TRUSTe

Effective Date: December 2022

Introduction

Our Privacy Policy describes the information that we collect, how it’s used, shared, and retained, your choices about how it’s used and shared, and your rights under certain privacy laws. This policy applies to all TracFone brands including Total by Verizon, Straight Talk Wireless, Tracfone, Simple Mobile, SafeLink Wireless, Walmart Family Mobile, Net10 Wireless, Page Plus, GoSmart Mobile, and Clearway Wireless for Business. TracFone is a Verizon company.

When you use our websites and services you are subject to this Policy and the terms and conditions of the service associated with your brand. We do not require you to provide personal information to us to enjoy some of our services. However, if you do not provide certain personal information, you may not be able to use or access portions of our websites, such as the account features or account information.

Categories and Types of Personal Information We Collect

We, and service providers acting on our behalf, collect information when you purchase and use our products and services and when you interact with us. Depending on the products and services you use, the personal information we collect may include:

If you are referred to TracFone by your Health Maintenance Organization (HMO), we share your mobile number with the HMO provider. If a child or other beneficiary is the qualifying recipient for the Lifeline Assistance Program, we will also collect the child’s or other beneficiary’s name, date of birth, and partial Social Security number to verify their eligibility in the program.

How We Collect Personal Information

We collect information from you when you interact with us and use our products and services, including information about how you use these products and services and our websites, when you make a purchase, or when you establish or modify an online account. We also collect information when you interact with our customer service representatives or use our websites or apps to place an order or ask questions about your account or service; seek technical support; contact us on social media; enter a TracFone-sponsored or affiliate contest; participate in surveys; sweepstakes or promotions; refer a friend or respond to a referral; or participate in our rewards program. When you communicate with us, we may monitor or record the interaction to help us better serve you; to personalize your experiences; to train or otherwise support employees, resources or systems; and for fraud detection and security purposes. We may use artificial intelligence guided by humans, such as chat bots, to respond to your inquiry. When you interact with us through third-party services like Facebook Messenger or Twitter Direct Message, your communications are also governed by these companies’ privacy policies.

Some devices may have pre-installed applications that are used by us and our partners to collect network strengths, performance, coverage, and quality, as well as for marketing purposes. Additionally, these applications may collect information regarding your device, such as device identifiers, features, and software versions installed, for campaign management such as push notifications or to preinstall certain applications. Some apps installed or updated on your device in this way do not appear as icons on your device screen because of their limited utility. To see what apps are installed on your devices, use your device app controls in the settings menu on your device.

We and our partners also automatically collect information about your use of our sites or apps using cookies, pixels, web beacons, scripts, and other similar technologies. We use the information collected in this way to analyze trends, administer websites, analyze users’ movements around our websites, and to gather demographic information about our customer base as a whole. We and our partners also use these tools to collect and store information about our users. You can control the use of cookies using browser controls, but if you choose to disable cookies, you may limit your use of certain features or functions on our websites or services.

How We Use Personal Information

TracFone uses personal information to:

Interest Based Advertising. We and our advertising partners use cookies and similar technologies to help tailor the ads you see on our sites and to help make decisions about ads you see on other sites. These companies may place and access cookies, pixels, tags, web beacons and scripts, or use similar technologies, on our pages and the browsers you use and may access advertising identifiers from your mobile device operating systems. These companies employ these technologies to determine whether you fall into an audience advertisers wish to reach and measure advertising effectiveness. If you wish to not have this information used for the purpose of serving you cross contextual targeted ads you may opt out using the NAI’s interest-based advertising opt out. Please note that by “opting out,” you will no longer receive targeted advertisements but may continue to receive general advertisements.

Analytics. We use mobile analytics software to better understand the functionalities of our mobile software on your phone. This software may record information such as how often you use an application, the events that occur within an application, aggregated usage, performance data, and location where an application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within a mobile application.

De-identified and aggregated information. We may also de-identify or aggregate information so that we or our affiliates may use it for business and marketing purposes. For example, the data we aggregate might be used to analyze, personalize and improve our services. We may de-identify your CPNI and, if we do so, we will maintain and use the data in a non-individually identifiable form and will not attempt to re-identify the data.

How We Share Personal Information

We share information within TracFone and with other Verizon companies for a variety of purposes, including providing you the latest information about our products and services and offering you our latest promotions. We will not share Customer Proprietary Network Information (CPNI), which relates to the type, quantity, destination, technical configuration, location, amount of use and related billing information of your wireless services, with Verizon for them to market services that are different from the ones you have without giving you an opportunity to opt out. We will also not share certain credit information, such as credit scores, your account history and information in your consumer reports, without giving you an opportunity to opt out.

We share information with vendors and partners. We use vendors and partners to perform services on our behalf, such as marketing, fulfillment services, shipping to customers and to help us offer, provide, repair, restore and bill for services. We will require that vendors and partners protect and restrict use of personal information consistent with the terms described in this Policy. Your wireless number may be shared for text messaging services operated by vendors. These vendors may directly contact you on our behalf by text messages with promotions, discounts, advertisements, reminders related to your services, or other information that may be helpful or informative to you. You can opt out of these messages using the mechanism provided.

When you purchase or use services that are offered by TracFone and one of our partners, both parties may receive information. When this is the case, you should also review the partner company’s privacy policy because it may describe uses of information that are different from ours.

We also share de-identified information with companies to assist with the delivery of advertising campaigns or aggregate reports.

We may further share customer personal information in the following situations:

Walmart Family Mobile Customers. If you are a Walmart Family Mobile customer, we work with Walmart Stores, Inc. ("Walmart") to offer the Walmart Family Mobile service. Any information you provide directly to Walmart will be subject to Walmart's Privacy Policy, not this one. This includes information you provide to Walmart in connection with your device purchase, upgrade, return, or replacement, whether in its stores, by phone or online, including but not limited to, if you purchase a Family Mobile device or obtain technical support for the device at or from Walmart or its agents. In addition, if you activate Walmart Family Mobile communications services at a Walmart store, Walmart may request personal information from you that is passed to TracFone as part of the activation process, but which may also be retained by Walmart. You can learn more by visiting Walmart's Privacy Policy.

Software Application for Our Websites. TracFone also works with other companies who supply software applications for use on our websites. The software is used to collect survey or feedback information or support real-time chat sessions from customers who visit our websites and utilize these tools. Information from your web session, including your device serial number, phone number, and account email may be associated with your responses when you use these tools. This information is used by TracFone exclusively for analysis of survey or feedback results and will not be shared with any third party for any other purposes.

How Long We Retain Personal Information

We retain personal information as long as it is needed for business, tax, and legal purposes. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How You Can Opt Out of Email Marketing

We may send you emails regarding promotional offers or other news. You can always choose not to receive our email direct marketing communications by opting-out or unsubscribing. You can do this by clicking on the unsubscribe link found at the bottom of every email promotion we deliver. Upon such election and within a reasonable time thereafter, we will not email you directly with promotional messages though you may see marketing messages from TracFone in other forms and directed at a general audience.

How We Secure Personal Information

We use administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process. Nonetheless, we cannot guarantee personal information will be perfectly secure at all times. Our security controls are designed to maintain data confidentiality, maintain data integrity, and give us an appropriate level of access to your data. For example, when you enter sensitive personal information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). If you have any questions about security on our websites, you can contact us at [email protected].

Links to Other Websites

Third Party Links. Our websites may contain links to other websites that are not owned, operated, or controlled by us. Any personal information collected by such third-party websites is not governed by this Policy. We recommend that you examine the privacy policies of such third-party websites prior to submitting any personal information.

Third-Party Websites. In some instances, our websites’ content is also featured on other websites with differing or non-existent privacy policies. These websites may collect personal information from website visitors that may or may not be used in conjunction with our website information. Prior to supplying personal information to any third-party company linking to our website, please read and understand their privacy policies.

Policy Regarding Information Obtained from Children

Our websites are not structured to attract children under the age of 13. We do not knowingly collect information, directly or passively, from children under the age of 18. Ordering online products and services from TracFone is limited to adults (ages 18+). Of course, wireless devices and services purchased for family use may be used by minors without our knowledge. If that happens, any information collected from the usage will appear to be the personal information of the adult subscriber and treated as such under this Policy.

Advertisements

Advertisements may appear on pages throughout our websites. Some advertisements may request information directly from our customers or take our customers to websites that may request personal information. We have no control over our advertisers' privacy policies, so please examine the privacy policy of any company advertising on our websites prior to submitting any personal information.

Public Forums/Blogs

Our websites may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You should not provide personally identifiable information in any publicly accessible blog or community forum.

To request removal of personal information from our blogs and forums, contact us at [email protected], and we will do our best to comply with the request. In some cases, we may not be able to remove personal information, in which case we will let you know if we are unable to do so and why.

Refer-A-Friend

If you choose to use our referral service to tell a friend about our websites, we will ask you for your friend's name and email address and automatically generate a one-time email to send your friend inviting them to visit the site. If you use the “Import Contacts” feature, we may collect your friends’ names and addresses in order to administer TracFone’s Refer-A-Friend program. We do not store your friend's information or use it for any other purpose.

Gift Purchases

If you purchase a gift, we will ask you for the recipient’s name and mailing address in order to ship the product to the individual. We do not retain the recipient’s information or use it for any other purpose.

Social Media Features

Our websites include social media features and widgets, such as the "Share This" button or other interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policy of the company providing the feature or widget.

Surveys

Occasionally, we may conduct surveys on our websites. Surveys are conducted at random and are completely voluntary to our website visitors. The survey may require you to provide personal information in exchange for the information or services provided by the survey. We may use this information in an aggregate manner to better tailor the types of services, information, and advertising that are provided on our websites.

Mobile Applications

If you allow it, our apps may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you do not wish to receive these types of communications, you may turn them off using your device controls.

Geolocation

You may opt out of the collection and use of location for features offered in our apps at any time by editing the location services setting on your device.

How Customers and Visitors Can Access and Update Personal Information

You can verify your account and manage personal information, including deleting or changing certain personal information, by logging into your account on our website and going to the account profile or account information section.

If you are unable to log into your account, please contact a customer care agent by calling 1-800-867-7183. All requests for changes or deletion of account information require account verification by answering security questions or providing the Personal Identification Number (PIN) you set when you first activated your account.

In certain circumstances we may be required by law to retain personal information, or may need to retain personal information in order to continue providing a service.

California Privacy Rights

California consumers have certain rights as it relates to personal information under the California Consumer Privacy Act, as amended (CCPA). These rights include the right to request access to personal information, to request the deletion of personal information, to request correction of inaccurate personal information, and to say no to the sale and sharing of personal information. You will not be penalized or discriminated against if you exercise any of these rights.

Your Right to Know

We describe the personal information we collect and how we use it in this privacy policy. As detailed above in “How We Collect Personal Information,” we collect information from you when you interact with us and use our products and services.

Depending on what products and services you use and how you interact with us, we may collect these categories of personal information, some of which may be considered sensitive personal information under California law:

We incorporate personal information into different types of records, not always by distinct data elements. For example, your name could be part of your customer account record, transaction record, or call records. Our policies require that we retain records for as long they are needed for legal, tax, audit, investigative, and/or security purposes and then securely delete or destroy them.

We use this information for business and commercial purposes and other purposes described in this policy as well as disclose it to third parties, such as vendors and partners and to law enforcement, among others, as detailed elsewhere in this policy. Business and commercial purposes include providing services to you; communicating with you and providing customer service; personalizing your experiences; improving our services; providing marketing and advertising; debugging; auditing our processes and services; short-term transient uses; research; and security, fraud, and legal compliance purposes.

We share information that identifies you with a partner who uses it to assist in your interactions with third parties. First, we may share personal information collected about you to confirm your identity when you are transacting with or signing into a third party service, such as your bank. Second, we may share personal information collected about you with third parties you are attempting to do business with to help make a credit decision on an application for service that you have submitted to a third party. We also allow select third parties to directly collect information about your activity on our websites and in our apps using cookies, mobile ad identifiers, pixels, web beacons, social network plugins and similar technologies to inform our and others’ cross contextual advertising. These activities may be considered selling or sharing personal information under California law. For information about how to opt out of these activities, and to learn more about TracFone’s selling and sharing activities, please visit our “Your Privacy Choices” pages linked in the “Your Right to Opt Out of Selling and Sharing Personal Information” section below. We do not knowingly sell or share personal information related to children under 16 years of age.

California law defines sensitive personal information as:

We do not use, sell, share, or disclose sensitive personal information for any purpose other than to provide the goods or services requested by you, with your consent, or for other purposes expressly authorized by California law, such as to detect security incidents.

Your Right to Access

Under California law, California consumers have the right to access the personal information we have about them. If you are a California resident, you or your authorized agent can log into your account and request access to personal information. If you do not have an account, you can submit a request to obtain, free of charge, an electronic, portable copy of personal information. Instructions on how to submit this request can be found below under “How to Submit Your CCPA Request.”

Verifiable Consumer Request. We take security very seriously so we will provide personal information only after you verify your identity through safe and secure means, which means using methods and information that are not publicly available. Also, we will honor up to two consumer rights requests every twelve months as required by California law.

Time to Provide Personal Information. We will endeavor to provide this information to you within 45 days, but it may take up to 90 days. If we need more than 45 days, we will contact you to let you know that we need additional time.

Your Right to Delete

California consumers also have the right to delete personal information. We are unable to delete information that is necessary to provide you ongoing service, for security purposes, that we are contractually obligated to retain, or that is necessary to comply with legal obligations. You or your authorized agent may submit a request to delete. Instructions on how to submit this request can be found below under “How to Submit Your CCPA Request.”

Your Right to Correct

California consumers have the right to correct inaccurate personal information that a business maintains about them. If you are a California resident, you or your authorized agent may submit a request to correct. Instructions on how to submit this request can be found below under “How to Submit Your CCPA Request.”

Your Right to Opt Out of the Sale and Sharing of Personal Information

California consumers have the right to opt out of the sale or sharing of personal information. The term “sale or sharing” is broadly defined to include sharing personal information for monetary or other valuable consideration and the sharing of personal information for cross contextual advertising purposes, but does not cover all sharing of personal information.

Our activities that fall under the definition of “sale or share” in the CCPA are:

To opt out of the selling and sharing of personal information, including for identify verification and credit inquiry purposes, please visit our Your Privacy Choices pages, available at:

How to Submit Your CCPA Request

If you wish to exercise your right to access, delete, or correct personal information, you or your authorized agent can make a request through your existing online account. If you do not have an existing account, you can submit a request by calling 1-877-799-1999 or submitting a request online at:

Your Right to Non-Discrimination

If you exercise any of your California rights, TracFone will not treat you differently such as by denying goods or services, charging a different price (including through discounts), or providing a different level of quality of goods or services.

Shine the Light

California Civil Code Section 1798.83 entitles California consumers to request, once per year, that we disclose the identity of any third parties to whom we have shared personal information for the third parties’ direct marketing purposes. If you wish to submit a request, you may write to us at [email protected] or call us at 1-877-799-1999.

Nevada Privacy Rights

Nevada law allows customers to opt out of the sale of their personally identifiable information by online service providers such as website operators. Nevada law defines "sale" as the exchange of certain personally identifiable customer information for money. Personally identifiable information includes name, address, phone number, SSN, or any identifier that can be used to contact you electronically.

TracFone doesn’t sell personally identifiable information today and we don’t have plans to start. If TracFone ever starts selling such personal information, current TracFone customers will be opted out. If you have any questions, please contact us at 1-877-799-1999.

Virginia Privacy Rights

Virginia consumers have certain rights as it relates to personal information. These rights include the right to know what information we collect about you and howe we use it; to access and delete certain information; to request that we correct information that you believe is inaccurate; to opt out of having personal information about you sold, used for targeted advertising, or used to build a profile about you to make legally or similar significant decisions about you; to have us not use sensitive data about you without your consent; to not be discriminated against for invoking these rights; and to appeal the denial of a request to exercise one of these privacy rights.

Your Right to Know

We describe the personal information we collect and how we use it in this privacy policy. As detailed above in “How We Collect Personal Information,” we collect information from you when you interact with us and use our products and services.

Depending on what products and services you use and how you interact with us, we may collect these categories of personal information, some of which may be considered sensitive personal information under Virginia law:

We use this information for business and commercial purposes and other purposes as well as disclose it to third parties, such as vendors and partners and to law enforcement, among others, as detailed elsewhere in this policy. Business and commercial purposes include providing services to you; communicating with you and providing customer service; personalizing your experiences; improving our services; providing marketing and advertising; debugging; auditing our processes and services; short-term transient uses; research; and security, fraud, and legal compliance purposes.

We may share information that identifies you with a partner who uses it to assist in your interactions with third parties. First, we may share personal information collected about you to confirm your identity when you are transacting with or signing into a third party service, such as your bank. Second, we may share personal information collected about you with third parties you are attempting to do business with to help make a credit decision on an application for service that you have submitted to a third party. This activity may be a sale of personal information under Virginia law. We also allow select third parties to directly collect information about your activity on our websites and in our apps using cookies, mobile ad identifiers, pixels, web beacons, social network plugins and similar technologies to inform our and others’ cross contextual advertising. This activity may be considered targeted advertising under Virginia law. For information about how to opt out of these activities, and to learn more about TracFone’s selling and targeted advertising activities, please visit our “Your Privacy Choices” pages links in the “Your Right to Opt Out of Selling Personal Information and Targeted Advertising” section below. We do not knowingly sell or share personal information related to children under 16 years of age.

Virginia law defines sensitive personal information as:

We do not use, sell, share, or disclose sensitive personal information for any purpose other than to provide the goods or services requested by you, with your consent, or for other purposes expressly authorized by Virginia law.

Your Right to Access

Under Virginia law, Virginia consumers have the right to access the personal information we have collected about them. If you are a Virginia resident, you or your authorized agent can log into your account and request access to personal information. If you do not have an account, you can submit a request to obtain, free of charge, an electronic, portable copy of personal information. Instructions on how to submit this request can be found below under “How to Submit Your Privacy Rights Request.”

Verifiable Consumer Request. We take security very seriously so we will provide personal information only after you verify your identity through safe and secure means, which means using methods and information that are not publicly available. Also, we will honor up to two consumer rights requests every twelve months as required by California law.

Time to Provide Personal Information. We will endeavor to provide this information to you within 45 days, but it may take up to 90 days. If we need more than 45 days, we will contact you to let you know that we need additional time.

Your Right to Delete

Virginia consumers also have the right to delete personal information. We are unable to delete information that is necessary to provide you ongoing service, for security purposes, that we are contractually obligated to retain, or that is necessary to comply with legal obligations. If you would like us to delete, you or your authorized agent may submit a request to delete. Instructions on how to submit this request can be found below under “How to Submit Your Privacy Rights Request.

Your Right to Correct

Virginia consumers have the right to correct inaccurate personal information that a business maintains about them. You or your authorized agent may submit a request to correct. Instructions on how to submit this request can be found below under “How to Submit Your Privacy Rights Request.”

Your Right to Opt Out of the Sale of Personal Information

Virginia consumers have the right to opt out of the sale of personal information. The term “sale” is defined to mean the exchange of personal data for monetary consideration.

Our activity that falls under the definition of “sale” under the Virginia law is:

To opt out of the sale of personal information, including for identity verification and credit inquiry purposes, please visit our Your Privacy Choices pages, available at:

Your Right to Opt Out of Targeted Advertising

Virginia consumers have the right to opt out of targeted advertising. The Virginia law defines targeted advertising as displaying advertisements to a consumer where the ad is selected by using or sharing personal information obtained from that consumer’s activities over time and across nonaffiliated websites or apps to predict that consumer's preferences or interests.

Our activity that falls under the definition of “targeted advertising” under the Virginia law is:

To opt out of targeted advertising, please visit our Your Privacy Choices pages, available at:

Your Right to Opt Out of Profiling

We do not use personal information to profile in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Your Right to Appeal

As a Virginia resident, if we deny your privacy rights request, you have the right to appeal that decision. You may submit this appeal using a link in the notice informing you of the denial. You also may submit an appeal of a decision we have made regarding your privacy rights by emailing us at [email protected]. When submitting your appeal through email, use the word "APPEAL" in your subject line and provide your name, contact information including phone number, a description of the decision you are appealing, and the reason for your appeal.

How to Submit Your Privacy Rights Request

If you wish to exercise your right to access, delete, or correct personal information, you can make a request through your existing online account. You, if you do not have an existing account, or your authorized agent can submit a request by calling 1-877-799-1999 or submitting a request online at:

Changes To This Policy

We may make changes to this Policy, so please check back periodically. When we do, we will revise the effective date above. If we decide to use or disclose information that identifies you personally in a way that is materially different from what we stated in our privacy policy at the time we collected that information from you, we will give you a choice about the new use or disclosure by appropriate means, which may include an opportunity to opt out.

How to Contact Us

Please direct any questions or comments regarding our privacy policy to:

[email protected]

Verizon Privacy Office

1300 I Street, NW Suite 500 East

Washington, DC 20005

If you have any unresolved privacy or data use concerns that we have not addressed to your satisfaction, please contact our U.S. based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.