PRIVACY POLICY*

This Privacy Policy identifies and describes the way TELECLARO uses and protects the information we collect about you, including Customer Proprietary Network Information (“CPNI”). All use of TELECLARO products and services, including visits to our web site, are subject to this Privacy Policy, so please read it carefully and contact us with any questions. PERSONAL INFORMATION??This policy applies to personally identifiable information (“personal information”), which is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; social security number; call records; wireless device location). Personal information does not include “anonymous” or "aggregate" information – neither of which are associated with a specific person or entity.

We collect personal information about you when you use our services or otherwise interact with us. Such information includes:

Information you provide. We collect personal information when you sign up for and use our services, and when you e-mail, call, or otherwise communicate with us. For example, we may collect personal contact, billing, and credit information when you sign up for voice or data services or purchase other products or services. We may also collect personal information when you call or e-mail our customer service representatives, enter information on our Web sites, submit survey responses, pay for service, or submit a job application or résumé. If you provide personal information to us in connection with a co-sponsored Web site, this policy will apply to our use of the information and the co-sponsor’s policy will apply to their use of the information.

Information automatically collected. We automatically collect certain information, some of which may be associated with personal information, whenever you use our services or Web sites. For example, our systems capture details about the type and location of wireless device(s) you use, calls and text messages you send and receive, and other data services you use (for example your ringtone purchases). When your computer Web browser or other communication device accesses our Web sites or wireless deck pages (TELECLARO wireless Web pages designed for access by wireless device browsers), we automatically receive certain information, such as your IP address, browser type, date and time, and the Web page you visited before visiting our site. Our network also automatically captures necessary routing information when you use our services to access the Internet from your wireless device. Information from other sources. We may also obtain personal information about you from other sources. For example, we may obtain updated address information from our shippers or other vendors. We may also purchase personal information (for example, e-mail lists, postal mail lists, demographic and marketing data) from others.

We use personal information for a variety of business purposes, including for example, to complete transactions and bill for products and services; verify your identity; respond to your requests for service or assistance; anticipate and resolve actual and potential problems with our products and services; create and improve products and services; suggest additional or different products or services; make internal business decisions about current and future offers; provide personalized service and user experiences; and protect our rights and property. If you submit a job application or résumé, we use personal information to communicate with you and, subject to applicable law, evaluate your qualifications for employment. We may also use personal information to contact you about TELECLARO or third-party products, services, and offers that we believe you will find of interest. We may contact you by telephone, postal mail, e-mail, or other methods. You may opt-out of receiving marketing communications from us at any time.

Teleclaro mobile application reads user's contacts (if allowed by the user) in order to show one-touch dialing option for all the user's contacts. This information stays within your phone and is not accessible to us. If the user however decides that they want to see the calling rates for the number they are calling, our app can (upon your approval) send the phone numbers from address-book (without any other information) to our servers and then resolve calling rates for each phone number in your address-book; so you are aware of the calling rates before actually making a call.

We do not sell, rent, or otherwise provide your personal information to unaffiliated third-parties (parties outside the TELECLARO Branch name) to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows:

With your consent. We may disclose personal information about you to third-parties with your consent. We may obtain your consent in several ways, such as in writing; online, through "click-through" agreements; orally, including through interactive voice response; or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.

To the primary account holder. We may disclose personal information of an account user to the primary account holder (the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you or your use of the service to them or others at their direction. When you are the primary account holder, but you receive special or discounted pricing, terms, or other benefits through another party’s agreement with us (for example, an employee discount), we may provide enough personal information to that party to verify your initial and continuing eligibility for benefits under their agreement with us and to calculate any associated discounts.

Transaction processing. We may disclose personal information to third-parties who complete transactions or perform services on our behalf (for example, billing, shipping, customer service, and marketing), transactions on your behalf (for example, verification of your account information at your request to some third-party business), or transfers related to your service (for example, number portability). We typically restrict by contract the manner in which these third-parties may use and disclose personal information about you without your consent.

Third-party services. Your personal information may be disclosed when the use of our services allow you to take advantage of services and products offered by other companies. Business transfers. We may disclose personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information could be transferred to third-parties as a business asset in the transaction.

Legal process & protection of TELECLARO and others. We may disclose personal information or communications where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (for example, lawful subpoena, court order, E-9-1-1 information); to enforce or apply agreements; to initiate, render, bill, and collect for services and products; to protect our rights or property; in connection with claims, disputes, or litigation; to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or if we determine disclosure is necessary in an emergency situation.

We use a variety of physical, electronic, and procedural safeguards to protect personal information from unauthorized access, use, or disclosure while it is under our control. For instance, when you provide sensitive information (such as credit card numbers) to our Web sites, we use transmission encryption technologies like Secure Socket Layer (SSL). Although we cannot guarantee that loss, misuse, or alteration of your personal information will not occur, we strive to prevent such occurrences. ??Our practices and procedures are designed to limit personal information access to those TELECLARO employees and agents with a legitimate need to access such information. TELECLARO employees are bound by confidentiality obligations, which obligate them to protect the confidentiality of our customers’ personal information. Violations subject employees to disciplinary action, up to and including termination. ??We retain personal information for as long as we have a business need or as applicable laws, regulations, or government orders require. When we dispose of personal information, we use reasonable procedures to erase or render it unreadable (for example, shredding documents and wiping electronic media). We will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred and creates a risk of identity theft or service disruption, or as otherwise required by law.

Access to Your Information??You may access and modify your contact information by visiting my.simplemobile.com or a TELECLARO retail store, or by contacting Customer Service. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. ??Choices Regarding Use of Your Information.

We want to provide you with meaningful choices regarding our marketing communications and you may choose to limit or opt-out of certain communications from TELECLARO at any time. While you may elect not to receive marketing information from us, if you subscribe to our services or buy our products, you will continue to receive invoices, customer-service and transactional notices, and similar communications.

If you are a TELECLARO customer and you manage your account online, you can change your marketing preferences by logging in https://www.teleclaro.com/shoppingcart/home.asp My Account. If you are a TELECLARO customer but do not manage your account online, you can change your marketing preference by completing our customer opt out form. If you are not a Horizon Mobile customer and would like to opt-out of marketing communications from TELECLARO, you can do so by completing our non-customer opt out form. You may also manage your marketing preferences by contacting Customer Service by dialing or 1-888-252-1112 from any phone, or, with respect to marketing e-mails, by following the “unsubscribe” instructions on any marketing e-mail we send you.

Not all marketing communications you receive on your device are sent or authorized by TELECLARO. When you provide your mobile number or other contact information to others, you may receive unwanted calls, text messages, or e-mails on your device. We take steps to reduce unsolicited advertising, but we cannot block all such advertisements or unwanted communications.

When you use TELECLARO communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill unless you block that information, which you can generally do by dialing *67 prior to dialing the called party’s number. Refer to the specific instructions for your communication device regarding Caller ID Blocking.Caller ID Blocking does not prevent the display of your information when you dial certain business numbers, including 911, 900 numbers, or toll-free numbers.

We do not solicit children to purchase our services or products. If, however, you authorize a child to use our services or products by providing them a device associated with your Horizon Mobile account, any personal information associated with such use will be treated as your information in accordance with this policy. Our Web sites are not designed to attract children under the age of 13 and we do not intentionally or knowingly collect personal information on our sites from anyone under the age of 13. We encourage parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission. We may offer security features designed to allow the customer to implement restrictions to adult orientated content, but such features are not foolproof.

We may use cookies (small data text files placed on your computer or device) or similar technologies to identify the computer or device and record your preferences and other data so that our Web sites can personalize your visit(s). We may also use information collected from cookies to improve our sites, make recommendations, and complete transactions you request. You may be able to set your browser(s) to reject cookies or delete cookies, but that may result in the loss of some functionality on our sites. We may also use Web beacons (small graphic images on a Web page or an HTML e-mail) to monitor interaction with our Web sites or e-mails. Web beacons are generally invisible because they are very small (only 1-by-1 pixel) and the same color as the background of the Web page or e-mail message. If we combine or link cookie or Web beacon information with personal information, we will treat the combined or linked information as personal information under this policy. We may employ third-parties to place advertisements about our products and services on other Web sites. The use of cookies, Web beacons, or similar technologies by such third-parties is subject to their privacy policies – not this policy. ??Customer Proprietary Network Information (CPNI)

Customer Proprietary Network Information, or "CPNI", is a form of personal information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details; call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted policies and procedures designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under FCC rules, applicable law, or explained in this policy. However, you may designate other “authorized users” (for example, a spouse) to access and manage your account information, including CPNI.

We provide password protected online access to your account information through www.kloktel.com/shoppingcart/home.asp. For multi-line accounts, the primary account holder is authorized to access online account information for all the devices on the account. Other users may generally access online account information related only to their respective device (for example, if a parent provides a device to their child, the child may access online information about that device – including CPNI). The primary account holder, however, may designate additional or more limited access rights for other users.

We may monitor and record phone calls, e-mails, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests.

We do not publish directories of our customers’ wireless numbers. Nor will we provide or make such numbers available to third-parties for listing in their public directories, without the customer’s prior consent.

If you use or link to a public forum, bulletin board, chat room, or social network on or from a TELECLARO Web site, be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of personal information you choose to submit or share with others.

Our network detects your device's approximate location whenever it is turned on (subject to coverage limitations). This location technology makes the routing of wireless communications possible and is also the basis for providing enhanced emergency 9-1-1 service, which permits us to provide your general location to a public safety answering point, emergency medical service provider, or emergency dispatch provider. We may also use this technology to disclose, without a user’s consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm.

With your consent, we may also provide location-based services or provide third-parties access to approximate location information so they may provide such services to you. You should carefully review the specific Horizon Mobile terms and conditions applicable to your use of location-based services for any special privacy implications or rules. You should also carefully review the privacy policies and other terms of third-parties with whom you have authorized the sharing of your location information, and you should consider the risks involved in disclosing your location information to other people. Where a wireless device user requests that their location information be revealed to other persons (through a TELECLARO application or a third-party application you place on your device), the wireless device user will be provided options for managing when and how such information should be shared (except in the case of certain parental controls or similar services associated with enterprise or multi-line accounts, which may be managed solely by the primary account holder or their designee). TELECLARO follows the CTIA’s Best Practices Guidelines for Location-Based Services.

Some devices may automatically upload to Horizon Mobile network servers information you have stored on the device and/or SIM card in order to facilitate specific functions. For instance, some devices back-up your address book. You may choose to disable such uploads but this may affect functionality of the device or your services. Refer to instructions for your device and service for details or contact Customer Service for more information. We may also provide you the ability to upload other information from your device to TELECLARO network servers. For instance, you may have the option to upload pictures, recordings, calendars, tasks, or notes. Uploaded information will not be used by TELECLARO for purposes other than as disclosed in connection with those services, this Privacy Policy, or applicable Terms and Conditions, and will not be shared with third-parties for their use, without your prior consent.

Services and functionality offered through certain devices are provided in conjunction with other entities. As a result, personal information from your devices may be uploaded and stored on their servers. For instance, ___________ services are provided in conjunction with _________, and personal information from your device is stored on the _________ servers. Their specific terms and conditions, terms of use, and privacy polices apply to those services.

This policy does not modify or alter any applicable agreement you have with KLKTEL. For example, our Terms of Use govern your use of our web sites. Additionally, if you use our products or use or subscribe to our services, our Horizon Mobile Terms and Conditions and certain other terms may apply to your use, purchase, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency.

You play an important role in ensuring the security of personal information, including protecting against unauthorized access to your device. Many devices store information both in the phone and on the SIM card. Therefore, before discarding, trading in, or giving away your device, be sure you remove and retain your SIM card and follow the manufacturer's instructions for deleting personal information or other data on the device. (This can be found in your owner's manual or on the manufacturer’s Web site.) If you provide a third-party access to your device, you should understand that personal information will remain on the device and may be accessible, deleted, altered, or transferred to another device or our network servers by the person using the device, and that we will treat that user as you for purposes of this policy. ??We encourage you to use passwords to prevent unauthorized access to your device, your online account, and your voicemail. You may also establish an optional password to identify yourself during calls with our Customer Service representatives. We recommend that you use unique, non-obvious passwords, that you periodically change your passwords, and that you not share your passwords with others. Notify us immediately if you believe your device has been lost or stolen or if you believe your personal information has been accessed without your consent.

When you install third-party applications (for example, programs, widgets, etc.) on your device, you may give your consent for the third party to access certain information you have stored on your device (for example your contact list). You may also give your consent for the third party to access information stored on TELECLARO network to facilitate the application’s functions (for example, you may consent to third-party access to your location information – see Location Based Services). In either case, the manner in which such third-parties may use, share, or disclose such information is governed by their terms and conditions and their privacy policy – not this policy.

We cannot guarantee that your communications using our services or devices will be private or secure. Although it is illegal for unauthorized persons to intercept or access your communications or information, such interceptions or access can occur.

California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed personal information to any third parties for the third parties' direct marketing purposes. As stated in this Privacy Policy, TELECLARO will not sell or share your personal information with non-TELECLARO companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us calling Customer Service at 1-888-252-1112.

We may update this policy if we materially change our practices or if legal or regulatory changes require it. If we decide to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time the personal information was collected, we will notify you by posting notice of the change on our Web site's home page for at least 30 days before we implement that change and will give you an opportunity to opt-out of the proposed use or disclosure of previously collected personal information. You should refer to this policy often for the latest information and the effective date of any changes.

Any questions about this policy or about TELECLARO privacy practices, please call Customer Service at ?1-888-252-1112. For SMS Questions or to Cancel or Stop go to CALLTURE SMS SHORT CODE 58055.

TELECLARO AS BRAND NAME RESERVES THE RIGHT TO CANCEL ANY LINE OR SERVICE DUE TO AN EXCESS OF USAGE, AT ANY TIME WITHOUT ANY PREVIOUS NOTICE ALSO, RESERVES THE RIGHT TO SEND MANUAL OR AUTOMATIZED SMS TEXT TO ANY USER GROUP OR INDIVIDUAL REGISTERED BY POINTS OF SALES, ACCESS NUMBERS AND THE WEBSITE.

WARNING: IF YOU REGISTER WITH TELECLARO YOU GIVE AUTHORITY TO CALLTURE SMS CODE 58055 TO SEND SMS MESSAGES. HOW EVER, ALL USERS CAN BLOCK TO RECEIVE SMS DIRECTLY IN THE MESSAGE, CALLING TO CUSTOMER SERVICE OR DIRECTLY GOING TO CALLTURE SMS SHORT CODE 58055.