Customer Proprietary Network Information (CPNI). CPNI is a subcategory of protected customer information defined by federal law as information about a consumer's account, including usage and billing of telecommunications services. Those services are offered by providers of traditional local, long distance, and wireless services, as well as providers of Voice over Internet Protocol (VoIP) services to consumers. CPNI includes what services you subscribe to, how you use them, and what you are charged for them. It does not include your name, address, telephone number, or other types of information such as information about your telephone equipment or Internet access services. We are required to treat CPNI confidentially, and we do. The FCC regulates when and how CPNI can be shared and used.
- Marketing rules. The FCC has categorized consumer CPNI into three distinct service groups: local, long distance, and wireless service. The CPNI that a carrier can use to market its services to its customers – without their approval – depends on what service groups the customer already buys from. Carriers are permitted to use CPNI for marketing similar products within a service group. For example, if you subscribe to our local service, we are allowed to use that local service information to sell you additional local service products and services.
- Approval rules. We obtain customer approval to use CPNI across service groups in two different ways. In some circumstances, we ask for customer consent. In other words, we may ask customers to “opt-in" to our use of CPNI across service groups. In most circumstances, however, we inform customers that CPNI will be used unless they instruct us not to. In these cases, the customers must specifically “opt-out" to our use of CPNI across service groups. We can ask for long-term approval (that lasts until it is withdrawn) or we can ask for approval each time we interact with a customer (short-term approval).
- Rules on non-marketing uses of CPNI. We are allowed to use consumer CPNI for various non-marketing purposes without specific customer approval. These activities include installing, providing, billing for, and collecting for Services. We may also use CPNI without specific approval to protect our rights or property or those of our customers or other carriers and to address fraud, abuse or unlawful subscriptions to or use of our services.
- Access rules. Before speaking with a caller about account information, we take steps to authenticate the identity of the caller and confirm that he or she is authorized to have access to information on the account. We do not discuss account information with anyone other than the account holder. Per FCC rules, we will not discuss call detail information with customers over the telephone unless the customer provides specific information about the calls in question, such as in the context of a billing inquiry, or unless the customer provides their specific password. We will not release CPNI in a retail store unless our customer presents a valid photo ID. Additionally, our customers cannot access online account information using only account information or generally known information. Rather, online account access is restricted through security code and password requirements.
How We Collect Information And How We Use It
We collect information in three primary ways:
- You give it to use when you purchase or interact with us about a product or service we offer or provide;
- We collect it automatically when you visit our websites or use our products and services; and
- We obtain it from other sources such as credit agencies.
Visiting Our Site. When you visit our website to browse, we may collect and store the domain name and host from which you access the Internet, the IP address of your computer, your browser software and operating system, the date and time you accessed the site and the Internet address of any website from which you link directly to our site or to which you link after visiting our site. We may use this information to measure the number of visitors and repeat visitors to sections of our site, to calculate the average time spent at our site, to determine from where and to where our visitors link, and to help make our site more useful. This type of information may be shared with third parties, such as when we aggregate and disclose site traffic information for marketing and commercial purposes. When you visit our website, we may ask if you would like us to send you marketing materials about our Services and other associated products. If you request such materials, then we may use Personally Identifiable Information you give us to send you such materials.
Using Our Services. When you use our Services, you must provide certain Personally Identifiable Information for us to properly provide you with the Services. We collect and store this Personally Identifiable Information and any modifications that either you or we make to that information. We may disclose User Information (i) to provide you Services that you request and provide you with the best customer experience possible; (ii) to answer questions you may have about the Services you purchase; (iii) to communicate with your regarding Service updates, offers and promotions, and deliver customized content and advertising to you; (iv) to address network integrity and security issues; (v) to obtain a credit report; (vi) to provide local directory and directory assistance; (vii) to law enforcement or other governmental officials as required by law, if appropriate, for your protection, safety, or in connection with an investigation or prosecution of possible unlawful activity, in which cases we may be required to disclose the information without your consent or knowledge as required by federal and/or state statutes and regulations; (viii) in connection with a sale or merger of Emery; or (ix) for other legally permissible purposes. We may also share aggregate anonymous data relating to the transactions on the website and use of the Service for marketing, research and other purposes.
How we protect your information. We employ and maintain technology and security measures designed to protect User Information. When you submit sensitive information via our website, that information is subject to a variety of protections both on-line and off-line, including password protected systems and firewalls. Sensitive and private data exchange between the website and its users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. However, no data transmission over the Internet can be guaranteed to be 100% secure.
Third Party Websites. You may find advertising or other content on our website that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our website. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. We are not responsible or liable for the actions or policies of third parties.
Any loss of control of passwords may result in the loss of control over Personally Identifiable Information or User Information. You will be responsible for any actions taken on your behalf or any person using your password or user identification. If passwords have been compromised, then you should immediately change your password or notify us so that we may issue a new password.