RingFree Mobility Inc. (the “Company”) is committed to ensuring the privacy of those who use our service (“User” or “You”), which is comprised of our website located at http://rf.com (the “Site”) and related software applications that enable You to make Internet calls using Your cell phone (“Service”). This Privacy Policy (“Policy”) describes what information is collected from Users and how that information is used and disclosed by Company. By using the Service, You consent to the terms of this Policy. The terms “we,” “us,” and “our” refer to Company.

Authorized Users

Children. The Service is not intended for children under the age of 13. For that reason, Company does not knowingly collect or maintain any information through the Service from persons under 13 years of age. IF YOU ARE UNDER 13 YEARS OLD, YOU MAY NOT REGISTER WITH, OR OTHERWISE PROVIDE PERSONAL INFORMATION TO THE SERVICE. Any persons who use the Service and provide their information to Company through the Service represent that they are 13 years of age or older.

Information We Collect

During Your use of the Service, Company may collect certain information, as follows.

Personally Identifiable Information

“Personally identifiable information” or “PII” means any information that identifies or may be used to identify, contact, or locate an individual to whom such information pertains, including email address, phone number, Your physical location, cell carrier account information, or other contact information.

Company collects PII when You register on and use the Service, including when You contact Company, (i) to set-up Your profile, including email and password, (ii) when the Service is activated by Company, including Your country of residence, Your cell service carrier, and Your telephone number, (iii) when You use the Service and Company routes Your calls, including call history, screen names of persons You call, Your ‘favorites’, and the caller ID of Your cell phone, or (iv) for support services or to provide Company comments for product improvement. When You use our Service, Company may also collect information about Your age, gender, and interests.

Non-Personally Identifiable Information

Aggregate Data. “Aggregate Data” is data that Company collects about a group or category of features, services or individuals, from which individual identities have been removed. For example, information about how a User uses a feature may be collected and combined with information about how others use the same feature, without any PII included in the resulting data.

Cookies. General User data, such as User’s computer’s Internet Protocol (IP) address, operating system and browser type, and the date and time of User’s visit, may be automatically collected through the use of “cookies” (small text files stored by a browser on a User’s computer to give User a unique identification). Cookies also keep track of services a User has used, record registration information regarding a User’s login name and password, record a User’s preferences and keep User logged into the Service. We use cookies to collect non-personally identifiable data to provide better and more relevant services and content to You. Cookies permit us to recognize users and avoid repetitive requests for the same information. Most browsers will accept cookies until You change Your browser settings to refuse them and opt-out of the use of cookies. However, some Company features will not function properly or at all if Your cookies are disabled.

You can find out how to disable cookies here – www.allaboutcookies.org/manage-cookies/

Web Beacons. Company may use, and allow third parties to use, web beacons on the Service to monitor the effectiveness of advertising or for other legitimate purposes. Web beacons are small, graphic images on web pages that allow Company or third parties to monitor who is visiting the Service. Web beacons collect the IP address of the computer that the web beacon is sent to, the URL of the page the web beacon comes from and the time it was viewed. Web beacons may be linked to User’s PII.

How Is Such Information Used/Shared?

We do not sell, rent or share PII with third parties without Your prior consent except in the limited circumstances described in this Policy. We use Your PII to provide the Service to You and to improve Company’s services and products. We may share Your personal information with third-parties (i) who assist us in performing internal functions necessary to operate our business (including without limitation analyzing data and providing marketing assistance); (ii) when doing so is appropriate to carry out Your request; and (iii) if Company reasonably believes that doing so is legally required or is in Company’s interest to protect its property or other legal rights or the rights or property of others. We will also allow access to Your PII to our various partners such as Internet access providers and voice providers that sign up with the Service to allow such partners to manage User accounts that such partners share with the Company. For instance, a VOIP provider that participates in the Service will have full access to and the ability to add, modify and delete its customers’ data through the Service. We are not responsible for any information You provide to any third party vendors, and we encourage You to become familiar with their practices before disclosing information directly to them.

We do not share personal information with third parties for their direct marketing, advertising or promotional use without Your consent or except as part of a specific program or feature for which You will have the ability to opt-in.

Company uses Aggregate Data to help identify trends and understand needs of Users in order to provide better features and services. We share automatically collected and other aggregated non-personally-identifiable information with interested third parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Service.

Company may also use third-party ad servers or network advertisers to deliver ads to Users. These third-party ad servers may use cookies, web beacons or other technology to collect non-personally identifiable information about User’s visits to the Service in order to present advertisements that may be of interest to User.

In addition, information about our Users, including personally identifiable information, may be disclosed as part of any merger, acquisition, debt financing or sale of Company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of our business assets.

External Websites

Our Service may contain links to external websites. These are provided for Your convenience only, and we do not have control over the content or privacy and security practices and policies of such third party Services. Any personal information You provide on linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites before providing them with personal information.

Access to Registration Information

If You register, You will have access to Your email address and password and You may update or correct such information at any time by going to the log-in section of the Service. Company may retain Your registration and other information even after you choose to no longer use our Service.

Your registration information is accessible online only through the use of a password. To protect the confidentiality of Your personal information, You must keep Your password confidential. You are responsible for all uses of the Service by any person using Your password. Please advise us immediately if You believe Your password has been misused or otherwise misappropriated at support@rf.com.

Choice

If we propose to use PII for any purposes other than those described in this Policy and/or in the specific service notices, we will offer You an effective way to opt-out of the use of personally identifiable information for those other purposes. You can decline to submit PII to any of our services when requested or permitted to do so, but in that case Company may not be able to provide those services to You.

Security

We use reasonable security measures in an effort to prevent loss, misuse and alteration of information under our control. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Consequently, we cannot ensure or warrant the security of any information You transmit to us and You do so at Your own risk. Additionally, we have absolutely no control over the security of other Services You might visit, interact with or do business with.

If we learn of a security system breach, then we may attempt to notify You electronically so that You can take appropriate protective steps. By using the Service or providing personal information to us, You agree that we can communicate with You electronically regarding security, privacy, and administrative issues relating to Your use of the Service. Company may post a notice on the Service, if a security breach occurs. Depending on where You live, You may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw Your consent from receiving electronic notice), You should notify us.

Special Note to International Users

The Service is hosted in the United States. If You are a User accessing the Service from outside the United States, including the European Union or Asia, please note that You are transferring Your personal data to the United States, which may not have the same data protection laws. By providing Your personal data, You consent to:

The use of Your personal data for the uses identified above in accordance with this Policy;
The transfer of Your personal data to the United States as indicated above.

Policy Changes

We will modify this Policy if our privacy practices materially change. For changes to this Policy that may be materially less restrictive on our use or disclosure of personal information that You have provided to us, we will attempt to obtain Your consent before applying the Policy to Your personally identifiable information. Otherwise, we will notify You of such changes by posting the new policy on our Service and indicating the date it was last updated at the bottom of the Policy. We encourage You to review the Policy each time You visit our Service to see if it has been updated, in order to make sure You understand how personal information You provide will be used. Your continued use of the Service constitutes Your agreement to this Policy and any updates.

Additional Information

If You have any questions about this Policy, or the practices of or Your dealings with the Service, please email us at support@rf.com, or call us at +1 415 946 4091, or write us at:

Ringfree Mobility, Inc.
584 Castro St #850
San Francisco, CA 94114

Last Updated: January 27, 2011