Privacy Policy

FREEMO Privacy Policy 

Last Revised: March 21, 2023

1. ABOUT THIS PRIVACY POLICY

Thank you for using FREEMO and its related tools and services, including, without limitation, our network and cellular services, our mobile application (the “Application”), websites (the “Sites”), SMS, APIs, email notifications, buttons, and widgets, (collectively, the “Services”), and any information, text, graphics, photos or other materials uploaded, downloaded or appearing on the Services (“Content”). The Services are owned and operated by FREEMO, Inc., a Washington corporation (“FREEMO,” “we,” “us” or “our”). The Services are compatible with the network and cellular services of AT’T and any of our other participating carriers (“Partners”). 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 Lock screen and within the Application. Users of the Services (collectively, “End Users”, and each, an “End User”) can earn reward credits (“Reward Credits”), which may be redeemed by 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 Services; 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, 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 transaction service providers may also collect credit, debit or other billing account information. If you choose to use our Services’ social networking functions 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 (“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 information related to your use of the Services (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 provide our Services, 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. Location Data. Through the Services, FREEMO may collect and process information about your actual location (“Location Data”). FREEMO uses various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide FREEMO with information on nearby devices, Wi-Fi access points and cell towers. FREEMO uses your Location Data to deliver the Services, personalize content, tailor the Services to End Users, and as otherwise provided in Section 4 “Use of Personal and Non-Personal Information” below. The FREEMO Services collect information about your location even when you are not actively engaging with the Services or when your device is idle. It is your responsibility to notify users on your account that we may collect and use Location Data from devices.

Your device is also capable of using optional content at your request or the request of a user on your account, offered by third parties that make use of a device’s location information (“Location-Based Services”). You should review the privacy policies of each third party offering Location-Based Service to learn how the location information will be used and protected.

Our directory assistance service (411) may use the location of a device to deliver relevant customized 411 information based upon the user’s request for a listing or other 411 service. By using this directory assistance service, the user is consenting to our use of that user’s location information for such purpose. This location information may be disclosed to a third party to perform the directory assistance service and for no other purpose. Such location information will be retained only as long as is necessary to providethe relevant customized 411 information and will be discarded after such use.

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 wireless device 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 Location 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 Personal Information and 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 FREEMO with which the advertiser works, for example, its ad agency or an advertising network) may determine certain characteristics about you.

Please note that technical limitations may, in some circumstances, prevent you from blocking the transmission of caller identification information when you make a call using your wireless device. If so, your billing name may be displayed along with your wireless number on outbound calls to other wireless and landline phones with Caller ID capability and may also be shown on the bill of the person receiving your call.

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 and Non-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 support@beastmobile.net 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. 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.

Applicable laws require FREEMO to take steps to protect certain information, known as “customer proprietary network information” or “CPNI” from unauthorized disclosure or use. Among other things, FREEMO will require verification of your identity before you are permitted to access your account, whether to make changes to your service, including, but not limited to, suspending, deactivating, adding new service, or changing service, or to obtain usage details, account balances, or other details regarding your account or service. Consistent with applicable laws, FREEMO will provide information relating to your service or account , including CPNI, upon the direction of any person able to provide information FREEMO deems sufficient to identify such person as a FREEMO subscriber.

7. COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES

A) Tracking 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 (“Tracking Technologies”), to collect information from any computer or mobile device you use to access the Services about your activities while using the Services or interaction with advertisements whether provided by FREEMO or third parties (see “Information Collected by Tracking Technologies” below). Tracking Technologies generally allow 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 a database.

Through the use of Tracking Technologies, we and these companies may store your non-personally identifiable registration information and user preferences and may also automatically collect information about your activity, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while using our Services. In addition, FREEMO may set Tracking Technologies on your computer or wireless device when you view advertisements delivered on or in connection with a third-party website you are visiting. After a Tracking Technology is set, FREEMO may track how you interact with the Ad Content (for example, registering, purchasing, clicking, browsing, etc.). We do not tie data obtained from Tracking Technologies used for behavioral or targeted advertising purposes to any Personal Information you submit while on our site; however, data obtained from Tracking Technologies 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). Although we may place or allow third parties to place their Tracking Technologies when you use our Services (as described more fully in the subsection below entitled “Information Collected by Tracking Technologies: Targeted or Behavioral Advertising”), we do not have access or control over third party Tracking Technologies nor does our privacy policy cover the use of Tracking Technologies by third parties.

B) Information Collected by Tracking Technologies: Targeted or Behavioral

Advertising. Targeted advertising (also known as behavioral advertising) uses information collected about 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 advertising should be displayed to a particular individual on websites or mobile applications. 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 Site. The information collected is only linked to an anonymous ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number. The information used for targeted advertising either comes from Tracking Technologies, our Services, or third parties. The information collected by the Tracking Technologies allows us or third-party advertisers to deliver, and gauge the effectiveness of, targeted advertisements, both on our Services 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. In addition to the uses specifically set forth above, FREEMO may use and disclose Non-Personal Information collected through the use of Tracking Technologies for any purpose in its sole discretion.

8. LINKS

The Services may contain links to other web sites that are not subject to the same policies as this Privacy Policy. For instance, clicking on elements within the Services may take you to an entirely different site. These sites may send their own Tracking Technologies to you and may collect information and make use of that information in ways that the Services would not.

This includes co-branded sites where you may see the FREEMO logo as well as the logo of another service provider. Any information you provide to these co-branded sites is collected and maintained by that service provider. Once you have left the Services, this Policy will no longer apply to Personal Information,

Non-Personal Information, or any other information collected from or provided by you. You should check the applicable privacy policy to determine how other sites may handle your data. FREEMO makes no representation concerning and is not responsible for the quality, content, nature, or reliability of any linked sites. The inclusion of any link does not imply any endorsement, investigation, verification or monitoring by FREEMO of any information in any linked site.

9. 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.

10. 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 username and password you use for accessing our Services confidential. We ask you not to your username or password 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)indata 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. 

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. 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 support@beastmobile.net. 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 message boards and other online forums that we may make available through our Services, 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 Services 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. FROM FREEMO

Consistent with applicable laws, FREEMO or its authorized agents may contact you by regular mail, predictive or autodialing equipment, email, text messaging, facsimile or other reasonable means to inform you about our services or other matters FREEMO may believe to be of interest to you.

14. 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 Services. 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 any part of our 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 SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon discontinuing use of the Site, Application and/or 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.

15. HOW TO CONTACT US

To ask questions about our Privacy Policy or to lodge a complaint, please contact us at:

FREEMO 

Attn: Privacy Matters 

215 3rd Avenue 

Kirkland, WA 98033 

support@getfreemo.