Universal Calling Inc

Your privacy is vital to our long-term relationship with you, and protecting your privacy is just one part of our mission to provide you with highly personalized and valuable service.

In addition, in an effort to comply with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect personally identifying information from children under the age of 13.

This statement describes our privacy policy with respect to:

• What Information is Collected; How Information is Collected; and by Whom is Information Collected
• Data Controller and Data Processor
• The Sharing of Collected Information
• How You Can Access, Change or Limit the Information Collected About You
• Security of Information
• Customer Proprietary Network Information (CPNI)
• Transfer data internationally
• User Rights Regarding Personal Data
• Amendments to Our Privacy Policy

What Information is Collected; How Information is Collected; and by Whom is Information Collected

Data Controller and Data Processor
UniversalCalling.com acts both as a processor and controller in regards to personal data collecting and personal data processing for our website visitors and service users.

Required Personally Identifiable Information
To register on our Web site, you must submit your name and e-mail address. In addition, to purchase a calling card, you must submit additional information, including your address, phone number and credit card information. This required personally identifiable information is necessary for us to process transactions for you, protect you against credit card fraud and contact you. When you register with UniversalCalling.com™, we will ask you for an “e-mail.” The e-mail you select may appear on the web site in connection with future services we provide, such as discussion forums in which you may voluntarily participate.

Absent your prior consent, we will never share the information stored on that database, as well as other information we collect or you provide with any business partners or third parties, including those who offer services that complement those provided by us or which we believe may be of interest to you.

Transaction Information
When you authorize a purchase transaction, we will collect certain information related to that transaction such as the location from which you are requesting the search or transaction, the product or service involved, the quantity or amount of the product or service and certain personally identifiable information, such as your password, your credit card information and any special handling requests. This personally identifiable information will never knowingly appear in public areas of our Web site.

Third Party Information
During the processing of your transactions, we collect verification information from our credit card authorization services. Credit card authorization services verify that credit card information and address that they have on file for you matches the information that you have provided to us.

General Information
We collect general information about you when you visit our web site. This information includes technical information related to your computer and the manner in which you are accessing our site and includes such information as the internet protocol (IP) address of your computer, what operating system your computer is using, what browser software (e.g., Explorer, Netscape or other) your computer is using, and who your Internet service provider is, the Uniform Resource Locator (“URL”) of the web site from which you just came and the URL to which you go next and certain operating metrics, such as the amount of time you use our Web site.

The general information that we gather about you may be aggregated with general information of all users to help us better understand how our site is used. In addition, we aggregate the general information and the personal information. We compile and analyze this aggregated information so that we can provide more meaningful information to corporate partners and more relevant content and advertisements to you.

The Sharing of Collected Information

Personally Identifiable Information
As noted above, we only share certain information about you with those of our vendors who are responsible for handling your account or performing other necessary services that you require. We will not share your personally identifying information with other third parties without your consent, except for the following limited purposes:

1. We are compelled to do so by law or by an order of a court or governmental authority.
2. In order to cooperate with law enforcement authorities, credit card fraud investigations, credit card chargeback investigations, or governmental regulatory bodies, if we or they suspsect any illegal or fraudulent activities.
3. As necessary to complete a transaction for you.
4. As we deem necessary to protect the rights, safety or property of UniversalCalling.com, our users or others or to enforce our terms of use agreement or privacy policy.
5. If you use our Web site through a link from one of our promotional partners, then we may be required to share your user registration information or other personally identifying information about any search or transaction that you initiate through such promotional partner with that partner.

Aggregated General Information
In addition, we may share aggregated general information about our site with our business partners or the general public. For example, we may share information regarding the daily number of unique users to our site with potential corporate partners or others. Aggregated data does not contain any information that could be used to contact or identify you.

Third Party Sites
We may publish links to other sites from our web site. Please note that UniversalCalling.com does not control the content, practices or policies of any other site, including what information those sites collect about you. Accordingly, we do not endorse or hold ourselves responsible for the privacy policies or information gathering practices of any site that you may link to from our site. In addition, you may choose to respond to advertisements that are posted on our web site or made available via our service or to direct marketing offers from third party sponsors or advertisers. We do not control the content, practices or policies of our sponsors or advertisers and, accordingly, do not endorse or hold ourselves responsible for the privacy policies or information gathering practices of any sponsor or advertiser who may collect information about you.

How You Can Access, Limit or Change the Information Collected About You

• You can access your personal information by logging into your account on UniversalCalling.com
• You can change your personal information in your account setting of UniversalCalling.com
• You can limit or change the information collected about you by emailing your request to support@UniversalCalling.com

Security

UniversalCalling.com uses the high security standard encryption (SSL) to encrypt all of your credit card information while it is in transit to us. All data stored on the UniversalCalling.com server is protected by a secure “firewall” so that no unauthorized use or activity can take place. Although UniversalCalling.com will make every effort to safeguard your personal information from loss, misuse or alteration by third parties, you should be aware that there is always some risk that thieves may find a way to thwart our security system that transmissions over the Internet will be intercepted. Our liability to you in the event of a security breach by a third party is limited by the terms of our User Agreement.

Amendments to Our Privacy Policy

We may, from time to time, amend our Privacy Policy. If we do, then we will post such amendments to this document so that you may always have access to our most recent policy. We reserve the right, at our discretion, to change, modify, add or remove portions of our Privacy Policy at any time and from time to time. If at any point we decide to disclose personal information in a manner different from that stated at the time it was collected, we will notify users by email. You will be given the choice at that time to “opt-out” of any disclosures of your personal information that you made available to us prior to the change in our policy.

Customer Proprietary Network Information (CPNI)

UniversalCalling.com has put in place policies to protect certain customer proprietary network information (“CPNI”) that may come into the possession of UniversalCalling.com during the course of normal business operations.

CPNI includes the types of telecommunications services purchased, how these telecommunications services are used, and related billing information for those services. CPNI also typically includes the type of information found on bills, such as call details and the types of local, long distance and wireless telecommunications services that have been purchased. CPNI does not include telephone numbers and the associated names and addresses.

Carriers have a duty, and customers have a right, to protect CPNI under federal law. While UniversalCalling.com is not a carrier, UniversalCalling.com is governed by confidentiality agreements with its carriers. Accordingly, UniversalCalling.com does not sell, trade, or share our customers’ CPNI with unaffiliated third-parties or with anyone not authorized to represent UniversalCalling.com without express permission, or as may be required by law.

UniversalCalling.com does utilize CPNI when providing customer service for its customers and as otherwise allowed by law and its contracts with the carriers. Carriers are permitted to use or disclose CPNI when offering telecommunications services of the same type that a customer has already purchased from us. UniversalCalling.com may also use or disclose a customer’s CPNI for legal or regulatory reasons such as a court order, to investigate fraud or to protect against the unlawful use of the company’s telecommunications network and services.

Use of CPNI

CPNI is collected and maintained in the normal course of providing telecommunications services. This information allows companies to provide higher quality service and suggest better products to best suit a customer’s needs. CPNI also allows company representatives to offer promotions, packaged deals, and targeted discounts and special offers to help customers save time and money.

UniversalCalling.com fully abides by all federal and state law governing CPNI disclosure. Accordingly, UniversalCalling.com does not sell or release any CPNI to unaffiliated third parties.

UniversalCalling.com may share or release CPNI information to third parties upon receiving lawful and express consent from customers. If a customer opts-in, UniversalCalling.com may release CPNI to authorized agents for the sole purpose of allowing these agents to act on our behalf. This may include selling, marketing, or providing customers with more information about related products and services. All authorized agents who receive CPNI are bound by confidentiality agreements, and may not release, disclose, or sell customer information.

Restricting Use of CPNI

Any approval or denial of approval for the use of CPNI outside of the service to which the customer already subscribes is valid until the customer affirmatively revokes or limits such approval or denial. Restricting CPNI usage will not affect the provision of any services to which the customer subscribes. Customers can contact the UniversalCalling.com service representatives at the UniversalCalling.com customer service number or the representatives of the carriers at the numbers listed on the calling cards to modify the use of their CPNI. Customers may also contact the UniversalCalling.com or carrier representatives with any questions regarding the use and disclosure of CPNI.

Transfer data internationally

UniversalCalling.com provides services to people from all over the world and in doing so we do transfer data internationally. By using our website and services, you agree to any such transfer of personal data from outside your country.

User Rights Regarding Personal Data

You have the following rights listed below as a user of our website and services.

1. The right to be informed about what personal data is being collected and what is it being used for
2. The right of access to your personal data that we collect
3. The right of rectification of any personal data that is inaccurate or incomplete
4. The right to erasure or request to delete your personal data we collect
5. The right to restrict processing – an individual’s right to block or suppress processing of their personal data.
6. The right to data portability – this allows individuals to retain and reuse their personal data for their own purpose.
7. The right to object to their personal data being used. This includes, if a company uses personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest.
8. Rights of automated decision making and profiling – For example, individuals can choose not to be the subject of a decision where the consequence has a legal bearing on them, or is based on automated processing.

Acknowledgment and Acceptance of our Privacy Policy

This Privacy Statement is incorporated into and subject to the User Agreement contained on this web site (the “User Agreement”). As you know, your use of the UniversalCalling.com web site is subject to the User Agreement. When you register with us, you affirmatively agree to all terms of the Terms, including this Privacy Policy. Your continued use of this Web site constitutes your continued agreement to the terms of the User Agreement, including this Privacy Policy. If you do not agree with the terms of our Privacy Policy, you should cease using our Web site.