- Effective 1/29/2008
WHAT YOU CAN EXPECT FROM TOUCHTONE
- TouchTone respects and protects your privacy. As a provider of telecommunications and related services and products, we recognize that we must maintain the confidentiality of every customer's telephone calling and other account information. We also respect and protect the privacy of our Web visitors. The expansion of online services and changing technologies continues to create unique privacy concerns and we recognize the need to maintain the confidentiality of information that Web visitors reasonably expect to remain private. Our customers and Web visitors expect, deserve and receive nothing less than our fullest commitment to their privacy. We also have an obligation to assist law enforcement and other government agencies responsible for protecting the public welfare, whether it be an individual or the security interests of the entire nation. If and when we are asked to help, we do so strictly within the law and under the most stringent conditions.
- When you sign up for certain TouchTone-offered services, you may agree to additional privacy policies that address service-specific privacy practices.
WHAT PERSONAL IDENTIFYING INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE
TouchTone collects personal identifying information regarding our customers, including information customers give us, information collected as a result of the customer's relationship with us and information we obtain from other sources. Examples include name, address, e-mail address, telephone number, billing, payment, usage, credit and transaction information (including credit card numbers, account numbers and/or social security number), in addition to demographic information.
We also collect personal identifying information that our Web visitors choose to provide to us (e.g., name, address, telephone number, e-mail address) when registering on our Web sites; ordering TouchTone offered products or services, sending us e-mail, responding to our surveys, entering contests or sweepstakes, or in connection with online ordering or billing functions. We use the personal identifying information of a customer to provide, confirm, change, bill, monitor and resolve problems with the quality of TouchTone offered products and services. We also use the personal identifying information of a customer or Web visitor to develop, market and sell our products and services. We may aggregate the personal identifying information of different customers or Web visitors to produce data about a group or category of services, customers or Web visitors. For example, we might use aggregate data about the types of services our customers have generally purchased at the same time in order to develop attractive bundled service offerings. Such aggregate data, however, will not reflect any personal identifying information of any specific customer or Web visitor.
- We do not provide personal identifying information to third parties for the marketing of their products and services without your consent.
- We may also provide personal identifying information to third parties who perform functions or services on our behalf. Examples include shipping companies who deliver TouchTone products; TouchTone authorized agents who market and sell TouchTone offered products and services on our behalf; and Web site development or advertising companies, who provide Web design, analysis and advertising services.
- When we provide such personal identifying information to third parties to perform such functions or services on our behalf, we require that they protect personal identifying information consistent with this policy and do not allow them to use such information for other purposes.
- We may, where permitted or required by law, provide personal identifying information to third parties (including credit bureaus or collection agencies) without your consent:
- To obtain payment for TouchTone offered products and services, enforce or apply our customer agreements, and/or protect our rights or property.
- To comply with court orders, subpoenas, or other legal or regulatory requirements.
- To prevent unlawful use of communications or other services, to assist in repairing network outages, and when a call is made to 911 from a customer phone and information regarding the caller's location is transmitted to a public safety agency.
- To notify a responsible governmental entity if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure without delay.
- A customer's name and telephone number may also be transmitted and displayed on a Caller ID device unless the customer has elected to block such information. Caller ID Blocking does not prevent the display of the number when you dial certain business numbers, 911, 900 numbers or toll-free 800, 888, 877 or 866 numbers. For more information, contact TouchTone Customer Service at 800-266-4006.
OUR "DO NOT CALL" LISTS
We comply with all applicable laws and regulations regarding "Do Not Call" lists. These laws generally permit companies to contact their own customers even though such customers are listed on the federal and, in some instances, state "Do Not Call" lists.
- Residential consumers may request that they be removed from TouchTone's telemarketing lists at any time, including when a TouchTone marketing and promotional call is received or by contacting a TouchTone Customer Service Representative.
- Where required by state laws and/or regulations, we also honor requests from business customers to be removed from our telemarketing lists.
CUSTOMER PROPRIETARY NETWORK INFORMATION
In the normal course of providing telecommunications services to our customers, we collect and maintain certain customer proprietary network information, also known as "CPNI". Your CPNI includes the types of telecommunications services you currently purchase, how you use them and related billing information for those services. Your telephone number, name and address are not CPNI.
- Protecting the confidentiality of your CPNI is your right and our duty under federal law. We do not sell, trade or share your CPNI - including your calling records - with anyone outside of TouchTone or with anyone not authorized to represent us to offer our products or services, or to perform functions on our behalf except as may be required by law or authorized by you.
- As a general rule, we are permitted to use CPNI in our provision of telecommunications services you purchase, including billing and collections for those services. We are permitted to use or disclose CPNI to offer telecommunications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as a court order, to investigate fraud or to protect against the unlawful use of our telecommunications network and services and to protect other users.
WHAT ONLINE INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE
- We use Web usage information to facilitate and enable the functioning of our Web sites and to expand and improve our Web visitors' online experience. We may also aggregate such Web usage information with other visitors' Web usage information to assess trends and better design, monitor and otherwise improve our Web sites, as well as to focus our marketing efforts.
- In some cases we may combine Web usage information related to your access to our Web sites with personal identifying information. We use the combined information to provide our customers and Web visitors with a better online experience by providing customized features and services and to market and provide advertising about goods and services that may be of particular interest. Once combined, the resulting data is protected as personal identifying information as described in this policy.
Cookies are alphanumeric identifiers that a Web server sends to your computer when you visit a Web site. Cookies can contain a variety of information, such as a simple count of how often you visit a Web site or information that allows us to customize our Web site for your use. Web beacons (also known as "clear gifs" or "one-pixel gifs") are small graphic images on a Web page or in an e-mail that allow us to monitor the activity on our Web sites or to make cookies more effective.
- We, or a third party acting on our behalf, may use Web beacons in certain of our Web pages and e-mails to gauge the effectiveness of our marketing campaigns and e-mail correspondence. For example, we may use Web beacons in our HTML-based e-mails to let us know which e-mails have been opened by the recipients.
- We may use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show your ads on sites across the Internet.
- TouchTone uses Google Analytics features based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting). You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at anytime. Google Analytics Opt-out Browser Add-On.
- You can configure your Web browser to alert you when a Web site is attempting to send a cookie to your computer and allow you to accept or refuse the cookie. You can also set your browser to disable the capacity to receive cookies or you can delete cookies previously accepted. Some TouchTone Web pages (and other Web pages) may not work correctly if you have cookies disabled.
- We may use advertising companies to deliver ads for TouchTone offered services and products on our Web sites or on third party Web sites. These Internet ads are often called "banner ads" and may contain third-party cookies or Web beacons that allow tracking of visitors' responses to our advertisements. Although these third parties may receive anonymous Web usage information about ad viewing on such Web sites, we prohibit them from using this information for any purpose other than to assist us in measuring the effectiveness of our ads.
- We periodically send customers news and updates via e-mail regarding TouchTone offered services, products, and special promotions. Every marketing e-mail we send contains instructions and an opt-out link that will allow you to stop additional TouchTone marketing e-mails based on line of business.
- We do not provide your e-mail address to third parties for the marketing of third-party products without your consent.
- TouchTone Web sites are not designed to attract children under the age of 13. We do not target children for the collection of information online and do not knowingly collect personal identifying information from anyone under the age of 18.
- Ordering online products and services from TouchTone is limited to adults (age 18 or over or as otherwise legally defined).
- We comply with all applicable laws and regulations, including the Children's Online Privacy Protection Act (COPPA), which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13.
LINKING TO OTHER SITES
- We care about the privacy of our customers and Web visitors and strive to provide you with relevant information to help you learn how better to protect your privacy and security while online.
HOW WE PROTECT YOUR INFORMATION
All TouchTone employees are subject to the TouchTone Code of Business Conduct and certain state-mandated codes of conduct. The TouchTone Code requires all our employees to follow every law, rule, regulation, court and/or commission order that applies to our business at all times. In addition, the Code specifically requires compliance with legal requirements and company policies related to the privacy of communications and the security and privacy of customer records. Employees who fail to meet any of the standards embodied in the Code of Business Conduct may be subject to disciplinary action, up to and including dismissal.
- We employ security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data, including personal identifying information. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of your personal identifying information, and we will continue to enhance our security procedures as new technology becomes available. For example:
- We maintain and protect the security of our servers and we typically require user names and passwords to access sensitive data.
We use industry standard encryption methods to protect your data transmission unless you authorize unencrypted transmission.
- We limit access to personal identifying information to those employees, contractors, and agents who need access to such information to operate, develop, or improve our services and products.
If we determine that a security breach has occurred and that such breach creates a risk of identity theft or service disruption, we will make reasonable attempts to notify you.
- If we intend, however, to use personal identifying information in a manner materially different from that stated at the time of collection, we will attempt to notify you at least 30 days in advance using an address or e-mail address, if you have provided one, and by posting a prominent notice on our Web sites, and you will be given a choice as to whether or not we use your information in this different manner.
CONTACTING US: QUESTIONS, COMMENTS, CONCERNS
TouchTone honors requests from customers and Web visitors to review their personal identifying information that we maintain in reasonably retrievable form and we will gladly correct any such information that is inaccurate. You may verify that appropriate corrections have been made. Please contact TouchTone Customer Service at 800-266-4006.