DRAFT. This page was prepared for review by qualified legal counsel before public release. Some sections include placeholders.

Privacy Policy

Last updated: 2026-05-13

Molokai Tech Services LLC ("we," "us," "Molokai Cellular") operates the cellular, phone, and related services offered at ai.molokaitech.com and my.molokaitech.com. This policy explains what we collect, why, and how we handle it.

1. Information we collect

1.1 Information you provide

• Account data: email address, optional name, password (hashed with bcrypt).
• Billing data: processed by Stripe, our payment processor. We do not store full card numbers; we receive only the last four digits and a Stripe customer identifier.
• Service address & emergency location: required for E911 compliance under FCC rules and Hawaii state law.
• Support communications: any messages you send via the customer portal AI support chat, email, or phone.

1.2 Information collected automatically

• Usage and CPNI: call and SMS metadata (numbers dialed, time, duration, location of the connecting cell), data usage by month, device identifiers tied to your SIM/eSIM (ICCID, IMEI), in accordance with the FCC's Customer Proprietary Network Information rules (47 CFR 64.2001-2011).
• Site analytics: IP address, browser user agent, referrer, pages visited. Used for site operations and abuse prevention.
• Security logs: failed logins, suspicious activity, fraud signals.

2. Why we collect it

1. To provide the service you signed up for (provisioning eSIMs, routing calls, etc.).
2. To bill you and prevent payment fraud.
3. To comply with our legal obligations (FCC, IRS, state tax, law enforcement requests under valid legal process).
4. To investigate abuse, security incidents, and policy violations.
5. To respond when you contact support.

3. CPNI — Customer Proprietary Network Information

U.S. federal law (47 CFR 64.2001-2011) treats call records, location, calling-pattern, and service-feature data as CPNI. We do not use, disclose, or permit access to your CPNI for marketing purposes without your prior consent. You may opt in or out of CPNI marketing use at any time by emailing [email protected]. We maintain access logs of every internal CPNI lookup and retain those logs for at least two (2) years.

Our designated CPNI compliance officer is the Member or Manager listed on file with the State of Hawaii Department of Commerce and Consumer Affairs. We file an annual CPNI compliance certification with the FCC under 47 CFR 64.2009(e).

4. Sub-processors and third parties

We share data with the following service providers strictly as necessary to operate the service:

• Stripe — payment processing.
• Anthropic — AI model provider for the customer support chat.
• SMTP provider (mail.hi808.net / SendGrid as applicable) — transactional email delivery.
• Cloudflare — DNS, DDoS protection, edge proxying.
• Carrier / MVNE Partner [TBD — pending agreement] — eSIM provisioning, network access, lawful intercept compliance.
• Twilio — legacy SMS for business phone customers (where applicable).

We do not sell your personal information. We do not share it with advertisers.

5. How long we keep data

• Subscription, billing, and tax records: 7 years.
• CPNI access logs: at least 2 years.
• Support chat transcripts: 1 year.
• Account data after cancellation: up to 90 days, then purged or anonymized.
• Security logs and fraud signals: up to 2 years.

6. Your rights

Depending on where you live, you may have rights under the California Consumer Privacy Act (CCPA), other U.S. state privacy laws, or, if you contact us while traveling from a jurisdiction such as the EU/UK, the GDPR. Regardless of jurisdiction, you may request:

• Access to the personal information we hold about you.
• Correction of inaccurate information.
• Deletion of your account and associated data, subject to legal retention requirements.
• Portability of your data.
• Opt-out of CPNI marketing use.
• Non-discrimination for exercising any of the above rights.

To exercise these rights, email [email protected] from the address on file or contact us by phone at 808-259-1615.

7. Children

Molokai Cellular is not directed at children under 13. We do not knowingly collect personal information from anyone under 13. If you believe a minor has provided us information, contact us and we will delete it.

8. Security

We use TLS for all data in transit, bcrypt for password storage, role-based access controls for staff and contractors, and audit logging for CPNI access. No system is perfectly secure; if we become aware of a breach affecting your personal information we will notify you in accordance with applicable law.

9. International users

All data is processed and stored in the United States.

10. Changes

We will notify you of material changes by email (to the address on file) and by posting a notice on this page at least 30 days before the change takes effect.

11. Contact

Molokai Tech Services LLC
[Mailing Address — pending]
[email protected]
808-259-1615

This page is a draft prepared for review by qualified legal counsel and may not constitute compliant disclosures in all jurisdictions. Molokai Tech Services LLC does not represent that the contents constitute legal advice or that they meet the requirements of any specific regulatory regime as of the date listed above.