Privacy Policy

1. Introduction & Scope

At Wholesale Mobile ("Wholesale Mobile", "we", "us", or "our"), we are committed to protecting the privacy and security of the personal information of our customers, prospective customers, website and app visitors, and other individuals who interact with our services (collectively, "you"). This Privacy Policy explains what information we collect, how we use and share it, the choices and rights available to you, and how you can contact us with questions.

Wholesale Mobile is a mobile virtual network operator (MVNO) service delivered through an "MVNO as a Service" arrangement. We do not own a wireless network. Your service is provided with the help of the following partners, each of which handles personal information on our behalf only as needed to provide and support your service:

• MVNX Link, LLC, which provides the billing system, customer web and app portal, and related back-office technology platform that supports your account, and acts as our technology and billing service provider
• Our mobile virtual network operator (MVNO) of record, which carries the regulatory responsibilities associated with your service and handles related filings and compliance functions
• Our mobile virtual network aggregator (MVNA) and the underlying facilities-based wireless carrier, which provide the network connectivity for your service
• Customer care and other service providers that help us support your account, as described in Section 10

Together, these partners are referred to in this Policy as our "Network Partners." Each is bound by contractual data-use, security, and confidentiality restrictions. This Policy describes practices applicable across this full service relationship, regardless of which partner performs a given function. If you would like to know which companies currently serve in these roles, contact us using the information in Section 18.

This Policy applies to personal information we collect through our website(s), mobile application(s), customer service channels (including phone, chat, email, and any AI-assisted support tools), retail or point-of-sale interactions, and any other means by which you interact with Wholesale Mobile. It does not apply to third-party websites, applications, or services that we do not own or control, even if linked from our services.

This Policy is intended to comply with applicable U.S. federal law and the state consumer privacy, telecommunications, and data protection laws described in Sections 6 through 8. Where a specific state or federal law grants you rights broader than those described generally in this Policy, that law governs for residents of that state.

2. Definitions

For purposes of this Policy, the following terms have the meanings below. Some terms are drawn from specific statutes and apply only to the extent that statute applies to you.

Personal Information / Personal Data

Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Definitions vary slightly by state law; we apply the broadest applicable definition to any given individual.

Sensitive Personal Information / Sensitive Data

A subset of personal information subject to heightened protection under certain state laws, which may include precise geolocation, government identifiers (such as Social Security number, driver's license, or passport number), financial account information, biometric data used for identification, health information, and information revealing racial or ethnic origin, religious beliefs, citizenship or immigration status, or sexual orientation.

CPNI (Customer Proprietary Network Information)

Information collected by a telecommunications carrier relating to the quantity, technical configuration, type, destination, location, and amount of use of your telecommunications service, and information contained in your telephone bill, as defined under Section 222 of the Communications Act and FCC rules at 47 C.F.R. Part 64, Subpart U. CPNI is subject to specific federal use, disclosure, and security requirements described in Section 6.

Automated Decision-Making / Profiling

The use of a computational process, including one derived from artificial intelligence or machine learning, to process personal information and evaluate, analyze, or predict aspects of an individual's behavior, characteristics, or preferences, with or without human involvement.

Sale and Sharing

"Sale" generally means the exchange of personal information for monetary or other valuable consideration to a third party. "Sharing" (a term used in California law) generally means disclosing personal information to a third party for cross-context behavioral advertising, regardless of whether money changes hands. Our practices with respect to sale and sharing are described in Section 10.

3. Information We Collect

We collect the following categories of information about you:

Identifiers and Account Information

• Name, mailing address, email address, phone number
• Account credentials and account or subscriber number
• Government-issued identification, date of birth, or Social Security number, where required for identity verification, number porting, SIM activation, or fraud prevention
• Payment and billing information, including payment card or bank account details (processed via our payment processor)

Network, Service, and CPNI

• Call and messaging detail records, including numbers dialed or received, call duration, and timestamps
• Data usage volumes and session information
• Device identifiers (IMEI, SIM/ICCID, MAC address), device make and model, and network and roaming status
• Precise or approximate location information generated by your device's use of the network, where enabled

Customer Service and Support Data

• Records of your communications with us, including phone call recordings (with notice as required by law), chat transcripts, and email correspondence
• Interactions with automated or AI-assisted support tools, as described in Section 5

Technical and Online Activity Data

• IP address, browser type, operating system, and device type
• Pages viewed, links clicked, referring and exit pages, and other usage data collected via our website and app
• Information collected through cookies and similar technologies (see Section 11)

Information from Third Parties

• Fraud-prevention databases and identity-verification services, used to confirm your identity and prevent fraud (such as unauthorized SIM swaps)
• Retail partners, authorized dealers, or distributors through which you purchased service
• Our Network Partners, in connection with provisioning and service delivery

4. How We Use Your Information

We use the categories of information described above for the following purposes:

• Service delivery: to provision, activate, maintain, bill for, and support your wireless service, including functions performed by our Network Partners
• Account and customer management: to create and manage your account, process payments, and respond to inquiries
• Fraud prevention and security: to detect, investigate, and prevent fraud, unauthorized account access, SIM-swap fraud, and other misuse of our services
• Network management: to monitor, maintain, and optimize network performance and capacity
• Communications: to send service-related notices, and, where you have provided consent or as otherwise permitted by law, marketing and promotional communications (see Section 6 regarding TCPA and CAN-SPAM)
• Legal and regulatory compliance: to comply with applicable law, respond to lawful requests from public authorities, and meet telecommunications regulatory obligations, including CPNI, E911, and law enforcement assistance obligations
• Product improvement: to understand how our services are used and to develop, test, and improve our offerings
• As described in Section 5, to operate and improve automated and AI-assisted tools used in providing service to you

5. Our Use of Artificial Intelligence and Automated Decision-Making

We use, or may use, artificial intelligence (AI), machine learning, and other automated systems to help operate and improve our services. This section describes those uses and the choices available to you. We provide it as a standalone disclosure because several states now impose specific transparency, opt-out, and appeal obligations on the use of AI and automated decision-making in consumer-facing services. Because Wholesale Mobile is served through the arrangement described in Section 1, the practices below reflect the AI and automated-systems requirements in the agreements among Wholesale Mobile, MVNX Link, LLC, and, where applicable, our Network Partners. Those requirements cover data-use restrictions, consent and disclosure requirements for AI-generated communications under the Telephone Consumer Protection Act (TCPA), and human review of adverse automated decisions.

Where We Use AI and Automated Systems

• Customer service: We may use AI-assisted chat and automated call-routing and response tools to answer questions, troubleshoot service issues, and route you to a live representative
• Fraud and security: We use automated systems and machine-learning models to detect potentially fraudulent activity, such as SIM-swap attempts or unauthorized account changes, and to flag accounts for further review
• Account and service recommendations: We may use automated systems to recommend plans, add-ons, or offers based on your usage patterns
• Network operations: We use automated and AI-based tools to monitor and optimize network performance; these tools do not make decisions about individual customers
• Quality assurance: Customer service interactions, including calls and chats, may be analyzed by automated tools (in addition to human review) for quality, training, and compliance purposes

Automated Decisions with Legal or Similarly Significant Effects

Where we use automated decision-making technology to make a decision that produces a legal effect or similarly significant effect concerning you, such as a decision to deny or suspend service or restrict your account based solely on automated processing, we will, to the extent required by applicable law:

• Provide notice that automated decision-making technology is being used
• Provide a meaningful explanation of the logic involved, and the significance and likely consequences of the processing, to the extent feasible
• Offer you the ability to opt out of the automated decision-making process, request human review, or appeal the decision, consistent with rights available under applicable state law (for example, Colorado's AI-related consumer protections and California's automated decision-making technology regulations)

How to Exercise AI-Related Rights

To opt out of a covered automated decision, request human review of an automated decision that affected you, or ask questions about our use of AI, contact us using the information in Section 18. We will verify your identity and respond within the time required by applicable law.

Use of Personal Information to Train AI Models

We do not use your personal information to train third-party or publicly available AI models. We may use de-identified or aggregated customer service interaction data to improve our own automated support tools.

6. Federal Regulatory Disclosures

Customer Proprietary Network Information (CPNI)

As a provider of telecommunications service, Wholesale Mobile, working with our MVNO of record and with MVNX Link, LLC as our billing and technology service provider, is required by Section 222 of the Communications Act and FCC rules (47 C.F.R. Part 64, Subpart U) to protect the confidentiality of your CPNI. We do not use, disclose, or permit access to your CPNI except as required or permitted by law, including to provide the service you have requested, to market additional communications-related services to you within the scope permitted by your approval status, to protect our rights or property, or to comply with legal process. These obligations extend to MVNX Link, LLC and our other Network Partners in their roles processing this data on our behalf, under contractual data-use restrictions. Where your approval is required before we use CPNI for certain marketing purposes, we will obtain that approval through the opt-in or opt-out method required by FCC rules. You may contact us at any time using the information in Section 18 to ask about, or change, your CPNI approval status.

Telephone Consumer Protection Act (TCPA) and CAN-SPAM

We will only send you marketing calls, text messages, or emails in accordance with the consent requirements of the TCPA and the CAN-SPAM Act. You may opt out of marketing text messages by replying "STOP" and out of marketing emails using the unsubscribe link in those messages. Opting out of marketing communications does not affect service-related messages necessary to operate your account.

Communications Assistance for Law Enforcement Act (CALEA) and Lawful Process

We may be required to assist law enforcement agencies in accordance with CALEA and to disclose information in response to a valid subpoena, court order, search warrant, or other lawful process, or in response to an emergency involving danger of death or serious physical injury.

7. Your Privacy Rights Under State Law

Depending on your state of residence, you may have some or all of the following rights under applicable comprehensive state privacy laws, which currently include (among others) the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Texas Data Privacy and Security Act (TDPSA), and similar laws in other states. We extend the core rights below to all customers, regardless of state of residence, except where noted.

• Right to know / access: the right to confirm whether we process your personal information and to obtain a copy of it
• Right to correct: the right to correct inaccurate personal information we maintain about you
• Right to delete: the right to request deletion of personal information we have collected from or about you, subject to legal exceptions (for example, information we must retain for billing, tax, fraud-prevention, or regulatory purposes)
• Right to data portability: the right to receive a copy of certain personal information in a portable format
• Right to opt out of targeted advertising
• Right to opt out of the sale or sharing of personal information
• Right to opt out of profiling or automated decision-making that produces legal or similarly significant effects, as described in Section 5
• Right to non-discrimination: we will not deny goods or services, charge different prices, or provide a different level of service because you exercised a privacy right
• Right to appeal: in states that require it (including Colorado, Connecticut, and Virginia), if we decline to act on your request, you may appeal our decision using the process described in Section 13

To exercise any of these rights, contact us using the information in Section 18. We will verify your identity before responding and will respond within the timeframe required by the applicable law of your state of residence (commonly 45 days, extendable by an additional 45 days when reasonably necessary). You may designate an authorized agent to submit a request on your behalf, subject to verification.

8. California-Specific Disclosures

This section supplements Section 7 for California residents and is intended to comply with the CCPA/CPRA.

Categories of Personal Information Collected

In the preceding 12 months, we have collected the categories of personal information described in Section 3, which map to the CCPA categories of: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, or visual information (for example, call recordings); and inferences drawn from the above.

Sale and Sharing of Personal Information

We do not sell personal information for monetary consideration, and we do not share personal information with third parties for cross-context behavioral advertising.

Sensitive Personal Information

We collect limited categories of sensitive personal information, such as government identifiers used for identity verification and, where applicable, precise geolocation. We use sensitive personal information only for purposes permitted under the CPRA and do not use it to infer characteristics about you beyond those purposes.

Shine the Light

California residents may request information once per calendar year about our disclosure of personal information to third parties for their own direct marketing purposes, if any, using the contact information in Section 18.

9. Children's Privacy

Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without verifiable parental consent, consistent with the Children's Online Privacy Protection Act (COPPA). Accounts are for adults 18 years of age or older. If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take steps to delete that information. A parent or guardian who believes we may have collected information from a child under 13 should contact us using the information in Section 18.

10. How We Share and Disclose Information

We disclose personal information to the following categories of recipients:

• MVNX Link, LLC, our billing, customer portal, and technology platform service provider, which processes your information to deliver account, billing, and support functionality on our behalf
• Our MVNO of record, network aggregator, and the underlying wireless carrier, to provision, deliver, and support the wireless connectivity for your service and to meet regulatory obligations tied to it
• Customer care providers and other service providers who perform functions on our behalf, such as payment processing, customer support platforms (including AI-assisted support tools), identity verification, and cloud hosting, under contracts that restrict their use of your information to the services they provide
• Professional advisors, such as auditors, lawyers, and insurers, as needed
• Law enforcement, government authorities, or other third parties where required by law, subpoena, court order, or other legal process, or to protect the rights, property, or safety of Wholesale Mobile, our customers, or the public
• A successor entity in connection with a merger, acquisition, financing, or sale of assets
• Other parties with your consent or at your direction

MVNX Link, LLC and our other Network Partners are each contractually restricted from using your personal information for any purpose other than providing services to Wholesale Mobile and its subscribers, and from selling your personal information. If Wholesale Mobile changes its underlying technology platform or any Network Partner in the future, your subscriber data remains associated with Wholesale Mobile and will transition accordingly, consistent with our data ownership and portability commitments.

We do not sell your personal information to third parties for monetary consideration, and we do not disclose it to advertising partners for cross-context behavioral advertising.

11. Cookies, Analytics, and Tracking Technologies

We and our service providers use cookies, web beacons, software development kits (SDKs), and similar technologies on our website and app to operate our services, remember your preferences, and analyze traffic and usage.

Types of Cookies We Use

• Strictly necessary cookies, required for our website and app to function
• Performance and analytics cookies, used to understand how visitors use our services
• Functional cookies, used to remember your preferences

Your Choices

You can control cookies through your browser settings and, where required by law, by responding to Global Privacy Control or other opt-out preference signals as described in Section 15.

12. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction, including encryption of data in transit and at rest where appropriate, access controls, network monitoring, and vendor security requirements. Before we process a SIM change or a request to move your number to another provider, we use secure methods to verify your identity and notify you of the request, as required by FCC rules. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Data Breach Notification

If we experience a security incident involving unauthorized access to personal information that triggers a notification obligation, we will notify affected individuals and, where required, regulators and consumer reporting agencies, in accordance with applicable state breach notification laws (each of the 50 states, the District of Columbia, and U.S. territories maintains its own breach notification statute and timing requirements) and any applicable FCC telecommunications breach reporting requirements.

Appeal Rights

If we decline to act on a privacy rights request described in Section 7, and your state of residence provides a right to appeal (including Colorado, Connecticut, and Virginia), you may appeal by contacting us using the information in Section 18 and stating that you are submitting an appeal. We will respond to your appeal within the timeframe required by applicable law and will inform you of any further options, including the ability to contact your state Attorney General, if we deny your appeal.

14. Data Retention

We retain personal information for as long as reasonably necessary to provide the services, fulfill the purposes described in this Policy, and comply with our legal obligations, including CPNI recordkeeping obligations, tax and accounting requirements, and fraud-prevention needs. Retention periods depend on the type of information and the reason we hold it. As examples, we generally keep account and billing records for the life of your account and for a period afterward that tax, accounting, and legal requirements call for, and we keep call and messaging detail records for the period that applicable law and our carrier obligations require. When information is no longer needed, we securely delete or de-identify it.

15. Do Not Track and Global Privacy Control Signals

Some browsers transmit "Do Not Track" signals; because there is no accepted industry standard for responding to such signals, we do not currently respond to them. Where required by applicable state law, we do honor the Global Privacy Control (GPC) as a valid method for California, Colorado, and Connecticut residents (among others) to opt out of the sale or sharing of personal information and targeted advertising through participating browsers.

16. Third-Party Links and Services

Our website and app may contain links to third-party websites, applications, or services that we do not own or control. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing them with information.

17. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy with a new effective date and, where required by law, will provide additional notice of material changes (for example, by email or a prominent notice on our website) before the change takes effect.

18. Contact Us

If you have questions about this Policy or wish to exercise your privacy rights, please contact us: