We at TelcoDR, Inc. d/b/a “Goji” (“Goji”, “we”, “our” or “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy practices.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information“) that we gather when you are accessing or using our services, including when you visit our site gojimobile.com  (the “Site”) or download our app (the “Goji App”)(collectively, the “Services”). We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share your Personal Information with third parties, as described below.

California Users. If your Personal Information is subject to the California Consumer Privacy Act, and subsequently amended by the California Privacy Rights Act (“CPRA”), please review this Privacy Policy and see the sections below regarding California Resident Rights and Data Rights under CPRA.

Nevada Users. If the information we collect from or about you is subject to Nevada’s data privacy law, Nevada Revised Statutes § 603A.300 et seq. (with any implementing regulations and as may be amended from time to time, “Nevada Privacy Law”), please review this Privacy Policy and see the section below regarding Nevada Residents for a description of right under and other information related to the Nevada Privacy Law.

Virginia Users. If your Personal Information is subject to the Virginia Consumer Data Protection Act (“VCDPA”), please review this Privacy Policy and see the section below regarding Data Rights under VCDPA for a description of your rights under and other information related to the VCDPA.

What information does Goji collect and how does Goji use such information?

Information You Provide to Us

We receive and store any information you provide to us. For example, through the registration process, your account settings or when are you are seeking comparison mobile plans, we may collect Personal Information as follows:

• Contact Information, such as your name and email address.
  

• Application and Registered User Information, such as mobile phone data and wireless carrier information. This is typically collected when you submit a request for comparison mobile plans.

• Communications, including via email, chat, text, or phone, including voice recordings (as permitted by applicable law) if you speak with our representatives, or otherwise provide information to us through our website, email, or paper correspondence, or otherwise. We may communicate with you regarding your mobile plan or topics other than your mobile plan if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services.

Information Collected Automatically

As is true of most digital platforms, we and our third-party providers may also collect Personal Information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include:

• Log Data such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site;
  

• Analytics Data, such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site; and

• Location Data, such as general geographic location if you opt-in to sharing such information via the Site or the Goji App.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “cookies”) to automatically collect this Personal Information. For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.



To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.



Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave

our Services.



We and our third-party partners may also use cookies and tracking technologies for advertising purposes.

Will Goji share any of the Personal Information it receives?

We may share your Personal Information with third parties as described in this section:



Information that’s no longer personally identifiable. We may anonymize your Personal Information so that you are not individually identified and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage information to a partner in a manner that would identify you personally, as an individual.



Legally Required Disclosures. We may disclose Personal Information about you to law enforcement, or other governmental authority to protect our interests, or if we are required by law to divulge such information.

Advertisers. We may allow advertisers and/or partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.

Agents. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing provider to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Business Transfers. We may choose to buy or sell assets. In these types of transactions or in contemplation of a transaction, Personal Information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of Goji and Others. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service at gojimobile.com and other agreements; or protect the rights, property, or safety of Goji, our employees, our users, or others.

How does Goji use third-party tracking technologies for online advertising?

Goji may participate in interest-based advertising and use third party advertising partners to collect information from visitors to the Site for the purpose of displaying interest-based advertisements on other websites, apps or services, social networks, or on other devices you may use. Typically, though not always, these third party ad networks use cookies and tracking technologies to recognize your browser or device and to collect information about your visit to our Service to provide you customized content, advertising and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at https://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Is Personal Information about me secure?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We use certain physical, administrative, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services, and you do so at your own risk.

What choices do I have?

Updating Your Information

Once you have registered for an account, you may update or correct your profile information and preferences at any time by accessing your account settings page through the Site or the Goji App.

Deactivating Your Account

We do not delete information about you upon deactivation of your account. Although your deactivated status is reflected promptly in our user databases, we may retain the information you submit for a variety of purposes, including legal compliance, backups and archiving, prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from Goji and links to third-party financial accounts and services will automatically terminate.

Unsubscribing from Emails

If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.

Does Goji collect children’s information?

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@gojimobile.com.

Will Goji ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on Goji.com and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to legal@gojimobile.com, and we will try to resolve your concerns.

RIGHTS OF CALIFORNIA RESIDENTS

California enacted the CCPA in 2018 and subsequently amended under the California Privacy Rights Act (“CPRA”), effective January 1, 2023. The CPRA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) regarding “personal information” (as defined under the CPRA). If you are a California Resident, please review the following information about your potential rights regarding your personal information under the CPRA. The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used in this section have the meaning ascribed to them in the CPRA. Goji is a “business” under the CPRA. For purposes of this section only and regarding California residents only, Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. It does not include de-identified information, aggregate consumer information, or publicly available information, as those terms are defined in the CPRA.

Our Collection and Use of Personal Information. In the preceding 12 months, we may have collected from or about you all of the categories of Personal Information and from all of the sources listed the section entitled “INFORMATION WE COLLECT FROM OR ABOUT YOU.” We may collect, use, or sell Personal Information for the business or commercial purposes listed above in the section entitled “WITH WHOM WE SHARE INFORMATION.”

Our Disclosure and Sharing of Personal Information. We may disclose your Personal Information to our service providers or other entities that have agreed to limitations on the use of your Personal Information or that fit within other exemptions or exceptions in or as otherwise permitted by the CPRA or other applicable laws.

We also sell Personal Information within the meaning of the CPRA, but we do not sell Personal Information of minors under 16 years of age.

DATA RIGHTS UNDER CALIFORNIA PRIVACY RIGHTS ACT AND VIRGINIA CONSUMER DATA PROTECTION ACT

Your Data Rights: You may have certain data rights under the California Privacy Rights Act (“CPRA”) or the Virginia Consumer Data Protection Act (“VCDPA”), including the right to (1) request to know more about the categories and specific pieces of personal information we collect, use and disclose, (2) request deletion of your personal information, (3) opt out of any sales of your personal information that may be occurring, and (4) not to be discriminated against for exercising these rights.

The rights to know and delete are subject to our being able to reasonably verify your identity and authority to make these requests. To verify your identity when you submit a request, we will ask you to provide two or three pieces of personal information to confirm in our records.

Additionally, you may have the right to opt out of the processing of your personal data for targeted advertising, as defined by the VCDPA, or the sharing of your personal information for cross-context behavioral advertising, as defined by the CPRA. You may also have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable.

Sale of Personal Information. Goji sells the personal information of consumers as set forth above in the section entitled Rights of California Residents. In addition, we allow our advertising partners to use Cookies and other Tracking Technologies to collect Personal Information about you to show ads targeted to your interests.

Sensitive Personal Information Disclosure. Goji collects and discloses for a business purpose does not include “sensitive personal information” as defined under the California Privacy Rights Act.

CPRA Retention Disclosure. We keep your Personal Information to enable your continued use of the Services, and for as long as it is required to fulfill the relevant purposes described in this Privacy Policy, as permitted or as may be required by law, or as otherwise communicated to you. For example, we retain your transaction history so that you can review past purchases (and repeat orders if desired) and what addresses you have shipped orders to, and to improve the relevance of products and content we recommend.

CPRA Non-discrimination Statement.  Goji will not discriminate against any consumer for exercising their rights under the CPRA.

VCDPA De-identified Data Disclosure.  Goji may use de-identified data in some instances. Goji either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.How to Submit a Request Under the CPRA or VCDPA. If your Personal Information is subject to the CPRA or VCDPA, you may submit these requests by emailing us at support@gojimobile.com. To the extent we sell your Personal Information as the term “sell” is defined under the CPRA, you have the right to opt-out of the sale at any time. You may submit a Request to Opt-Out by sending an email to support@gojimobile.com. You may also authorize someone to exercise these rights on your behalf. To do so, we require signed permission. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or equivalent document that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact Goji at support@gojimobile.com. Once we have a copy of the valid signed authorization, your designated representative/authorized agent will be able to exercise these rights with respect to the account(s) listed on such authorization for the life of the account, unless there is a specified term or expiration date on the authorization form. Any information gathered as part of the verification process will be used for verification purposes only. Responses to verifiable consumer requests will be delivered through your online account with us or, if you do not have an account, by postal mail or email.

NEVADA RESIDENTSNevada law gives Nevada residents the right to opt-out of the “sale” of certain Personal Information, provided certain requirements are met. Terms used in this section shall have the meaning ascribed to them in the Nevada Privacy Law. For purposes of this section only and regarding Nevada residents only:

● Personal Information means any one or more of the following items of personally identifiable information about a consumer collected by an operator through an Internet website or online service and maintained by the operator in an accessible form: (i) first and last name; (ii) home or other physical address which includes the name of a street and the name of a city or town; (iii) electronic mail address; (iv) telephone number; (v) social security number; (vi) identifier that allows a specific person to be contacted either physically or online; or (vii) any other information concerning a person collected from the person through the Internet website or online service of  Goji

● “Sale” means the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons.

To exercise this right, please send an email to support@gojimobile.com and including “Nevada Do Not Sell Request” in the subject line.

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOU RECORDS, AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES TO THIS PRIVACY POLICY.