Privacy policy

Last Updated: June 9th, 2025

Introduction and overview

The website https://www.smartlessmobile.com website (this “Site”) and the SmartLess Mobile Services are provided by SmartLess Mobile LLC (“SmartLess Mobile”, the “Company”, “we”, “our”, or “us”).  The following sets forth the Privacy Policy (the “Privacy Policy” or “Policy”) of SmartLess Mobile with respect to the information collected through the Site, our mobile application (“App”)  or otherwise from SmartLess Mobile customers and Site users, and is incorporated into and made a part of the SmartLess Mobile Terms and Conditions and Agreement to Arbitrate Disputes and Judge or Jury Trial Waiver (the “Terms and Conditions”), available at https://www.smartlessmobile.com/terms-and-conditions. To the extent that any provision or clause in our Terms and Conditions conflicts with any provision or clause in this Privacy Policy or a specific service plan we offer, the terms of those more specific documents will govern.  

Your privacy is important to SmartLess Mobile, Accordingly, SmartLess Mobile provides this Policy so that you understand how SmartLess Mobile collects, uses and, in certain circumstances, shares the information that you provide and/or that is automatically provided to SmartLess Mobile when you interact with the Site, use our App, or purchase or use SmartLess Mobile products or services (“Services”).

This Privacy Policy applies to you and anyone who (a) visits the Site or installs our App; b) applies for SmartLess Mobile Services; (c) uses our Services under your account; or d) otherwise provides us with Personal Information.  This Privacy Policy also explains the steps SmartLess Mobile 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 this Site, installing or using our App, or purchasing or using any SmartLess Mobile Service, you accept the practices described in this Privacy Policy.  SmartLess Mobile is not responsible for the content or privacy practices on any third-party website that may be linked to or from this Site.  Any questions regarding this Privacy Policy should be directed to our customer service department by dialing 611 from your Device, calling toll-free at 1-888-SMRTLSS (767-8577) or by accessing your account on www.smartlessmobile.com. 

Contents

1.   Definitions

2.   The personal information we collect

2.1   Personal information you provide directly to us
2.2   Personal information automatically collected from you
2.3   Personal information we receive from third parties

3.   How we use the personal information we collect about you

4.   How we share or allow access to your personal information

5.   How you might share your information with third parties

6.   Your rights and our obligations related to your customer proprietary network information

7.   How can you access or correct your personal information?

8.   Your advertising choices and consent options

9.   How we store, retain and protect personal information we collect about you, and how long we keep your personal information

10.  Governing law and notice to non-U.S. residents

11.   Information from children

12.  The application of various state privacy laws

13.  California resident privacy rights

13.1    Categories of personal information collected
13.2    Sources of personal information
13.3    Purpose of collection
13.4    Disclosures of personal information for a business purpose
13.5    Sale and sharing of personal information
13.6    Use and disclosure of sensitive personal information
13.7    California consumer privacy rights
13.8    Consumer requests and verification

14.   Nevada resident privacy rights

15.   Changes and updates to this privacy policy

16.   Our contact information

1.  Definitions

“Call Detail Information” means any information that pertains to the transmission of specific telephone calls, including, for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the number from which the call was placed, and the time, location, or duration of any call.   
 

“Device” means any phone, smartphone, tablet, accessory, or other device provided or sold to you by SmartLess Mobile or that you activate or use with our Services (note that certain functions are only available when using a voice enabled Device; tablets provided or sold to you by SmartLess Mobile are not voice enabled).
 

“Geolocation Data” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area.
 

“Precise Geolocation Data” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by law or regulation.
 

“Personal Information” is information that identifies you or is reasonably capable of being associated with or linked, directly or indirectly, with you or your household.  It does not include aggregate, de-identified, and/or anonymous information that is not reasonably capable of being associated with or linked, directly or indirectly, with you or your household.
 

“Services” means voice telephony (“Talk”), text messaging (“Text”), broadband Internet access services (“Data”), SIM card, embedded SIM (“eSIM”) (SIM card and eSIM, to the extent either technology may be available to you depending on your Device, your Service, and/or any other factor(s) in our sole discretion, are referred to interchangeably as “SIM,” “SIM Card,” and/or “SIM Kit”), and any other services provided to you by SmartLess Mobile, and prepaid wireless.  
 

“Underlying Carrier” means the wireless provider whose facilities we use to provide you wireless Services.

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2.  The personal information we collect

 We, our service providers, or contractors may obtain Personal Information about you when you visit our Site, use our App, contact us, and subscribe to and use our Services in the following ways: 

2.1  Personal information you provide directly to us

You may give us Personal Information, such as your name, email address, phone number, postal address, username and password, payment information, and communications you send to us.  For example, you may provide this Personal Information in the following circumstances:

Registration and Ordering. Before using certain parts of this Site or purchasing SmartLess Mobile Services, you must complete an online registration form or provide certain information to SmartLess Mobile’s representatives. During registration (whether via this Site or otherwise), you will be prompted to provide SmartLess Mobile with certain personal information, which may include, but is not limited to, your name, billing address(es), phone number, port-in phone number, email address, and credit card number.  This Personal Information is used for billing purposes, fulfilling your orders, and communicating with you about your order and this Site, and for marketing purposes.  If SmartLess Mobile encounters a problem when processing your order, it will use your Personal Information to contact you.

Other Contacts with Us.  When you contact us or we contact you, we and our vendors may monitor or record that communication for quality assurance, to train or support employees, resources or systems, and security purposes.  We may also collect information when you contact us on social media, open emails we send or interact with our ads, or register to receive news or updates.

Your Submissions to Us. Certain areas of this Site may permit you to enter your email address and other contact information to receive further information about SmartLess Mobile or for other purposes.  Your submissions for these purposes are completely voluntary, so you have a choice whether to participate and disclose information to SmartLess Mobile.  Should you choose to submit information in response to these requests, SmartLess Mobile may collect and publish your name, email address, geographic location and other information collected by SmartLess Mobile to market SmartLess Mobile Services.

2.2  Personal information automatically collected from you

We, our service providers, or contractors may automatically or passively collect Personal Information, such as Internet or other electronic network activity information and Geolocation Data, when you use or interact with our Services and our Site.

We collect information when you use our Services.  This includes information about the calls you make and receive, text messages you send and receive, when you visit our websites or use our app, and wireless network and device information, including location, Internet protocol (IP) address and connection speed, mobile telephone number, device and advertising identifiers, browser type, and operating system.  

We collect information using cookies and other tracking technology. In addition to the information that you volunteer as described above, we use tracking technologies, such as cookies, JavaScript tags and pixels. These technologies are industry standard used by most major web sites and are used to collect information, recognize you as a customer, improve your user experience, to help track usage on our web site, to study the effectiveness of our customer communications, to customize and personalize each visitors’ experience and to enhance our overall marketing effectiveness. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser, however, some areas of this Site may not function properly if you do so.
 

We may transfer your personal information collected through these tracking technologies to third-party service providers to help us analyze usage and to serve relevant advertisements. These providers may collect data on our behalf across the Internet in addition to on this web site. This information may be used to tailor marketing messages on this web site and other sites or to trigger real time interaction. This information may be collected through a web form automatically and prior to your pressing a submit button; and they may be able to use information from your visits to this site to send marketing messages to you in a way that may personally identify you. The information collected by these service providers may include your device’s IP address, user agent, email addresses (where hashed or otherwise rendered pseudonymous) and other user and device level pseudonymous information. Please keep in mind that your browser settings may not permit you to control the technologies utilized by these third-party companies.  If you would like more information about these practices, please click: http://optout.aboutads.info/#!/

Location-Based Services.  We use location information to route wireless communications and to provide 911 service, which allows emergency services to locate your general location.  We may disclose, without your 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.  Depending on your device, you may also be able to obtain a wide array of services based on the location of your device (for example, driving directions, enhanced 411 Directory Assistance or search results, etc.).  These data services, known as Location-Based Services (“LBS”) are made available by us and other entities, usually via applications.  These services use various location technologies and acquire location data from various sources.  These applications and services use various location technologies (including Global Positioning Satellite (“GPS”), Assisted GPS (“AGPS”), cell ID and enhanced cell ID technologies) to identify the approximate location of a device, which is then used in conjunction with the application to enhance the user’s experience (for example, to provide driving directions, to provide enhanced 411 Directory Assistance or search results, etc.).  LBS may, or may not, involve any interaction with or dependency on our Underlying Carrier’s network, and location-based services may or may not look to our network to obtain location data.  Where our Underlying Carrier allows third parties the capability of accessing data about your location that is derived from our Underlying Carrier’s network, our Underlying Carrier requires those third parties to observe specific privacy and security protections consistent with this policy.  It is important that you understand the location capabilities and settings of your device, and that you carefully read and understand the terms under which these services are provided – whether by us or another entity.  You should 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 we provide a location-based service, you will receive notice of the location features of the service and collection of location data is with your consent.  You will be provided with options for managing when and how such information should be shared.

2.3  Personal information we receive from third parties

We may obtain information about you and combine it with your account information. We collect information about you from various sources; including from companies that collect consumer information such as demographic and interest data, and lead information we receive from SmartLess Mobile Marketing programs.  In addition, if you access social media platforms, such as Facebook, Google, Instagram, Reddit or X, from our sites or apps, to log into our sites or apps, to share information about your experience or to interact with us, we may collect information from these third-party services.  
 

Please note that the information we may receive from those third-party sites is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform.
 

We may also collect risk scores and other indicators from companies that help us identify fraud.
 

We may combine the various types of Personal Information we receive from or about you, including information you provide to us, information we automatically collect, and information from other sources, and use it as described in this Privacy Policy.
 

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3.  How we use the personal information we collect about you

Generally, SmartLess Mobile collects the above information for the following purposes: (i) to improve your experience on this Site or in the App; (ii) to improve the Services that SmartLess Mobile sells to consumers; (iii) to communicate with you regarding this Site or our Services; (iv) to market and sell Services to you and send you information about and to determine your eligibility  for promotions and special offers; (v) to contact you about Services you have purchased from SmartLess Mobile; (vi) to respond to your inquiries; (vii) to manage and develop our business and operations, administer accounts, and collect and process payments; and (viii) if you authorize text messaging, we will use your mobile number to communicate with you about your account and to send marketing text messages to you.  
 

If you decide that you no longer wish to receive emails or text messages from SmartLess Mobile that you had authorized, you may opt-out of receiving emails and text messages by managing your account preferences on this Site or by any other reasonable opt-out method available to you.  Please note that SmartLess Mobile may have to communicate with you about product or service orders that you choose to place. You cannot opt-out of receiving product or service-related emails.  
 

SmartLess Mobile will not sell, rent, trade, license or otherwise disclose your specific Personal Information to third parties, except as noted below.  SmartLess Mobile may sell, rent, trade, license, use and disclose all non-Personal information and aggregate information, so long as such information does not personally identify you or any user, to any third party for any purpose, including, but not limited to, research and analytical purposes.  

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4.  How we share or allow access to your personal information

SmartLess Mobile may disclose your personal information to third parties, including in the following circumstances:

• SmartLess Mobile uses third party service providers to perform specific functions on its behalf, and it must disclose Personal Information to help those parties perform their services (for example, SmartLess Mobile would disclose your name, address and phone number to a commercial carrier such as Federal Express or UPS in order to deliver a physical product that you order, and it would disclose your name and credit card number and other information to financial services and credit card processing companies in order to process your orders).   These organizations are contractually required to treat your Personal Information as confidential and to use Personal Information only to provide the services we request of them.

   

• SmartLess Mobile may be required to disclose personal information in response to a legal process, order, or investigation (for example, a subpoena or court order).

   

• SmartLess Mobile may disclose personal information where disclosure is necessary or appropriate to protect its legal rights or to protect itself or others against fraudulent, malicious, abusive, unauthorized, or unlawful use of our Services; protect our network, databases, Services, Devices, users, and employees from physical or financial harm; and investigate violations of our Terms and Conditions or other contracts.

   

• SmartLess Mobile may share personal information among its affiliated companies (for example, for the purpose of marketing products and services to you). 

   

• SmartLess Mobile may provide identity verification services to third parties, and your personal information may be included in the data transferred to third parties in connection with those services. 

   

• In order to help protect customers and consumers from fraudulent use of our Services, we may share Personal Information or risk scores derived from such data with banks or other entities that provide us with fraud prevention services.

   

• SmartLess Mobile may acquire, merge with or be acquired by another company, or it might sell some or all of its assets, and, in such a case, your personal information may be included in the transferred business assets.  Also, in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, your personal information may be included in the transferred assets.

   

• SmartLess Mobile may disclose Personal Information to governmental authorities or other entities if we believe disclosure is necessary or appropriate, including: 

  • to protect against fraudulent, malicious, abusive, unauthorized, or unlawful use of our Services;
  • to protect our network, databases, Services, Devices, users, and employees from physical or financial harm; 
  • to investigate violations of our Terms and Conditions or other contracts;
  • to respond to subpoenas, court orders, search warrants, or other legal process;
  • to respond to requests for cooperation from law enforcement or other government entities, including pursuant to the Communications Assistance for Law Enforcement Act (CALEA), which may require that we monitor or facilitate monitoring and otherwise disclose the nature and content of communications transmitted through the Services or Devices without any further notice or liability;
  • to recover payment for previously billed Services;
  • to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to local, state, or federal governments and governmental agencies; and
  • in emergency situations involving danger of death or serious physical injury to you or any other person, to respond to 911 requests, and for other emergencies or exigencies.

   

• SmartLess Mobile may share your Personal Information with our affiliates, service providers, contractors, or marketing partners for our marketing and advertising purposes, including when we use our marketing partner’s analytic and advertising tools, such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies that automatically or passively collect Personal Information from your use of our Services.

   

   

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5.  How you might share your information with third parties

When using our Services, you may choose to install, access, or use services offered by third parties, such as websites and applications.  Please also refer to the Acceptable Use Policy inside our Terms and Conditions, available at https://www.smartlessmobile.com/terms-and-conditions.  In some cases, our Services may have links to websites operated by third parties, plugins for social media services, or third-party advertisements.  
 

When you interact with third-party services, you may be consenting to those third parties accessing, collecting, using, or disclosing your Personal Information through our Services or directing us to share or allow access to your Personal Information by those third parties, such as your IP address, browsing activity, or location information.  Those services operate independently of our Services, and your Personal Information will be governed by their terms and conditions, including their privacy policies, not this Privacy Policy.  We encourage you to review the privacy policies of any third-party services that you use to better understand their privacy practices.  You may be able to restrict or disable the use and disclosure of certain information, such as your location information, using settings available on your Device or through the third-party services.
 

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6.  Your rights and our obligations related to your customer proprietary network information

 CPNI is information made available to us solely by virtue of our relationship with you that relates to the type, quantity, destination, technical configuration, geolocation data, and amount of use of the telecommunications services you purchase from us, as well as information related to the billing for those services.  

Under federal law, you have the right, and we have the duty, to protect the confidentiality of your CPNI. When we share your CPNI with our service providers or contractors, we require them to take reasonable measures to protect the confidentiality of that information.  

We are permitted to use or disclose your CPNI for certain purposes without further notice or consent from you, including: to provide you with our Services; to market service offerings to you related to the services you purchase; to protect us, you, other subscribers, and other carriers from fraud, abuse, or unlawful use of the Services; and in an aggregate form.   We also may use your CPNI, or share it with affiliates and third-party agents, for the purpose of offering you communications-related products and services, packages, discounts, and promotions that may be different from the types of services you have already purchased.  

You have the right to opt out of the use of your CPNI for marketing purposes and can opt-out by adjusting your preferences in the marketing preferences section of your account page. Opting out will not affect our provision of Services to you or our use of your CPNI for permitted purposes.  If you choose to opt-out, your choice is valid until you choose to opt in.  You may also contact us to correct your CPNI or request that we disclose your CPNI to you.  

We will not disclose your CPNI except when provided with your password, and we may implement other authentication measures.  If you do not provide a password, we may not release your CPNI to you except by sending it to your address of record or by calling you at your telephone number of record.  Be sure to use a strong password with our Services and not one you use for other services.  We may disclose your CPNI to any “authorized user” that you have designated to us in writing or to any person who is able to provide us with your password.

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7.  How can you access or correct your personal information?

For existing SmartLess Mobile subscribers, you may access select Personal Information we have collected from you, such as your Contact Information, Payment Information, and Account Profile Information, by logging-on to your account at https://www.smartlessmobile.com. Once logged on, you will be able to access, modify, or correct this information. You can also request to access, modify, or correct this information by calling 1-888-SMRTLSS (767-8577) or by emailing us at info@smartlessmobile.com.  We will not disclose your Personal Information when you call us except when you provide a password.  If you do not provide a password, we may not release your Personal Information to you except by sending it to your address of record or calling you at your telephone number of record.  Be sure to use a strong password with your online account profile and not one you use for other services.  We may disclose your Personal Information to an authorized agent that you have designated in writing to us.

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8.  Your advertising choices and consent options

Google Analytics and Google AdWords.  We may use Google Analytics on our Sites to help us analyze traffic and improve services.  For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/.  You may opt-out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.  

Our Sites also use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site.  This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network.  Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our Sites.  Any data we collect will be used in accordance with this Privacy Policy, and Google is responsible to abide by its own privacy policy.  You can set your preferences for how Google advertises to you using the Google Ad Preferences page: https://adssettings.google.com.
 

Marketing Communications.  In accordance with our Terms and Conditions, you provide consent for us to contact you via email, voice call or text, including manual, autodialed, and prerecorded calls and texts.  You also provide consent for us to use CPNI for marketing purposes, as described in the Terms and Conditions. You may limit or revoke these authorizations as follows:

• Call us at 1-888-SMRTLSS (767-8577)
• Unsubscribe from our email communications following the unsubscribe instructions contained within our emails.
• Reply “STOP” to our text messages.

Your instructions to opt-out from these communications will be processed as soon as reasonably practicable. Please note that exercising a marketing opt-out will not affect the services you receive and will not affect our right to contact you about the services to which you subscribe, including notifications regarding compliance obligations related to those services.  

Do Not Track.  Because Do Not Track (“DNT”) and similar signals do not yet operate according to common, industry-accepted standards, our Services may not respond to DNT signals.
 

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9.  How we store, retain and protect personal information we collect about you, and how long we keep your personal information

We use technical, administrative, and physical safeguards to help protect against unauthorized access to, use or disclosure of Personal Information we collect or store.  In addition, we train our employees on the importance of privacy and security, as well as the proper ways to access, use or disclose customer information. Our practices and policies prohibit employees with whom we share this information from using sensitive information unless they are authorized to do so and have a business need. 
 

Our policies require that we retain records for as long as they are needed to provide you Services or for legal, tax, audit, investigative, and/or security purposes and then securely delete or destroy them.  
 

Although we strive to keep information secure, we can’t guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal information.  We use our security and incident response plans to handle such incidents.
 

We may assign you a user ID and a password when you as part of your participation and access to the Site and your account.  Only you may use your user ID and password.  You may not share your user ID and password with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password.  You are fully responsible for all activities that occur under your user ID.  You play a role in protecting your information as well.
 

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10.  Governing law and notice to non-U.S. residents

Our Services are solely intended for individuals located within the U.S.  and its territories and are subject to U.S. law.  If you are located outside of the U.S.  and its territories, please do not use the Services.  
 

If you do not reside in the U.S.  and provide Personal Information to us, please note that your Personal Information will be transferred, processed, collected, used, accessed and/or stored in the U.S.  and subject to U.S.  laws.  The laws in the U.S. may not provide the same protections for your Personal Information as the jurisdiction in which you are located.  Do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers.

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11.  Information from children

Our Services are not directed toward children, and we do not knowingly collect Personal Information from children under the age of 16.  
 

If you are a minor, please do not provide us with any Personal Information or use or access the Services without receiving your parent’s or guardian’s permission.  If we learn that we have collected any Personal Information from a child under the age of 16, we will take steps to delete the information as soon as possible.  If you believe that we might have any Personal Information provided by a child under the age of 16, or if you are a parent or guardian of a child under the age of 16 (that has provided us with Personal Information without your consent, please contact us via email at info@smartlessmobile.com or call us at 1-888-SMRTLSS (767-8577).
 

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12.  The application of various state privacy laws

We are not subject to the defined scope of many state privacy laws, such as the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) or the Connecticut Data Privacy Act (“CDPA”), and therefore the specific rights and obligations identified in these laws do not currently apply to us.  However, residents of these states may refer to these Privacy Policy provisions regarding our current data practices and may contact us regarding data inquiries or further information requests via the Our Contact Information section below.  We also recognize that privacy laws continue to evolve rapidly, so we are undertaking reasonable means to monitor developments in these laws and update our polices accordingly.

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13.  California resident privacy rights

This section explains how we collect, use, and disclose personal information about users, customers, and visitors who reside in California (“consumers” or “you”).  It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”).  This section uses certain terms that have the meaning given to them in the CCPA including personal information.  “Personal Information” for purposes of this Privacy Policy is as defined by applicable laws.  

The following section does not apply to individuals who do not live in California on a permanent basis, individuals who do not collect personal information about, or individuals for whom all of the information we collect is exempt from California laws.

13.1  Categories of personal information collected

We may collect information that falls into the above categories of Personal Information about you in The personal information we collect section above.

13.2  Sources of personal information

We may obtain Personal Information about you from the sources identified in The personal information we collect section above.

13.3  Purpose of collection

We may use your Personal Information for the business or commercial purposes described in the How we use personal information we collect about you section above.

13.4  Disclosures of personal information for a business purpose

We may disclose your Personal Information to a contractor or service provider for a business purpose.  
 

When we disclose Personal Information for a business purpose, we enter a contract that prohibits any such contractor or service provider from selling or sharing your Personal Information.  Any such contract requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for performing the contract.
 

We may disclose the categories of Personal Information about you for a business purpose as described in the How we share or allow access to your personal information section above.

13.5  Sale and sharing of personal information

The definitions of Personal Information, ‘share,’ and ‘sale’ under CCPA are broad.  The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.”  We may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content. Additionally, we may disclose your personal information to our service providers and contractors to provide service and with government authorities to ensure compliance.
 

We do not knowingly sell or share personal information related to children under 16 years of age.  
 

Specifically, we may share and use the following categories of Personal Information as follows:

13.6  Use and disclosure of sensitive personal information

We do not use or disclose sensitive personal information about you except as necessary to provide you with our Services, including processing and fulfilling orders and verifying your information, to prevent fraudulent or illegal actions, and for other purposes that are not for the purpose of inferring characteristics about you.
 

For purposes of this section, “sensitive personal information” is defined as:
 

Personal information that reveals:

• A consumer’s social security, driver’s license, state identification card, or passport number.

   

• A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

   

• A consumer’s precise geolocation.

   

• A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.

   

• The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

   

• A consumer’s genetic data.

   

• The processing of biometric information for the purpose of uniquely identifying a consumer.

   

• Personal information collected and analyzed concerning a consumer’s health.

   

• Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.  

13.7 California consumer privacy rights

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

• Right to Know: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
  • The categories of Personal Information that we collected about you;
  • The categories of sources from which the Personal Information was collected;
  • The business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information that we have collected about you;
  • The categories of Personal Information that we disclosed about you for a business purpose or shared with third parties; and

  • For each category of Personal Information identified, the categories of recipients or third parties to which the information was disclosed or with which the information was shared.

     

• Right to Delete: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.  

   

• Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of Personal Information described in Sale and sharing of personal information above.  

   

• Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.”  However, as described in Use and disclosure of sensitive information above, we do not collect or process Sensitive Personal Information for this purpose.

   

• Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.  
   

Under California’s “Shine the Light” law, California residents have the right to request in writing, once per year (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that we have disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties.  To request the above information, please contact us at personaldatarequests@smartlessmobile.com or by contacting 1-888-SMRTLSS (767-8577) with reference to California Disclosure Information.
 

To exercise your Right of Access, Right of Deletion, Right to Opt-Out, or Right to Correct, please visit our Personal Information Requests page or contact us as described in the Our contact information section below.   
 

You may exercise your Right to Opt-Out of Sale or Sharing that may occur through optional cookies on our Site by visiting our Do Not Sell or Share my Personal Information page, accessed through our footer on most of our web pages, and toggling the “Optional Cookies” switch to “OFF”. If you clear your cookies through your browser after opting out, you may need to opt-out again upon returning to this Site (as indicated by the banner that may appear). 
 

Global Privacy Control: SmartLess Mobile participates in a service called the Global Privacy Control (GPC) that allows you to set a “Do Not Sell or Share” preference at the browser level which will be recognized for residents of California. For you to leverage this service, you will need to have a GPC-enabled browser or browser extension that you can activate within the browser. Upon visiting a website, your browser will automatically send the site a “Do not Sell or Share” signal and our website will recognize the signal and honor your preference. To download a GPC-enabled browser, go to the Global Privacy Control Website. To check if our website received your signal, click on the “Do Not Sell or Share My Personal Information” link at the bottom of most web pages. If we receive your GPC signal, we will automatically opt you out of the sale of your personal information. When we’re detecting your active GPC signal, we will not allow you to opt back into the sale or sharing of your personal information. 

13.8  Consumer requests and verification

Right to Non-Discrimination

We do not discriminate against you if you exercise any rights described in this section.  

Verifying Requests

You may request to exercise your rights under this Privacy Policy by contacting us as described in the Our Contact Information section below.  To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request.  If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address.  When you make such a ` the following: 

• As required under applicable law, we will verify your identity.  You will need to provide us with your email address and full name.  We may ask for additional information if needed.

   

• We will confirm that you want your information accessed, corrected, and/or deleted.

   

• We will confirm our receipt of your request within 10 days.  If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.

   

• We will respond to your request within 45 days upon receipt of your request.  If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.

   

• In certain cases, a request for access, correction, or deletion may be denied.  For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order.  If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf.  You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf.  Your agent may contact us as described in the Our Contact Information section below to make a request on your behalf.  Even if you choose to use an agent, we may, as permitted by law, require:

• The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;

   

• You to verify your identity directly with us; or

   

• You to directly confirm with us that you provided the authorized agent permission to submit the request.

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14.  Nevada resident privacy rights

We comply with applicable requirements of the Nevada privacy law (Nevada Revised Statutes Chapter 603A), which in some instances provides Nevada residents with choices regarding how we use and share your personal information.  
 

Nevada Personal Information (“Nevada PI”) includes personally identifiable information about a Nevada consumer collected online, such as an identifier that allows the specific individual to be contacted.  Nevada PI also includes any other information about a Nevada consumer collected online that can be combined with an identifier to identify the specific individual.  
 

We may share such Personal Information with categories of third parties including federal and state regulators, subsidy program administrators, compliance and service support entities, and marketing entities.
 

Unaffiliated third parties outside of our control may collect covered information about your online activities over time and across different Internet websites or online services (via, e.g., “cookies”) when you use our Services.
 

You have the right to request that we not sell your Personal Information.  Although we do not currently sell Personal Information, you may submit a request directing us to not sell Personal Information if our practices change in the future.  To exercise this right, you may contact us using one of the methods described in the Our Contact Information section below.
 

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15.  Changes and updates to this privacy policy

We reserve the right to modify this Privacy Policy at any time.  When we do, we will post the changes on this page.  We will give you notice of any materially adverse changes to this privacy policy and may give you notice of all other changes but reserve the right to make such modifications immediately if required.  It is your responsibility to regularly check this page to determine if there have been changes to the Privacy Policy and to review such changes.  
 

The most current version of this Privacy Policy can be viewed by visiting our website and clicking on “Privacy Policy” located at the bottom of the pages.  Any changes will take effect immediately.  The effective date of this Privacy Policy is stated above.  Continued access or use of our Services following the effective date of any changes shall indicate your acceptance of such changes.  If you do not agree to the modified provisions of this Privacy Policy, you must discontinue your access and use of the Services.

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16.  Our contact information

If you have any questions or concerns about this Privacy Policy or how we treat your Personal Information, 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.

If we are unable to resolve your issue, you may file an informal consumer complaint with the FCC at 888-CALL-FCC (888-225-5322), or at https://consumercomplaints.fcc.gov/hc/en-us.  

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