WINN TELEPHONE COMPANY -
CUSTOMER PRIVACY POLICY
Winn Telephone Company (“WTC”) together with its affiliated companies,
including Winn Telecom is committed to respecting and protecting the privacy of
our customers. As discussed below, we have strict policies governing access by
employees and others to customer communications and information. We access
customer accounts, records or reports for authorized business purposes only. We
educate our employees about their obligation to safeguard customer information
and communications, and we hold them accountable for their actions. In short,
privacy is a priority for WTC in all aspects of our business.
This Customer Privacy Policy is divided into four sections: Section I:
general principles that express WTC’s commitment to assuring strong and
meaningful customer privacy protection; Section II: WTC’s protection of the
confidentiality of Customer Proprietary Network Information (CPNI); Section III:
WTC’s “Do Not Call” practices, which are designed to protect our customers from
unwanted telemarketing; and Section IV: WTC’s contact information should you
have any questions about this policy or WTC’s privacy practices more generally.
GENERAL PRIVACY PRINCIPLES
The following principles express WTC’s commitment to assuring strong and
meaningful customer privacy protection, and are intended to guide WTC’s efforts
to balance customer privacy with customer interest in receiving quality
services. These principles apply to our use of "individual" customer information
– that is, information about specific customers.
“Individual” customer information includes “personal information” –
information particular to you, including your address, phone number, fax number
and email address – and “non-personal information” that may include information
such as your network traffic data, services and features used or call record
details. These policies are fully
consistent with applicable laws and regulations governing privacy, including the
regulations of the Federal Communications Commission (“FCC”). Individual
customer information is distinct from “aggregated” customer information, which
does not reveal a customer’s identity. Further, the examples provided below are
intended to be illustrative, not all-inclusive.
1.
WTC Obtains and Uses Individual Customer
Information for Business Purposes Only.
WTC obtains and uses customer information that helps us to provide our
customers with quality telecommunications services. In addition to supporting
the direct provision of service, this information may be used to protect
customers, employees and property against fraud, theft or abuse; to conduct
industry or consumer surveys; and to maintain good customer relations. Access to
databases containing customer information is limited to employees who need that
information to perform their jobs. These employees are required to follow strict
rules when handling customer information, and are subject to disciplinary action
if they fail to do so.
In order to better serve our customers, we may ask them questions to
elicit additional information about their special needs and interests. For
example, we may ask whether customers work at home, whether any members of the
household have special needs, or whether teenagers reside in the household in
order to determine whether customers may be interested in or might benefit from
additional lines or services. In all cases, the information we gather is used to
facilitate the provision of quality customer service. We do not share this
information with third parties to market non-WTC services to our customers.
2. WTC Collects
Information from Customers in a Number of Different Ways.
WTC may collect information from you through communications such
as via the web, or by phone, email or mail delivery, or through the services
provided to you as the customer.
You may visit our site without divulging any personal
information; however, there are areas of the website that might require personal
information in order to contact WTC directly, specifically, when registering
e-mails, obtaining remote access, and contacting online technical support.
Information may also be collected in the following ways:
-IP addresses may be collected for the purposes
of system administration, to gather broad demographic information, and to
monitor the level of activity on our site.
-Information may be collected regarding the
referring URL, which browser you used to come to our site, and the pages of our
site that you viewed during your visit and any search terms entered on our site.
-E-mails may be sent by the customer to WTC on
this website. WTC may retain the
information in any e-mail that you send to us, such as your name, e-mail,
address, or telephone number.
·
Broadband Internet Service
-WTC may monitor the network and take measurements of
network performance and the performance of your Internet connection to improve
the customer’s, or WTC’s, overall service levels.
-during communications with WTC for service support, we
may also access information about your customer premise equipment such as
computers and wireless modem devices or other device settings to provide
customized technical support or to install specific applications or services for
your use.
-WTC reserves the right to access broadband traffic
from individual accounts for the purposes of general maintenance and management
of the network, as well as upon request by law enforcement officials.
·
Provision of Information
by Third Parties
-WTC may
obtain credit information about you from third parties when you purchase
products or services from WTC.
·
Information Collected on Our Websites
-We collect data about visitors to our
subscriber website, using some
automated means such as Google Analytics, and reserve the right to use other
methods such as cookies, clear GIFs, and passive automatic electronic
collection. We may work with third-party companies to engage in such collection.
3.
WTC
Informs Customers Regarding How Information Is Used
WTC uses customer information in a transparent fashion, and discloses to
customers the types of information WTC obtains about them how and when that
information is used, when that information might be disclosed,
the stringent measures we employ to protect that
information, and ways that customers can restrict the use or
disclosure of that information. This Privacy Policy is available on our website
at http://www.winntelephone.com
and from WTC service representatives.
4. WTC Gives Customers Opportunities To
Control Access to Information.
WTC is committed to providing customers with opportunities to control
how WTC uses customer information about them. For example, customers may inform
us of which telephone listings they want to include in our directories and in
directory assistance and may also choose to have a non-published number, or a
non-listed number, or to exclude your address from your listing. Customers in
areas where Caller ID services are available have the ability to block the
display of their phone numbers and names. (Note that Caller ID blocking does not
prevent the transmission of your phone number when you dial certain business
numbers, including 911, or 800, 888, 877, and 900 numbers.) Further, customers
can express a preference not to be called for marketing purposes (please see
Section III, below, for more information on WTC’s “Do Not Call” policy).
Customers may also opt out of our direct mailings and other service marketing
programs. (Please see Section II, below, for WTC’s policy on the use of
“Customer Proprietary Network Information”). A
customer may indicate a change in such preferences at any time by contacting WTC
customer service.
We do use individual customer information internally for planning
purposes – so that we can, for example, develop, test and market new products
and services that meet the needs of our customers. Ordinarily, such information
is combined into aggregations that do not include individual customer
identities. Under certain circumstances, we are required by law to disclose the
aggregated information to other companies, but in such cases customer identities
are not included.
5.
WTC Enables Customers To Control How WTC Discloses Individual Information.
Ordinarily, WTC will only share individual customer information with
persons or entities outside the company to assist us in the provision of
services to which the customer subscribes, or as required by law or to protect
the safety of customers, employees or property. We do not use third-party
marketers, nor do we share access to individual customer information derived
from the provision of WTC telecommunications services with other companies
interested in marketing other services to our customers – and we would not do so
without the consent of the customer. WTC is committed to ensuring that customer
information is not used without the knowledge and permission of our customers.
However, there are exceptions to our general practice. For example,
unless you request otherwise, we may share certain non-sensitive information
with our affiliated companies with whom we have established business
relationships. In addition, if WTC
enters into a merger, acquisition, or sale of all or a portion of its assets, a
customer’s personally identifiable information will, in most instances, be
transferred as a part of the transaction, subject to required notices to
affected customers. In addition, we may, where permitted by law, provide
information to credit bureaus, or provide information and/or sell receivables to
collection agencies, to obtain payment for WTC billed products and services. We
are also required by law to provide billing name and address information to a
customer’s long distance carrier and other telephone companies to allow them to
bill for telecommunications services. (By law, customers with non-published or
unlisted service have the right not to have their billing name and address
disclosed when they make a calling card call or accept a collect or third party
call. However, if they do restrict disclosure, they will be unable to make
calling card calls or accept collect and third party calls.) Similarly, we are
required to provide directory publishers with subscriber listing information –
name, address and phone number, and for yellow page advertisers, primary
advertising classification – for purposes of publishing and delivering
directories. In addition, under certain circumstances, we may share customer
information with other carriers or with law enforcement, for example, to prevent
and investigate fraud or other unlawful use of communications services.
6. All WTC Employees Are Responsible
For Safeguarding Customer Communications and Information.
WTC takes reasonable precautions to protect your personal information
against unauthorized access. WTC
requires WTC personnel to be aware of and protect the privacy of all forms of
customer communications as well as individual customer records. WTC makes clear
that employees who fail to comply with its privacy policies will face
disciplinary action, which can include dismissal. All employees are trained
regarding their responsibilities to safeguard customer privacy. We strive to
ensure that information we have about our customers is accurate, secure and
confidential, and to ensure that our employees comply with our privacy policy.
We never tamper with, intrude upon or disclose the existence or contents
of any communication or transmission, except as required by law or the proper
management of our network. Access to databases containing customer information
is limited to employees who need it to perform their jobs – and they follow
strict guidelines when handling that information. We use safeguards to increase
data accuracy and to identify and authenticate the sources of customer
information. We use locks and physical security measures, sign-on and password
control procedures, and internal auditing techniques to protect against
unauthorized use of terminals and entry into our data systems. WTC requires that
records be safeguarded from loss, theft, unauthorized disclosure, and accidental
destruction.
In addition, sensitive, confidential, or proprietary records are
protected and maintained in a secure environment. It is our policy to destroy
records containing sensitive, confidential, or proprietary information in a
secure manner. Hard copy confidential, proprietary, or sensitive documents are
made unreadable before disposition or recycling, and electronic media must be
destroyed using methods that prevent access to information stored in that type
of media. Just as employees would report stolen property, missing records and
suspicious incidents involving records are referred to WTC Management. We
encourage our employees to be proactive in implementing and enforcing WTC’s
privacy policies. If employees become aware of practices that raise privacy or
security concerns, they are required to report them to their supervisors.
WTC’s regulatory department is responsible for ensuring that all WTC
business units and their employees comply with privacy laws and regulations. WTC
also requires any consultants, suppliers and contractors that may come into
contact with customer proprietary information to observe these privacy rules
with respect to any of our customers’ individual customer information. They must
abide by these principles when conducting work for us, and they will be held
accountable for their actions.
7. WTC Takes Special Care to Protect the Safety and
Privacy of Young People Using Its Services.
WTC does not knowingly collect information about children. WTC believes that
children should get their parents’ consent before giving out any personal
information. WTC encourages parents
and legal guardians to participate in their child’s experience using WTC’s
services. Children should always ask
a parent for permission before sending personal information to WTC.
8. WTC Complies with All Applicable
Privacy Laws and Regulations Wherever WTC Does Business.
Customer and policymaker perceptions of privacy have changed over time
and will continue to do so. Changes in technology can also alter what is
appropriate in protecting privacy. Laws may change accordingly. We regularly
examine – and update as necessary –WTC’s privacy policies and internal
procedures to ensure compliance with applicable law and evolving technology. WTC
also will monitor customer needs and expectations. WTC will work with
policymakers and consumers to ensure that we continue to safeguard privacy,
giving customers choices, flexibility and control. WTC considers privacy laws
and regulations to be the minimum standards to which we will adhere in
protecting privacy. In addition to complying with the law, WTC will adhere to
its internal privacy policies and procedures wherever we do business.
9. WTC Gives an Authorized Gov’t Agency
Access to Customer Information Only Upon Valid Request
WTC may release customer information in response to requests from
governmental agencies, including law enforcement and national security agencies,
in accordance with federal statutory requirements or pursuant to court order.
Before releasing any customer information, WTC will ensure that the underlying
governmental request satisfies all procedural and substantive legal requirements
and is otherwise proper. For example, WTC will ensure that any court orders are
valid, properly issued, and legally enforceable. Except as required by law or
with the approval of the customer, WTC will not release any customer information
in response to subpoenas or similar requests issued by private parties. Further,
WTC will be diligent in authenticating the validity of any “governmental”
request to ensure that the request actually originates from an authorized
government agency.
10. WTC Uses Customer Proprietary
Network Information (CPNI) In Accordance with the Law
Customers count on WTC to respect and protect the privacy of information
we obtain in the normal course of providing telecommunications services to our
customers. WTC is committed to protecting the privacy of all customer
information, and in particular the privacy of customer proprietary network
information (or CPNI).
a.
Definition of "Customer Proprietary Network Information."
The term “customer proprietary network information” is defined by
federal statute to mean: (i) information that relates to the quantity, technical
configuration, type, destination, location, and amount of use of a
telecommunications service subscribed to by any customer of a telecommunications
carrier, and that is made available to the carrier by the customer solely by
virtue of the carrier-customer relationship; and (ii) information contained in
the bills pertaining to telephone exchange service or telephone toll service
received by a customer of a carrier.
b.
Use of Customer Proprietary Network Information.
Under federal law, you have the right to, and we have the duty to
protect, the confidentiality of your CPNI. However, we may use CPNI without your
consent, in a manner consistent with applicable law, to: (i) initiate, render,
bill, and collect for our services; (ii) market services among the categories of
service to which you already subscribe; (iii) provide inside wiring
installation, maintenance, and repair services; (iv) provide maintenance and
technical support for our services; (v) protect our rights and property, and
protect users of our services and other carriers from fraudulent, abusive, or
unlawful use of, or subscription to, these services; and (vi) provide any
inbound telemarketing, referral, or administrative services for the duration of
a customer-initiated call.
Further, after providing you with the required notice and opportunity to
“opt out,” we may use your CPNI, in a manner consistent with applicable law, to
market additional communications-related services to you and conduct surveys in
order to improve our service offerings.
WTC will not use your CPNI for purposes other than those described above
unless we first obtain your express “opt in” consent. For example, without such
consent we will not use CPNI to market services not provided by WTC, and will
not share your CPNI with third parties (subject to the limitations discussed
below).
c.
Limits on the disclosure of CPNI outside
WTC.
As a general rule, WTC does not use third-party marketers and will not
disclose your CPNI to third party contractors without your explicit “opt in”
consent. This means that our records of the services you buy and the calls you
make generally will remain private if you choose to keep them so, since we will
not ordinarily disclose this information to outside parties without your
permission. However, we will release customer information without involving you
if disclosure is required by law, or necessary to protect the safety of
customers, employees or property. For example: When you dial 911, information
about your location may be transmitted automatically to a public safety agency.
Certain information about your long distance calls may be transmitted to
your long distance company for billing purposes. We are also required by law to
give competitive local exchange carriers access to customer databases for
purposes of serving their customers, to exchange credit information with other
carriers, and to provide listings (other than certain non-published and
non-listed information) to directory publishers.
We will disclose information as necessary to comply with law enforcement
statutes, such as to comply with valid, properly issued, and legally-enforceable
subpoenas, warrants and court orders.
We may, where permitted by law, share CPNI with third parties where
necessary to provide the services to which you subscribe, to protect our rights
or property, and to protect users of our services and other carriers from
fraudulent, abusive or unlawful use of services.
We may, where permitted by law, provide CPNI to third parties such as
credit bureaus, or sell receivables to collection agencies, to obtain payment
for WTC billed products and services.
d. Authentication to prevent
unauthorized access to CPNI.
WTC is committed to ensuring that only properly authorized individuals
are able to access CPNI for legitimate purposes. This includes ensuring that any
request by a “customer” to access CPNI is valid and properly authenticated, in
accordance with applicable law and industry best practices. In general, our
internal policies and procedures are designed to ensure that CPNI is not
released to unauthorized individuals.
Further, if a “customer” calls us to access “call detail records” (which
include the number called, the number from which a call was placed, and the
time, location, or duration of any call), we will not release those records
unless (i) during the call, the customer provides a pre-established password;
(ii) the information is sent to the customer’s address of record; or (iii) after
the call, we call the customer’s telephone number of record to provide the
requested information. If a “customer” attempts to access CPNI through our
website, we will only provide such access if the customer has first established
a password and back-up authentication mechanism for the relevant account, in a
manner that does not rely on readily-available biographical or account
information. If a “customer” attempts to access CPNI by visiting a retail
location in person, we will only provide such access if the “customer” presents
valid photo identification matching the name of record on the account. (Note
that different procedures may apply to certain business customers served by a
dedicated account representative where the underlying service agreement
addresses CPNI protection and authentication.) We also will notify you at your
address of record if anyone changes the access authorization or authentication
information associated with your account.
e.
Notice of unauthorized access to CPNI.
As a company, we are vigilant in our efforts to protect your CPNI.
However, should we become aware that your CPNI has been accessed without proper
authority, we will take swift action to fully document and address such
unauthorized access and provide appropriate notice. In particular, we will (i)
notify law enforcement (including the United States Secret Service and the
Federal Bureau of Investigation) within seven business days; and (ii) notify you
and any other affected customers within seven business days thereafter, unless
earlier notification is necessary to avoid immediate and irreparable harm, or we
are instructed by law enforcement personnel to refrain from providing such
notice.
11. WTC’s "Do Not Call" List
Any WTC customer can express a preference not to be called by us for
marketing purposes, and WTC will respect such preference. A customer that does
not wish to receive sales calls from WTC specifically may ask to be placed on
our company-specific “Do Not Call” list. We will note the customer’s request
immediately, although it may take up to 30 days for the customer’s telephone
number to be removed from any active lists or sales programs that are currently
underway.
Any customer can ask to be put on our “Do Not Call” list by contacting
WTC’s customer service department.
All customers should call
989-866-2421. The requesting customer should provide, at a minimum, the
telephone number that is the subject of the request, although inclusion of the
customer’s name and address is also useful. If a customer is served by multiple
telephone numbers, the customer should tell us all numbers that should be placed
on the “Do Not Call” list.
A residential customer will remain on our “Do Not Call” list for five
years, and a business customer will remain on our “Do Not Call” list for one
year, unless the customer asks to be removed from the list by contacting our
customer service department. If a customer’s telephone number ever changes, the
customer must give us updated information in order for the “Do Not Call” status
to remain in effect.
Notwithstanding the fact that a customer’s telephone number is on our
“Do Not Call” list, we may still contact that customer with respect to surveys,
billing, and other service-related matters. Further, the customer should
understand that being on our “Do Not Call” list will not prevent calls from
other companies unaffiliated with WTC.
FURTHER INFORMATION
While we have made
significant efforts to protect your personal information, we cannot ensure or
warrant the security of any information you transmit to us, and you do so at
your own risk. Unfortunately, no
data transmission over the Internet can be guaranteed to be 100% secure and we
will not be held liable should a third party illegally obtain your personal
information via Internet transmission.
WTC reserves the right to change, modify
or update this Privacy Policy at any time without notice. In the event of any
modification, we will post the changes in this Privacy Policy so that you will
always know what information we are gathering and how we might use that
information. However if such changes are material, we will either announce the
change on the home page of the site or take such other action as we deem
appropriate under the circumstances. Accordingly, you should periodically visit
this page to determine the current Privacy Policy to which you are bound.
If you have any questions or comments
concerning this Customer Privacy Policy, or if you believe that the Company has
not adhered to its privacy policy, please contact WTC’s customer service at
886-2421. You may contact WTC via
regular mail at:
Winn Telephone Company
2766 W.
Blanchard Road, PO Box 367
Winn, MI 48896