In order to operate the Cheetah Wireless Technologies, Inc. Network Service and to reduce the risk of fraud, Cheetah Wireless Technologies, Inc. ("CWTI") must ask you to provide us information about yourself and your credit card. This Privacy Policy describes the information we collect and how we use that information.

CWTI takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy.

If you have questions or concerns regarding this Privacy Policy, you should first contact CWTI by emailing to admin@cwti.net.  If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact customersupport@cwti.net.

By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the CWTI End User Agreement. This Privacy Policy will take effect on January 1, 2006. This Privacy Policy was last updated on March 27, 2007.801

Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country but CWTI will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the CWTI service.

Notification of Changes
This policy may be revised over time as new features are added to the CWTI service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your CWTI account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner).

We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the CWTI Web site at www.cwti.net at any time for the most current version of our Privacy Policy.

CWTI Shops and other pages on the CWTI Web site include links to third party Web sites. These sites are governed by their own privacy statements, and CWTI is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

Required Information
To open a CWTI account, you must provide your name, address, phone number, and e-mail address. In order to make payments through CWTI, you must provide credit card, debit card or bank account information. We also ask you to choose a different security questions to answer (such as your city of birth or your pet's name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.

Pursuant to section 326 of the USA PATRIOT Act, the U.S. Department of the Treasury require CWTI Funds to obtain, verify, and record the following information for each subscriber.

• Name
• Address
• Date of Birth (for Individuals)
• Tax Identification Number (social security number for individuals or employer identification number for businesses)

If you choose to register or apply for certain optional features or products offered through CWTI Web sites, such as listing your business in CWTI advertising links you will be required to provide additional information to establish that you qualify for such features or products.


Information About You From Third Parties
In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with CWTI, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to CWTI, and that the card has not been reported as lost or stolen.

If you register your online business in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to CWTI, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. CWTI, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave the CWTI Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the CWTI site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with CWTI. We do not track the Web sites that you visit before or after you leave the CWTI site.

Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a CWTI customer if you return to the CWTI site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your CWTI account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your CWTI account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by CWTI. We may, however, share cookie information regarding whether or not a certain user is already registered with CWTI with certain merchants with whom we have an official co-marketing relationship.

Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from CWTI to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.


 

Internal Uses
We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products and 4) to improve our products and services.
We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.


Disclosure to Third Parties Other Than CWTI Customers
CWTI will not sell or rent any of your personally identifiable information to third parties. CWTI will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other CWTI customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

1. We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.
2. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information) to victims who request it.
3. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
4. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
5. We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information.
6. As with any other business, it is possible that CWTI in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by CWTI, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.

Our Contacts with CWTI Customers
We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a CWTI account, to send you notice of payments that you send or receive through CWTI (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

We also use your e-mail address to send you other types of communications that you can control, including the CWTI newsletter, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the CWTI Web site and changing your preferences in the Profile page of the My Account tab.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

Your Use of Information and Our Services
In order to facilitate the transactions between CWTI members, our service allows you limited access other users' contact or shipping information. As a seller you may have access to the User ID, email address and other contact or shipping information of the purchaser, and as a purchaser you may have access to the User ID, email address and other contact information of the seller.

By entering into our User Agreement, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through an CWTI-related communication or CWTI-facilitated transaction, you will only use this information for: (a) CWTI-related communications that are not unsolicited commercial messages,  (b) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).

In all cases, you must provide users with the opportunity to remove them from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another CWTI user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.

CWTI does not tolerate spam. Therefore, without limiting the foregoing, you may not add a CWTI user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report CWTI-related spam to CWTI, please contact us at http://www.cwti.us/Contact.asp

Information Security
CWTI is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. For our subscribers we retain the complete credit card information, for our “adhoc” or casual users, we retain only the last 4 digits for identification purposes only.  We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.

The security of your CWTI account also relies on your protection of your CWTI password. You may not share your CWTI password with anyone. CWTI will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the CWTI website.
Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with http://www.cwti.net/ should be treated as unauthorized and suspicious and should be reported to CWTI immediately. If you do share your CWTI password with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away as described in Section F below.

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your CWTI account, at any time by contacting us (See section F.).  You can also close your account the same way. If you close your CWTI account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

If you have any questions about this privacy statement, CWTI's information practices, or your dealings with CWTI, you can contact us 702-243-3824 Monday through Friday between the hours of 8am and 6pm PST, or write us at CWTI, 1421 East Sunset Road, Suite 11, Las Vegas, Nevada 89119