SafetyNet Wireless Device Unlocking Policy

1. INTRODUCTION

1.1. Purpose and Scope

This Device Unlocking Policy (“Policy”) sets forth the terms, conditions, and procedures governing SafetyNet Wireless’s (“Company,” “we,” “us,” or “our”) unlocking of wireless devices in accordance with applicable federal and state laws and regulations, including but not limited to:

1. The Unlocking Consumer Choice and Wireless Competition Act, Pub. L. No. 113-144
2. 47 C.F.R. § 27.16
3. The CTIA Consumer Code for Wireless Service
4. All applicable state laws and regulations

1.2. Applicability

This Policy applies to all wireless devices that are:

1. Sold, leased, or otherwise provided by SafetyNet Wireless
2. Locked to the SafetyNet Wireless network
3. Subject to unlocking requests from current or former customers

1.3. Binding Effect

By purchasing, leasing, activating, or using a device from SafetyNet Wireless, you acknowledge that you have read, understood, and agree to be bound by this Policy, which is incorporated by reference into our Terms and Conditions.

2. DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

2.1. “Account Holder” means the individual or entity whose name appears on the SafetyNet Wireless account and who is legally responsible for payment and compliance with service terms.

2.2. “Authorized User” means an individual who has been granted permission by the Account Holder to use services or devices on the account.

2.3. “Device” means any wireless handset, tablet, mobile hotspot, or other equipment capable of connecting to a wireless network.

2.4. “Good Standing” means an account that: (i) has no past-due balances; (ii) is not subject to any payment disputes; (iii) has no unresolved violations of our Terms and Conditions; and (iv) is not under investigation for fraud.

2.5. “Lifeline Device” means a device provided at no cost or at a subsidized price through the federal Lifeline program pursuant to 47 C.F.R. Part 54, Subpart E.

2.6. “Locked Device” or “Network Locked Device” means a device programmed with software, firmware, or hardware restrictions that prevent the device from operating on a wireless network other than SafetyNet Wireless or our underlying carrier networks.

2.7. “Postpaid Service” means wireless service billed after usage on a recurring monthly basis.

2.8. “Prepaid Service” means wireless service that requires payment in advance of usage.

2.9. “Unlock” or “Unlocking” means the removal or disabling of software, firmware, or hardware restrictions that prevent a device from operating on other compatible wireless networks.

2.10. “Unlock Code” means the unique numeric or alphanumeric sequence required to unlock a specific device.

3. DEVICE LOCKING PRACTICES

3.1. Authority to Lock Devices

SafetyNet Wireless reserves the right to lock all devices sold, leased, or distributed by the Company to prevent operation on other carriers’ networks. Such locking is implemented for the following legitimate business purposes:

1. Prevention of fraud, theft, and trafficking of subsidized devices
2. Ensuring devices subsidized through the federal Lifeline program are used in accordance with program requirements under 47 C.F.R. Part 54
3. Protection against unauthorized use or modification
4. Compliance with contractual obligations with device manufacturers and network providers
5. Recovery of device subsidies and promotional pricing
6. Protection of network security and integrity

3.2. Disclosure Requirements

In accordance with CTIA Consumer Code requirements, SafetyNet Wireless shall:

1. Clearly disclose at or before the point of sale whether a device is locked
2. Provide written or electronic notice of unlocking eligibility requirements
3. Make this Policy readily accessible on our website and upon request
4. Provide unlocking eligibility information upon customer inquiry

3.3. No Warranty of Unlock Capability

4. UNLOCKING ELIGIBILITY REQUIREMENTS

4.1. General Eligibility Criteria

A device shall be eligible for unlocking only when ALL applicable conditions set forth in this Section 4 are satisfied. The Company reserves the right to verify all eligibility requirements before processing any unlock request.

4.2. Postpaid Devices

Postpaid devices shall be eligible for unlocking when ALL of the following conditions are satisfied:

1. The device has been active on SafetyNet Wireless’s network for a minimum of sixty (60) consecutive days from initial activation
2. The device has been fully paid for, including without limitation:
   • Full retail price or all installment plan payments
   • Any applicable early termination fees
   • All activation fees and upgrade fees
   • Any other device-related financial obligations
3. The account associated with the device is in Good Standing as defined in Section 2.4
4. The device has not been reported as lost, stolen, or associated with fraudulent activity to SafetyNet Wireless or any device registry or database
5. The requesting party is: (i) the Account Holder; (ii) an Authorized User with written authorization from the Account Holder; or (iii) a former Account Holder who satisfied all obligations while the account was active

4.3. Prepaid Devices

Prepaid devices shall be eligible for unlocking when the following conditions are satisfied:

1. The device has not been reported as lost, stolen, or associated with fraudulent activity
2. The account associated with the device is in Good Standing
3. All prepaid service terms have been satisfied

4.4. Lifeline Program Devices

Devices provided through the federal Lifeline program shall be eligible for unlocking when ALL of the following conditions are satisfied:

1. The device has been active on SafetyNet Wireless’s network for a minimum of twelve (12) months from initial activation
2. One of the following applies:
   • The customer is no longer enrolled in the Lifeline program; OR
   • The customer has properly transferred their Lifeline benefit to another carrier in accordance with FCC rules; OR
   • The customer has maintained continuous Lifeline eligibility and requests unlocking for legitimate purposes
3. The device has not been reported as lost, stolen, or associated with fraudulent activity
4. No federal regulations under 47 C.F.R. Part 54 or state regulations prohibit unlocking
5. Unlocking would not violate any conditions of the Lifeline program or result in waste, fraud, or abuse

4.5. Military Personnel Exception

1. Presentation of valid military orders demonstrating:
   • Permanent Change of Station (PCS) outside the continental United States; OR
   • Deployment to an overseas location for ninety (90) days or more
2. The device is not reported as lost, stolen, or involved in fraud
3. The account has no past-due balance exceeding thirty (30) days

Upon verification, such requests shall be processed within two (2) business days.

4.6. International Travel

The Company may, in its sole discretion, provide temporary international unlock codes subject to the following:

1. The customer provides proof of international travel
2. The device will be automatically re-locked upon detection of use on a U.S. network
3. The customer agrees to additional terms and conditions for international unlocking
4. This temporary unlock does not satisfy permanent unlock requirements

4.7. Additional Restrictions

The Company reserves the right to deny any unlock request if:

1. The request appears to be part of a bulk unlocking scheme
2. The device was obtained through fraud or misrepresentation
3. Unlocking would facilitate illegal activity
4. The requestor cannot verify their identity or authorization
5. The device is subject to a law enforcement hold or investigation

5. UNLOCKING REQUEST PROCESS

5.1. Methods for Submitting Unlock Requests

Customers may submit device unlocking requests through the following channels:

5.2. Required Information and Documentation

All unlock requests must include the following information:

a) Mandatory Information:

• Full legal name of Account Holder
• Device IMEI/MEID number (obtainable by dialing *#06#)
• Mobile telephone number associated with the device
• Account number and authentication PIN/password
• Specific reason for unlock request

b) Additional Documentation (if applicable):

• Proof of purchase for prepaid devices seeking accelerated unlocking
• Military orders for service member exceptions
• Death certificate and estate documentation for deceased Account Holders
• Power of attorney or legal authorization for third-party requests

5.3. Processing Timeframes

The Company shall process unlock requests according to the following timeframes:

5.4. Unlocking Methods and Procedures

Upon approval, the Company shall unlock devices using one of the following methods:

1. Remote Unlock: Over-the-air unlocking without customer action required
2. Unlock Code: Numeric/alphanumeric code sent via SMS or email with instructions
3. Manual Process: Step-by-step instructions for customer-initiated unlocking
4. In-Store Service: Physical unlocking at authorized locations (availability varies)

The Company shall provide clear instructions and technical support for the unlocking process at no additional charge.

5.5. Confirmation and Records

Upon successful unlocking, the Company shall:

1. Provide written confirmation of unlock status via email or SMS
2. Maintain records of the unlock request and completion for no less than two (2) years
3. Update device status in internal systems and relevant databases

6. RESTRICTIONS AND LIMITATIONS

6.1. No Guarantee of Compatibility

Technical limitations may include but are not limited to:

1. Incompatible radio frequencies, bands, or network technologies
2. Absence of required features (e.g., VoLTE, Wi-Fi calling, 5G capability)
3. Carrier-specific software or features that will not function
4. Regional or international compatibility restrictions
5. Network authentication or provisioning incompatibilities

CUSTOMERS ARE SOLELY RESPONSIBLE FOR VERIFYING DEVICE COMPATIBILITY WITH THEIR INTENDED CARRIER.

6.2. Warranty and Risk Allocation

a) Manufacturer’s Warranty: Unlocking performed in accordance with this Policy shall not void the device manufacturer’s warranty, pursuant to the Unlocking Consumer Choice Act.

b) Service Warranties: Unlocking may void:

• SafetyNet Wireless extended warranties or protection plans
• Certain service guarantees or promotional terms
• Technical support eligibility for non-network issues

c) ASSUMPTION OF RISK: CUSTOMERS REQUEST UNLOCKING AT THEIR OWN RISK. THE COMPANY SHALL NOT BE LIABLE FOR:

• Device malfunction following unlocking
• Data loss during or after the unlock process
• Loss of features or functionality
• Incompatibility with other networks
• Any consequential or incidental damages

6.3. Continuing Financial Obligations

Device unlocking does NOT release, waive, or modify any financial obligations, including but not limited to:

1. Remaining device installment payments
2. Service contract commitments
3. Early termination fees or liquidated damages
4. Outstanding account balances
5. Applicable taxes, fees, or surcharges
6. Collection or legal proceedings for unpaid amounts

All financial obligations remain due and payable according to their original terms regardless of unlock status.

6.4. Anti-Fraud and Abuse Prevention

The Company reserves the absolute right to deny, reverse, or refuse any unlock request if:

1. Fraud, misrepresentation, or deception is suspected or detected
2. The device was obtained through fraudulent means or identity theft
3. The request appears to be part of:
   • Bulk unlocking for commercial resale
   • Device trafficking operations
   • Organized fraud schemes
4. The device or account is under investigation by law enforcement agencies, regulatory authorities, or the Company’s fraud prevention department
5. Multiple unlock requests from the same individual exceed reasonable personal use
6. The request violates any federal or state law or regulation

6.5. Reversal of Unlocking

The Company reserves the right to reverse or re-lock a previously unlocked device if:

1. The unlock was obtained through fraud or misrepresentation
2. Payment for the device is reversed, charged back, or disputed
3. The device is subsequently reported as lost or stolen
4. Required by law enforcement or court order

7. UNLOCKED DEVICE SALES

7.1. Sale of Factory Unlocked Devices

The Company may, in its sole discretion, offer factory unlocked devices for direct sale subject to the following terms:

a) Pricing: Unlocked devices shall be sold at full manufacturer’s suggested retail price (MSRP) without subsidies, discounts, or promotional pricing

b) Eligibility Restrictions: Unlocked devices are NOT eligible for:

• Lifeline program subsidies under 47 C.F.R. Part 54
• Promotional pricing or bundled offers
• Device installment plans (unless specifically offered)
• Trade-in credits when purchased unlocked

c) Network Requirements: Unlocked devices must be compatible with SafetyNet Wireless network frequencies and technologies for initial activation

d) No Locking Upon Activation: Devices sold as unlocked shall not be subsequently locked upon activation on our network

7.2. Disclosure Requirements

In accordance with CTIA Consumer Code and FCC requirements, the Company shall clearly disclose the following information for all device sales:

a) At Point of Sale:

• Lock status (locked or unlocked)
• Network compatibility specifications
• Unlocking eligibility requirements if locked
• Any restrictions on use with other carriers
• Warranty terms and limitations

b) Documentation: Written disclosure shall be provided via:

• Receipt or invoice
• Device packaging insert
• Electronic confirmation for online purchases
• Terms and conditions of sale

c) Online Disclosure: Device listings shall prominently display lock status and unlocking policy information

7.3. Previously Unlocked Devices

Devices previously unlocked by SafetyNet Wireless:

1. Shall remain unlocked permanently unless re-locked pursuant to Section 6.5
2. May be reactivated on SafetyNet Wireless network if compatible
3. Are subject to standard service terms upon reactivation

8. FORMER CUSTOMERS

8.1. Eligibility for Former Customers

Former customers may request device unlocking provided ALL of the following conditions are satisfied:

a) Account Status When Active:

• All eligibility requirements in Section 4 were met during active service
• The device was active for the minimum required period
• No fraud or terms violations occurred during service

b) Financial Obligations:

• Final bill paid in full within ninety (90) days of issuance
• No outstanding equipment installment balances
• No unresolved payment disputes or chargebacks
• All early termination fees satisfied

c) Time Limitations:

• Request submitted within two (2) years of account closure
• Device has not been recycled or reported as disposed

d) Device Status:

• Not reported as lost, stolen, or involved in fraudulent activity
• IMEI/MEID not blocked on industry databases

8.2. Verification Requirements

Former customers must provide:

1. Previous account number and associated phone number
2. Device IMEI/MEID number
3. Identity verification matching account records
4. Last four digits of payment method on file (if requested)

8.3. Processing of Former Customer Requests

1. Standard Processing: Within five (5) business days due to additional verification requirements
2. Denied Requests: Former customers whose requests are denied may appeal through the dispute resolution process in Section 11
3. No Technical Support: The Company provides unlock codes/instructions but not technical support for former customers

8.4. Deceased Account Holders

For deceased account holders, the following may request unlocking:

1. Executor or administrator of the estate with court documentation
2. Surviving spouse with death certificate and proof of relationship
3. Next of kin with appropriate legal documentation

Such requests shall be processed within seven (7) business days of receiving complete documentation.

8.5. Business and Government Accounts

Business Accounts:

1. Only authorized representatives listed on the business account may request unlocking
2. Corporate-liable devices require written authorization from an authorized signatory
3. Bulk unlock requests for business accounts must be submitted in writing with justification

Government Accounts:

1. Government-purchased devices may have different unlocking terms per contract
2. Requests must come from authorized government representatives
3. Additional security verification may be required

9. NON-SAFETYNET DEVICES

9.1. Bring Your Own Device (BYOD)

For devices not sold, leased, or provided by SafetyNet Wireless:

a) No Locking Authority: The Company does not and will not lock devices not originally distributed by SafetyNet Wireless

b) No Unlocking Capability: The Company cannot and will not attempt to unlock devices locked by other carriers or manufacturers

c) Customer Responsibility: Customers are solely responsible for:

• Ensuring their device is unlocked before activation
• Contacting the original carrier for unlock codes or procedures
• Verifying device compatibility with our network

d) Information Assistance: Upon request, the Company may provide:

• General information about contacting other carriers
• FCC resources regarding unlocking rights
• No guarantee of accuracy or completeness of such information

9.2. Third-Party Unlocking Services

a) No Endorsement: SafetyNet Wireless does not endorse, recommend, or approve any third-party unlocking service, software, or method

b) Disclaimer of Liability: THE COMPANY SHALL NOT BE LIABLE FOR:

• Device damage resulting from third-party unlocking attempts
• Loss of data or functionality
• Voiding of manufacturer warranties
• Security vulnerabilities introduced by third-party unlocking
• Any costs or fees paid to third parties

c) Service Denial: The Company reserves the right to:

• Deny activation of improperly unlocked devices
• Terminate service for devices that pose security risks
• Refuse technical support for devices unlocked by third parties
• Report illegally unlocked devices to appropriate authorities

9.3. Device Eligibility Verification

The Company may verify that any non-SafetyNet device:

1. Is not reported as lost or stolen in industry databases
2. Has not been altered in ways that violate FCC regulations
3. Is compatible with our network technology and frequencies
4. Does not pose a security threat to our network or other customers

10. COMPLIANCE AND LEGAL NOTICES

10.1. Regulatory Compliance

This Policy is established and maintained in accordance with:

a) Federal Law:

• Unlocking Consumer Choice and Wireless Competition Act, Pub. L. No. 113-144
• Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
• 47 C.F.R. § 27.16 (Network Access Requirements)
• Digital Millennium Copyright Act (DMCA) exemptions for phone unlocking

b) Industry Standards:

• CTIA Consumer Code for Wireless Service
• GSMA Device Unlocking Guidelines (where applicable)

c) State Laws:

• All applicable state consumer protection laws
• State-specific telecommunications regulations
• State contract and commercial law requirements

10.2. Law Enforcement and Legal Process

a) Compliance with Legal Orders: The Company shall comply with:

• Valid court orders and subpoenas
• Law enforcement requests accompanied by appropriate legal process
• National security letters and orders
• Emergency requests involving imminent danger

b) Override of Standard Procedures: Law enforcement requests may override standard unlocking procedures when:

• Required by court order
• Necessary for criminal investigation
• Related to national security matters
• Involving emergency circumstances with risk of death or serious injury

c) Customer Notification: The Company may be prohibited from notifying customers of law enforcement requests.

10.3. Modifications to Policy

a) Right to Modify: SafetyNet Wireless reserves the right to modify this Policy at any time for:

• Compliance with new or amended laws or regulations
• Changes in business operations or network technology
• Security or fraud prevention improvements
• Clarification of existing terms

b) Notice and Effectiveness:

• Updates posted at: www.safetynetwireless.com/unlock
• Routine changes effective thirty (30) days after posting
• Changes required by law effective immediately or as required
• Material adverse changes communicated via bill message, email, or SMS

c) Continued Use: Use of our services after Policy changes constitutes acceptance of modified terms.

10.4. Relationship to Other Agreements

1. This Policy is incorporated by reference into our Terms and Conditions
2. In case of conflict, Terms and Conditions control except where this Policy provides more specific terms
3. Device purchase agreements may contain additional unlocking terms
4. Nothing in this Policy creates rights beyond those required by applicable law

10.5. Severability

If any provision of this Policy is held invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to render it valid and enforceable.

11. DISPUTE RESOLUTION

11.1. Internal Review Process

Customers who disagree with an unlocking decision must first seek resolution through the following escalation process:

a) First Level Review:

• Contact Customer Service: 1-888-224-3213
• Request must be made within thirty (30) days of initial decision
• Response provided within five (5) business days

b) Supervisor Review:

• Available if first level review is unsatisfactory
• Request supervisor review during call or via email
• Decision provided within five (5) business days

c) Written Appeal:

• Submit to: [email protected]
• Include: Original request details, reason for appeal, supporting documentation
• Final decision within ten (10) business days

11.2. External Dispute Resolution

If internal review does not resolve the dispute, customers may:

a) File FCC Complaint:

• Online: consumercomplaints.fcc.gov
• Phone: 1-888-CALL-FCC (1-888-225-5322)
• Mail: Federal Communications Commission, Consumer and Governmental Affairs Bureau, Consumer Inquiries and Complaints Division, 445 12th Street, SW, Washington, DC 20554

b) State Regulatory Agencies:

• Contact information available in Terms and Conditions
• State-specific consumer protection agencies

11.3. Binding Arbitration

All disputes regarding device unlocking not resolved through the above processes are subject to the binding arbitration provisions set forth in our Terms and Conditions, including class action waiver provisions.

12. ADDITIONAL INFORMATION

12.1. Customer Support Resources

For device unlocking assistance:

12.2. Record Retention

SafetyNet Wireless shall maintain records relating to device unlocking for the following periods:

• Unlock requests and decisions: Minimum two (2) years
• Customer communications: Minimum one (1) year
• Policy versions: Minimum three (3) years
• Compliance documentation: As required by law

13. DISCLAIMER OF WARRANTIES

13.1. DISCLAIMER OF WARRANTIES

13.2. LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SAFETYNET WIRELESS AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AFFILIATES, SUCCESSORS, AND ASSIGNS SHALL NOT BE LIABLE FOR:

1. Any indirect, incidental, special, consequential, exemplary, or punitive damages
2. Device malfunction, damage, or failure after unlocking
3. Loss of data, features, or functionality
4. Incompatibility with other carriers’ networks
5. Inability to re-lock the device
6. Lost profits or revenues
7. Cost of replacement devices or services
8. Any damages exceeding the amount paid for the device

13.3. INDEMNIFICATION

Customer agrees to indemnify, defend, and hold harmless SafetyNet Wireless from any claims, losses, damages, liabilities, and expenses (including attorneys’ fees) arising from or related to:

1. Customer’s use of the unlocked device
2. Violation of this Policy or applicable laws
3. Use of third-party unlocking services
4. Misrepresentation in unlock requests

14. JURISDICTION-SPECIFIC PROVISIONS

14.1. State-Specific Requirements

14.2. Territories

Puerto Rico:

• Office of the Telecommunications Regulatory Board oversight
• Spanish language requirements
• Contact: 1-787-756-0804

U.S. Virgin Islands:

• Department of Licensing and Consumer Affairs oversight
• Contact: 1-340-713-3522

14.3. Tribal Lands

For devices used on Tribal lands, additional Tribal telecommunications regulations may apply. Contact relevant Tribal authorities for specific requirements.

14.4. Compliance Notice

This Policy is designed to meet or exceed all state-specific requirements. Where state law provides greater consumer protections than this Policy, state law shall govern. Customers should contact their state’s consumer protection agency for information about their rights.

15. GENERAL PROVISIONS

15.1. Entire Agreement

This Policy, together with our Terms and Conditions, constitutes the entire agreement regarding device unlocking and supersedes all prior understandings or agreements.

15.2. Governing Law

This Policy shall be governed by federal law and the laws of Florida, without regard to conflict of law principles.

15.3. Waiver

No waiver of any provision of this Policy shall be effective unless in writing and signed by an authorized representative of SafetyNet Wireless.

15.4. Assignment

Customers may not assign any rights or obligations under this Policy without prior written consent of SafetyNet Wireless.

15.5. Contact Information