Effective Date: August 28, 2020
Any capitalized terms used herein shall have the same meaning as defined in the Broadband VI Service Agreements.
Your California Privacy Rights
- For all requests, include Subscriber’s full name, street address, city, state and zip code.
- In an email request, Subscriber must state “Re: Your California Privacy Rights” in the subject line and send Subscriber email to firstname.lastname@example.org.
- In a postal request, Subscriber must send a letter or post card to:
PO Box 26304, Christiansted, VI 00824
Attention: Your California Privacy Rights
When Subscriber uses the Service, the Personal Information Subscriber sends and receives is transmitted over a wireless network, and may be subject to interception by unauthorized third parties who seek to do you harm. While it is Broadband VI’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Subscriber sends and receives through the Service, Broadband VI cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.
Broadband VI does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Subscriber is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to Broadband VI. If Broadband VI learns that Broadband VI has collected Personal Information from a child under age 13, Broadband VI will delete that information as quickly as possible to the extent technically feasible. If Subscriber believes that its child under age 13 may have provided Broadband VI Personal Information, please contact Broadband VI at email@example.com.
Broadband VI collects various types of information about Subscribers and Subscribers’ use of the Service via the Broadband VI website, Help Desk and call centers, postal mail, remote kiosks, the Broadband VI Facebook Page or other social network platforms or by other means, generally classified as Personal Information and Non-Personal Information. Generally, Broadband VI gathers and uses Personal Information internally in connection with providing the Service to Subscriber, including to personalize, evaluate and improve the Service and Broadband VI’s ability to provide the Service to Subscriber, to contact Subscriber, to respond to and fulfill Subscriber requests regarding the Service, and to analyze how Subscriber uses the Service. Broadband VI may share Subscriber’s Personal Information with its Affiliates and with other third parties as described below:
What Information does Broadband VI collect and how does Broadband VI use this Information?
Personal Information is the information Subscriber provides to Broadband VI voluntarily or passively through Subscriber use of the Service and/or website, and which is directly associated with or reasonably linked to a specific person, computer or device. For example, through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Subscriber’s premises, when Subscriber contacts Broadband VI regarding the Service, and through Subscriber account settings, Broadband VI collects Personal Information such as Subscriber name, email address, phone number, billing address and billing information (such as credit card account number or other financial account information), service address, and the nature of any of Subscriber devices or other property making use of the Service. Personal Information also includes customer proprietary network information (“CPNI”) which is collected and used to provide VoIP services. CPNI includes any information that relates to the quantity, technical configuration, type, destination, location, and amount of use of our VoIP service, such as call detail, logs, and specifics regarding your VoIP account. P lease note that by law, CPNI does not include a subscriber’s name, postal address, or telephone number.
Subscriber may be required to provide certain Personal Information to Broadband VI in order to register with Broadband VI, to assist Broadband VI in improving Subscriber’s Service or troubleshooting problems Subscriber is experiencing with the Service, Subscriber computer or device, or otherwise to improve the quality of the Service. Broadband VI will communicate with Subscriber if Subscriber has provided Broadband VI the means to do so. For example, if Subscriber has given Broadband VI Subscriber’s email address or phone number, Broadband VI will email or call Subscriber about Subscriber use of the Service or product improvements or upgrades, and other transactional information about Subscriber Service. Broadband VI may also combine Subscriber Personal Information with additional Personal Information obtained from Broadband VI Facebook Pages or other social network platforms, its Affiliates, its Operational Service Providers (third party owned companies that provide or perform services on Broadband VI’s behalf, to help serve Subscriber better and to perform functions in order to support Broadband VI businesses and operations), or other companies, such as credit bureaus, background check firms, and marketing research companies. Some forms of Non-Personal Information as described below will be classified as Personal Information if required by applicable law or when such information is directly associated with or reasonably linked to a specific person, computer or device, or is combined with other forms of Personal Information.
Broadband VI also collects Network Information, information about Subscriber access to, and use of, the Broadband VI Network, which may or may not be directly associated with or reasonably linked to a specific person, computer or device. For example, Broadband VI may collect information about the performance of the Provider Equipment installed on Subscriber property or at Subscriber premises, when Subscriber is using the Service, the various devices Subscriber is using to access the Service, the amount of data Subscriber is transmitting and receiving, the content of the data Subscriber are transmitting and receiving, the websites Subscriber is visiting, and any other information that is transmitted over the Broadband VI Network. Broadband VI may also aggregate Network Information from multiple customers and Broadband VI will share such aggregated Non-Personal information about the overall performance of the Broadband VI Service and the Broadband VI network with our Affiliates and other third parties. Aggregated information does not identify a specific individual, computer or device. We use Network Information to monitor and enhance the performance of the Broadband VI network. Broadband VI will not monitor the content of the websites viewed or email communications as part of Broadband VI’s standard network management.
Generally, Broadband VI will only monitor and preserve the following Network Information:
- When Subscriber is using the Service;
- How Subscriber is using the Service, such as monitoring traffic patterns regarding websites visited, amount of data being sent or received, or other activity;
- The amount of data Subscriber is transmitting and receiving through the Service; and
- General information regarding the performance of the Provider Equipment installed on Subscriber’s property or at Subscriber’s premises, and its interaction with the rest of Broadband VI’s network.
However, Broadband VI reserves the right to, and may, monitor, access, review and preserve any Network Information and/or content in the following situations:
- In response to an inquiry from Subscriber or another Authorized User on Subscriber’s account regarding Subscriber or their use of the Service or problems Subscriber or they are experiencing using the Service;
- If Broadband VI has reason to believe Subscriber is using the Service in violation of Subscriber’s Service Agreement or any applicable statutes, rules, ordinances or regulations;
- If Broadband VI has reason to believe Subscriber use of the Service is negatively affecting other Subscribers; or
- When Broadband VI is required by law or legal process to do so, or when Broadband VI a good faith belief that Broadband VI is required by law or legal process to do so.
How is Personal Information used for marketing and advertising purposes?
Broadband VI will use Personal Information to send Subscriber marketing and advertising messages related to Broadband VI’s Service and website using Subscriber’s email address, postal address, or telephone number (for voice, texts, automated and pre-recorded calls).
Broadband VI may deliver a marketing or advertising message based on Subscriber visits to Broadband VI website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter. Broadband VI may also send Subscriber “First Party Advertising,” which is advertising or marketing that is customized or personalized based on a history of Subscriber’s use of our Services (possibly combined with information from our Facebook fan page or other social network platforms). First Party Advertising is based solely on a combination of information Broadband VI collects from Subscriber – not from Subscriber’s visits to other websites across the Internet. Broadband VI may use CPNI for its own First Party Advertising for products/services a Subscriber has already purchased. We will need your consent before using CPNI for marketing
or advertising unrelated services. Subscriber may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage Subscriber is viewing. And Subscriber may continue to receive general advertising if Subscriber opts-out of First Party Advertising, it will not be customized or personalized for Subscriber.
Broadband VI does not provide third party “Network Advertising,” which is advertising based on Subscriber’s overall Internet usage across different third-party websites or online services. Multiple third-party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Because Broadband VI does not provide network ads, Broadband VI does not recognize the “Do Not Track” settings on various Internet browsers. Broadband VI does not engage or allow third parties to track you across the Internet and across time for advertising purposes.
If you receive advertising or marketing communications from one or more Affiliates, you must opt-out individually from each of the Affiliates from which you are receiving brand-specific marketing communications. Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable.
- To Our Affiliates. Broadband VI relies on various Affiliates in order to provide the Service to Subscribers. These are companies that are related to Broadband VI by common ownership or control. Broadband VI may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, promotional and/or marketing and advertising purposes.
- To Operational Service Providers: Broadband VI and its Affiliates contract with other companies and people to perform tasks or services on Broadband VI’s behalf and need to share Subscriber Personal Information to provide products or services to Subscribers. For example, Broadband VI may use a payment processing company to receive and process Subscriber’s ACH or credit card transactions for Broadband VI, or Broadband VI may contract with third parties to assist Broadband VI in optimizing Broadband VI’s network. Unless Broadband VI tells Subscriber differently, Broadband VI does not grant its Operational Service Providers any right to use the Personal Information Broadband VI shares with them beyond what is necessary to assist Broadband VI.
- For Business Transfers/Restructuring: Broadband VI may choose to buy or sell assets, or Broadband VI may sell assets or be sold. In these types of transactions, customer Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if Broadband VI (or Broadband VI’s assets) are acquired, or Broadband VI goes out of business, enter bankruptcy, or go through some other change of control, including restructuring, re-organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.
- When Required by Law or in Response to Legal Process: Broadband VI reserves the right to access, read, preserve, and disclose any Personal Information to which Broadband VI has access if Broadband VI is required by law or legal process to do so, or if Broadband VI has a good faith belief that Broadband VI is required by law or legal process to do so.
Is Subscriber Personal Information secure?
Broadband VI endeavors to protect the privacy of Subscriber’s account and other Personal Information Broadband VI holds in its records using reasonable administrative, technical and physical security measures. However, Broadband VI cannot and do not guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Information at any time. Subscriber’s account is protected by a password for Subscriber privacy and security. It is Subscriber’s responsibility to prevent unauthorized access to Subscriber’s account and Personal Information by selecting and protecting Subscriber password and/or other sign-on mechanism appropriately and limiting access to Subscriber computer, tablet or device and browser by signing off after Subscriber has finished accessing Subscriber’s account. Subscriber is required to notify us immediately if Subscriber’s password or account has been disclosed to a person whose name does not appear on Subscriber’s account, even if you have allowed such disclosure. Subscriber understands, acknowledges and agrees that Subscriber is solely responsible for any use of Broadband VI Services via Subscriber’s username and password.
Additionally, if Subscriber contacts Broadband VI, Broadband VI will ask Subscriber for verification of Subscriber’s identification and account. Broadband VI will not send an email or text, nor should Subscriber respond to any email or text communications asking for any sensitive or confidential Personal Information, such as social security number, bank account or credit card account number, or a driver’s license number. If Subscriber receives an email or text requesting any such information from Broadband VI or someone that claims they are with Broadband VI or Our Affiliates please contact our Privacy Administrator immediately at firstname.lastname@example.org. For Broadband VI’s IT Support Services as detailed in our Service Agreement, the code that allows Broadband VI to access Subscriber’s computer desktop to help your resolve technical problems is limited only for that specific session. Broadband VI is not able to access Subscriber’s Computer without Subscriber’s knowledge, affirmative consent and involvement.
What Personal Information can Subscribers access, modify and/or delete?
Generally, Subscriber may access the following Personal Information in Subscriber’s account:
- Full name
- Username and password
- Email address
- Telephone number
- Billing and Service address
- Account and billing information
By contacting Broadband VI at email@example.com, or through any online access portal and/or via telephone, Broadband VI may enable Subscribers to view, access and modify Subscriber account settings, and in some cases, edit or delete the Personal Information listed above. For example, Broadband VI may retain historic email, billing and/or Service addresses for security and verification purposes and Subscribers may not delete such information even after the subscription expires or terminates. Current Subscribers may not delete any Personal Information because such information is necessary to provide and bill for the Service; Subscribers may only update or modify Personal Information. When Subscriber updates Personal Information, however, Broadband VI may maintain a copy of the unrevised information in Broadband VI’s records for internal security reasons and recordkeeping. Some information may remain in Broadband VI’s records after it is modified, amended or deleted by Subscriber or Broadband VI. Broadband VI may use any aggregated data derived from or incorporating Subscriber’s Personal Information after Subscriber updates or deletes it, but not in a manner that would identify Subscriber personally. Broadband VI may also maintain Personal Information regarding Subscriber and Subscriber’s use of the Service after Subscriber is no longer a Broadband VI customer as required by Broadband VI’s business practices, by law, and/or tax reporting purposes. The information Subscriber can view, update, and delete may also change. If Subscriber has any questions about viewing or updating information Broadband VI has on file about Subscriber, please contact Broadband VI at firstname.lastname@example.org.
What third party disclosure choices do Subscribers have?
If you have any questions or concerns regarding Broadband VI’s privacy practices and policies, please contact Broadband VI at email@example.com.