1. Introduction & Scope

MVNX Link, LLC ("MVNX Link", "we", "us", or "our") is a Nevada limited liability company that provides technology, onboarding, implementation, account-management, and support services for companies launching or operating mobile virtual network operator (MVNO) businesses. This Policy explains what personal information we collect through our public website, customer portal (the "Portal"), application and onboarding processes, and ongoing business relationship, how we use and share it, the choices and rights available to you, and how to contact us.

This Policy applies to prospective and onboarded MVNO clients ("Applicants" or "MVNO Clients"), including their owners, officers, employees, and other authorized representatives. It does not cover an MVNO Client's own end subscribers. Subscriber information is governed by the applicable MVNO Client's subscriber-facing privacy policy.

2. Definitions

Personal Information / Personal Data

Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including individuals acting in a business or professional capacity.

Sensitive Personal Information

A subset of personal information subject to heightened protection under certain laws, which may include government identifiers, financial account information, and precise geolocation.

Applicant / MVNO Client

A company or individual that seeks to launch or operate an MVNO using MVNX Link services, or that has executed an agreement with MVNX Link to do so.

Automated Decision-Making / Profiling

The use of a computational process, including artificial intelligence or machine learning, to process personal information and evaluate, analyze, or predict aspects of an individual's or Applicant's behavior, characteristics, risk, or eligibility.

3. Information We Collect

Business and Representative Identifiers

• Company name, business address, website, and entity information
• Name, title, email address, and phone number of authorized representatives
• Employer Identification Number (EIN) or other business tax identifiers
• Portal account credentials

Application, Underwriting, and Compliance Data

• Business plans, launch timelines, target markets, and projected subscriber volumes
• Financial information submitted for underwriting or billing setup
• Beneficial ownership information and government-issued identification collected for KYC/AML verification
• Results of sanctions, export-control, and watchlist screening

Technical and Usage Data

• IP address, browser type, operating system, device type, login activity, pages viewed, workflow activity, and information collected through cookies and similar technologies

Communications and Third-Party Information

We may collect emails, support tickets, call recordings with notice where required, and other correspondence, as well as information from KYC/AML and identity-verification vendors, sanctions-screening providers, financial-verification services, and underlying technology, MVNA, connectivity, or MVNO-of-record partners involved in evaluating or providing service.

4. How We Use Your Information

• Evaluate, underwrite, and process applications and exploration requests
• Perform KYC/AML, sanctions, and export-control screening
• Negotiate, execute, and administer contracts and related agreements
• Configure, provision, implement, and support MVNO services
• Administer accounts, billing, requests, and ongoing customer support
• Detect, investigate, and prevent fraud, misuse, and unauthorized access
• Comply with applicable law and lawful requests from public authorities
• Understand, develop, test, secure, and improve our website, Portal, services, and automated tools

5. Our Use of Artificial Intelligence and Automated Decision-Making

We use, or may use, AI, machine learning, and other automated systems to help operate and improve our website, Portal, onboarding, security, and support processes. Automated tools may assist with sanctions/watchlist matching, fraud and security detection, customer-support routing or responses, and quality assurance.

Where automated decision-making produces a legal or similarly significant effect concerning an Applicant, we will provide notice, explanation, human review, or appeal rights to the extent required by applicable law.

We do not use your personal information to train third-party or publicly available AI models. We may use de-identified or aggregated data to improve our own automated tools.

6. Regulatory and Compliance Disclosures

AML and KYC

As part of onboarding an MVNO Client, we may collect and verify beneficial ownership, identity, and business information consistent with applicable requirements and industry practices.

Sanctions and Export Control

We may screen Applicants and beneficial owners against U.S. Treasury OFAC sanctions lists and other applicable watchlists and do not knowingly provide services to sanctioned parties or in violation of U.S. export-control law.

CAN-SPAM

Marketing emails are sent in accordance with applicable law and may be unsubscribed from without affecting service-related communications.

CPNI

This Policy does not itself govern end-subscriber Customer Proprietary Network Information (CPNI). Subscriber-facing CPNI practices are addressed in the applicable MVNO Client's privacy policy.

7. Your Privacy Rights Under State Law

Depending on your state of residence and applicable law, you may have rights to know or access personal information, correct inaccuracies, request deletion subject to legal exceptions, obtain portable copies of certain information, opt out of certain sale, sharing, targeted advertising, profiling, or automated decision-making, receive non-discriminatory treatment, and appeal certain privacy-request decisions.

To exercise a right, contact us using Section 18. We may verify your identity and will respond within the timeframe required by applicable law. An authorized agent may submit a request where permitted, subject to verification.

8. California-Specific Disclosures

For California residents, the categories of information described in Section 3 may include identifiers, commercial and financial information, internet or electronic-network activity, audio/electronic/visual information, professional information, sensitive personal information used for KYC/AML or billing, and inferences drawn from such information.

We do not sell personal information for monetary consideration and do not share personal information with third parties for cross-context behavioral advertising. We use sensitive personal information for the business, security, compliance, and service purposes described in this Policy.

9. Children's Privacy

MVNX Link's website and Portal are business services intended for adults acting on behalf of an Applicant or MVNO Client. They are not directed to children, and we do not knowingly collect personal information from children under 13.

10. How We Share and Disclose Information

We may disclose personal information to underlying MVNA, connectivity, MVNO-of-record, and technology partners as needed to evaluate, provision, and support service; platform and BSS/OSS providers; KYC/AML, identity-verification, sanctions-screening, payment, and financial providers; professional advisors; government authorities or other parties where legally required; a successor in a merger, acquisition, financing, or sale of assets; and other parties with your consent or at your direction.

We do not sell personal information for monetary consideration or disclose it to advertising partners for cross-context behavioral advertising.

11. Cookies, Analytics, and Tracking Technologies

We and our service providers may use strictly necessary cookies for authentication and operation, performance or analytics technologies to understand usage, and functional technologies to remember preferences. You can control cookies through browser settings. Where required by law, we honor applicable opt-out preference signals as described in Section 15.

12. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction, including appropriate encryption, access controls, monitoring, and vendor security requirements. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Data Breach Notification

If a security incident involving personal information triggers a notification obligation, we will notify affected individuals and regulators where required in accordance with applicable law.

Appeal Rights

If we decline a privacy-rights request and applicable law provides an appeal right, you may appeal by contacting us under Section 18 and stating that you are submitting an appeal.

14. Data Retention

We retain personal information for as long as reasonably necessary to evaluate an application, administer the MVNO Client relationship, fulfill the purposes described in this Policy, and comply with applicable legal, regulatory, tax, accounting, contractual, and security obligations. Retention periods vary depending on the nature of the information and the purpose for which it was collected. When information is no longer required, we securely delete or de-identify it in accordance with our data-retention practices.

15. Do Not Track and Global Privacy Control Signals

Some browsers transmit "Do Not Track" signals; because there is no accepted industry standard for responding to them, we do not currently respond to those signals. Where required by applicable law, we honor Global Privacy Control (GPC) or other legally recognized opt-out preference signals.

16. Third-Party Links and Services

Our website and Portal may contain links to third-party websites, applications, or services that we do not own or control. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing information.

17. Changes to This Policy

We may update this Policy to reflect changes in our practices, services, technology, or applicable law. We will post the updated Policy with a new Last Updated date and, where required, provide additional notice of material changes.

18. Contact Us

If you have questions about this Policy or wish to exercise privacy rights, contact: