In the preceding 12 months, we have collected the following categories of personal data:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers such as signature
• Internet or electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement
• Geolocation data
• Audio, electronic, visual, or similar information
• Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and personal attributes
• Account data including email, account user name, account password, phone number, company name
• Customer Data as defined in the Terms of Service
• Device information
• Web server access log data
• Credit card or payment information (credit card numbers are provided by you directly to our payment provider without being handled by Company)
• Details on how you use or intend to use Company Services and business requirements
• URLs that can be invoked to communicate with customer applications
• The IP address sending requests to Company Services or receiving requests from Company Services
• Phone numbers
• Actions performed by you while using Company Services, including dashboard actions
• Call detail information and your end users’ telephone numbers that you pass on to us
• Company product usage information

We collect personal data directly from you, automatically from your use of our products and Services, from unaffiliated parties, and by using or combining personal data to derive additional personal data about you.

Some information, such as account information, you provide us through our portal or through a request to Company Support. We also collect some information automatically, such as product usage data, which is collected via tracking technologies, such as cookies and web beacons (to help us understand how customers are using our web portal and products so we can improve your navigation experience) and via application and system logging (to track IP address, device information, operating system, browser ID, and a risk score). Some information is collected via third parties, such as a risk score based on device and browser information collected when users sign up for the service.

We may share your data for the following purposes.

• Credit card payment information is collected by our payment processors, which share that data with us.
• Device/browser information at the time of enrollment is shared with third-party risk assessment providers to protect our platform and its users from attacks, fraud, and other abuse.
• Some data is shared with and received from telephony operators to the extent necessary to route and connect communications from the sender to the intended recipient. How those telephony operators handle the data is generally determined by those operators’ own policies and local regulations.
• When necessary, we may collect and share your address with telecommunications carriers from whom we’re requesting phone numbers for your use.
• Some data is shared with and received from third-party fraud prevention and security service providers to protect Company customers from malicious activity.
• To acquire an SMS short code on your behalf.
• We may access and disclose information to law enforcement officials, including the content of communications, if: (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or government request; (ii) to enforce our agreements and policies; (iii) to protect the security or integrity of our services and products; (iv) to protect ourselves, our other customers, or the public from harm or illegal activities; or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.
• Company may share data with its affiliated companies or third-partycompanies that provide and support the Services.

We apply appropriate security controls to protect the privacy of your data both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

You can access and make changes to certain account data via the account portal. You will also be able to access call detail information collected about usage of the services.

You may request deletion of your Company account and its data. You should know that deletion of your Company account will result in you permanently losing access to your account and all Customer Data to which you previously had access through your account.

Please note that certain data associated with that account may nonetheless remain on Company’s servers. For instance, call detail records and billing information will be retained. Similarly, data associated with your account that we are required by law to maintain will not be deleted. Data may also be retained in an aggregated or anonymized form that does not specifically identify you.

To request deletion of your Telekit account, email us at support@telekit.com. Or, if you prefer, please write to us at:

Vail Systems Attn: Telekit, 570 Lake Cook Road STE 400 Deerfield, IL 60015

Our site uses cookies and similar technologies to keep customers logged in and to track how customers use our portal and sites. A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.

Use of these tracking technologies enables us to provide personalized information, to remember product preferences, to keep our sites running efficiently, to help you obtain information you need and to provide a secure environment for transactions. Do-not-track signals are web browser settings that request that a web application disable its tracking of an individual user. At this time, our site does not respond to do-not-track signals and similar mechanisms.

Company uses certain trusted third parties to help us provide, improve, promote, and protect the services we provide. These third parties may access, process, or store your information to perform tasks only for the purposes we’ve authorized and we require them to provide at least the same level of protection for your information as described in this Privacy Policy. We may also share with third parties aggregated or anonymized data that does not directly identify you.

Company websites may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by Company Services and websites.

Because the Company is 100% committed to you, we want to explain what the “Do Not Sell My Personal Information” link on our webpages means. We provide this link to comply with the California Consumer Privacy Act (“CCPA”), which is a data protection law that provides California residents with certain choices about their data, including the ability to tell companies not to “sell” their personal information. The link is included on our webpages to inform you of this choice.

We do not sell your personal information. However, because the CCPA broadly defines “sell” and “personal information” in a way that the ordinary flow of information, or the analytics routinely performed on such information, could be construed as a “sale”, we provide this notice and inform you of your rights.

The CCPA provides California residents the following rights:

• The right to know about the personal information a business collects aboutthem and how it is used and shared;
• The right to delete personal information collected from them (with some exceptions);
• The right to opt-out of the sale of their personal information; and
• The right to non-discrimination for exercising their CCPA rights.

Right to Know: As a California resident you may request that we disclose to you what personal information we have collected, used, shared, or sold about you during the 12 months before your request, and why we collected, used, shared, or sold that information. Specifically, you may request that we disclose:

• The categories of personal information collected;
• Specific pieces of personal information collected;
• The categories of sources from which the business collected personal information;
• The purposes for which the business uses the personal information;
• The categories of third parties with whom the business shares the personal information; or
• The categories of information that the business sells or discloses to third parties.

Right to Delete. As California resident you may request that we delete personal information we collected from you and to tell our service providers to do the same. However, there are exceptions that allow us to keep your personal information, suchas where retention of personal information is necessary to:

• Complete the transaction for which the personal information was collected,provide a good or service requested by you, or reasonably anticipated within the context of the Company’s ongoing business relationship with you, or otherwise perform a contract between the Company and you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, which we understand you consent to absent a written notice to the contrary by you;
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company;
• Comply with a legal obligation; or
• Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Opt-Out or "Do Not Sell" Choice". As a California resident you may request that we stop selling your personal information (“opt-out”). With some exceptions, we cannot sell your personal information after we receive your opt-out request unless you later provide authorization allowing us to do so again. We must wait at least 12 months before asking you to opt back in to the sale of your personal information.

Right to Non-Discrimination. As a California resident you cannot be denied goods or services, charged a different price, or provided a different level or quality of goods or services just because you exercised your rights under the CCPA. However, if you refuse to provide your personal information, or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. If you ask us to delete or stop selling your personal information, you may not be able to continue participating in any special deals we offer in exchange for personal information.

How do I submit my request? If you are a California resident and would like to exercise any of your rights, please contact us at our email privacy@vailsys.com with “Privacy Request” in the subject line. Or, if you prefer, please write to us at:

Vail Systems, Inc. Attn: Telekit Data Privacy 570 Lake Cook Road STE 400 Deerfield, IL 60015

Please note the following on personal information requests by California residents:

1. You may only make a personal information request twice in a 12-month period;
2. Company will need to collect information from you to verify your identity;
3. If the Company cannot verify your identity, we may deny your request and inform you that we were unable to verify your identity; and
4. Company will respond within 45 days of receiving a personal information request.

We do not knowingly collect any personal information directly from children under the age of 13. If we discover we have received any information from a child under the age of 13, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about a child under the age of 13, please contact us at compliance@vailsys.com

In the event of any sale, merger, reorganization, restructuring, dissolution or similar event involving our business or assets, personal data may be part of the transferred assets.

If you have any complaints regarding our compliance with this privacy policy, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this privacy policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please see our Terms & Conditions for further information.

We may update this Privacy Policy as necessary to reflect changes we make and to satisfy legal requirements.

If we decide to make changes to our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and underwhat circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted.

In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our website notifying users of the change. In some cases where we post a notice, we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

If you have questions or concerns regarding this statement, you may send an email to support@telekit.com with “Privacy Policy Inquiry” in the subject line. Or, if you prefer, please write to us at:

Vail Systems Inc. Attn: Telekit,

570 Lake Cook Road
STE 400
Deerfield, IL 60015

This Acceptable Use Policy (“AUP”) is incorporated by reference into and governed by the Company Terms of Service (“Terms”). This AUP describes actions that Company prohibits when any party uses the Company Services. Capitalized terms that are not defined in this AUP are defined in the Terms, and the Terms take precedence over any conflicting provisions in this AUP. You, the Customer, may not use Company Services without agreeing to this AUP. Thus, you agree not to use, and not to encourage or allow any End User to use, the Services in prohibited manners, including but not limited to the following:

1. Using the Services to encourage any illegal, abusive, or other activities that interfere with the business or activities of Company.
2. Using the Services in a way that could damage or overburden the Services or interfere with other users’ use or enjoyment of the Services.
3. Attempting to bypass or break any security mechanism on any of the Services or using the Services in any other manner that poses a security or service risk to Company or any of its users.
4. Reverse-engineering the Services in order to find limitations, vulnerabilities, or evade filtering capabilities.
5. Using the Services in any manner that may subject Company or any third party to liability, damages, or danger.
6. Launching or facilitating, whether intentionally or unintentionally, a denial of service attack on any of the Services or any other conduct that adversely impacts the availability, reliability, or stability of the Services.
7. Transmitting any material that contains viruses, trojan horses, worms or any other malicious, harmful, or deleterious programs.
8. Using the Services in any manner that violates: industry standards; any third party policies including all of the applicable guidelines published by the CTIA, the Mobile Marketing Association, or any other accepted industry associations, carrier guidelines (or any similar or analogous industry standards, third party policies or requirements in any other jurisdiction); or requirements that Company may communicate to its Customers including any usage requirements.
9. Engaging in any unsolicited advertising, marketing or other activities, including any activities that violate anti-spam laws and regulations including the CAN SPAM Act of 2003, the Telephone Consumer Protection Act, and the Do-Not-Call Implementation Act (or any similar or analogous anti-spam, data protection, or privacy legislation in any other jurisdiction).
10. Using the Services in connection with any unsolicited or harassing messages (commercial or otherwise) including unsolicited or unwanted phone calls, SMS or text messages, voice mail, or faxes.
11. Using the Services to harvest or otherwise collect information about others, including email addresses or phone numbers.
12. Using the Services to engage in or in connection with fraudulent activity.
13. Using the Services to receive, send or otherwise process Protected Health Information as defined by the Health Insurance Portability and Accountability Act of 1996 as amended, (“HIPAA”), except in compliance with HIPAA and the HIPAA rules.
14. Violating or facilitating the violation of any local, state, federal, or foreign law or regulation, including laws and regulations regarding the transmission of data or software.
15. Taking any action to participate in, encourage, or promote any activity prohibited under this AUP or the Terms.
16. Using the Services to transmit any material that infringes the intellectual property rights or other rights of third parties.
17. Using the Services to transmit any material that is libelous, defamatory, discriminatory, or otherwise malicious or harmful to any person or entity.
18. Creating a false identity or forged email address or header, or phone number, or otherwise attempting to mislead others as to the identity of the sender or the origin of a message or phone call. Using the Services, or any component of the Services, in any manner not authorized by Company.

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