Effective and Last Updated on 05/14/2024

1. INTRODUCTION

The following sets forth the Privacy Policy ("Privacy Policy") of Marconi Wireless Holdings, LLC, and its Affiliates (collectively, "CREDO," "CREDO Mobile, "we" or "us") and is incorporated into and made a part of CREDO's Plans Terms and Conditions, and CREDO's Terms of Use. For purposes of this Privacy Policy, "Affiliates" means any entity that directly or indirectly controls, is controlled by, or is under common control with Marconi Wireless, Holdings, LLC, where "control" means the ownership of, or the power to vote, at least ten percent (10%) of the voting stock, shares, or interests of such entity.

Your privacy is important to CREDO. Accordingly, CREDO provides these policies so that you understand how CREDO collects, uses and, in certain circumstances, discloses the information that you provide and/or that is automatically provided to CREDO because of your visiting and using the credomobile.com website or any other website owned and operated by CREDO (collectively, the "Website") or purchasing or using CREDO products or services. This Privacy Policy also explains the steps CREDO has taken to secure your personal information. Finally, this Privacy Policy explains your options regarding the collection, use and disclosure of your personal information. By visiting the Website or purchasing or using any CREDO product or service, you accept the practices described in this Privacy Policy. CREDO is not responsible for the content or privacy practices on any third-party website that may be linked to or from the Website.

Any questions regarding this Privacy Policy should be directed to: CREDO Customer Care at membersupport@credomobile.com.

2. INFORMATION COLLECTION

CREDO primarily collects personally identifiable information from and about individuals who use our services, take actions with us, visit our websites or mobile applications, or join our marketing and activism lists. This section describes the categories of personal information CREDO collects and the ways that CREDO collects them.

CREDO does not target minors as customers or activists and does not intentionally collect information from people under 13 years of age. If we learn that we have collected personal information from an individual younger than 13, we will delete the information.

2.1 Information You Provide to Us

2.1.1 Account Information

When you sign up for services or take an action with CREDO, you provide information that we use to open an account, process an order, or action, or establish a membership with CREDO. The information you provide varies depending on the service you've requested, but may include:

• Contact Information: Your name, email address, zip code, billing and shipping address, and phone numbers
• Payment Information: Your bank account or credit card information
• Credit Check Information: Your full name, Social Security Number, and date of birth
• Order Information: A list of the products you purchase from us, the amount, and types of telephone services you enroll in—this may include the date and method by which you joined CREDO and the dates of any purchases and account changes
• Technical Information, including your internet protocol ("IP") address, cookies, web beacons, clear gifs, browser type and version, time zone setting and location, browser plug-in types, operating system and platform, and other technology on the devices you use to access our Website
• Usage Information, such as information about how you use our Website (for example time of day, duration of visit, pages visited, actions taken on pages, or other automatically collected meta-data)
• Action Information: A list of the CREDO donations groups you vote for, contributions you make through CREDO, and any other actions you volunteer for through CREDO—this may include the date and method by which you joined CREDO and the dates of any actions and account changes

2.1.2 Additional Information You Choose to Provide

While using CREDO's services or taking an action with CREDO, you may choose to provide us with additional personal information:

• Other Information: When you engage in open ended communication with CREDO by filling in a form on our site, responding to a survey from us, entering a contest or sweepstakes, or communicating directly via phone, email, or mail with a CREDO representative, you may voluntarily choose to provide us with personal information that may be collected and stored along with the communications themselves.

2.2 Information We Collect Automatically

2.2.1 Information We Collect Automatically When You Use CREDO Telephone Services

When you are enrolled in one of our telephone services, we receive information from our underlying carriers about your usage of those services, including:

• Phone Records: The phone numbers you call or text, the phone numbers you receive calls or texts from, the timing and duration of your calls and texts, the timing and amounts of your data usage, the city and state or country your phone is in at the time of a call, and billing information related to your international roaming usage
• Device Information: The models, instrument numbers, serial numbers, and activation statuses of your connected mobile devices and eSIM/SIM cards
• Port Information: Requests from another carrier to port your number from CREDO to the other carrier and responses from other carriers to requests to port your number from another carrier to CREDO
• Customer Proprietary Network Information ("CPNI") generated using our communications services. See the CPNI section of this policy for more information.

When you are enrolled in one of our telephone services, we also generate account and billing data based on the services and plans you're enrolled in, including:

• Billing Information: A monthly bill with itemized charges for mobile and/or long-distance telephone services based on your usage records
• Account Number: A number that CREDO assigns to mobile accounts

CREDO is committed to minimizing the data it collects and stores about how you use our telephone service. Accordingly, we want you to be aware that:

• CREDO does not receive, store, or assign precise handset location information, handset IP addresses, or logs of websites visited by your phone while providing telephone service.
• CREDO does not receive or store the content of customer communications sent using our services except customer communications directed to us for customer service purposes.

2.2.2 Information We Collect Automatically When You Visit Our Websites

We use website cookies, pixels, and similar tools to identify return visitors to our Websites and automatically collect information about you when you visit any of our Websites, including:

• Identifiers and Device Information: Your IP address, device type, operating system, browser type, and internet service provider
• Geo-location: City and country
• Site Use Information: Your referring URL, referring ad/campaign, time and date of any logins, which site pages you visit, and how you interact with them
• Do Not Track Signals: CREDO may receive "do not track" signals from your browser when you visit our Websites. However, given the lack of a standard for interpreting those signals, we are not currently set up to respond to them.

3. INFORMATION USE

CREDO uses the information we collect for a variety of business purposes, including to provide and improve our services, to communicate with you, to process transactions, to comply with legal obligations, and for marketing and advertising purposes. We may also use your information to protect our rights and property, to prevent fraud, and to ensure the security of our services.

4. INFORMATION SHARING AND DISCLOSURE

CREDO may share your personal information with third parties in certain circumstances, including service providers who help us operate our business, legal and regulatory authorities when required by law, and in connection with business transfers. We do not sell your personal information to third parties.

5. YOUR RIGHTS AND CHOICES

You have certain rights regarding your personal information, including the right to access, correct, or delete your information, and the right to opt-out of certain communications. California residents have additional rights under the California Consumer Privacy Act (CCPA).

6. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt-out of the sale of personal information (though we do not sell personal information). You may exercise these rights by contacting us at membersupport@credomobile.com or calling 1-866-306-2900.

7. PRIVACY POLICY CHANGES

This policy may be changed from time to time. Please refer to the effective date of the policy to determine whether changes have been introduced. To inquire about the content of such changes, or if you have any questions about this Privacy Policy, the practices of CREDO sites or apps, or your dealings with our Websites or apps, please contact:

CREDO Customer Care
PO Box 981445
West Sacramento, CA 95798-1445