Firethorn Privacy Statement

In this Privacy Statement ("statement"), we, Firethorn Holdings, LLC, provide information about how we collect, use, disclose and transfer personally identifiable data that you provide to us when you visit www.mobilebanking.com (the "site").

Scope

This statement covers only data collected through this site. This statement does not apply to any other data collection or processing, including, without limitation, data collection practices of other web pages to which we link or data that we or our affiliates collect offline or through other web sites. Occasionally, we may refer to this statement in notices and consent requests related to requests for information; under such circumstances, this statement applies as modified in the particular notice or consent request (e.g., with respect to types of data collected or purposes of collection).

Types of Data and Collection Methods

When you do any of the following from the site – request information, subscribe for a service, register as a user, respond to an online survey or otherwise actively send us data – we usually collect data such as your name, your wireless handset device type, your wireless carrier company name, telephone number(s), email address(es), and mailing address(es). In connection with chargeable services, we will also collect payment information (e.g., credit card number and related verification information). In each such instance, you will know what data we collect through the site, because you actively submit it.

When you visit the site, we automatically receive and record information from your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access our web site, the Internet address of web sites from which you link to our site, the computer technology you are using and your movements and preferences on our site. We use technology that many other web sites employ, including, without limitation, "cookies" or small data files stored on your computer's hard drive, to collect information such as the aforementioned. In some instances, we also use cookies to collect information in connection with future visits from that site, to recognize you as a previous visitor and to track your activity on our site. You can refuse cookies by turning them off on your browser. In some instances if you do not have cookies turned on you may not be able to take advantage of some of the functionality of the site, such as participation in surveys.

Collection Purposes, Use of Data

We may use the data we collect for the following general purposes:

• To deliver the application you requested to you
• To respond to the request that you sent us such as your request for information, or your request to subscribe to a service we offer;
• To administer, protect and improve our site and our systems;
• To better understand the preferences of our site visitors and perform market research;
• To identify server problems;
• To compile aggregated statistics about site and subscriber usage;
• To help personalize your experience of our site;
• To improve our products and services and other internal business purposes;
• To inform you about products and services associated with our mobile banking software;
• To inform you about the products and services of participants in our mobile banking software; and
• Any other use we describe at the point where we collect the data.

To the extent permitted by applicable law, we reserve the right to combine the various types of data that we collect and to combine the data that we collect with data that we obtain from third parties or other sources. We may use the combined data for any of the purposes described in this privacy statement.

By providing your cell phone and/or telephone number to us, you agree that such action constitutes a purchase, inquiry and/or application for purposes of telemarketing laws.  Regardless of the fact that your cell phone and/or telephone number may be listed with the Federal Do-Not-Call Registry, or your local State Do-Not-Call list, you expressly consent to receive future information about products and services offered by us via telephone and Short Message Service (sms) or Multi-Media Service (mms) text messaging campaigns, unless you subsequently ask us not to do so.

Interactive Features/Forums

The site may provide interactive features (such as forums) that allow you to disclose information directly to other users. Your participation in such interactive features is completely voluntary and Firethorn assumes no obligations or responsibility with respect to the information you provide or share through such interactive features. To participate in these interactive features, we may require you to register with us and provide certain information such as your name, company name, email address, location, phone number, and desired display name (which may be viewable by other users of the interactive features). We may use the information you provide during the registration process for analytical and development purposes (such as to make product or service enhancements) and to enable you to use the interactive features and to manage your account. You may also personalize our interactive features by voluntarily providing additional information such as your location, instant message contact information, web site address, occupation, and other information. Our interactive features may also allow you to upload an avatar or other graphical representation of yourself. If you voluntarily provide such additional information, it may be viewable by other users of the interactive features - so you should not provide information you do not want other users to see.

Where We Store and Process Data

We keep data we collect in the United States of America, and we may have contractors and employees around the world in various locations, including, without limitation Asia and the European Economic Area.

Disclosures of Personal Information

We are not in the business of selling or renting your information to telemarketers and do not share your personally identifiable information with others, except as follows: We may share your information within the Qualcomm group of companies.  If you would prefer that we not share your information within the Qualcomm group of companies, please see the “Opt-Out” section below to learn about your choices.  We also may share your information with agents and service providers who use the data only on our behalf and for our purposes under confidentiality agreements. We also may share your information with wireless carriers and/or financial institutions that participate in our mobile banking software. We may share your information as required by law or in the interest of protecting or exercising our or others' legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business or assets (including, without limitation, in the event of bankruptcy). Also, we may share your personal information where you have granted us permission. Finally, we reserve the right to fully use and disclose any information collected via the site that is not in personally identifiable form, such as aggregated data.

Opt-Out

In connection with promotions or other projects, we may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. To opt-out of receiving marketing from us or from our sharing of your information within the Qualcomm group of companies for marketing purposes, please contact us at webmaster@mobilebanking.com. You may also unsubscribe from our services by sending an email to webmaster@mobilebanking.com. Please note that our affiliates and other data recipients have their own data privacy policies which may differ from ours, and you would have to contact them separately with respect to opt-out requests for your separate relationships with them.

We reserve the right to communicate electronically with subscribers, whether or not you have opted out, to notify you about service or product affecting changes, respond to your email inquiry, confirm transactions, orders, payments and registrations placed online, send information that you have requested, notify you of updates to terms and conditions of service, make inquires regarding your account, and provide emergency, security and account maintenance information.

Access

If personal information you have submitted through the site is no longer accurate, current, or complete, and you wish to update it, please send an email to webmaster@mobilebanking.com. Upon request we will update or amend your information, but we reserve the right to use information obtained previously to verify your identity or take other actions that we believe are appropriate.

Links

Our website may contain links to other websites that we do not own or operate.  We are not responsible for the content, activities, or privacy practices of those websites, including the use of personally identifiable information about you collected by those websites and our provision of links to such other websites is not an endorsement by us of the those websites or any products or services they may offer.  Those websites and the data that they collect and that you provide them are governed by the privacy policies of such websites and not this privacy statement.

Security

Transmissions over the Internet are never 100% secure or error-free. It is your responsibility to safeguard any password and User ID you use to access the site and to notify us at webmaster@mobilebanking.com if you ever suspect that this password or User ID has been compromised. You are solely responsible for any unauthorized use of the site conducted via your password and User ID.

Children's Privacy

The site is intended for adults in the United States. We do not intentionally or knowingly collect personally-identifiable information from children under the age of 13 and individuals under the age of 13 are prohibited from submitting any personal information on the site.

Amendments

We reserve the right to change this statement from time to time and in our sole discretion. We reserve the right to change, modify, add or remove portions of this statement at any time, but will alert you that changes have been made by indicating on the statement the date it was last updated. When you visit the site, you are accepting the current version of this statement as posted on the site at that time. We recommend that users revisit this statement on occasion to learn of any changes.

Contact Us

If you have questions or concerns about this Privacy Policy, contact us at webmaster@mobilebanking.com or write to us at Firethorn Holdings, LLC, Attn: Privacy Practices, 3333 Piedmont Road, Suite 300, Atlanta, GA 30305.

Last revised: December 5, 2009