Your privacy is important to iSkoot; therefore, iSkoot is committed to respecting Your privacy and the confidentiality of Your personal data, traffic data and communications content. This Privacy Statement is designed to assist You in understanding how iSkoot uses and safeguards the information You provide in using iSkoot's software for your mobile internet telephony and data services.

iSkoot collects and processes, or has third party service providers who collect and process on iSkoot's behalf, personal data relating to You, as strictly necessary to (1) perform the internet telephony and data service, in particular to convey the communications You make by means of the iSkoot Software, (2) invoice to You Your use of the internet telephony and data service and (3) carry out iSkoot marketing activities.

In this Privacy Statement the following capitalized definitions are being used in the singular as well as plural.

Communications Content: any information that is communicated by users of iSkoot Software while using the iSkoot Software.

Feedback Information: any information that is reported to iSkoot by filling in the feedback forms on the Website.

Passive Information: Information that is necessary in order to provide You with the desired functionality of the iSkoot Software, such as a session ID token, source and destination addressing information, and the version of the software You are using.

Personal Data: any information relating to an identified or identifiable user of iSkoot Software and/or internet telephony and data Services, including but not limited to such user's Register Information and Subscriber Information.

PSTN: Public Switched Telephone Network.

Register Information: any information provided when voluntarily registering at the Website, including, but not limited to, username and password.

iSkoot: iSkoot, Inc., a company incorporated under the laws of Delaware, USA.

iSkoot Software: Software that allows You to communicate with any other "buddy system"/internet telephony and data service user from your mobile phone.

Subscriber Information: Information that is necessary in order to verify Your identity and to provide internet telephony and data services, such as Your name, billing information and e-mail address on the Website.

Traffic Data: any data processed for the purpose of the conveyance of communication or the billing thereof, including, but not limited to, the duration of a call and the (IP) numbers of the called party and the calling party.

User Profile: any information about the user, filled in by the user on the Website, that is meant to be shared with other users of the Software, such as your IM chat service ID, that can be searched for by other iSkoot users and/or, only after the user's approval, can be added to another user's "friend's list", including the user's own "friend's list".

Internet telephony and data service: means the payable services provided by iSkoot and/or iSkoot's partners, and other services which may be extended or changed from time to time.

Website: the website located at www.iskoot.com.

You: You, the user of the iSkoot Software and the internet telephony and data service, also used in the form "Your" where applicable.

CONTENTS

• Register Information
• User Profile
• Personal Data of friends
• Feedback Information
• Passive Information
• E-mail addresses

iSkoot does not collect any Communications Content.



3. How does iSkoot use this information and for what purpose?
• Register Information
You need to register to use the iSkoot Software.

• User Profile
iSkoot does not store the User Profile centrally on a server. In the event You choose to make the User Profile available, this information is temporarily transmitted to computers of other users in the peer-to-peer network. Since the User Profile is not stored centrally, iSkoot cannot guarantee that this information will always be available and will not disappear.

• Feedback Information
Any and all information which is voluntarily submitted in feedback forms on the Website, is used for the purposes of reviewing this feedback and improving the iSkoot Software and Website. iSkoot reserves the right to utilize Feedback Information without attribution for marketing purposes, for instance by displaying selected comments on the Website or in other communications. Further, iSkoot may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. iSkoot will not use any personally identifiable Feedback Information without Your explicit permission thereto.

• Passive Information
Passive Information is automatically generated and is not stored centrally. iSkoot will only use this Passive Information, on an aggregated level, to provide You with better service or for statistical information.

• E-mail addresses
iSkoot respects the privacy of personal e-mail accounts and stores Your e-mail addresses just as securely as other Personal Data. iSkoot will not send You unsolicited e-mail messages or junk mail, and Your details will not be passed to third parties without Your explicit permission. However, iSkoot will use e-mail to send You messages about faults and service issues. iSkoot may also use e-mail to keep You up to date with news about the iSkoot Software and internet telephony and data services. If You do not want to be kept informed in this way by e-mail, please contact iSkoot at remove@iskoot.com.

• Subscriber Information
iSkoot asks for Subscriber Information in order to verify Your identity and to provide internet telephony and data services. We use a third party banking organizations and other providers of payment services to bill You for internet telephony and data services and we will, therefore, provide this billing provider with the necessary billing data. This Subscriber Information is securely stored on a server of iSkoot or iSkoot's third party billing provider and is used by iSkoot, as well as by any such third party billing provider, in accordance with relevant legislation.

Please note that Your billing data is sensitive information, which can be used to find out information about Your use of internet telephony and data services. Please be sure to keep this information safe and do not share it with others.

• Traffic Data
In order to transmit Your calls through the PSTN iSkoot collects Traffic Data. iSkoot will erase Traffic Data, or make Traffic Data anonymous, as soon as it is no longer needed for the purpose of the transmission of the communication, unless applicable law provides otherwise.



4. To whom does iSkoot transfer Your personal information?
iSkoot shall not sell, rent or trade any Personal Data, Traffic Data or Communications Content to any third party without Your explicit permission, unless it is obliged to do so under applicable laws or by order of competent authorities.

In order to provide You with internet telephony and data services or other services You have requested, iSkoot may sometimes, if necessary, share Your Personal Data and Traffic Data with carriers, partner service providers and/or agents, for example the PSTN-VoIP gateway provider, distributor of iSkoot Software and/or internet telephony and data service and/or the third party banking organization or other providers of payment services. iSkoot will require these third parties to take appropriate organizational and technical measures to protect Your Personal Data and Traffic Data and to observe relevant legislation.

Please be informed that, notwithstanding the abovementioned, in the event of a competent authority requesting iSkoot or iSkoot's local partner responsible towards such authority, to retain and provide Personal Data and/or Traffic Data, or to install wiretapping equipment in order to intercept communications, iSkoot and/or its local partner will provide all necessary assistance and information to fulfill this request as required by applicable law.

Information collected on the Website may be stored and processed in any country in which iSkoot maintains facilities. In this regard, iSkoot reserves the right to transfer information outside of Your country. As iSkoot continues to develop its business, iSkoot might sell or buy subsidiaries or business units. In such transactions as well as in the event iSkoot or substantially all of its assets are acquired, personal information of iSkoot users will generally be one of the transferred business assets. By using iSkoot Software or internet telephony and data services You consent to any such transfer of information outside of Your country. In case of such transfer, the information remains subject to any pre-existing Privacy Statement.



5. What are cookies and how does iSkoot use them?
Cookies are pieces of information that iSkoot will transfer to Your computer's hard drive through Your browser to enable iSkoot's systems to recognize Your browser. Cookies also enable iSkoot to gain information about the use of its Website and to enhance the Website accordingly to the preferences of the users.

The Help option on the toolbar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether. iSkoot's cookies do not contain any identifying information. Please bear in mind that some personalized services may not be available if You choose to disable cookies.



6. How far does iSkoot's responsibility extend?
The Website may contain links that will let You leave the Website and access another website. Linked websites are not under the control of iSkoot and it is possible that these websites have a different privacy policy. The Privacy Statement applies solely to personal information that is acquired on the Website, so iSkoot urges You to be careful when You enter any personal information online. iSkoot accepts no responsibility or liability for these other websites.



7. How does iSkoot protect Your personal information?
iSkoot shall take appropriate organizational, physical and technical measures to protect the Personal Data and Traffic Data provided to it or collected by it, and shall not retain such information any longer than required in order to perform its services or as required under relevant legislation. Your Personal Data and Traffic Data can be accessed only by authorized employees, consultants or agents of iSkoot, iSkoot's affiliates or iSkoot's third-party service providers who need to have access to these data in order to be able to fulfill their given duties.

iSkoot shall take appropriate technical measures to protect the confidentiality of the Communications Content via its iSkoot Software and internet telephony and data services, with due observance of applicable obligations and exceptions under relevant legislation. Other than for acts of gross negligence, iSkoot hereby disclaims any liability relating to the disclosure of Your Personal Data and Traffic Data.



8. Can this Privacy Statement be modified?
iSkoot reserves the right to modify the provisions of this Privacy Statement if deemed necessary. We will inform You of these changes on the Website. You agree that by continuing to use the iSkoot Software or internet telephony and data services following the publishing of the revised Privacy Statement You indicate your acceptance of the Privacy Statement.



9. What rights do You have and how can You contact iSkoot?
If You would like to exercise your right to view, correct, complete or remove Your Personal Data, please contact iSkoot at remove@iskoot.com. Within a reasonable period of time and upon verification of your identity, iSkoot will fulfill Your request, provided iSkoot will not act contrary to applicable legislation by fulfilling Your request.