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PRIVACY POLICY

Last Updated: November 12, 2014

Introduction: What This Privacy Policy Covers

NetZero, Inc. and NetZero Wireless, Inc. ("NetZero", "we" or "our") are committed to protecting your privacy. This privacy policy ("Policy") applies to NetZero Internet and mobile websites (the "Sites") and NetZero services (the "Services"). The purpose of this Policy is to disclose NetZero's practices related to information we collect from you and have about you. Please read this Policy carefully. You may select any of the links below or simply scroll down the page to read each section.

  1. Collection of Your Information
  2. Use, Sharing & Disclosure of Your Information
  3. Targeted Advertising, Email & Opt-Outs
  4. How We Keep Your Information Secure
  5. Minors' Use of the Services
  6. Changes to the Privacy Policy
  7. International Users

This Policy applies to the Sites and Services only. When you visit websites to which we link, or if you click on third party advertisements that appear on our Sites, you will be interacting with a third party that operates under its own privacy and security policies. For example, a third party website will have its own policy regarding the use of cookies and web beacons or collection of your information. In addition, you may choose to use services and products offered by third parties through our Services or devices such as third party applications. Your use of such services and applications may result in these third parties collecting your personal information and obtaining information from NetZero, including location information (when applicable). You may also choose to give personal information directly to third parties when using such services. In each case, personal information you give a third party will be subject to its terms, conditions, and policies-not this policy. You should review a third party's privacy policy and terms of service before providing your information or using the service. We encourage you to review the privacy policies of any other website or application from which you request products or services.

I. Collection of Your Information

A. Information you provide to us:

We collect information about you when you register for the Services, such as:
  • your name;
  • your address;
  • your telephone number;
  • your primary and alternate email addresses;
  • your birth date;
  • your education;
  • your occupation; and
  • other household and demographic information.
If you join one of our paid Services, we may also collect:
  • billing and payment information, such as your credit card number and billing address; and
  • your social security number or other government identification number.
In addition to information collected from you during registration, we collect information you provide through:
  • online surveys;
  • contest and sweepstakes entries;
  • technical and customer service calls;
  • your voluntary submission of information;
  • email correspondence with us; and
  • acceptance of our applications that interact with third party sites or services, such as Facebook or Twitter.
Note that surveys may be conducted by an independent third party and completion of surveys is voluntary. If you do not wish to participate in a survey, simply decline to participate when asked, but we would like your feedback in order to improve our Sites and Services.

Please see Section II of this Policy to see how we use, share and disclose information you have provided to us.

B. Information we collect through your interaction with our Sites:

We collect information from your access device and browser, including:
  • what type of browser you use;
  • software on your computer, mobile device or other similar device;
  • processor type;
  • operating system;
  • IP address;
  • navigational data such as the URLs you visit and any searches you may perform; and
  • mobile device location information.
As you browse and interact with our Sites or use our Services, we collect information related to your use of the Sites and Services, including:
  • how often you visit the Sites;
  • how often you use the Services;
  • how you navigate and conduct searches on our Sites;
  • your interaction with advertisements and other links that are contained within our Sites;
  • call and data usage and history, including information such as the numbers you call and when you call them, as well as the particular services you use, and other information found on your bill ("Customer Proprietary Network Information" or "CPNI"); and
  • applications purchased, downloaded or used.
Although we reserve the right to monitor Site or Service activity, we will not intentionally disclose any private email messages or online communication between you and a third party, except in the following circumstances:
  • when we believe, in our sole discretion, you are acting in violation of our Terms of Service, our Acceptable Use Guidelines or any applicable law, rule or regulation; or
  • to protect the integrity of our Services or the Internet community as a whole.
Please see Section II of this Policy to see how we use, share and disclose information we collect through your interaction with our Sites or Services.

C. Information we receive from third parties:

We may collect information about you from other sources, including publicly available sources, our Affiliates or our third party partners such as Advertisers (as defined in Section III below), service providers or others, in order to update or supplement information we have collected directly from you. An "Affiliate" is a company that controls, is controlled by or is under common control with NetZero.

D. Information collected through technological methods:

In addition, we may use, and may allow our Affiliates or third party partners to use, technological methods such as cookies or web beacons to collect information about you.

Cookies are small pieces of data that may be stored on your computer, mobile device, or other similar device and are used to make the Sites easier to use and to improve effectiveness of advertising. For example, cookies keep track of your preferences, what Sites or other websites you visit, any personalization you may have done, any passwords you have elected to be remembered, and they may also measure whether you've seen or interacted with an advertisement on our Sites or other sites. Cookies (or similar technological methods) also allow us, our Affiliates and our third party partners to serve you with advertisements including targeted advertisements when you are on or off the Sites. Cookies may be set on your browser when you visit our Sites, or when you open emails from us.

Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movement of users. Web beacons help us and our third party partners better manage content delivery by informing us when you are on our Sites and what content is effective. We also use web beacons in our emails to let us know which emails you have opened.

Please see Sections II and III of this Policy to see how we use, share and disclose information collected through technological methods.

II. Use, Sharing & Disclosure of Your Information

A. How we use your information:

We use the information we collect in a variety of ways, including:
  • to operate and improve the Sites and Services;
  • to fulfill a transaction or request;
  • for internal purposes, such as confirming and tracking your order, subscription or registration, and for billing purposes;
  • to understand your use of the Sites and Services;
  • to better tailor and target advertisements and content to you while you are on and off our Sites;
  • to communicate with you;
  • to offer you products and services including offers from our Affiliates or Advertisers;
  • to conduct research;
  • to develop research reporting for us, our Affiliates and third party market research partners;
  • to verify your identity, and help prevent fraud and identity theft; and
  • in the case of mobile device location data, to provide our mobile voice and data services, emergency services, and our and third-party location-based applications and services such as navigation, weather, mapping and other applications or tools.
B. How we share your information:

We may share your information, including in some cases information that specifically identifies you such as your name, your email address, your physical address or telephone number ("personally identifiable information" or "PII"), with Affiliates and trusted third party partners in ways including the following:
  • to help operate the Sites and Services;
  • to facilitate fulfillment of a transaction or request;
  • to assist with identity verification, and prevention of fraud and identity theft;
  • to serve you advertisements and to improve the effectiveness of targeted advertising (see Section III of this Policy for more information); or
  • to provide research reporting for us, our Affiliates and third party partners.
Examples of third party partners include vendors who process credit cards payments, services providers who compile and analyze data collected by us, service providers who supplement or match information we have collected with information from other parties, market research companies, Advertisers, call centers, and email support vendors. Upon entering into relationships with these third party partners, we implement reasonable contractual and technical protections to limit the use of your information, including your PII, to the scope of the service. When we share or sell aggregated and unaggregated reporting information about the use of and users of the Sites and Services (e.g., market research data), including search and URL information, to Affiliates and third party partners, we do not intentionally disclose PII.

In addition, we may share information in the following circumstances:
  • without notice, to law enforcement or government agencies in response to subpoenas, court orders, or other legal process (including civil and criminal) or otherwise as required by law;
  • in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, or in cases where we believe the Terms of Service or Acceptable Use Guidelines are being violated; or
  • in connection with the actual or potential sale of our business.
Please see Section I of this Policy to see the types of information we collect.

III. Targeted Advertising, Email & Opt-Outs

A. Targeted Advertising Opt-Outs:

We may display targeted advertisements to you while you are on and off our Sites based on information we obtain from you, about you, and/or from third parties.

We work with advertisers, agencies, and other companies that connect advertisers to the Internet (collectively, "Advertisers") in order to display targeted advertisements to you while you are on and off our Sites. These advertisements are targeted based on information that we or third parties may have collected about you such as demographic information (gender, age, general geographic location, etc.) as well as behavioral information. Behavioral information is information about your preferences that is collected or inferred based on, among other things, online data such as the URLs or websites you visit and searches you perform, and offline data such as your purchases and subscriptions.

We and our Advertisers may use technological methods to measure the effectiveness of advertisements and to personalize advertising content; for example, web beacons may enable us or our Advertisers to recognize your browser when you visit our Sites or when you open an email. In addition, a unique third party cookie may be placed or recognized on your browser when you visit our Sites or when you open an email.

You may opt out of targeted advertising from many Advertisers by exercising your choice here. Please note that although you may opt out of targeted advertising, you may continue to see advertisements; these advertisements may not, however, be as relevant to you as targeted advertisements.

If you choose to opt out of receiving targeted advertising, please note that the opt-out tools accessed here are specific to the browser and computer, mobile device or other similar device you are using at the time you opt out. Your opt-out choice cannot be honored if you access our Sites using a different browser on this computer, mobile device or other similar device, or if you access our Sites from a different device. Also, since the opt-out tools involve placing a special cookie on your browser, your opt-out choice cannot be honored if all cookies on your device(s) are deleted. As a result, you should repeat this opt-out process with each browser and device you use to access the Sites and Services and whenever cookies are deleted from your device(s). NetZero has no control over any opt-out tool offered by others and cannot guarantee the performance of such tools.

Instead of using the cookie-based opt-out tools described above, you may also choose to not allow cookies to be stored on your computer, mobile device, or other similar device by modifying your web browser settings. Each browser is different, so make sure to check each browser's user guide to learn how to change your cookie preferences for each browser. If you choose to reject cookies, however, you may not be able to automatically access products and services offered by us that require a user "login" or "sign in." In addition, any cookie-based opt-out tools may not be implemented on your device.

Please see Section I.D. of this Policy for more information on technological methods of data collection such as cookies and web beacons.

B. Email Opt-Outs:

You may receive email advertisements and promotions from us, our Affiliates and our Advertisers regarding products or services we believe you may be interested in, new features or products we are introducing, or other promotions. If you decide that you wish to cease receiving such email, you may do so at any time by following the opt-out instructions in the email.

Since it is necessary for us to contact you regarding certain matters, you may not opt out of receiving messages related to material company announcements or policy changes, or administrative matters relating to your account, like billing, collections, customer service or similar matters.

If you subscribe to a free or discounted version of a Service, you acknowledge that as a condition of receiving such free or discounted Service, you are required to receive information and advertising solicitations from third party Advertisers. You may opt out of receiving such communications from the Advertiser by following the instructions provided by the Advertiser. These solicitations are a condition of receiving the free or discounted Service and you agree that if you opt out of receiving these solicitations you are required to terminate the relevant Service.

IV. How We Keep Your Information Secure

We use secure socket layer ("SSL") technology to protection your information. SSL encrypts your order information as additional protection against the decoding of that information by anyone other than us. However, despite all reasonable security precautions and processes, such as password protection, encryption technology, and use of firewall technology, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect all information we collect and process, we cannot guarantee or warrant the security of any information you transmit to or from our Sites, and you do so at your own risk. Once we receive your transmission, we will take commercially reasonable precautions to protect its security on our systems.

V. Minors' Use of the Services

NetZero believes it is important for parents and guardians to participate in and monitor their children's use of the Internet. NetZero offers general audience Sites and Services and these Sites and Services are not intended for children under the age of 13. If we have actual knowledge that a user is under the age of 13, we require the parent or guardian to provide parental consent as required by the Children's Online Privacy Protection Act ("COPPA"). NetZero will not use or disclose PII from children under 13 except as may be permitted under COPPA. Please click here for further information related to children under the age of 13.

VI. Changes to the Privacy Policy

By using the Sites or Services, you signify your acceptance to this Policy. If you do not agree to this Policy, please do not use any of the Sites or Services. We reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Sites or Services to ensure you are aware of any changes in our privacy practices. Your continued use of our Sites or Services will signify your acceptance of the changes to this Policy. Notification of any material changes to this Policy will be posted on the NetZero home page and/or member start page.

If you have any questions about this Policy please contact us at:
NetZero Legal Department
21255 Burbank Boulevard
Woodland Hills, CA 91367

or

privacy@support.netzero.com.

VII. International Users

The information we collect from users is processed and maintained in the United States, where privacy laws may not be as protective as in your home country. If you are using our Sites or Services from outside of the United States, by providing information to us you are consenting to the transfer of the information to the United States for processing in a manner consistent with this Policy.

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