WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO. PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE MAKE TO THIS PRIVACY POLICY.

1. INTRODUCTION

Numberless, Inc. (“Numberless,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). Numberless “Services” are (a) an end-to-end encrypted communication application (the “App” or “Port”) that allows people to connect and communicate with each other without using emails, usernames or phone numbers. (b) the websites port.numberless.tech and porting.me (collectively referred to as the “Website” or “Web page” or “Websites”).

This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use our Services. Numberless is committed to protecting the privacy of its Users whose information is collected and stored while using our Services. This Privacy Policy is applicable to our Services offered to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Use or Terms of Service as applicable, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES. BY ACCESSING OR USING OUR SERVICES, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR SERVICES.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT CONTACT@MAIL.NUMBERLESS.TECH

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

2. WHAT INFORMATION DO WE COLLECT?

When you use our Services, we collect personal information (also referred to as personally identifiable information or “PII”) which may include device information, network information and IP address of your mobile device. The information so collected will be stored on our servers.

3. HOW DO WE COLLECT INFORMATION?

We collect personal information from you in the following ways:

a. At Onboarding on our Services.

We collect information from you automatically when you navigate through our Services in the following ways:

a. Usage details;

b. IP addresses;

4. OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”

We do not use Cookies on our Services

5. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Services are reasonably scanned to meet or exceed PCI Compliance. Our Services receive regular security scans and penetration tests. Our Services also receive regular malware scans. In addition, our We require username and passwords for our employees who can access your personal information that we store and/or process on our servers.

6. DATA SECURITY MEASURES.

a. Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

b. Fair Information Practice Principles. In the event of a personal data breach, we will notify you within fifteen (15) days via (i) email. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

7. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us may be shared by Numberless with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Numberless may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:

We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use or Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Numberless, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Numberless, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not sell, trade, rent, or otherwise transfer personal information to others.

8. YOUR CALIFORNIA PRIVACY RIGHTS

Numberless does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Services that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@mail.numberless.tech.

9. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Services are not meant for use by children under the age of 13. We do not collect and store personal information. Our Services do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at contact@mail.numberless.tech.

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

10. GENERAL DATA PROTECTION REGULATION

a. For European Visitors, Consumers, and Customers.

(i) If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).

(ii) Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.

(iii) In such situations, however, we will still respond to let you know of our decision.

(iv) As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

b. EU Standard Contractual Clauses. We will comply with the EU Standard Contractual Clauses with respect to the transfer of Personal Data from the EU to countries other than the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of personal data to processors established in third countries (Commission Decision 2010/87/EC).

c. Rights of the Data Subject. To make any of the following requests, please contact us (i) via email at privacy@mail.numberless.tech.

(i) Access. You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.

(ii) Rectification. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

(iii) Objection. You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.

(iv) Erasure. You can request that we erase some or all of your Personal Data from our systems.

(v) Restriction of Processing. You can ask us to restrict further processing of your Personal Data.

(vi) Portability. You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.

(vii) Withdrawal of Consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

(viii) Right to File Complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm to locate your Data Protection Authority.

11. CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

a. not use false or misleading subjects or email addresses;

b. identify the email message as an advertisement in some reasonable way;

c. include the physical address of Numberless, Inc., which is Numberless, Inc., 355 Bryant St #407, San Francisco CA 94107.;

d. monitor third-party email marketing services for compliance, if one is used;

e. honor opt-out/unsubscribe requests quickly; and

f. give an “opt-out” or “unsubscribe” option.

12. MODIFICATIONS TO OUR PRIVACY POLICY

We will post any changes to this Privacy Policy in a notice of the change at the bottom of our Website with a hyperlink thereto. Please regularly review this Privacy Policy. Notwithstanding if you continue to use our services, you are bound by any changes that we make to this Privacy Policy.

13. LIST OF THIRD-PARTY SERVICE PROVIDERS

Numberless uses the following third-party service providers for the provision of services as detailed under the Terms of Use or Terms of Service, as applicable.

Name of Third-Party Service Provider:

Amazon Web Services Inc. (North Virginia, US)

Contact Information:

Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/

Address: 410 Terry Avenue North, Seattle, WA 98109-5210

Firebase Cloud Messaging

Contact Information:

Website: https://support.google.com

Telephone: +1(855)817-0841

Additionally, if you have any questions or concerns about our third-party service providers, please email us at contact@mail.numberless.tech.

14. COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Services violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

a. Your physical or electronic signature;

b. Identification of the copyrighted work(s) that you claim to have been infringed;

c. Identification of the material on our Services that you claim is infringing and that you request us to remove;

d. Sufficient information to permit us to locate such material;

e. Your address, telephone number, and email address;

f. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and

g. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

Numberless’ Copyright Agent to receive DMCA Takedown Notices is Attn: Aniruddh Balasubramaniam, 355 Bryant St #407, San Francisco CA 94107, Email: copyright@mail.numberless.tech. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Numberless in connection with the written notification and allegation of copyright infringement.

15. ANTI-BRIBERY COMPLIANCE

Numberless represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”). Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Numberless, or (B) the obtaining or retention of business by Numberless. Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Supplier Personnel.

16. CONTACT US

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

- Aniruddh Balasubramaniam

- Email: privacy@mail.numberless.tech

- Address: Numberless, Inc., 355 Bryant St #407, San Francisco CA 94107.

PLEASE NOTE: IF YOU USE OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE OR OUR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR SERVICES.