PGPP Privacy Policy

LAST UPDATED: 6-8-2022

PGPP MOBILE APPLICATION PRIVACY POLICY

Invisv, Inc. (“Invisv,” “we,” or “us”) values the privacy of its customers and want them to be familiar with how we collect, use and disclose their personal information. This Mobile Application Privacy Policy (the “Privacy Policy”) describes our practices in connection with personal information that we collect from or about users (“you”) of the PGPP mobile application (the “App”).

PERSONAL INFORMATION

“Personal Information” is information that identifies you or relates to you as an identifiable individual. The App collects Personal Information, including:

• Payment-Related Information, such as your payment card or other payment information (we use a third party payment processor to collect and process this information and do not access or store it on our systems);

• Services Purchased (i.e., the services provided through the App and the related plan type you choose);

• App Usage Data, such as the date and time the App on your device accesses our servers to access tokens based on your services purchased.

At Invisv, we believe that users shouldn’t have to sacrifice privacy to communicate freely. Our offerings are designed to significantly minimize, and in some contexts eliminate, the possibility of associating actual communications and usage data to individual users. In other words, we take steps aiming to ensure that this information does not reveal your specific identity or directly relates to an identifiable user. However, despite these efforts, some of this information may have to be personally identifiable on a strictly temporary or highly limited basis in order for us to be able to provide our services. As such, some privacy laws may consider such information Personal Information. In this Privacy Policy, we refer to this information as “Other Information.” We retain, use, disclose and otherwise treat Other Information in the same way we treat Personal Information and references to Personal Information in this Privacy Policy include Other Information. Other Information is comprised of the following:

• For our mobile offerings, the embedded subscriber identity module (eSIM) necessary to transmit communications across the network. The eSIM constitutes a set of credentials necessary to sign on to and use a mobile carrier’s network. The eSIM utilized by the App to provide our services to you will be assigned and replaced on a frequent basis in order to avoid associating the same unique identifier with all of your communications;

• For the PGPP Relay functionality that can be enabled and used through the App, information about which relay server IP address your device communicates with. In order to prevent all of this information from being visible to all of the parties involved (e.g., your network provider and the websites you visit), the PGPP Relay functionality relays your web traffic through multiple connection points and limits access of each connection point to what is necessary in order to complete the connection. While your IP address is visible to your network provider and the first connection point, the information of the website you are trying to visit is encrypted. The second connection point creates a provisional IP address and decrypts the information of the website you are trying to visit in order to complete the connection. However, the second connection point is not privy to your original IP address. To maximize your privacy, connection points and provisional IP addresses are assigned and replaced on a frequent and random basis.

Collection of Personal Information

We and our service providers collect Personal Information through the App, for example:

• when you enroll in one of our mobile data plans; or

• when you provide related payment information in connection with your subscription.

We need to collect Personal Information in order to provide the requested services to you. If you disclose Personal Information relating to people other than yourself to us or to our service providers in connection with our services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the App and fulfilling your requests.

  • To provide our services and the App to you, such as the mobile data services you request;

  • To complete your service-related transactions, process refunds, verify your information, and provide customer service;

  • To respond to your inquiries and fulfill your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request other information about our services;

  • To send administrative information to you, such as communications on your subscription, etc.

• Providing you with information and materials about our offerings.

  • To send you marketing related or informational emails, with information about our services, products and other news about our company.

• Accomplishing our business purposes.

  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;

  • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

  • To protect our rights, privacy, safety or property, and/or that of you or others; and

  • For compliance with applicable law and regulations.

Disclosure of Personal Information

We disclose Personal Information:

• To our third-party service providers, to facilitate services they provide to us.

  • These can include providers of services such as fraud prevention, information technology and related infrastructure provision, payment processing, auditing, and other services.

• To our third-party advisors.

  • We may disclose your Personal Information to our advisors, including auditors, legal counsel, tax advisers and consultants, relating to or in connection with the operation of our business, compliance with our legal, regulatory or contractual obligations and/or your investments with us.

• To law enforcement agencies and other government authorities.

  • In order to comply with our legal or regulatory obligations, we may disclose your Personal Information to law enforcement agencies, regulatory or tax authorities and other governmental or public agencies or authorities.

• To third parties in the event of reorganization.

  • Your Personal Information may be disclosed to third parties in the event of any reorganization, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We also disclose Other Information to certain third parties (referred to in this Policy as “Network Providers”) that provide the network infrastructure we rely on to provide you with the mobile data services you have requested. Without such disclosure, we would not be able to provide our services to you. The third parties receiving Other Information from us include:

• Telecom North America (Telna) and network partners such as AT&T Corporation.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. If you have any questions or concerns regarding the security of your Personal Information or your interaction with us, please notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Receiving marketing-related emails from us.

If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking on the unsubscribe link contained in every such email you receive from us. Alternatively, you may notify us of your decision to opt out in accordance with the “Contacting Us” section below.

Accessing, changing, or deleting your Personal Information.

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.

When contacting us, please make clear what Personal Information is subject to your request. We may need to verify your identity before implementing your request. We will respond to your request in compliance with applicable law.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the processing of your personal information by, or other practices of, any third parties, including any third party operating any website or service to which the App might link. The inclusion of a link in the App does not imply endorsement of the linked site or service.

USE OF SERVICES BY MINORS

The App and our services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the App or otherwise to us.

DO NOT TRACK SIGNALS

Since we do not track users over time and across third-party web sites or online services, we do not currently respond to browser do-not-track signals.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy in or through the App.

CONTACTING US

Invisv, Inc., located at 4676 ADMIRALTY WAY #503 MARINA DEL REY, CA 90292, is the company responsible for the collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at legal@invisv.com, or:

4676 ADMIRALTY WAY #503 MARINA DEL REY, CA 90292

ADDITIONAL INFORMATION FOR RESIDENTS OF THE UK AND EUROPEAN ECONOMIC AREA

Controller

Invisv, Inc. is the controller responsible for the processing of your Personal Information. You may contact us in accordance with the “Contacting Us” section above.

Purposes and Legal Bases

We process Personal Information for the purposes and based on the legal bases described in the chart below. Please refer to the definitions in the “PERSONAL INFORMATION” section above for more information about the specific categories of Personal Information referenced in this chart.

Making the services available to you

Purpose	Examples of Processing Activities	Personal Information	Legal Basis
App functionality and services	Provide the App and services to you, such as arranging access to the App, facilitating your purchases, and providing the mobile data services	Payment-Related Information; Services Purchased; Device Information; App Usage Data; and Other Information	Necessity of the processing to enter into and perform our service contract with you
Customer service	Respond to your inquiries and fulfill your requests, for example, when you send us questions, suggestions, compliments or complaints, and to process refunds	Payment-Related Information; and Services Purchased	Necessity of the processing to enter into and perform our service contract with you Necessity of the processing to pursue legitimate interests, such as responding to your inquiries regarding our services
Communicating important changes	Send you important information regarding our relationship with you, such as any changes to our terms, conditions, policies, or procedures, and/or other administrative information	Payment-Related Information; Services Purchased; and Device Information	Necessity of the processing to pursue legitimate interests, such as to ensure our App is used in accordance with our terms, conditions, and policies Necessity of the processing to perform our service contract with you, where provided in our Terms of App Necessity of the processing for compliance with legal obligations, such as to inform you of material changes to our Terms of App or policies or to comply with applicable consumer and/or data protection laws
Administering the App	Administer the App, including troubleshooting and diagnostic testing, conducting performance analyses of our systems and App, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and data hosting	Payment-Related Information; Services Purchased; Device Information; App Usage Data; and Other Information	Necessity of the processing to pursue legitimate interests, such as ensuring the ongoing availability and proper functioning of the App

Accomplishing Our Business Purposes

Purpose	Examples of Processing Activities	Personal Data	Legal Basis
Fraud prevention, audits and security	Conduct audits, verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements; monitor for and prevent fraud; and security purposes, including system security	Services Purchased; Device Information; App Usage Data; and Other Information	Necessity of the processing for compliance with legal obligations, such as to detect and prevent cyberattacks Necessity of the processing to pursue legitimate interests, such as identifying and/or preventing fraudulent transactions or use
Legal and compliance	Fulfill our legal and compliance-related obligations, including complying with applicable laws; comply with legal process; respond to requests from public and government authorities; meet national security or law enforcement requirements; enforce our terms and conditions; facilitate corporate transactions; protect our operations; protect our rights, privacy, safety, or property and/or that of you, or others; allow us to pursue available legal remedies, defend claims, and limit the damages that we may sustain	Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question, which may include Payment-Related Information; Services Purchased; Device Information; App Usage Data; and Other Information	Necessity of the processing for compliance with legal obligations, such as complying with legal processes Necessity of the processing to pursue legitimate interests, such as enforcing terms and conditions and bringing or defending legal claims

Retention Period

We retain Personal Information only for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide our services to you;

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Cross-Border Transfers

Some countries are recognized by the European Commission or the United Kingdom as providing an adequate level of data protection (the full list of these countries is available here for the EEA https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries\_en and here for the United Kingdom https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/). Your Personal Information may be stored and processed in any country or jurisdiction where we have facilities or in which we engage service providers, and these countries or jurisdictions may not be recognized by the European Commission or the United Kingdom as providing an adequate level of data protection.

Data Protection Authority Complaints

If you have any concerns regarding the processing or security of your Personal Information, you may lodge a complaint:

• with an EU/EEA supervisory authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item\_id=612080; or

• if you are a resident of the United Kingdom, the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/).

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH AND VIRGINIA

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, postal address, email address, account name, and online identifiers.	service providers and Network Providers; Network Providers have access to Other Information only
Personal information as defined in the California customer records law, such as name an, contact information and other information that identifies, relates to, describes, or is capable of being associated with, a particular individual.	service providers and Network Providers; Network Providers have access to Other Information only
Commercial Information, such as transaction information and purchase history.	service providers
Internet or electronic network activity information, such as IP addresses and eSIMs	service providers and Network Providers; Network Providers have access to Other Information only

We do not sell Personal Information, and we do not share or otherwise process Personal Information for purposes of cross-context behavioral or targeted advertising, as defined under applicable law. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated.

Sources of Personal Information

We collect your Personal Information from you when you are signing up for or using the App and/or our services.

Retention Period

We retain Personal Information only for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide our services to you;

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Individual Requests

If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you may, subject to applicable law, have the right to make the following requests:

1. You may request to know whether we process your Personal Information, and to access such Personal Information.

   a. If you are a California consumer, you may request that we disclose to you the following information covering the 12 months preceding your request:

   i.  The categories of Personal Information we collected about
   you and the categories of sources from which we collected
   such Personal Information;
   
   ii.  The business or commercial purpose for collecting Personal
   Information about you; and
   
   iii.  The categories of Personal Information about you that we
   disclosed, and the categories of third parties to whom we
   disclosed such Personal Information (if applicable).
   

2. You may request to correct inaccuracies in your Personal Information;

3. You may request to have your Personal Information deleted; or

4. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information. Where applicable, you may request to obtain a copy of the Personal Information you provided to us in a portable format.

We will not unlawfully discriminate against you exercising your rights under applicable law. To make a privacy request, please contact us per the “Contacting Us” section above. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your name, contact details or government identifier, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Appeal Process

If you are a resident of Colorado, Connecticut or Virginia and we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us per the “Contacting Us” section above.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.