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Mobile Broadband Privacy Policy

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet's vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how GroupAccess collects information from all end users of GroupAccess Internet Services (the "Services") such as those who access some of our Services but do not have accounts ("Visitors") as well as those who pay a monthly service fee to subscribe to the Service ("Members"). This Policy will also address what we do with the information we collect, the choices Visitors and Members have concerning the collection and the use of such information. Therefore, GroupAccess requests that you read this Privacy Policy carefully.

Personally Identifiable Information Collected By GroupAccess And How It Is Used Introduction
GroupAccess collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Service. We use this information primarily to provide a customized experience as you use our Services and, generally, do not share this information with third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases described below.

Registration
Members are asked to provide certain personal information when they sign up for our Services. This information includes name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member's account (such as for billing purposes). This information is not shared with third parties, unless specifically stated otherwise or in special circumstances. However, in instances where GroupAccess and a partner jointly promote the Services, GroupAccess may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services. This personal information is shared as a result of the joint promotion and for the sole purpose of allowing GroupAccess and the partner to assess the results of the promotion. In this instance, personal information may not be used by the partner for any other purpose. GroupAccess may also generate non-identifying and aggregate profiles from personal information of the Members provided during registration (such as the total number, but not the names of the Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

GroupAccess Partners
Some GroupAccess products and services are offered to Visitors and Members in conjunction with a non-affiliated partner. For example, To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred thus, allowing you to decide not to use that particular service or feature. GroupAccess will share non-identifying and aggregate information (except as described above), but not personal information, with such partners in order to administer the co-branded products or services offered.

Online Shopping
At some Web sites, you can purchase products and services or register to receive materials, such as a catalog or new product and service updates. In many cases, you may be asked to provide contact/personal information, such as your name, address, email address, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient's name, address, and phone number. GroupAccess has no control over the third parties' use of any personal information you provide when placing such an order. Please exercise care when doing so.

Responses to Email Inquiries
When Visitors or Members send email inquiries to GroupAccess, the return email address is used to answer the email inquiry we receive. GroupAccess does not use the return email address for any other purpose and does not share the return email address with any third party.

Voluntary Customer Surveys
GroupAccess may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary.

We take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other GroupAccess' customers to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

Special Cases
It is GroupAccess policy not to use or share the personal information about Visitors or Members in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses. However, GroupAccess may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services. This may be for any reason if, in our sole discretion, we believe that it is reasonable to do so, including but not limited to the following reasons: to satisfy laws, such as the Electronic Communications Privacy Act; regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or other user policies; to operate the Services properly; or to protect GroupAccess and our Members.

"Cookies" and How GroupAccess Uses Them
A "cookie" is a small data file that can be placed on your hard drive when you visit certain Web sites. GroupAccess may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. These cookies do not enable third parties to access any of your customer information. Additionally, be aware that if you visit non-GroupAccess web sites where you are prompted to log in or that are customizable, you may be required to accept cookies.

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

GroupAccess Commitment to Children's Privacy
Protecting children's privacy is especially important to us. It is our policy to comply with the Children's Online Privacy Protection Act of 1998 and all other applicable laws.

Therefore, GroupAccess recommends that children ask a parent for permission before sending personal information to GroupAccess, or to anyone else online.

Public Forums
Please remember that any information you may disclose in our Member Directory, or other public areas of our Web sites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

GroupAccess Commitment to Data Security
The Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.

Where to Direct Questions About GroupAccess Privacy Policy
If you have any questions about this Privacy Policy or the practices described herein, you may contact:

Customer Service
GroupAccess, Inc.
3119 Castle Canyon Way
San Jose, CA 95135

Revisions to This Policy
GroupAccess reserves the right to revise, amend, or modify this policy, our Service Contract and any other policy and/or agreement at any time and in any manner. Notice of any revision, amendment, or modification will be posted in accordance with the Service Contract. This Privacy Policy is effective July 1, 2007.

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