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Privacy Policy

Updated: May 7, 2017

This Privacy Statement describes how Sooner Wireless collects information from or about you, either as a customer or as a visitor to the Sooner Wireless website, when you order services from us, how we use the information we collect and the choices you have concerning the collection and use of such information. The goal of this Policy is to ensure that your Sooner Wireless experience is secure so that you may use our products and services with complete confidence. Please review this Policy carefully.

Personal Information Collected

Sooner Wireless limits the information collected about you to what is needed for conducting business, including the offering of products and services by us or by third parties that might be of interest to you. You may choose to provide personally identifiable information (PII) to Sooner Wireless in a number of ways: in person, telephonically or electronically via our website. Examples of how you may share PII with us include: ordering a service or equipment from us, sending us e-mail, responding to Sooner Wireless surveys, registering to receive news or public information or applying for a job. We may also obtain PII from third parties (for example, credit agencies) with your permission.

Examples of PII are:

• Name (including company name for business customers)

• E-mail address

• Credit card number or financial/bank account number or information, including routing numbers

• Passwords or personal identification codes (PINs)

• Date of birth

• Social Security number

• Driver's license number or government issued identification number

• Company contact information for business customers

The following information is not PII:

• Mailing address, unless unlisted or restricted at your request

• Telephone number, unless unlisted or restricted at your request

• IP Address allowing you to use our internet service

• PII included in aggregate data complied by Sooner Wireless

• Sooner Wireless may compile or aggregate PII from numerous customers or Web visitors to collect data about groups of customers or potential customers or categories of service. Sooner Wireless does not consider this information as PII because the aggregated information does not contain the PII of any individual customer or Web visitor.

Use of Personally Identifiable Information

Sooner Wireless uses PII to provide products and services to meet customers' needs, including new products or services. Sooner Wireless may share PII with any Sooner Wireless-affiliated company, and these companies are subject to the terms of this Policy.

Sooner Wireless retains PII only as long as is necessary for Sooner Wireless to comply with business, tax and legal requirements. This retention period could be the entire time you are our customer depending on the type of PII.

Sooner Wireless does not:

• Collect PII from you unless you provide it to us in person, telephonically or electronically by visiting our website, including information you provide in order to use our services.

• Sell the names and addresses of Sooner Wireless web visitors to unaffiliated suppliers without your prior approval.

• Allow third parties to change your service provider or otherwise access your account information, at your request, without complying with our security policies, including our Customer Account Protection Plan that protects your account from changes not authorized by you.

Customer Proprietary Network Information (CPNI)

CPNI is information that relates to the quantity, technical configuration, type, destination, location and amount of use of the telecommunications services purchased by you from Sooner Wireless. CPNI is available to Sooner Wireless solely through its relationship with you and information contained in your bill for telecommunication services. CPNI does not include information that is typically classified as PII, such as your name or e-mail address and does not include compiled or aggregated PII. U.S. federal law requires Sooner Wireless to protect the confidentiality of CPNI. Unless you opt-out from the use of CPNI, Sooner Wireless may use CPNI to market service offerings to you to which you do not already subscribe. To opt-out, just contact us. Sooner Wireless may, without prior approval from you, use CPNI to provide or market service offerings to you, if the service offerings are within the same categories of service to which you already subscribe, regardless of your CPNI selection.

Value-Added Services

Because we appreciate the trust you have placed in us, we continually look for ways to enhance your customer experience. From time to time, we may notify you about a Sooner Wireless product or service using the information you have provided to us either in person, telephonically or electronically by visiting our website, including information you provide to use our services. We strive to limit our offers to those we think you would benefit from and appreciate receiving. We want every contact you have with us to be a positive experience. If you prefer not to receive these Sooner Wireless value-added services, offers and opportunities, just contact us.

Sooner Wireless complies with all applicable laws and regulations regarding Do Not Call Lists. Generally, Sooner Wireless is allowed to contact its customers, even if the customers are registered with federal or state Do Not Call Lists, because of our relationship with you. Sooner Wireless will, of course, honor any request to remove your name from our telephone, mail or e-mail solicitation lists and will delete your information from existing files within a reasonable time period. Just contact us.

Information Disclosed to Third Parties

Sooner Wireless does not sell PII of its customers to third parties. In limited circumstances, Sooner Wireless may provide PII to third parties:

• To assist us in developing, promoting, establishing, maintaining and/or providing Sooner Wireless-related products and services to you, including joint marketing efforts or promotions, but PII may not be used by the third parties for any other purpose;

• To assist us in establishing accounts, billing, collecting payment (i.e. credit bureaus and collection agencies), enforcing the Terms and Conditions or the Acceptable Use Policy of our Sooner Wireless services where permitted by law, and protecting or enforcing our rights or property or the services of our other customers from fraudulent, abusive, or unlawful use by you of our services;

• To comply, when required by law, with court or administrative orders, civil or criminal subpoenas, warrants from law enforcement agencies, federal or state regulatory requirements, mandatory governmental audits, E911 reporting requirements, grand jury investigations, civil or criminal governmental investigations or reporting required by the National Center for Missing and Exploited Children, designated by federal law as a reporting mechanism for child pornography; and

• To appropriate law enforcement, 911 centers or emergency services when Sooner Wireless, in good faith, believes the disclosure is necessary to protect a person, Sooner Wireless property or the public from an immediate threat of serious harm.

On-line Information

In addition to PII identified in Section A of this Statement, we, or our third party partners, may collect non-personal information automatically when you enter the Sooner Wireless website, such as domain name, browser, your computer operating system, information about the Web page from which you linked to the site, and time spent on different pages within the site. We or our partners may use this information to evaluate and improve our site, and may share the information with third parties on an aggregated basis to enhance our products and services offered. This on-line information is typically collected via cookies (cookies are small, encrypted data strings our server writes to your hard drive that contains your unique Sooner Wireless User ID.). Like virtually all other web sites that you visit, we use cookies to deliver Web content specific to your interests and to control access to your personal shopping cart after your initial entry. The cookie permits the server to recall information from your previous shopping trip, should you decide to think about your purchase. A cookie is not used to access or otherwise compromise the data on your hard drive. With most browsers, you can choose to change your browser settings to disable cookies. Please be aware that cookies may be required to complete certain functions on the Sooner Wireless website and other websites you may link to from the Sooner Wireless website, including making purchases or payments on your Sooner Wireless account.

Security Measures

Sooner Wireless uses security techniques designed to protect your information from unauthorized access, including firewalls and access control procedures. We have security measures in place to protect against the loss, misuse and alteration of information under our control. For example, when you place an order on a Sooner Wireless website, the information you submit is encrypted using the Secure Sockets Layer (SSL) protocol.

Sooner Wireless employees are bound by non-disclosure agreements designed to prevent them from disclosing any PII or CPNI. Further, Sooner Wireless's Working with Integrity Guidelines state that Sooner Wireless employees must abide by all state and federal laws and regulations in the performance of their job duties.

Our policies also limit access to PII to only those employees, contractors, agents or representatives that require the information to perform their jobs or assist Sooner Wireless with providing products and services to you.

Children

Children below the age of majority should consult with their parents or guardians before furnishing any data to us. Parents should consider using one of a number of available parental control tools that provide a child-friendly, on-line environment and can prevent children from disclosing PII without parental consent. If a child has provided personal information without the consent of a parent or guardian, that parent or guardian should contact us to request that the information be deleted from our records. More information about parental controls may be found on Sooner Wireless websites or by contacting a Sooner Wireless customer care representative.

Sooner Wireless does not knowingly collect PII from children under the age of 13 in connection with providing products and services, and it strives to comply with all provisions of the Children's Online Privacy Protection Act (COPPA). If Sooner Wireless inadvertently collects information from minors below the age of 13, the information will be treated as PII of the adult customer.

Links

Sooner Wireless is not responsible for the content or privacy policies of other non-Sooner Wireless websites. You should keep this in mind when accessing sites through links on the Sooner Wireless website. Further, Sooner Wireless may advertise on other websites. The advertising companies placing our ads may use cookies to track the effectiveness of our ads. The use of such technology is subject to the privacy policies of the advertising companies, and not this Statement.

Google Gmail

Some of our customers may have email provided by Google pursuant to their specific agreements. Use of Google Gmail is subject to both this Statement and the Gmail privacy policy available under the Terms section at http://mail.google.com.

Statement Updates

We may update this Privacy Statement at any time in connection with our constant efforts to improve our products and services. We strongly encourage you to periodically review this Statement. We reserve the right to expand our capabilities for information collection and use and change this Statement in this regard. If any change constitutes a material change to this Statement, we will post a notice on our websites in a prominent position. If Sooner Wireless decides to use PII in a manner that is materially different from what is contained herein, we will post the change on this page for 30 days before making the change.

Security Breaches

While our goal is to prevent any unauthorized disclosure of PII, Sooner Wireless cannot guarantee that an unauthorized disclosure will not occur. We will make reasonable efforts to contact you if we determine that security breach has occurred and that there is a reasonable risk of identity theft or as otherwise required by law.

Contact Us

If you have questions, concerns, or complaints about this Statement or Sooner Wireless's privacy practices, please contact a Sooner Wireless customer care representative; email us atjeff@burnhaminv.com; or write to us at Sooner Wireless LLC, 1300 12th Avenue SE, Suite 236, Norman, OK 73071. We will respond to your inquiries in a timely manner.

Internet Information

Sooner Wireless's network management practices are designed to provide the best possible online experience to its customers. To that end, Sooner Wireless monitors traffic flows between points within its network and between its network and locations on the internet for purposes of reasonable network management. Sooner Wireless uses this information to manage its network, provide security for its customers, plan for future needs, and ensure its network runs efficiently. Monitored information includes the amount of data sent to and from your connection, the source and destination of the data, and the type of information sent and received. In limited circumstances, Sooner Wireless may also look into the contents of the information to determine whether it is malicious in nature (such as a virus, spam, worm, etc) or when required by law to comply with judicial orders or regulations.

Safe Harbor Principles

Sooner Wireless adheres to the Safe Harbor Privacy Principles and complies with the U.S.- EU Safe Harbor Framework as agreed to and set forth by the United States Department of Commerce and the European Union ("EU"). http://export.gov/safeharbor. For individually identifiable information received by Sooner Wireless in the United States, from Users in the EU, Sooner Wireless adheres to the following principles:

• Notice. Sooner Wireless will inform Users about the purposes for which it collects and uses PII, the types of non-agent third parties to which Sooner Wireless discloses PII, and the choices and means, if any, Sooner Wireless offers for limiting use and disclosure of PII.

• Choice. Sooner Wireless will offer Users the opportunity to choose (opt-out) whether their PII is (a) to be disclosed to a third party who is not an agent, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized. For sensitive PII, Sooner Wireless will give Users the opportunity to affirmatively and explicitly (opt-in) consent to such disclosure or use.

• Access. Upon request, Sooner Wireless will provide Users with the PII that it holds about them and will take reasonable steps to provide individuals with a means to correct, amend or delete PII that is inaccurate or incomplete.

• Dispute Resolution. For complaints that cannot be resolved between Sooner Wireless and the User, such disputes will be governed by the current provisions of Sooner Wireless's Terms and Conditions.

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