Last modified: Dec 1, 2014

At SEVEN Networks Inc. (“SEVEN”, “us” or “we”) we recognize and respect your privacy. This Privacy Policy (“Policy”) applies to your use of the Open Channel applications (the “Apps”), as well as the website www.seven.com and affiliated pages (the “Website”; the Website and the Apps are together referred to as the “Services”). If you have any questions, please contact us at support@seven.com.

We have created this Policy to explain our privacy practices so you will understand what information about you is collected, used and disclosed by SEVEN and its “Affiliates” (businesses that are or become legally part of the same group of companies that SEVEN is part of). We collect information from you in order to provide corresponding service and better user experience. With your consent of this Privacy Policy, your usage, statistics, input while using Open Channel would be collected.

What information does SEVEN collect?

SEVEN collects information to provide better service to all of our users. This enables us to help you make better informed choices in the use of applications or to highlight network issues to your serving network operator which in turn would benefit the community in which you live.

When you sign up for or use our Services we may ask you to provide certain information. For example, we may ask you to provide personally identifying information - information that personally identifies you or can be used to directly contact you - such as your name, e-mail address or phone number. If you contact us, we may keep a record of your communication and contact information.

When you use the Apps, you choose to route all of traffic through, or to, Open Channel in your mobile device and in some cases through Open Channel servers. As a result, we receive information regarding you, your online activities, and your device or browser when you use the Services. For example, we may receive:

· Information about your device, including the type of device, its operating system, the mobile carrier or network, IP address, battery information, GPS or other general location information, and device identifiers. When you download the Apps, you may permit us to access data on or about your device, including permissions obtained through our Apps or your device (e.g. Google Play on Android).

· Information about your mobile applications and data usage, including the applications installed on your device, your use of those applications, the websites you visit, and the amount of data you use.

· Dates and durations of the applications and websites you visit

· Log information and other data from your device, such as webpage addresses and data fields.

· The date, time and duration of phone calls, but not details on the phone numbers you call or receive calls from

· The battery and network performance of your device, including signal quality readings and information on failed calls

· We may also receive geo-location information when you access location-based services on a device that uses one of our Apps. For example, if you access an online map application, we may receive location information as part of the mobile data traffic we receive when you use our Apps. While we receive this data as part of the provision of the Services, we do not log or otherwise collect the content of those communications unless we tell you about it in this Privacy Policy or with your permission.

· Information about you, including personally identifying information.

How does SEVEN use the collected information?

We may use the information we receive to provide, analyze, improve, and develop new and innovative services for users, SEVEN and third parties; to communicate with users; to support advertising and related activities; and to help protect ourselves or someone else. For example, Open Channel may use your information to:

· Provide the Services, such as by optimizing data traffic to reduce your mobile data usage and extend your battery life, monitoring active apps on your device, monitoring network quality, and encrypting data traffic;

· Communicate with you, including about products, services, and events; respond when you communicate with us; and send you information you request or that we think might interest you, such as App updates;

· Analyze how you use applications and data. For example, we may combine the information, including personally identifying information, that you provide through your use of the Services with information about you we receive from third parties for business, analytic, advertising, and other purposes;

· Provide market analytics and other services to third parties;

· Maintain, improve or administer our Services; perform business analyses; provide advertising and related activities either independently or in connection with our Affiliates; or otherwise support our internal operations by activities such as troubleshooting, data analysis, testing, and research;

· Enforce our Terms of Service; prevent unlawful activities and misuse of the Services; protect the legal rights, property, safety, and security of SEVEN, our Affiliates, and our users; and resolve disputes involving you relating to the Services; and

· Comply with applicable laws and assist law enforcement when we have a good-faith belief that such cooperation is reasonably necessary or meets the applicable legal standards.

Sharing Anonymized Information

We may share, sell, transmit, or otherwise make available to third parties information that does not include personally identifying information, or for which we have taken reasonable steps to remove all personally identifying information (“Anonymized Information”). Anonymized Information may provide insights into trends in mobile, app, online, and advertising activities.

Sharing Personally Identifying Information

We do not share or sell users’ personally identifying information to third parties unless you give us permission to do so (including by your use of the services as described by this Privacy Policy) or we have given you notice, such as by telling you about it in our App, or in certain other circumstances. Specifically, we may share personally identifying information in the following instances:

· Affiliates. We may share (or receive) information, including personally identifying information, with (or from) our Affiliates (as defined above) to help provide, understand, and improve our Services (such as by providing analytics) and Affiliates' services (including by providing you with a better and more personalized experience). For example, if you have an account with an Affiliate, that Affiliate may combine personally identifying information that it receives from Open Channel with information that it maintains about you, for a variety of business, operational, and advertising purposes.

· Service Providers. We may share your information, including personally identifying information, with third parties that perform services on our behalf to help us provide, understand, or improve the Services. For example, we may use Affiliates or other partners to help host our services and databases, perform analyses or research, send communications on our behalf, or measure the effectiveness of our advertising. Our service providers agree to only use your information in accordance with our agreements with them as well as this Privacy Policy.

· Other Parties When Required By Law or as Necessary to Protect the Services. We may access, use, preserve, and share your information, including your personally identifying information, with third parties when we have a good faith belief that it is necessary to: detect, prevent and address fraud and other illegal activity; protect ourselves, you and others, including as part of investigations; or prevent death or imminent bodily harm. We may also share such information if we believe that you have abused your rights to use the Services or violated an applicable law, or in connection with any dispute between you and us with respect to the Services.

· In Response to a Legal Request. We may also access, use, preserve, and share your information, including your personally identifying information, in response to a legal request if we believe in good faith that the response is required by law in that jurisdiction, applies to users in that jurisdiction, and is consistent with internationally recognized standards. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, investigation concerning possible violations of our terms or policies, or otherwise to prevent harm

· In Connection With a Transfer of Assets. If we sell all or part of our business, make a sale or transfer of assets, are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may disclose and transfer your personally identifying information to one or more third parties as part of that transaction.

· Other Disclosures. We also may disclose personally identifying information as described to you at the point of collection or pursuant to your consent.

Our Services may offer publicly accessible blogs or community forums. Any information you provide in these sections will be public and may be read, collected, and used by anyone who access them.

Data Retention

The metrics gathered by Open Channel Client are held in a secure temporary location on the device in an encrypted form that cannot be read without specifically designed tools and is never in human readable format. The length of time this information is held on the device before upload is based on the frequency of uploads (typically less than 24 hours) In uploading the data to Open Channel servers, the mobile device will use a secure encrypted channel to the network server and transmit the information from the device to the Open Channel server.

We may retain information regarding you and your use of the Services, including personally identifying information, for as long as needed to provide you with the Services and the uses described in this Privacy Policy. This often means that we will keep information for the duration of your account.

If you stop using the Services, you can request that we remove the personally identifying information that we collected from you through the Services by contacting us at support@seven.com. We reserve the right to reject requests that would require and unreasonable technical effort or are unnecessarily repetitive. We will not delete information that we believe is necessary to comply with our legal obligations, to resolve disputes, or to enforce our agreements.

Please note that in the course of providing the Services we collect and maintain Anonymized Information, which we may retain indefinitely.

Security

We maintain adequate safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive. While we strive to protect your information and privacy, no data transmission or storage can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of information you disclose or transmit to us and cannot be responsible for the theft, destruction, misuse, unauthorized access, alteration, or inadvertent disclosure of your information.

International Transfers

We may store and process your information through third-party or Affiliate hosting services in the United States, European Economic Area (“EEA”), and other international jurisdictions. As a result, we may transfer your information, including personally identifying information, to a jurisdiction with different data protection laws than your jurisdiction. By using the Services, you explicitly and unambiguously consent to the transfer of your information internationally, including but not limited to the United States, for the purposes described in this Privacy Policy.

Children’s Privacy

If you are under 13, you may not use any of the Services. The Services are not intended for use by or directed to, persons under the age of 13 and we do not knowingly collect personal information from such persons.

Your California Privacy Rights

California law permits residents of California to request certain details about what personal information a company shares with third parties for the third parties' direct marketing purposes. Seven Networks Inc. does not share your personal information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission. If you have questions about our sharing practices or your rights under California law, please write us at Seven Networks, Inc., 959 Skyway Rd Suite #100, San Carlos, CA, 94070.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our privacy practices. If we make any material changes, we may notify you by contacting you through our services, emailing you (to the address specified in your account, if we have an address for you), or by posting a notice on the Apps or our Website – or by some combination of these methods. We encourage you to periodically review the Website for the latest information on our privacy practices.

If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of all Applications, the Services and the Website. Your continued use of any Application, the Services or the Website following the posting of any modifications to this Policy will constitute your acceptance of the revised Policy. Please note that none of our employees or agents has the authority to vary any of our Policies.

Contacting Us/Reporting Violations

If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of an Application, the Services or the Site, please contact us at support@seven.com