privacy law by e-mailing info@getFreeMo.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.

12. PUBLIC MESSAGE BOARDS AND OTHER ONLINE FORUMS
Please note that when you choose to post messages and/or profile content on messages boards and other online forums that we may make available on our Site or Application, such content is viewable by third parties and, in the case of public online forums and any public profiles, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Information you post on our Site or Application and you should not post highly confidential or sensitive information. FreeMo is not responsible for how third parties who view your Personal Information may use this information (such as to send you unsolicited messages).

13. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is subject to occasional revision. FreeMo may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on the Site or Application. We encourage you to check this Privacy Policy from time to time and to refer to the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. We may also post a notice of changes to this Privacy Policy by e-mailing you about the changes. Your continued use of our Site, Application or other Services following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy. However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING OUR SITE AND APPLICATION AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon discontinuing use of the Site, Application and/or other Services, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to any data or information (including, without limitation, Personal Information) collected from you prior to such departure.

14. HOW TO CONTACT US
To ask questions about our Privacy Policy or to lodge a complaint, please contact us at:
FreeMo, Inc.
Attn: Privacy Matters
215 3rd Avenue
Kirkland, WA 98033
Email: info@getFreeMo.com
2017 FreeMo, Inc. All rights reserved