STARTEL SECURE MESSAGING PLUS PRIVACY POLICY

Revised: May 11 2022

Startel (“we”, “us”, or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we use and safeguard your information when you utilize the web-based and mobile applications (“apps”) associated with our Secure Messaging Plus service (“SM+”). Please read this Privacy Policy carefully, as accessing the application is deemed acceptance of these terms. If you have any general questions or concerns about this Policy, you may contact us by sending an email with your questions, comments or concerns to marketing@startel.com.

We may periodically need to revise our Privacy Policy. If changes are made, we will alert you by updating the “Revised” date of this Privacy Policy. SM+ users are encouraged to periodically review this Privacy Policy to stay informed of updates, as continued use of the application after the date a revised Privacy Policy is posted can be deemed an acceptance of the revised policy.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the app. We are not responsible for any of the data collected by any such third party. This Privacy Policy is also not applicable to any SM+ reseller, such as a telephone answering service or contact center that administers SM+ services on your behalf. SM+ users are encouraged to contact their reseller directly for more details on the privacy and confidentiality policies relevant to their SM+ services.

COLLECTION OF YOUR INFORMATION

Any data collected during your use of the app (for instance, your username, or the content of the messages you submit) is used only to facilitate your use of the application features and is never disclosed to third-party marketing companies or their affiliates.

DISCLOSURE OF YOUR INFORMATION

We share information we may have collected about you only in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, or safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

Interactions with Other Users

If you interact with other SM+ users, those users may see your name, user profile information, and descriptions of your activity (including read receipts) in addition to the content you send them.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to inception and misuse by unauthorized parties.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us at marketing@startel.com.

OPTIONS REGARDING YOUR INFORMATION

Account Information

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account
• Contacting the telephone answering service or contact center that administers your SM+ serviceUpon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, and/or comply with legal requirements.