Enterprise Privacy Policy for Services July 2022

PRIVACY POLICY FOR SERVICES

Updated July 2022

46 Labs is committed to honoring the privacy of our Users of our Service. The following policy outlines information gathering, use and disclosure practices with respect to User information that is collected by 46 Labs or provided by our Users. Accessing our Services or using the Website constitutes acknowledgement that you, the User, have read and accepted the practices, procedures and terms and conditions of this privacy policy.

1 Definitions.

1.1 "46 Labs Network and Services" shall have the meaning defined in 46 Labs' AUP.

1.2 "Customer Proprietary Network Information" or "CPNI" shall mean the confidential information about a User's purchase and use of Services, such as: call detail records, the types and amount of telecom products and services bought, user location information, and user invoice information. This type of information is required for us to perform the Services.

1.3 "EU Countries" shall mean and refer to the following countries: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK.

1.4 "Letter of Authorization" or "LOA" shall mean a request for a letter from the Customer, and usually a specific User, that is required for 46 Labs to access and purchase services in various geographies on behalf of the Customer.

1.5 "Personally Identifiable Information" or "PII" shall mean information about a User including personal demographic information, such as name, street address, email address, billing address, social security number, credit card number, copies of government issued identification, other service account information, and certain other financial information. This information may be required to provide Service on behalf of the Customer and their Users. The Customer and/or the User will be notified when the specific PII is required to perform Services on their behalf.

1.6 "PP" shall mean this privacy policy.

1.7 "Website" shall mean www.46labs.com. The Website Privacy Policy is publicly available on the website.

2 Information Collected and Used by 46 Labs.

2.1 Personal Demographic Information: This Information may include personal demographic information, such as name, street address, email address, billing address, government identification number, credit card number, or copies of government issued identification.

2.2 E-Mail. 46 Labs' policy is not to read or disclose private e-mail communications that are transmitted using 46 Labs services except to respond, if directed to us, or as required to operate the service, as set forth in the terms of use and policies established from time to time governing the service, or for other legally permissible purposes.

2.3 User Feedback: 46 Labs may ask contact information or conduct on-line surveys to better understand User's needs and to provide a customized experience. If User feedback is to be used other than as set forth in this policy, it will be disclosed at the time of collection. 46 Labs takes commercially reasonable steps to safeguard this information from unauthorized access. Information obtained under this section, including but not limited to user questions, suggestions, ideas, or other creative material belongs to us and will not be treated as confidential. 46 Labs may use, reproduce, adapt, distribute, display, disclose or create derivative works from this information without acknowledgement or compensation to the User.

2.4 Discussion Areas: 46 Labs may provide discussion areas so that Users can communicate freely and share ideas. Any information that is disclosed in these areas becomes public information. These discussion areas may be monitored by 46 Labs or law enforcement officials to enhance the safety and respect for all of our Users and visitors. 46 Labs reserves the right to edit discussion area content, however, 46 Labs is not responsible for any content or information posted to these discussion areas.

2.5 CPNI and Personally Identifiable Information, Use, Collection and Management.

3 Access, Updates to CPNI.

3.1 Access, Updates or Revisions: Customers may be permitted to access CPNI through the Service Platform or by contacting us as indicated in Section 8.

3.2 Retention: 46 Labs will only retain copies of such information necessary to comply with governmental regulation, orders, to resolve disputes, troubleshoot problems, enforce the Agreement and as otherwise reasonably necessary to provide the Service. Retention Periods for CPNI and Personally Identifiable Information vary by Jurisdiction the current retention periods for the Jurisdictions we serve are:

• United States: (18) months from the most recent Service Use.

• EU Countries: (6) six years from the most recent Service Use.

• All other Jurisdictions: (6) six years from the most recent Service Use.

4 Data Security.

46 Labs has put in place appropriate security measures to prevent User's personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to 46 Labs' employees, agents, contractors and other third parties who have an organizational need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 46 Labs makes no warranty, guarantee, or representation that use of our 46 Labs Network and Services are protected from all viruses, security threats or other vulnerabilities or that User information will always be secure.

5 User Use of Passwords or User Identifications.

Except as specifically permitted by this PP, Users shall not, lend, give, or otherwise disclose any passwords or user identifications to any unauthorized person, or permit any unauthorized person to use their accounts or related passwords or user identifications. Failure to properly protect User passwords or identifications may result in the loss of control over Personally Identifiable Information. Any failure to protect the disclosure of passwords or user identification shall be the sole responsibility of the User. If User passwords or identifications have been compromised for any reason, the User should immediately change such password or user identification or notify 46 Labs so corrective action may be taken.

6 Disclosure Consent.

Use of 46 Labs Network and Services constitutes voluntarily consent by the User to the collection and use Personally Identifiable Information as described in this PP or the Agreement. Users may request 46 Labs restrict the use and disclosure of this information by contacting as indicated in Section 8. Note: restrictions on the use of this information my hinder or render 46 Labs unable to provide services in the same manner or at the same level of quality and any such restriction that inhibits a User's use of the Service would be subject to credit limitations as described in the SLA and could be deemed by 46 Labs, in its sole discretion, as not entitling the Customer to a Support Failure Credit as described in the Service Support Agreement.

7 Modification and Update.

46 Labs reserves the right to modify this PP as indicated in the MSA.

8 Your Rights and Contacting 46 Labs regarding this Privacy Policy.

8.1 Rights: In certain Jurisdictions, you have the right to make a complaint to your local regulator for consumer or data protection regulator. Under certain circumstances, you have rights under data protection laws in your country in relation to your Personally Identifiable Information. This can include access to, correction of, erasure of, restricting access to, or withdrawal of consent to use your Personally Identifiable Information. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Please contact us with questions about these rights.

8.2 Contacting Us: For matters concerning this Privacy Policy including questions regarding violations or access to your private information, please contact us at: