Summit Broadband (“Summit Broadband”) is committed to protecting our customers’ personal information. This privacy notice applies to customers of our Internet, Cable and Phone Services, (“Services”) and describes Summit Broadband’s practices regarding the collection, use, protection and disclosure of your personal information.
The Communications Act of 1934 and the Federal Communications Commission (“FCC”) rules require us to provide subscribers of our Services with a separate, written statement about privacy policies concerning personally identifiable information, as defined below, at the time of entering into an agreement for Service and at least annually thereafter. This Privacy Notice is intended to be Summit Broadband’s required privacy notice.
When you subscribe to and use our Services, Summit Broadband collects certain types of information about you. We may collect this information (i) directly from you when you provide it to us, such as when you purchase products or services, complete a form on our website, or send us an email; (2)automatically through use of our Services; or (3) from third parties.
1. Customer information. In providing our Services to you, we collect certain information that identifies you individually or can be reasonably used to identify you individually (“Personally Identifiable Information” or “PII”). The type of Personally Identifiable Information we collect may include items such as your name, service address, billing address, telephone number(s), Social Security number, driver’s license number, bank account number, credit card number and other similar account information. PII does not include de-identified, aggregate or anonymous information that taken alone does not identify you individually. We also collect non-personally identifiable information, including usage statistics, traffic data, the domain names and IP addresses of our website visitors and high-speed internet service subscribers, device identifiers and other information. This information will be treated as PII when it is associated or otherwise combined with information that can identify you.
2. Cable television services. Through your use of certain of our cable television services, such as pay-per-view and video-on-demand, we may collect PII in the form of usage information for billing, programming and related purposes. For other cable television services, we will not collect, without your permission, PII regarding your video program viewing, except as needed to bill you, to provide you with a Service, to detect unauthorized reception of our Services, with your consent, or as required by law.
3. Internet services. Through your use of our Internet Services, we automatically collect certain information concerning your use of our Service, such as the Internet Protocol (IP) address(es), MAC addresses of equipment that is used, bandwidth used, system and connection performance, and dates and times of access. Some of this information may identify those subscribers who have downloaded certain materials or accessed certain websites. We may also collect information about the quantity, technical configuration, type, destination, location, and amount of your use of the Internet Services and information contained on your bill concerning your data plan and other features you may receive.
4. Telephone services. In providing telephone services, we collect subscriber list information, which is limited to your name, address and telephone number. We also collect information about the quantity, technical configuration, type, destination, location, and amount of your use of the telephone services and information contained on your telephone bill concerning the type of phone services and features you receive. That information, when matched to your name, address, and telephone number, is known as customer proprietary network information or “CPNI.” Subscriber list information alone does not constitute CPNI. We will take reasonable, good faith steps to protect information that may be considered CPNI and to comply with FCC requirements governing the use of and disclosure of CPNI.
1. Use policy. We consider PII and CPNI confidential and use it to provide our Services and for related business purposes, including without limitation to monitor for, detect and protect against fraud and unauthorized use of our Services, to communicate with you, for billing and collection purposes, and for accounting and tax purposes.
2. Sharing policy. Summit Broadband may disclose your PII and other information it collects to another entity (i) when it is necessary to render, or conduct a legitimate business activity related to the Services we provide to you or to confirm or update information provided by you; (ii) when permitted or required by law; (iii) for mailing list or other purposes, subject to your ability to limit the disclosure; or (iv) as otherwise authorized by you. When we provide your information to a third party for purposes of a business function, we will restrict their use of your information to the purposes for which it is disclosed and will prohibit any such third party receiving PII from further disclosure or use of the PII obtained from us.
3. Governmental entities and legal requests. If permitted by and subject to compliance with any federal law requirements, Summit Broadband may disclose PII and/or CPNI about you to governmental entities or to comply with valid legal process. Federal law provides generally that governmental entities must obtain a court order for disclosure of PII and can do so only upon a showing of clear and convincing evidence that you are reasonably suspected of engaging in criminal activity, and the information sought would be material to the case. The law also generally affords subscribers an opportunity to appear and contest the disclosure of PII to a government entity pursuant to a court order. With respect to non-governmental entities, federal law generally allows those entities to obtain information about you only with a court order and notice to you the subscriber.
4. Enforcement of our rights. We reserve the right to use or disclose PII about you without your consent only when such disclosure is permissible by applicable law (a) to protect our customers, employees, or property, (b) in emergency situations, (c) to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions or policies and/or (d)as otherwise required by law.
5. Internet services. We do not read your email messages, instant messages, online chats, “voice-over-internet” calls or the content of other online communications that reside on or pass through our Service. We may, however, retain and provide such communications if we are legally required to do so. Incoming and outgoing Summit Broadband-provided email messages are generally scanned automatically to identify and filter out likely spam or harmful messages and for viruses, spyware, and related problems that could harm your equipment, the network or other users.
6. Telephone services. You have a right to expect, and Summit Broadband has a duty under federal law, to take appropriate steps to keep your CPNI confidential. Summit Broadband will only use, disclose or permit access to your CPNI and PII: (1) in providing the Service from which the CPNI is derived or other Services necessary to, or used in, providing the Service; (2) to initiate, render, bill and collect for phone Services; (3) to protect our rights or property; (4) to protect users of our Services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, such Services; (5) as required by law; or (6) with your approval. All use of, disclosure of, and provision of access to your CPNI shall conform with the FCC’s rules governing CPNI use, disclosure, and access. Those rules are set forth at 47 C.F.R. § § 64.2001 – 64.2011.
To the extent that we generate CPNI from the provision of telephone Service to you (telephone-generated CPNI), we may use such CPNI to market communications-related products or services to you that are within the telephone category of Service, such as upgraded telephone service offerings. We may also use telephone-generated CPNI to market communications-related products or services to you that are outside of the telephone category of service. For example, we may use your telephone-generated CPNI to market our Internet Services to you. You have the right to limit our use of your telephone generated CPNI for such purposes and may do so by calling us at 877.678.6648. If we do not hear from you within thirty (30) days of receipt of this notification, we will assume that you approve of us marketing our services to you in this way. Please note that your Service will not be affected in any way should you choose to opt-out or otherwise restrict our use of your CPNI for these purposes.
Any approval or opt-out from our use of CPNI for marketing of communications-related products or services to which you do not already subscribe will remain in effect until you notify us otherwise.
Absent your approval, we will not use your telephone-generated CPNI to offer products or services to you that are non-communications-related products or services, such as cable television services. We may request your oral consent during a telephone call with you to use your CPNI for the purposes of marketing non-communications-related products and services to you. If you consent orally, Summit Broadband may use CPNI only during that telephone call in order to market additional services and products to you.
7. Directory listings and caller ID. Summit Broadband may disclose to third parties your PII in connection with features and services such as Caller ID and directory services. We offer our telephone customers the ability to designate their listings as non-published within print or directory assistance services. Because of the complexity of this process and the involvement of other entities in publishing, errors may occur from time-to-time.
8. Cookies. We may collect information using cookies, web beacons or similar technologies. These methods permit us to collect various types of information, including which pages you visit, how you use the Services, which of our email messages you read and other information.
10. Children’s privacy. The websites provided by Summit Broadband are not directed at, or intended for use by, children. Children should always get permission from a parent or guardian before sending personal information over the internet. If you think your child may have provided us with personal information, you can contact us and request that we delete the information. You can find more information about protecting children’s privacy by contacting the Federal Trade Commission (“FTC”) or viewing its website at ftc.gov.
11. Child exploitation. We are required by law to report any evidence we may become aware of relating to violations of laws concerning child exploitation.
You may check the accuracy of your PII in your account by contacting us at 877.678.6648. In most cases, the PII contained in these records consists solely of billing and account information. You may also examine the records containing your personally identifiable information at the Summit Broadband office during business hours and at your own cost and upon reasonable prior notice to us. If you wish to examine these records, please contact the Summit Broadband office noted on your billing statement. If your review reveals an error in our records, Summit Broadband will correct it. You will only be permitted to examine records that contain PII about your account and no other account.
You have the right to prohibit or limit certain kinds of disclosures and marketing. You may contact Summit Broadband at 877.678.6648 during normal business hours to ask us to put your name on our internal company “Do Not Call” and “Do Not Mail” lists so that you do not receive marketing or promotional telephone calls or postal mail from us or made at our request.
You also have the right to prohibit or limit disclosure of your PII for “mailing list” or other purposes as described above in this notice. You may contact us at 877.678.6648 during normal business hours or at the mailing address located on your billing statement to restrict such disclosures. Please include your name, address and account number when contacting us for this purpose.
Summit Broadband may retain PII and other information, including CPNI, in its regular business records while you are a subscriber and for a period of time after you are no longer a subscriber until such information is no longer needed for any business, tax or legal purpose.
We protect against the loss, misuse and alteration of CPNI collected from our Telephone Service, information collected as a result of use of our Internet Service that may constitute CPNI, and PII we collect through the use of appropriate administrative, technical and physical safeguards. Our servers are protected by reasonable physical and electronic security measures, and we use encryption wherever required or if we feel it is warranted. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose PII.
Federal law (including 47 U.S.C. §§ 222 and 551) places limits on the information a cable operator or provider of phone services may collect and share. Those laws also limit the circumstances under which a cable operator or phone service provider like Summit Broadband may disclose information to a governmental entity. Our customers may enforce their rights concerning Summit Broadband’s collection, use and sharing of your CPNI and PII Remedies available to you include the right to seek damages and reasonable costs and attorneys’ fees.