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Privacy Policy and your Privacy Rights

Effective Date: January 01, 2,018

  1. General Information

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy and Your Privacy Rights (“Privacy Policy”) sets forth the privacy practices of Carta Corp., a Delaware corporation, and/or its subsidiaries and affiliates (collectively “Carta”) located in the United States. For the purpose of the following terms, references to “We”, “Us”, and “Our” include Carta and its affiliates, subsidiaries, agents, representatives, successors and assigns. We create a platform for you to monitor the top up cards for mobile phone air time, messages, and internet data you have purchased from Carta (the “Cards”), activate and/or deactivate Cards, receive messages from Carta, and send Carta messages. These offerings are defined under this Privacy Policy collectively and individually as Our (“Services”).

This Privacy Policy is applicable to all data collection by Carta and shall apply to you the user’s, a wholesaler and/or distributor of Cards and any business on whose behalf You act when you use our Services and/or Sites, (“You” or “Your”) use of this web portal, Your use of any affiliated third party Web sites that may contain a link to this Privacy Policy, to any pages, facilities, services, or capabilities accessible on or by any top-level Carta domain owned by Us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a “Site” and collectively the “Sites”), and the Services. 

This Privacy Policy shall apply strictly to user information collected in the United States. This Privacy Policy describes how Carta treats Your use of the Sites, including the collection, storage, transfer, sharing, disclosure and handling of Your personal information and Your use of Our Services.

By using Our Services, You acknowledge that You have read this Privacy Policy and consent to Carta’s privacy practices as described in the Privacy Policy, including Our use and disclosure of Your personal information for the purposes described below. You further affirm Your consent by submitting content or materials to or through Our Services.

We take the privacy of Your personal information seriously. If You have any questions or concerns about this Privacy Policy or Your personal information please contact Us directly at the email or mailing address listed in Section 3 (Contact and Electronic Communication).

  1. Changes and Updates to this Privacy Policy

Carta reserves the right to revise or update this Privacy Policy at any time, and You agree to be bound by those revisions or updates. Carta will notify You of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Effective” date on the Sites. Your use of the Sites thereafter constitutes Your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. This Privacy Policy is incorporated as part of the Web Portal Terms and Conditions for Wholesalers (which can be found at Portal Terms and Conditions for Wholesalers) (the “Portal Terms”) that apply with respect to Your use of the Sites and Our Services. If You do not agree to the terms and conditions of this Privacy Policy, including having Your personal information used in any of the ways described in this Privacy Policy, please do not provide Us with Your information or use the Sites or Services.

  1. Contact and Electronic Communication

By using Our Services or providing Your personal information to Us, You agree that We can communicate with You electronically regarding any legal, regulatory, technical, security, privacy and any administrative or consumer notification obligations that may be related to Your use of the Services. If you have any questions about this Privacy Policy or about Our Services related to the Privacy Policy, You can contact Carta by e-mail at activations@cartacorp.net

You may also contact Us at:

Carta

Attn: Ernesto Saavedra

esaavedra@cartacorp.net

  1. Types of Information Collected and How it is Collected

The types of information We collect from You when You access Our Sites or use Our Services are listed below. Carta may share both Your Information with its affiliates, subsidiaries, partners and other third parties, such as third parties who help operate the Sites and related databases. Use of such third parties is subject to the terms of use and privacy policies of those third parties. Carta is not responsible for the privacy practices of any other Web sites or third parties. You should review the terms of use and privacy policies that are posted on by those third parties, before using any services they provide. Carta accepts no liability for any information, products, advertisements, content, services or software accessible through these third party websites or for any action You may take as a result of linking to any such website. We collect information directly from You, through use of Our Sites or Services or from third parties that work with Carta to deliver Our Services.

  • Personal Information We Request From You

Certain areas of the Sites (e.g. creating a user account) will require You to provide personal information to Carta. That personal information may include Your name, phone number, e-mail address, mailing address, zip code, username, password, birth date, business name (on whose behalf you act when using the Sites and/or Services), business address, and business federal employment identification number. While it is Your choice whether to provide the requested information or not, We cannot provide certain Services You request if You do not provide the requested information. By submitting this personal information to Carta, You agree that Carta may use the information in accordance with this Privacy Policy, for example to provide You with the Services, adapt and improve Carta’s Services to better suit Your needs, and to meet regulatory or contractual requirements relating to the Services provided to You. If You do submit such personal information to Carta, Carta may share that information with third parties, in addition to using that information for the purposes for which it was submitted by You.

Carta may also use this personal information in other ways, such as to provide You with information about Services and offers that may be of interest to You, to seek follow-up from You about Your experiences with Carta or as otherwise disclosed to You at the point of collection. Where required, Carta will seek Your express consent to send such messages, including when sent by e-mail or other type of commercial electronic message. This consent is sought by Carta. You may withdraw Your consent by using the “unsubscribe” link located at the bottom of such messages You receive from Carta, or by contacting Carta as set forth in Section 3 (Contact and Electronic Communication).

Carta may share Your personal information with its affiliates, subsidiaries and partners and with other third parties. Additionally, to the extent required by applicable federal or state law, Carta may be required to disclose Your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. By submitting personal information to Carta, You give Carta permission to receive it, review it, edit it, store it and use it for the purposes described in this Privacy Policy.

  • Other Types of Information We Collect

Carta also gathers certain information about how You use Services, the use of Carta’s Sites, including the number of unique visitors, the frequency of visits, how users interact with the Sites, user experience preferences, IP address, and other information that may help Carta improve the user experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include, but is not limited to, the following:

Log Information

When You visit Carta’s Sites We automatically collect and store certain information in Our server logs. This type of information includes details of how You interacted with Our Sites, Services, or applications. It may include information such as: IP address, Unique Device Identifier, or CallerID / ANI (Automatic Number Identification) information, content of Web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; application usage activity, hardware information, hardware and system settings, browser type, browser language, the date and time of Your request, referral URL, etc.

Automatic Collection

Carta and its partners use cookies or similar technologies to analyze trends, administer Carta’s Sites, track users’ movements around the Site, and to gather demographic information about Our user base as a whole.

Cookies

A cookie is a small, data file that is managed by Your web browser or other application and stored on Your local system. Carta uses session and persistent cookies to, among other things, identify Your computer during a particular interaction and analyze Your behavior during a particular visit. Most web browsers provide You with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If You choose to decline cookies, You may not be able to fully use Carta’s Sites, Services, or applications.

Pixel Tags

Pixel tags, also known as web beacons, help Carta better manage user experience and content tracking. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by Carta or an affiliate organization. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but minimize distraction.

Third Party Data Sources

Carta may leverage external data sources in order to provide context and background on the users of its Sites, Services, or mobile applications in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

Do Not Track and Third Party Advertising Cookies

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify Web sites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most Web sites, including Carta Sites, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal. You can, however, make decisions about Your privacy and the advertisements You receive.

Some of the ads You receive on Sites are customized based on predictions about Your interests generated from Your visits to different Sites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising.

We partner with a third party to manage Our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide You advertising based upon Your browsing activities and interests. If You wish to opt out of interest-based advertising click here. Please note You will continue to receive generic ads.

As an alternative to the opt-out, You can also elect to block all cookies from first parties (such as Carta) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into Your browser software. Please note, however, that if You do decide to block cookies, some parts of Carta’s Sites may not function correctly.

  1. Retention and Deletion of Personal Information

Carta will retain Your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and Your consent to such purposes(s) remains valid after termination of Carta’s relationship with You. When personal information is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual.

  1. Use of Personal Information

In addition to any of the previously mentioned uses of personal information, Carta may use Your information collected on the Sites for such purposes as: (a) helping to establish and verify Your identity; (b) activating and maintaining Your account; (c) contacting You to offer Service updates and notices, promotional notices and other information about Services or other services available from Carta or its affiliates; (d) providing You with Services You have requested or authorized; (e) responding to Your questions, inquiries, comments and instructions; (f) improving the Sites by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, Service development and content improvement; (g) taking good faith steps to enforce terms and conditions; and (h) maintaining the security and integrity of the Sites and Carta’s systems.

  1. Sharing and Disclosure of Personal Information

Primarily, We may share or disclose Your personal information in the following instances:

  • To fulfill a service to You. For example, if You e-mail Us a question, We may use Your e-mail address to process Your request and respond to Your question.
  • To provide the Services to You. We will disclose Your personal information as necessary to provide you with the Services you have requested.
  • As set forth in a separate written agreement between You and Us.
  • To offer You products from Our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that We believe may be of interest to You, or to assist such parties for research, administrative, and/or business purposes. These parties are obligated by contract to only use the information they are provided for the purposes specified by Carta.
  • To unaffiliated third-party service providers, agents, or independent contractors who help Us maintain Our services and provide Us with other administrative services (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, and sending customer communications on Our behalf). Carta requires these service-related companies to contractually comply with the principles set out in the Privacy Policy, and require them to use such information only for the purposes for which it was provided to them.
  • To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on Us, and to protect and defend Our rights or property, including Our rights and property and Our services, or act in urgent circumstances to protect the personal safety of You and Our other visitors.
  • We may use anonymized or general information derived from the data We collect from You and aggregate it with information from Our other customers and visitors (“Non-Identifiable Aggregated Data”) for Our business purposes, including without limitation for analyzing customer needs and improving Our Services, and We will own all right, title and interest in any such Non-Identifiable Aggregated Data. Your data may be co-owned by third parties unaffiliated with Us.
  • To protect against fraud and potential fraud. We may verify the information You provide to obtain Our Services through third parties who are contractually prohibited from using any information We provide to them for any purpose not specified by Carta. In the course of such verification, We may receive additional personal information about You from such services. 
  • Legal Disclosure

We may disclose information about You and Your use of the services if We believe that such disclosure is reasonably necessary to: (i) comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding); (ii) protect or defend Our rights and/or property or the rights and property of others; (iii) enforce Portal Terms and/or this Privacy Policy; and (iv) respond to claims that the content(s) of a communication violates the rights of another.

Also, circumstances may arise where, for business reasons, We may decide to reorganize, or divest all or part of Our business through sale, assignment, merger, acquisition, bankruptcy proceedings, or We may acquire a new business. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business. 

  1. Your California Privacy Rights

Under California law, California residents may opt-out of our disclosing personal information about them to third parties for their marketing purposes. If you do not want Us to disclose information to other companies for their marketing purposes, please contact Us by any of the ways described in Section 3 (Contact and Electronic Communication). Pursuant to 1798.83 of the California Civil Code, residents of California have the right to request from a business with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information.

  1. People Under the Age of 18

The Services provided by Carta are not directed or available to persons under eighteen (18) years of age. If You become aware that Your child, who is under eighteen (18) years of age, is accessing the Services and providing personal information without Your consent, please contact Us by using the information provided in the Contact and Electronic Communication section of this Privacy Policy. Carta will take steps to remove the child’s personal information from Carta’s data collection systems and terminate Your child’s account should Carta determine that a child under eighteen (18) has accessed the Services.

  1. Security of Information

Information submitted via the Internet, including through a Web page, mobile application, or e-mail is subject to interception or incorrect routing, and the Internet is not a fully secure communications channel. Please consider this prior to submitting any information to Carta via the Sites. While Carta follows generally accepted industry standards to protect the information submitted to Us, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while Carta strives to use commercially acceptable means to protect Your personal information, Carta cannot guarantee its absolute security. 

  1. International Users

If You are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law. Please note that You are transferring information about You, including personal information, to a country and jurisdiction that does not have the same data protection laws as the European Union or the country you are visiting from. You consent to the transfer of information about You, including Your personal information, to the U.S. and the use and disclosure of information about You, including Your personal information, as described in this Privacy Policy.

  1. Monitoring and Enforcement

Carta has implemented various measures to monitor compliance with and enforce the elements in this Privacy Policy. If You have a privacy related inquiry, complaint or dispute, please contact Us at the postal or e-mail listed in Section 3 (Contact and Electronic Communication) of this Privacy Policy.

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