European Union Data Protection Directive Privacy Statement

ItsOn Inc. (“ItsOn”) is a business-to-business services provider that provides mobile device software and a managed service platform for wireless service providers. The ItsOn services platform augments the wireless provider’s existing network infrastructure, resulting in the capability for the provider to create, offer and manage flexible mobile data services to their customers. By virtue of providing the services platform and supporting the wireless service provider, ItsOn has access to the personal information of their individual customers that use the ItsOn service.

Meeting the needs and expectations of our customers has always been the highest priority of ItsOn and that includes protecting the privacy of personal information. The U.S. Department of Commerce and the European Commission have agreed on a set of privacy principles and frequently asked questions (the U.S.-EU Safe Harbor Framework) to enable U.S. organizations to satisfy the requirement under the Directive that adequate protection be given to personal information transferred from the EU to the United States. We have prepared this privacy statement to describe our approach to comply with the seven Safe Harbor privacy principles agreed to by the European Commission on 21 July 2000.

ItsOn complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. ItsOn has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ItsOn’s certification, please visit http://www.export.gov/safeharbor/

Notice: In the normal course of our business, we collect basic contact information from our
wireless service provider customers in a business-to-business context to administer and manage the business relationship. As part of using the service to manage their customers the wireless service providers are responsible for providing notice to their customers.

Choice: Similar to notice, offering and managing the choices of individuals using the services of a wireless service provider is the responsibility of the wireless service provider.

Onward Transfer: If requested by a wireless service provider to host any personal data related to their individual customers, we do so in a secure facility of a third party located in the United States. When a wireless service provider that hosts their customer data requires remote support services, we would have secure access to their data from the United States.

Security: We are committed to securing any personal information we have access to or provided to us. We have deployed process and technology measures with our third party service provider to provide reasonable assurance that any personal information is secured against unauthorized use, access, loss or disclosure.

Data Integrity: Any inaccuracies in the personal information we maintain about our business contacts at wireless service providers will be promptly corrected. The accuracy of the personal data related to customers of a wireless service provider is the responsibility of the wireless service provider.

Access: Any business contact at a wireless service provider that has provided us with their
personal information may request access to that information be contacting us at
privacy@itsoninc.com Any customer of a wireless service provider that would like to access their personal information would need to contact the wireless service provider directly.

Enforcement: We are committed to resolving any question or compliant and we encourage you to raise any concerns or complaints directly with us by sending us an email at
privacy@itsoninc.com or by contacting us as indicated below. We will also participate in the
American Arbitration Association’s dispute resolution program if necessary to resolve a
compliant.

How to Contact Us: You may address all communications to ItsOn Inc., 275 Shoreline Drive, Suite 350, Redwood City, California, USA 94065 or send an email to privacy@itsoninc.com

Please include your name, address, e-mail address in all communications and state clearly the nature of your request.

Changes to this Privacy Statement: This privacy statement is effective as of 8 April 2013. We may need to make changes to this privacy statement in the future to address business process or legal requirement changes. If such changes are made we will describe them in this privacy statement and indicate the new effective date.