Broadband transparency policy

Last Updated: June 9th, 2025

 

This disclosure provides SmartLess Mobile, LLC’s (“SmartLess Mobile”) customers (“you” and “your”) with information about the network management practices, performance characteristics, and commercial terms applicable to our mass market wireless broadband Internet access services (“Broadband Services”), consistent with the Federal Communications Commission’s Transparency Rule and applicable state laws and regulations.  Broadband Services provide customers with the ability to transmit and receive data from all or substantially all Internet endpoints.  As a Mobile Virtual Network Operator (“MVNO”), we provide our Broadband Services entirely by using the facilities of our Underlying Carrier, which is a leading nationwide mobile network operator (“Underlying Carrier”).  As a result, while we have some control over the network management practices and performance characteristics applicable to the Broadband Services you receive from us, we do not actively manage all aspects of the network and its performance—our Underlying Carrier retains control.

 

Our Broadband Internet Access Services are subject to our Terms and Conditions (including our Privacy Policy and Acceptable Use Policy) located at www.smartlessmobile.com/terms-and-conditions and www.smartlessmobile.com/privacy-policy. Nothing in this disclosure changes your rights and obligations, or ours, under our Terms and Conditions and Agreement to Arbitrate and Judge or Jury Trial Waiver (“Terms and Conditions”), or our Privacy Policy, available at www.smartlessmobile.com. It is important that you review our Terms and Conditions, Privacy Policy and Acceptable Use Policy frequently and when you activate service as those are subject to change. 

 

This disclosure is provided for informational purposes only and we may change it at any time, without notice. Your broadband access will be provided in accordance with the terms of your specific service plan, which will take precedence in the event of any conflict with this Transparency Disclosure. 

 


 

Network management practices

How does SmartLess Mobile manage congestion with respect to its Broadband Services?

 

Our Underlying Carrier’s network is engineered to provide consistent high-speed data service that SmartLess Mobile leverages to provide a high-quality Internet experience for all our customers. Because bandwidth is a limited resource and the network of our Underlying Carrier is shared among SmartLess Mobile’s customers and other users of our Underlying Carrier’s network, it is essential that our Underlying Carrier engages in reasonable network management practices to benefit all users of the network.  Legitimate network management purposes typically include reasonable security practices by providing confidentiality, integrity and availability of network services, reasonable measures to address traffic that is harmful to the network and providing services or capabilities consistent with customer’s choices regarding services offered.

 

At certain periods when the number of customers using the network exceeds available network resources, customers may experience reduced data speeds. Our Underlying Carrier may independently prioritize service for certain brands and subscribers over SmartLess Mobile which may result in your network speeds being reduced during times of network traffic congestion. Our Underlying Carrier may also use network management techniques to ensure the best possible experience for the most possible customers, including modifying the way streaming video is delivered.  It also may prioritize emergency communications, including by law enforcement, public safety officials, or national security authorities, consistent with or as permitted by applicable law, which may impact other users of its network, including our customers.

 

Does SmartLess Mobile limit data usage or provide customers with tools to monitor and control their data usage?

 

SmartLess Mobile offers service plans with pre-established allotments of data at designated speeds per month and the opportunity to purchase additional data on a one-time or recurring basis.  Currently, SmartLess Mobile offers Broadband Internet Access Services for compatible devices over our Underlying Carriers 4G LTE and 5G broadband networks. 5G and/or 4G LTE access requires a compatible device and SIM within an applicable coverage area. The actual availability, speed and coverage may vary.

 

Each of our current plans (5GB, 10GB, 15GB, 30GB) has a designated allotment of high-speed data. If you have used the total allotment of data corresponding to your plan and decide not to purchase a one-time or recurring pass, your Broadband speed will be reduced until the end of your billing cycle. Certain uses of Broadband Services may not count against a customer’s data allotment, check your specific service plan for details.  If you use the Broadband Services in a manner that violates our Terms and Conditions, including our Acceptable Use Policy, available at www.smartlessmobile.com, we may suspend, terminate, or restrict your data session, switch you to a more appropriate data plan, or terminate your service.  Customers may determine their remaining data balance by accessing their dashboard via our Mobile Application which is available for download on iOS and Android Devices

 

Does SmartLess Mobile block or reduce speeds for lawful Internet traffic based on content, application, service, or use of non-harmful devices or modify particular protocols?

 

SmartLess Mobile does not block or reduce speeds for (including impair or degrade) lawful Internet traffic on the basis of content, application, content provider, or use of non-harmful devices on its Broadband Services, subject to reasonable network management.  Nor do we modify particular protocols, protocol ports, or protocol fields in ways not prescribed by the protocol standards.  Our Underlying Carrier optimizes streaming video to deliver video in 480p resolution.  In addition, your plan may be subject to data caps and may include reduced speeds; please check your service plan for details.   As outlined in the Acceptable Use Policy in our Terms and Conditions, we or our Underlying Carrier may need to block or limit the flow of traffic from certain locations or take other appropriate actions in response to a specific security threat against the networks of our Underlying Carrier or our customers.

 

Does SmartLess Mobile favor some traffic over other traffic in its provision of Broadband Services either in exchange for consideration from a third party or to benefit an affiliate?

 

No, SmartLess Mobile does not favor some traffic over other traffic (such as through prioritization, resource reservation, or traffic shaping) in its provision of Broadband Services for any type of consideration from a third party or to bene  fit an affiliate.  During natural disasters and other emergencies, our Underlying Carrier may prioritize emergency communications, including those of law enforcement, public safety officials, or national security authorities, consistent with or as permitted by applicable law.

 

Does SmartLess Mobile require consideration from edge providers in exchange for the
non-discriminatory treatment of their content, application, service, or non-harmful device?  

 

No, SmartLess Mobile does not require consideration, monetary or otherwise, from edge providers (i.e., individuals or entities that provide any content, application, service, or non-harmful device) in exchange for the non-discriminatory treatment of their content, application, service, or non-harmful device, including, but not limited to, in exchange for transmitting traffic to and from our end users or preventing the blocking or reduction of speeds (including impairment or degradation) of the edge provider’s content, application, service, or non-harmful device.

 

Does SmartLess Mobile unreasonably interfere with or unreasonably disadvantage: (1) an end user’s ability to select, access, and use the Broadband Services; (2) the lawful content, applications, services, or devices of the end user’s choice; or (3) an edge provider’s ability to make lawful content, applications, services, or devices available to end users?

 

No, subject to reasonable network management, SmartLess Mobile does not unreasonably interfere with or unreasonably disadvantage: (1) an end user’s ability to select, access, and use the Broadband Services; (2) the lawful content, applications, services, or devices   of the end user’s choice; or (3) an edge provider’s ability to make lawful content, applications, services, or devices available to end users.

 

What practices have SmartLess Mobile adopted to manage network security?

 

As an MVNO, SmartLess Mobile does not have the ability to manage the security of its Underlying Carrier’s network.  However, it is our understanding that our Underlying Carrier has implemented reasonable physical, technical, and administrative safeguards to help guard against a wide range of security threats.  Specifically, our Underlying Carrier proactively monitors network activity to help guard against a wide range of security threats, including viruses, botnets, worms, distributed denial of service attacks, spam, and other harmful activity.  Our Underlying Carrier also takes steps to neutralize identified threats  .  SmartLess Mobile uses industry-accepted security measures to secure out network.  Despite these security practices, SmartLess Mobile cannot guarantee that you will not encounter unwanted, harmful, or malicious Internet traffic while using our Broadband Services or that information, during transmission through the Internet, while stored on our system, or otherwise in our care, will be safe from intrusion by others, such as hackers.  We encourage you to adopt your own reasonable security practices.  For additional information on our network security, please refer to the Service Security and Optimization section of out Terms and Conditions.

 

Does SmartLess Mobile restrict the types of devices that customers can use with its Broadband Services?

 

SmartLess Mobile customers may use any 4G or 5G-capable devices of their choice with our Broadband Services, so long as the devices are compatible with and do not harm or interfere with the networks of our Underlying Carrier and comply with all applicable laws, rules, regulations, and standards.  

 

What is geolocation data, and does SmartLess Mobile collect or share my geolocation data?

 

Geolocation data is generally understood to be subscribers’ real-time location information or other information used to determine a subscriber’s physical location when using SmartLess Mobile’s services. As an MVNO, SmartLess Mobile does not collect, store, use or share subscriber geolocation data, except to the extent that such information is included on records reported from our Underlying Carrier.  Our Underlying Carrier may use and collect geolocation data as needed to support the services we provide to you.  Our Privacy Policy, located at www.smartlessmobile.com/privacy-policy outlines SmartLess Mobile’s privacy practices in detail including any that relates to Geolocation Data.

 

While SmartLess Mobile does not collect, use, or share Geolocation Data other than described above, please be aware that applications on your SmartLess Mobile device could collect and share data; please visit those applications’ Terms and Conditions, Privacy Policies, and other documentation to determine data collection and sharing by applications you access on your SmartLess Mobile device.   

 

Back to top of page


 

Network performance characteristics

 

What factors affect the performance of SmartLess Mobile’s Broadband Services?

 

Although our Underlying Carrier engineers and manages its network to provide optimal performance to all users and user types, including   based on average and anticipated peak usage of the network, the end-to-end performance of our Broadband Services can depend on a variety of factors, many of which cannot be anticipated or are outside of our and our Underlying Carrier’s control, including: your location relative to our coverage area, your proximity to a cell site, the capacity of the cell site, the number of other customers connected to the same cell site, the number of customers simultaneously using the network, the services other users are using, topography, weather, obstructions, use inside a building or a moving vehicle, radio frequency interference, the capabilities of your device, the applications you are using, the server with which your device is communicating, the source or destination of your Internet traffic, overall traffic on the Internet, whether there are network outages, and applicable network management practices discussed above.  These factors can impact the availability of network resources for Broadband Services at any time.  

 

Additional factors not listed here may also affect service performance and availability.  

 

SmartLess Mobile is not liable for any service interruptions, degradation, or limitations resulting from the above factors, including but not limited to device incompatibility, network congestion, or roaming restrictions.

 

Note: Where roaming is available, wireless service is subject to the roaming provider’s terms and network availability which may change over time. Performance during roaming may differ from primary network coverage.

 

What performance can I expect from SmartLess Mobile’s Broadband Services?

 

SmartLess Mobile offers mobile broadband Internet access service using its Underlying Carrier’s 4G LTE and 5G networks.  The performance of broadband Internet access services is generally evaluated based on speed and latency.  Because, as described above, our reasonable network management practices and a variety of other factors can affect the performance of our Broadband Services, neither we nor our Underlying Carrier guarantee specific performance when you use our Broadband Services.   Additionally, the specific terms of your service plan may limit the amount of high-speed data included with your service plan and the actual speeds associated with data allocations included in your service plan.   Reduced network speeds may increase the latency you experience.

 

Speed

 

Speed reflects the rate at which Broadband Services can transmit data packets.  This capacity is typically measured in the number of kilobits, megabits, or gigabits that can be transmitted in one second (kbps, Mbps, or Gbps).  Some applications, like a short email without attachments or basic web browsing, do not require high-speed service to function optimally.  Other activities, like transferring large data files, can be performed faster with higher-speed services.   Applications involving real-time or near real-time, high bandwidth uses, such as streaming video or video conferencing, may require high-speed service to function optimally.

 

The maximum download speeds achievable on the network of our Underlying Carrier are typically between 79 – 357 Mbps for 5G devices and 13 – 61 Mbps for 4G LTE devices.  The maximum upload speed is typically between 6 – 30 Mbps for 5G and 2 – 11 Mbps for 4G LTE devices.  SmartLess Mobile provides its Services at speeds of at least 128 kbps download and upload, where the network will support such performance.  After you use your monthly high-speed data allotment included in your service plan, your data speed will be reduced for the remainder of the billing cycle, please check your service plan for details.  Customers can receive additional data by upgrading their service plan to one with a higher data allotment or by purchasing a data top-up.  

 

Latency

 

Latency is the time that a data packet takes to travel between two points on the Internet, usually expressed as the round-trip time in milliseconds (ms).  Some applications, such as email, can tolerate a substantial amount of latency without any noticeable impact on the application’s performance.   Other applications, such as real-time video conferencing, require lower latency to function properly.  Latency may increase as speeds are reduced.  The minimum round-trip latency achievable on the network of our Underlying Carrier is typically between 17 – 32 ms for 5G and 26 – 46 ms for 4G LTE devices.  



 Back to top of page


 

Commercial terms

Where can I find the rates and other fees that apply to SmartLess Mobile’s Broadband Services?

Descriptions of the rates and fees applicable to our Broadband Services are described in our service plan offers and in our Terms and Conditions, available on our website, www.smartlessmobile.com/terms-and-conditions. SmartLess Mobile does not charge termination fees and is not responsible for any termination fees that may be imposed by another carrier that ports your number to the SmartLess Mobile platform.

 

Where can I find the Terms and Conditions and Acceptable Use Policy that apply to SmartLess Mobile’s Broadband Services?

The Terms and Conditions (including our Acceptable Use Policy) can be found at www.smartlessmobile.com/terms-and-conditions  

 

What are SmartLess Mobile’s privacy practices for its Broadband Services?

SmartLess Mobile’s Privacy Policy for our Broadband Services is set forth in our Privacy Policy at www.smartlessmobile.com/privacy-policy

 

How can I get assistance if I have a question, concern, or complaint or need more information about SmartLess Mobile’s Broadband Services?

If you have questions or concerns about our Broadband Services, please contact us using the following information:

 

Chat: On www.smartlessmobile.com

 

Phone: 1-888-SMRTLSS (767-8577) or 611 from your Device during normal business hours: 
 

Hours of Operation: 5 AM - 7 PM PST, seven days a week.

 

 

Back to top of page