Perry Spencer Communications, Inc. (d/b/a PSC) (“PSC”) is committed to respecting and protecting the privacy of our customers. As discussed below, we have strict policies governing access by employees and others to customer communications and information. We only access customer accounts, records, or reports for authorized business purposes. We educate our employees about their obligation to safeguard customer information and communications and hold them accountable for their actions. In short, privacy is a priority for PSC in all aspects of our business.
This Policy applies to the information we collect:
- On this Website.
- In e-mail, text, and other electronic messages between you and this Website.
- Through third-party applications that you access through our Website.
- Through other methods, such as when we engage in certain speed testing of our Service.
CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under 13 may provide personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website, register on the Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please call (800) 511-4899 or e-mail firstname.lastname@example.org.
GENERAL PRIVACY PRINCIPLES
The following express PSC’s commitment to assuring strong and meaningful customer privacy protection and are intended to guide PSC’s efforts to balance customer privacy with customer interest in receiving quality services. These principles apply to using “individual” customer information—that is, information about specific customers. “Individual” customer information includes “personal information” – information particular to you, including your address, phone number, fax number, and e-mail address – and “non-personal information” that may include information such as your network traffic data, services and features used, or call record details. These policies are consistent with applicable laws and privacy regulations, including the Federal Communications Commission (“FCC”). Individual customer information is distinct from “aggregated” customer information, which does not reveal a customer’s identity.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline;
- That is about you but individually does not identify you; and
- About your Internet connection, the equipment you use to access our Website, and usage details.
PSC collects information from customers in several different ways.
PSC may collect information from you through communications such as via the web, by phone, e-mail, or mail delivery, or through the services provided to you as the customer.
You may visit our site without divulging personal information; however, areas of the Website may require personal information to contact PSC directly, specifically when registering e-mails, obtaining remote access, and contacting online technical support.
Information may also be collected in the following ways:
- Browsing our site:
- IP addresses may be collected for system administration, to gather broad demographic information, and to monitor the activity level on our site.
- Information may be collected regarding the referring URL, which browser you used to visit our site, the pages you viewed, and any search terms entered on our site.
- The customer may send e-mails to PSC on this Website. PSC may retain the information in any e-mail you send us, such as your name, e-mail, address, or telephone number.
- Broadband Internet Service:
- PSC may monitor the network and take measurements of network performance and the performance of your Internet connection to improve the customer or PSC’s overall service levels.
- During communications with PSC for service support, we may also access information about your customer premise equipment, such as computers and wireless modem devices or other device settings, to provide customized technical support or to install specific applications or services for your use.
- PSC reserves the right to access broadband traffic from individual accounts for general maintenance and management of the network and upon request by law enforcement officials.
- Provision of Information by Third Parties:
- PSC may obtain credit information about you from third parties when you purchase products or services from PSC.
Information We Collect Through Automatic Data Collection Technologies.
- We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide us.
HOW WE USE YOUR INFORMATION
PSC obtains and uses individual customer information for business purposes only.
PSC obtains and uses customer information that helps us to provide our customers with quality telecommunications services. In addition to supporting the direct provision of service, this information may be used to protect customers, employees, and property against fraud, theft, or abuse; to conduct industry or consumer surveys; and to maintain good customer relations. Access to customer information databases is limited to employees who need that information to perform their jobs. These employees must follow strict rules when handling customer information and are subject to disciplinary action if they fail to do so.
To better serve our customers, we may ask them questions to elicit additional information about their unique needs and interests. For example, we may ask whether customers work at home, whether any household members have special needs, or whether teenagers reside in the household to determine whether customers may be interested in or benefit from additional lines or services. In all cases, the information we gather is used to facilitate the provision of quality customer service. We do not share this information with third parties to market non-PSC services to our customers.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
PSC informs customers how we use information PSC obtains about them and their options regarding its use.
PSC transparently uses customer information and discloses to customers the types of data PSC obtains about them, how and when that information is used, when that information might be disclosed, the stringent measures we employ to protect that information, and ways that customers can restrict the use or disclosure of that information.
PSC allows customers to control access by others to customer information and how PSC uses individual information about them.
PSC is committed to providing customers with opportunities to control how PSC uses customer information about them. For example, customers may inform us which telephone listings they want to include in our directories and directory assistance. They may also choose to have a non-published or non-listed number or exclude their address from their listing. Customers in areas where Caller ID services are available can block the display of their phone numbers and names. (Note that Caller ID blocking does not prevent the transmission of your phone number when you dial certain business numbers, including 911, or 800, 888, 877, and 900 numbers).
Further, customers can express a preference not to be called for marketing purposes (please see section PSC’S “DO NOT MARKET” LIST below for more information). Customers may opt out of our direct mailings and other service marketing programs. (Please see the section USE OF CUSTOMER PROPRIETARY NETWORK INFORMATION below for details on PSC’s Policy on using “Customer Proprietary Network Information”). A customer may indicate a preference change by contacting PSC customer service.
We use individual customer information internally for planning purposes – so that we can, for example, develop, test, and market new products and services that meet the needs of our customers. Ordinarily, such information is combined into aggregations that do not include individual customer identities. Under certain circumstances, we are legally required to disclose the aggregated information to other companies, but customer identities are not included in such cases.
PSC enables customers to control how PSC discloses individual information about them to other persons or entities, except as required by law or to protect the safety of customers, employees, or property.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose to refrain from having your information collected or used in this way. You can opt-out out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also e-mail us at email@example.com or call us at 800-511-4899 to request access to, correct, or delete any personal information you provided. We cannot delete your personal information except by deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
All PSC employees are responsible for safeguarding individual customer communications and information.
We never tamper with, intrude upon, or disclose the existence or contents of any communication or transmission except as required by law or the proper management of our network. Access to databases containing customer information is limited to employees who need it to perform their jobs – and they follow strict guidelines when handling that information. We use safeguards to increase data accuracy and identify and authenticate customer information sources. We use locks and physical security measures, sign-on and password control procedures, and internal auditing techniques to protect against unauthorized use of terminals and entry into our data systems. PSC requires that records be safeguarded from loss, theft, unauthorized disclosure, and accidental destruction.
In addition, sensitive, confidential, or proprietary records are protected and maintained in a secure environment. Our policy is to securely destroy records containing sensitive, confidential, or proprietary information. Hard copy confidential, proprietary, or sensitive documents are made unreadable before disposition or recycling. Electronic media must be destroyed using methods that prevent access to information stored in that type of media. Just as employees would report stolen property, missing records and suspicious incidents involving records are referred to PSC Management. We encourage our employees to implement and enforce PSC’s privacy policies proactively. If employees become aware of practices that raise privacy or security concerns, they must report them to their supervisors.
While we have made significant efforts to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Unfortunately, no data transmission over the Internet can be guaranteed to be 100 percent secure. We will not be held liable should a third party illegally obtain your personal information via Internet transmission.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users and information that does not identify any individual without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PSC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PSC about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If disclosure is necessary or appropriate to protect the rights, property, or safety of PSC, our customers, or others. This includes exchanging information for fraud protection and credit risk reduction with other companies and organizations.
Ordinarily, PSC will only share individual customer information with persons or entities outside the company to assist us in providing services to which the customer subscribes. We do not use third-party marketers, nor do we share access to individual customer information derived from the provision of PSC telecommunications services with other companies interested in marketing other services to our customers – and we would not do so without the customer’s consent. PSC is committed to ensuring that customer information is not used without the knowledge and permission of our customers.
However, there are exceptions to our general practice. For example, unless you request otherwise, we may share certain personal or non-personal information with our affiliated companies with whom we have established business relationships. In addition, if PSC enters into a merger, acquisition, or sale of all or a portion of its assets, a customer’s personally identifiable information will, in most instances, be transferred as a part of the transaction, subject to required notices to affected customers. In addition, we may where permitted by law, provide information to credit bureaus or provide information and sell receivables to collection agencies to obtain payment for PSC billed products and services.
We are also required by law to provide billing name and address information to a customer’s long-distance carrier and other telephone companies to allow them to bill for telecommunications services. (By law, customers with non-published or unlisted service have the right not to have their billing name and address disclosed when they make a calling card call or accept a collect or third-party call. However, if they do restrict disclosure, they will be unable to make calling card calls or accept collect and third-party calls.) Similarly, we must provide directory publishers with subscriber listing information – name, address, and phone number, and for yellow page advertisers, primary advertising classification – for publishing and delivering directories. In addition, under certain circumstances, we may share customer information with other carriers or with law enforcement, for example, to prevent and investigate fraud or other unlawful use of communications services.
USE OF CUSTOMER PROPRIETARY NETWORK INFORMATION
Definition of “Customer Proprietary Network Information”
The term “customer proprietary network information” is defined by federal statute to mean: (i) information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (ii) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier.
Use of Customer Proprietary Network Information
Under federal law, you have the right to, and we have the duty to protect, the confidentiality of your CPNI. However, we may use CPNI without your consent, in a manner consistent with applicable law, to (i) initiate, render, bill, and collect for our services; (ii) market services among the categories of service to which you already subscribe; (iii) provide inside wiring installation, maintenance, and repair services; (iv) provide maintenance and technical support for our services; (v) protect our rights and property, and protect users of our services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, these services; and (vi) provide any inbound telemarketing, referral, or administrative services for the duration of a customer-initiated call.
Further, after providing you with the required notice and opportunity to “opt-out,” we may use your CPNI consistent with applicable law to market additional communications-related services and conduct surveys to improve our service offerings.
PSC will not use your CPNI for purposes other than those described above unless we obtain your express “opt-in” consent. For example, without such consent, we will not use CPNI to market services not provided by PSC or share your CPNI with third parties (subject to the limitations discussed below).
Limits on the disclosure of CPNI outside PSC
Generally, PSC does not use third-party marketers and will not disclose your CPNI to third-party contractors without your explicit “opt-in” consent. This means that our records of the services you buy and the calls you make generally will remain private if you choose to keep them since we will not ordinarily disclose this information to outside parties without your permission. However, we will release customer information without involving you if the disclosure is required by law or necessary to protect the safety of customers, employees, or property. For example: When you dial 911, information about your location may be transmitted automatically to a public safety agency.
Certain information about long-distance calls may be transmitted to your long-distance company for billing purposes. We are also required by law to give competitive local exchange carriers access to customer databases for purposes of serving their customers, to exchange credit information with other carriers, and to provide listings (other than certain non-published and non-listed information) to directory publishers.
We will disclose information necessary to comply with law enforcement statutes, such as valid, properly issued, and legally enforceable subpoenas, warrants, and court orders.
Where permitted by law, we may share CPNI with third parties where necessary to provide the services you subscribe to, protect our rights or property, and protect users of our services and other carriers from fraudulent, abusive, or unlawful use of services.
Where permitted by law, we may provide CPNI to third parties such as credit bureaus or sell receivables to collection agencies to obtain payment for PSC-billed products and services.
Authentication to prevent unauthorized access to CPNI
PSC is committed to ensuring that only properly authorized individuals can access CPNI for legitimate purposes. This includes ensuring that any request by a “customer” to access CPNI is valid and properly authenticated in accordance with applicable law and industry best practices. Our internal policies and procedures are designed to ensure that CPNI is not released to unauthorized individuals.
Further, if a “customer” calls us to access “call detail records” (which include the number called, the number from which a call was placed, and the time, location, or duration of any call), we will not release those records unless (i) during the call, the customer provides a pre-established password; (ii) the information is sent to the customer’s address of record; or (iii) after the call, we call the customer’s telephone number of record to provide the requested information. If a “customer” attempts to access CPNI through our Website, we will only provide such access if the customer has established a password and backup authentication mechanism for the relevant account in a manner that does not rely on readily available biographical or account information. If a “customer” attempts to access CPNI by visiting a retail location in person, we will only provide such access if the “customer” presents valid photo identification matching the name of record on the account. (Note that different procedures may apply to certain business customers served by a dedicated account representative where the underlying service agreement addresses CPNI protection and authentication.) We also will notify you at your address of record if anyone changes the access authorization or authentication information associated with your account.
Notice of unauthorized access to CPNI
As a company, we are vigilant in protecting your CPNI. However, should we become aware that your CPNI has been accessed without proper authority, we will take swift action to fully document and address such unauthorized access and provide appropriate notice. In particular, we will (i) notify law enforcement (including the United States Secret Service and the Federal Bureau of Investigation) within seven business days; and (ii) notify you and any other affected customers within seven business days after that, unless earlier notification is necessary to avoid immediate and irreparable harm, or we are instructed by law enforcement personnel to refrain from providing such notice.
PSC’S “DO NOT MARKET” LIST
Any PSC customer can express a preference not to be called by us for marketing purposes, and PSC will respect such preference. A customer who does not wish to receive sales calls from PSC may ask to be placed on our company-specific “DO NOT MARKET” list. We will note the customer’s request immediately, although it may take up to 30 days for the customer’s telephone number to be removed from any active lists or sales programs that are currently underway.
Customers can ask to be put on our “DO NOT MARKET” list by contacting PSC’s customer service department. All customers should call (800) 511-4899. The requesting customer should provide, at a minimum, the telephone number that is the subject of the request, although including the customer’s name and address is also useful. If a customer has multiple telephone numbers, the customer should tell us all numbers that should be placed on the “DO NOT MARKET” list.
A residential customer will remain on our “DO NOT MARKET” list until the customer notifies us in writing to remove their name from the list. A business customer will remain on our “DO NOT MARKET” list until the business notifies us in writing to remove its name from the list. If a customer’s telephone number changes, the customer must give us updated information for the “DO NOT MARKET” status to remain in effect.
Notwithstanding that a customer’s telephone number is on our “DO NOT MARKET” list, we may still contact that customer regarding surveys, billing, and other service-related matters. Further, the customer should understand that being on our “DO NOT MARKET” list will not prevent calls from other companies unaffiliated with PSC.
YOUR STATE PRIVACY RIGHTS
State consumer privacy laws may provide their residents with additional rights regarding using their personal information.
St. Meinrad Office:
11877 E. State Road 62
PO Box 126
St. Meinrad, IN 47577
By phone: (800) 511-4899