WELINK CUSTOMER PRIVACY NOTICE
EFFECTIVE DATE: JANUARY 24, 2019
This WeLink Customer Privacy Notice (the “Privacy Notice” or “Notice”) describes the types of information WeLink Communications LLC (“WeLink” “we” or “us”) collects when you subscribe to, use, and/or access our services or visit websites that post a link to this Notice (the “Services”).
I. Collection of Information
This section describes the types of information WeLink collects when you subscribe to, use, and/or access one or more of the Services. When you allow others to use or access the Services through your account, we collect information about their use, as well.
Information You Provide to Us
We collect information that you provide to us when you create an account with us or when you call us, use online account tools, report service issues, complete customer surveys, enter contests and promotions, or otherwise communicate with us. This information includes:
- Name and contact information (for example, billing address, service address, email address, and phone numbers);
- Payment information, such as your payment card or bank account information;
- Information related to a credit application for the Services, which may include your Social Security number, driver’s license number, or other government issued identifiers;
- Information you provide to authenticate your access to the Services, such as passwords, images, voice recordings, or other personal identifiers;
- Information you provide when you establish custom settings or preferences; and
- Customer correspondence and other communications records, including records of calls and chats with our customer service representatives.
Information We Collect When You Use the Services
We also collect information about your account and your use of the Services, which may include:
- Your account number;
- Billing, payment, and deposit history;
- Maintenance information;
- The types of Services to which you subscribe;
- The device identifiers and network addresses of equipment used with your account;
- Voice commands;
- Video and audio recordings;
- Records indicating the number and types of devices connected to our network;
- Technical information about your Service-related devices, including customization settings and preferences;
- Network traffic data;
- Information about your use of the Services and their features, including video activity data, as well as Internet or online information such as web addresses and other activity data in order to render Internet service; and
- Additional information about the Service options you have chosen.
We may collect information from the devices you use to access the Services that tells us where you are at a specific point in time. For instance, we may know that you are at home when you chat with us through the Service.
Information Provided by Third Parties
We also obtain data and information about you from third parties. For example, when you request new or additional Services or features from us, we may obtain credit information from credit reporting agencies. Additionally, if you rent your residence, we may have a record of whether landlord permission was required prior to installing our cable services as well as your landlord’s name and address.
We may obtain additional information about you from third parties such as demographic data (for example, gender, age, and census records, etc.), location data (for example, designated market area, zip code, etc.), interest data (for example, sports, travel, and other recreational activities, shopping preferences, etc.), or purchase data (for example, public records, loyalty programs, etc.). We may combine the data we collect from third parties with information in our business records, including information about your use of the Services. We may also combine information about your use of the Services with information we obtain from your use of other products, services, websites, and applications from WeLink. We use this combined data as described in the “Use of Information” section below.
Other Information We Collect AutomaticallyOur websites collect certain information automatically about you and your use of our websites (collectively “Other Information”). This Other Information includes:
- Device IDs, IP addresses or other unique device identifiers;
- Advertising identifiers; and
Cookies and other Tracking Mechanisms
Information We Collect When You Use the Website
- Where they are essential to make our websites work.
- To compile statistics that help us to understand how users use our websites and to help us improve the structure of our websites.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with our websites to track the activities of visitors to our websites, help us manage content, and compile statistics about usage of our websites. We or our service providers may also use clear GIFs in HTML e-mails to our users, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Google & Facebook
You can opt-out of remarketing by visiting the links below:
We have enabled Google Analytics Demographics and Interest Reporting which infers general demographic data (such as age, gender, and interests) on visitors but does not collect any personally identifiable information. Visitors can use this website with only minor loss of functionality if cookies are disabled from the web browser. If you would like to prevent us from using cookies when you visit our websites, please update the privacy setting in your chosen web browser. You can access information on privacy and setting the control cookie acceptance settings for web browsers (and Google Analytics) using the following links:
II. Use of Information
We use the information we collect to provide and improve the Services and our network, to communicate with you, to deliver relevant advertising, to create measurement and analytics reports, and to provide additional features and offerings. Sometimes we use information that personally identifies you, such as when we are authenticating your account or communicating with you. We also maintain and use information in de-identified or aggregated forms that do not identify you.
To provide and improve the Services, we use the information we collect to conduct business activities related to providing you with the Services, including:
- Establishing your account
- Measuring credit and payment risk;
- Billing and invoicing;
- Authenticating access to your account;
- Account administration;
- Service delivery;
- Maintenance and operations, including management of the network and devices supporting our service and our systems;
- Technical support;
- Hardware and software upgrades for devices and systems;
- Understanding the use of our services;
- Improving our services and identifying and developing new products and new services;
- Marketing and advertising;
- Detecting the unauthorized reception, use, or abuse of the Services and to protect our customers from fraudulent, abusive, or unlawful use of, or subscription to, the Services;
- Collecting fees and charges;
- Protecting our rights, our personnel, and our property; and
- Complying with applicable law.
We also use the information we collect to measure and analyze how our customers are using the Services. For video, this includes assessing which programs are most popular, how many people watch a program to its conclusion, whether people are watching advertisements, and what programming and video content we will carry on the Services. It also includes determining how our customers prefer to view certain kinds of programming when they use our video service, such as whether they like to watch certain programs live, or if they prefer to view them on demand, on mobile devices, or online.
When we provide you access to third-party content providers through our set-top boxes, we may measure how often and how long you use such services, but your use of those third-party providers are controlled by the terms and privacy policies of those providers. For Internet and voice services, we similarly analyze customer usage data, such as the amount of bandwidth that is being used, the peak times of usage, or the types of services that are being used.
To Communicate with You
We also use the information we collect to deliver and personalize our communications with you. For example, we may use the contact information you provide to inform you of Service updates or the status of a service request or outages, to invite you to participate in a survey, to collect amounts you owe, or in connection with other activities related to the Service. We will provide you with service-related announcements, through emails, texts, calls, WeLink-provided equipment, or other communications methods.
To Provide Recommendations and Deliver Relevant Advertising and MarketingWe may also use information about you and/or your use of the Services or other services we provide to determine which movies or television shows to recommend to you and to send you promotional communications for the Services and other products and services we think may be of interest to you. We may also use this information to help third-party advertisers and programmers deliver more relevant advertising.
These promotional communications and advertisements may be directed to you because you subscribe to one or more of the Services, because of the way you use the Services, because you live in a certain geographic area, or based on demographic and interest information that we collect or obtain from other companies.
To Create Analytics and Measurement Reports
We and service providers who work on our behalf may use and combine data from our business records – including account information, video activity data, and other usage data – with data from third parties to create measurement and analytics reports.
We use these reports for many of the purposes described above, such as for improving the Services, creating and delivering more relevant advertising on behalf of WeLink and other third parties, determining whether and how an advertiser’s messages are viewed, and analyzing the effectiveness of certain advertisements on the WeLink platforms and services and other platforms and services. We also use these reports to work with academic or research groups, and for other uses that help us develop and fund improvements in services and infrastructure. We may share these reports with programmers, advertisers, or others.
III. Sharing & Disclosures of Information
We limit the information we share and disclose to others as described below.
In order to provide and support the Services, sometimes we use third-party companies as service providers that work on our behalf to transmit, collect, process, or store information for us. We require these service providers to treat the information we share with them as confidential and to use it only for the purpose of providing the services for which they have been engaged. These engagements typically include services such as billing and collections, administration, auditing and accounting, professional advice and consulting, surveys, marketing, service delivery and customization, maintenance and operations, security incident verification and response, service notifications, fraud prevention, and services to improve our programming and advertising offerings. For example, WeLink uses service providers to process payments for us and we may share your payment information with those billing processors when you make a payment. Or, WeLink may use a service provider to obtain information about you to assess your credit and payment status.
The WeLink Family of Businesses
WeLink may share the information it collects with its affiliates that offer other WeLink and WeLink-branded products, services, and applications.
Account Owners and Users
WeLink may disclose any information about a customer’s account and use of the Services and their features to the primary account owner after appropriate authentication. The primary account owner may also authorize other users to access information on the account, and that may include data about you and your use of the Services.
Third Parties for Marketing Purposes
We may share, sell, license, rent, or otherwise permit access to information that personally identifies you to an unaffiliated third party for that third party to market its products or services to you. We may also share de-identified or aggregate information with third parties for their own uses when those third parties commit to not re-identify that information or share it with others who may attempt to do so.
Rights of California Residents
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information regarding the types of personal information the business shares with third parties for direct marketing purposes by such third party, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To see a copy of the information disclosure provided by WeLink pursuant to Section 1798.83 of the California Civil Code, please contact WeLink using one of the methods described in this Notice.
Other Third Parties
If we (or our parent company) enter into a merger, acquisition, or sale of all or a portion of our assets, information about you and your subscription, including information that personally identifies you, will, in most instances, be one of the items transferred as part of the transaction. If this Notice will be changed as a result of such a transaction, you should refer below under “Changes to the Privacy Notice.”
When Required by Law or To Protect WeLink and Others
There are times when we may be required by law to disclose information about you to third parties. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant.
WeLink may be required to disclose information that personally identifies you to a governmental entity in response to a subpoena, court order, or search warrant, depending on the type of information sought. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may also seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant.
A non-governmental entity, such as a civil litigant, can seek information that personally identifies you or your use of Services only pursuant to a court order. If WeLink is required to disclose information that personally identifies you to a private third party in response to a civil court order, we will notify you prior to making such disclosure unless legally prohibited from doing so.
We may also disclose information that personally identifies you as permitted by law and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.
IV. Your Choices
In many instances, you have choices about how we communicate with you and how we use and share your information.
Opting Out of Certain Marketing Communications
For your convenience, you may visit us at __________ to exercise your right to opt-out of certain marketing communications.
V. Your Rights
The Communications Act and CPNI
Section 222 of the Communications Act of 1934, as amended (the “Communications Act”), provides additional privacy protections for information about the quantity, technical configuration, type, destination, location, and amount of your use of telecommunications services, as well as voice services, and the information about those services contained on your bill. This information is known as customer proprietary network information or “CPNI.” CPNI does not include your name, address, and telephone number, which is defined by the Communications Act as “subscriber list information.” However, that information is otherwise considered personally identifiable information.
If you are a customer of a Service that is subject to these requirements, you have the right, and WeLink has a duty, under the Communications Act and other applicable laws, to protect the confidentiality of your CPNI. In addition, the FCC’s rules provide additional privacy protections and choices regarding use and sharing that are specific to our voice services that we describe in this Notice.
VI. Accessing and Correcting Information
It is important that your account records contain accurate information. You may correct or update information about your account by contacting us at firstname.lastname@example.org. We will correct our records upon reasonable verification that the changes you request are proper.
VII. Other Important Information
Protecting the Information We Collect
We follow reasonable practices to secure the information we collect. Although we take the responsibility of safeguarding your information seriously, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information.
WeLink maintains information that personally identifies you in our regular business records while you subscribe to one or more of the Services. We also maintain this information for a period of time after you no longer subscribe to a Service if the information is necessary for the purposes for which it was collected or to satisfy legal requirements. These purposes typically include business, legal, or tax purposes. If these purposes no longer apply, we will destroy, de-identify, or anonymize the information according to our internal policies and procedures.
Changes to the Privacy Notice
We may modify this Notice at any time. You can view the most current version of this Notice by going to http://www.welink.com. If we make material changes to this Privacy Notice, then we will provide you at least 30 days’ notice and will also notify you by e-mail, direct mail, bill messaging, or other reasonable methods that we select. If you continue to use the Service following notice of the changes, we will deem that to be your acceptance of and consent to the changes in the revised Privacy Notice.
How Do I Contact WeLink?
If you have any questions or suggestions regarding this Privacy Notice, or wish to contact us about your personally identifiable information, please reach us as follows email@example.com.