U-wifi Privacy Policy

Replacement Clean Draft

Effective Date: September 16, 2026

U-wifi, Inc. ("U-wifi," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit the U-wifi website, establish or use a U-wifi account, purchase or use U-wifi Internet or connectivity services, use a U-wifi-provided gateway or other equipment, use the FreeU application or other U-wifi applications or online services, participate in U-wifi credits, rewards, advertising, or promotional programs, communicate with us, or otherwise interact with U-wifi (collectively, the "Services").

This Privacy Policy applies to personal information collected by U-wifi in connection with the Services. It does not apply to information collected independently by third-party websites, applications, advertisers, services, or other businesses that you may access through the Internet or through links provided by U-wifi.

Your use of the Services is also subject to the U-wifi Terms and Conditions, Acceptable Use Policy, Internet Transparency Statement, and any other terms applicable to a particular Service or program.

1. Information We Collect

The information U-wifi collects depends on the Services you use, how you interact with us, and the choices you make.

1.1 Account and Contact Information

When you establish an account, order Services, communicate with us, or otherwise interact with U-wifi, we may collect information such as:

name;
billing and service address;
email address;
telephone number;
account number and account credentials;
business name and business contact information, where applicable; and
other information you provide in connection with your U-wifi account.

1.2 Billing and Payment Information

We may collect information necessary to bill you and process payments, including payment method information, billing history, transaction information, amounts owed, credits, refunds, and payment status.

Payment card and other payment information may be collected or processed on our behalf by third-party payment processors. U-wifi may not receive or retain complete payment card information when a payment processor handles the transaction.

1.3 Service and Subscription Information

We may collect information concerning the Services you purchase or use, including:

service plan and subscription information;
activation and termination dates;
service location;
promotional offers and discounts;
credits earned or applied to your account;
participation in U-wifi rewards, advertising, or promotional programs;
equipment associated with your account; and
customer preferences and account settings.

1.4 Gateway, Device, and Network Information

When you use U-wifi Internet Service or U-wifi-provided equipment, we may collect technical and operational information necessary to provide and manage the Services, including:

Gateway and equipment identifiers;
serial numbers;
SIM or network identifiers;
IP addresses;
device and connection information;
firmware and software versions;
activation and configuration information;
signal strength and signal quality;
network connection information;
bandwidth and data usage;
upload and download volume;
network performance and diagnostic information;
service interruptions and error information; and
information reasonably necessary to operate, maintain, secure, troubleshoot, and improve the Services.

U-wifi may remotely configure, manage, diagnose, update, secure, and maintain U-wifi-provided equipment as described in the U-wifi Terms and Conditions.

1.5 Internet and Service Usage Information

Because U-wifi provides Internet access, certain network and traffic information necessarily passes through systems used to provide the Service.

U-wifi may collect and use network-level information reasonably necessary to provide the Services, measure usage, administer applicable data-usage thresholds, manage network performance, maintain security, prevent fraud and abuse, diagnose technical problems, comply with legal obligations, and support customers.

For example, U-wifi may measure the amount of data downloaded during a Service Period to administer applicable network-management practices, including the usage threshold described in the U-wifi Terms and Conditions and Internet Transparency Statement.

U-wifi does not use the contents of customers' private communications for personalized advertising except with consent or as otherwise permitted by applicable law.

1.6 Website and Application Information

When you visit a U-wifi website or use a U-wifi application, including FreeU, we may automatically collect information such as:

IP address;
browser and device type;
operating system;
application version;
pages or screens viewed;
dates and times of access;
referring or exit pages;
interactions with website or application features;
advertising or promotional interactions; and
diagnostic, performance, and error information.

We may collect this information through cookies, pixels, software development kits, local storage, log files, and similar technologies.

1.7 Customer Service and Communications

We may retain communications between you and U-wifi, including customer-service requests, emails, chats, complaints, billing inquiries, technical-support information, survey responses, and other communications.

1.8 Information You Voluntarily Provide

We may collect information that you voluntarily provide through surveys, questionnaires, promotions, contests, account profiles, customer-support interactions, the FreeU application, or participation in the U-wifi Credits Program.

Depending on the program, this may include demographic information, interests, preferences, responses to questions or surveys, or information used to determine which offers, advertising, or other content may be relevant to you.

1.9 Information From Other Sources

We may receive information from service providers, technology providers, payment processors, marketing partners, business partners, publicly available sources, and other third parties where permitted by law.

We may combine information obtained from these sources with information we collect directly from you when reasonably necessary for the purposes described in this Privacy Policy.

2. How We Use Personal Information

U-wifi may use personal information to:

provide, activate, maintain, and administer the Services;
establish and manage your account;
provide and manage U-wifi Gateways and other equipment;
process payments and maintain billing records;
apply discounts, promotions, rewards, or credits to your account;
authenticate customers and protect accounts;
provide technical and customer support;
diagnose service or equipment problems;
monitor signal quality and network performance;
measure data usage;
administer applicable data-usage thresholds and network-management practices;
maintain, secure, troubleshoot, and improve the U-wifi network and Services;
prevent and investigate fraud, abuse, unauthorized use, and security incidents;
develop and improve U-wifi products, services, applications, and customer experiences;
communicate with you regarding your account and Services;
send information concerning new or existing U-wifi products, features, or services;
administer surveys, promotions, rewards, and the U-wifi Credits Program;
personalize advertising, offers, recommendations, and other content when you have elected to participate in a program permitting such use;
perform analytics and understand how customers use U-wifi products and services;
maintain business, tax, accounting, and legal records;
establish, exercise, or defend legal claims;
comply with applicable laws, regulations, legal process, and governmental requests; and
carry out other purposes disclosed to you when information is collected or with your consent.

3. U-wifi Credits Program and Personalized Marketing

U-wifi may offer customers opportunities to receive credits that may be applied toward the cost of eligible U-wifi Services by voluntarily participating in U-wifi promotional, advertising, rewards, survey, or personalized marketing programs (collectively, the "Credits Program").

3.1 Participation Is Voluntary

Participation in the Credits Program is voluntary. You are not required to participate in personalized or targeted marketing in order to purchase or receive U-wifi Internet Service. Customers who choose not to participate may purchase the applicable U-wifi Service at its otherwise applicable price but will not receive credits that require participation in the Credits Program.

3.2 Information Used for Personalized Marketing

If you affirmatively choose to participate in a Credits Program involving personalized or targeted marketing, you authorize U-wifi to use information described in this Privacy Policy, as applicable to the particular program, to select, personalize, deliver, and measure advertising, marketing messages, offers, promotions, surveys, recommendations, or other content that U-wifi believes may be relevant to you.

Depending on the particular program and the choices you make, this information may include:

account and subscription information;
general geographic information;
demographic information or interests you voluntarily provide;
responses to surveys or questionnaires;
interactions with the U-wifi website or applications;
interactions with advertisements, offers, or promotions;
participation in prior offers or promotions; and
other information specifically disclosed to you in connection with the applicable program.

U-wifi will not use the contents of your private Internet communications for personalized advertising merely because you participate in the Credits Program.

3.3 Credits

The activities required to earn a credit, the amount or value of a credit, eligibility requirements, expiration dates, limits, and the manner in which credits may be applied will be described in the applicable offer, program description, or other terms presented to you. Unless expressly stated otherwise, credits:

may be applied only toward eligible U-wifi Services;
are not cash or cash equivalents;
cannot be redeemed for cash;
are not transferable; and
may be subject to eligibility, expiration, or other program requirements.

3.4 Service Providers and Marketing Partners

U-wifi may use service providers and marketing or advertising partners to assist U-wifi in administering the Credits Program, providing or selecting advertising or offers, measuring customer interactions, administering surveys, determining eligibility for credits, or performing related services. U-wifi will disclose personal information to such parties only as described in this Privacy Policy, disclosed to you in connection with the applicable program, or otherwise permitted by applicable law.

3.5 Withdrawing From Personalized Marketing

You may withdraw from a voluntary Credits Program or change applicable marketing preferences using the methods made available by U-wifi. If you withdraw consent to personalized or targeted marketing that is required to earn particular credits, you may cease earning future credits associated with that participation. Withdrawal will not prevent you from continuing to purchase U-wifi Internet Service at the otherwise applicable price and will not affect credits already earned except as provided in the applicable program terms. Withdrawal does not affect processing that occurred before your withdrawal.

3.6 Additional Privacy Choices

Participation in the Credits Program does not constitute consent to any use or disclosure of personal information for which applicable law requires separate consent. Where applicable law requires U-wifi to obtain additional consent or provide a right to opt out of a particular use, disclosure, sale, sharing, or processing of personal information, including processing for targeted advertising, U-wifi will provide the required consent or choice mechanism.

4. Network Management and Data Usage

U-wifi uses network and Service information to operate and manage the U-wifi Internet Service. This includes measuring data usage during each Service Period. U-wifi may use data-usage information to determine whether an account has exceeded an applicable usage threshold, including the 1 terabyte download threshold described in the U-wifi Terms and Conditions and Internet Transparency Statement, and to administer any resulting network-management practices.

Network-management information may also be used to:

monitor network capacity and performance;
maintain service quality;
identify congestion;
diagnose technical problems;
optimize Gateway and network performance;
detect malicious, fraudulent, or abusive activity;
maintain network and customer security; and
plan network capacity and improvements.

Additional information regarding U-wifi's network-management practices is available in the U-wifi Internet Transparency Statement.

5. Cookies and Similar Technologies

U-wifi and service providers acting on our behalf may use cookies, pixels, software development kits, local storage, and similar technologies in connection with U-wifi websites and applications.

These technologies may be used to:

enable website and application functionality;
maintain account sessions and preferences;
authenticate users;
protect against fraud and security threats;
understand website and application usage;
measure performance;
improve the Services;
administer promotions and the Credits Program; and
provide or measure advertising where permitted by your choices and applicable law.

Your browser or device may allow you to limit certain cookies or similar technologies. Disabling some technologies may affect the operation of portions of the Services. Where applicable law requires consent or an opt-out mechanism for particular cookies or tracking technologies, U-wifi will provide the applicable choice.

6. How we Disclose Personal Information

U-wifi does not disclose personal information except as described in this Privacy Policy, at your direction, with your consent, or as otherwise permitted or required by law. We may disclose personal information to the following categories of recipients:

6.1 Service Providers

We may provide information to companies that perform services for U-wifi, including payment processing, billing, customer support, cloud hosting, network operations, equipment management, analytics, cybersecurity, communications, marketing, and other business functions. These providers may receive information reasonably necessary to perform services on U-wifi's behalf.

6.2 Network and Technology Providers

U-wifi may use third-party carriers, network operators, technology providers, equipment vendors, and other companies to provide or support the Services. We may provide information to those companies when reasonably necessary to activate, operate, troubleshoot, secure, or support the Services.

6.3 Advertising and Marketing Partners

If you participate in a Credits Program or otherwise make choices permitting personalized advertising or marketing, U-wifi may interact with advertising, marketing, analytics, survey, or promotional partners as described in this Privacy Policy and the applicable program terms. Where applicable law provides a right to opt out of the sale or sharing of personal information or processing for targeted advertising, U-wifi will provide the required privacy choices if U-wifi engages in activities subject to those requirements.

6.4 Professional Advisers

We may provide information to attorneys, accountants, auditors, insurers, financial institutions, consultants, and other professional advisers when reasonably necessary for legitimate business or legal purposes.

6.5 Corporate Transactions

We may disclose or transfer information in connection with an actual or proposed financing, investment, merger, acquisition, reorganization, sale of assets, change of control, bankruptcy, or similar corporate transaction, subject to applicable law.

6.6 Legal Process and Government Requests

We may disclose information when we reasonably believe disclosure is required or permitted by applicable law, regulation, subpoena, court order, warrant, governmental request, or other valid legal process. Where appropriate and legally permitted, U-wifi may review requests for customer information to determine whether they are valid and properly scoped before providing responsive information.

6.7 Protection of U-wifi and Others

We may disclose information when reasonably necessary to detect or prevent fraud, abuse, security threats, unlawful conduct, or violations of U-wifi's agreements or policies; protect U-wifi's network, property, customers, employees, or other persons; or establish, exercise, or defend legal rights.

6.8 At Your Direction

We may disclose information to another person or entity when you direct or authorize us to do so.

7. Aggregated and De-identified Information

U-wifi may aggregate or de-identify information so that it cannot reasonably be associated with a particular individual or household. We may use and disclose aggregated or de-identified information for lawful purposes, including network planning, analytics, research, product development, advertising measurement, business planning, and improvement of the Services. Where required by applicable law, U-wifi will maintain de-identified information in de-identified form and will not attempt to re-identify it except as permitted by law.

8. Data Retention

U-wifi retains personal information for as long as reasonably necessary for the purposes for which it was collected or as otherwise permitted or required by law. The appropriate retention period may depend on the type of information and the purposes for which it is used, including the need to:

provide and administer the Services;
maintain billing and transaction records;
provide customer support;
maintain network and information security;
prevent fraud and abuse;
comply with tax, accounting, regulatory, and legal requirements;
resolve disputes;
enforce agreements; and
establish, exercise, or defend legal claims.

When information is no longer reasonably necessary for these purposes, U-wifi may delete, destroy, anonymize, or de-identify it in accordance with applicable law and U-wifi's retention practices.

9. Information Security

U-wifi uses reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, use, alteration, disclosure, or destruction.

No Internet transmission, wireless network, information system, or method of electronic storage can be guaranteed to be completely secure. Accordingly, U-wifi cannot guarantee the absolute security of personal information. You are responsible for maintaining the confidentiality of your account credentials and for taking reasonable steps to protect your devices, home or business network, and U-wifi account against unauthorized access. If you believe your U-wifi account or credentials have been compromised, you should promptly contact U-wifi.

10. Your Privacy Choices

U-wifi provides customers with choices concerning certain uses of their information. Depending on the Services you use and applicable law, these may include the ability to:

update account and contact information;
manage marketing communications;
enroll in or withdraw from the Credits Program;
manage personalized or targeted marketing preferences;
manage certain cookie or application permissions; and
exercise applicable state privacy rights.

Transactional and service-related communications, including billing, security, account, network, and Service notices, are not marketing communications and may continue even if you opt out of promotional communications.

11. U.S. State Privacy Rights

Residents of certain states may have rights regarding their personal information under applicable state privacy laws. Depending on your state of residence, the nature of the information, U-wifi's activities, and applicable statutory exemptions, these rights may include the right to:

confirm whether U-wifi processes your personal information;
access or obtain a copy of certain personal information;
correct inaccuracies;
request deletion of certain personal information;
obtain certain information in a portable format;
obtain information concerning categories of personal information collected or disclosed;
opt out of certain sales or sharing of personal information;
opt out of processing for targeted advertising;
opt out of certain profiling or automated decision-making activities;
limit certain uses of sensitive personal information; and
appeal U-wifi's response to a privacy request.

These rights are subject to exceptions and limitations under applicable law and may not apply to all information U-wifi maintains. U-wifi may need to verify your identity before processing a privacy request. Where permitted by law, an authorized agent may submit certain requests on your behalf, subject to appropriate verification of the agent's authority and your identity. U-wifi will not unlawfully discriminate against you because you exercise an applicable privacy right. Instructions for submitting a privacy request or exercising an applicable opt-out right will be made available through the U-wifi website or by contacting U-wifi using the information in Section 16 below.

12. Sales, Sharing, and Targeted Advertising

Privacy laws in certain states define terms such as "sale," "sharing," and "targeted advertising" broadly and may apply those terms to some transfers or uses of information that do not involve a traditional sale of information for money. To the extent U-wifi engages in activities that constitute a sale or sharing of personal information or targeted advertising under applicable law, U-wifi will provide any disclosures, consent mechanisms, or opt-out rights required by that law. Participation in a voluntary U-wifi Credits Program does not waive privacy rights that cannot legally be waived and does not eliminate any consent or opt-out mechanism otherwise required by applicable law.

13. Children's Privacy

The Services are not directed to children under 13, and U-wifi does not knowingly collect personal information directly from children under 13 in a manner requiring parental consent under the Children's Online Privacy Protection Act or other applicable law. If U-wifi learns that it has collected personal information directly from a child under 13 in circumstances requiring parental consent without obtaining the required consent, U-wifi will take reasonable steps to delete the information or otherwise address the collection as required by law. Parents or guardians who believe a child has provided personal information to U-wifi may contact us using the information in Section 16.

14. Third-party Websites, Applications, and Services

The Services may contain links to or permit access to websites, applications, products, advertisements, or services operated by third parties. U-wifi does not control the privacy or security practices of independent third parties. Information that you provide directly to a third party, or that a third party independently collects from you, is governed by that third party's privacy practices rather than this Privacy Policy. We encourage you to review the privacy policies of third parties before providing them with personal information.

15. Changes to This Privacy Policy

U-wifi may update this Privacy Policy from time to time to reflect changes in the Services, U-wifi's information practices, technology, legal requirements, or other circumstances. When we update this Privacy Policy, we will post the revised version and update its effective date. If a change materially affects how U-wifi uses or discloses personal information, U-wifi will provide additional notice or obtain consent when required by applicable law. Your continued use of the Services after an updated Privacy Policy becomes effective is subject to applicable law and does not constitute consent where applicable law requires U-wifi to obtain separate affirmative consent.

16. Contact Us

If you have questions about this Privacy Policy, U-wifi's privacy practices, or your privacy rights, or if you wish to submit an applicable privacy request, please contact:

U-wifi, Inc. 1741 Ocoee Apopka Rd, 1st Floor Apopka, FL 32703 Email: support@u-wifi.com