Privacy and Customer Proprietary Network Information (CPNI)
This policy applies to personally identifiable information (“personal information”) that we directly associate with a specific entity or person (for example, name, social security number, addresses, telephone numbers and call records). Not included in personal information is “aggregate” or “anonymous” information, neither of which is associated with a specific entity or person.
Collection of Personal Information
We collect personal information about you when you use our services or otherwise interact with us including visiting our web site. This information includes personal information you provide when you sign up for and use our services, when you e-mail, call, or otherwise communicate with us. For example, we may collect credit personal contact, and billing information when you sign up for services or purchase other products or services. We may also collect personal information when you call and or e-mail our customer service representatives, enter information on our web site, pay for service, or submit survey responses. When your computer or other communication device accesses or web browsers, use our web sites, we automatically receive certain information, such as your browser type, IP address, and date and time. We may also obtain personal information about you from other sources. For example, we may obtain updated address information from our vendors or shippers. We may also purchase personal information (for example, e-mail lists, postal mail lists, marketing and demographic data) from others.
Use of Personal Information
We use personal information for a variety of business purposes, including but not limited to, completing transactions and billing for products and services, responding to your requests for service or assistance, verifying your identity, anticipating and resolving potential and or actual problems with our products and services, creating and improving products and services; suggesting different or additional products or services, making internal business decisions about current and future offers, providing personalized user experiences and service, and protecting our property and rights. We may also use personal information to contact you about GWI or third-party products, services, and offers, consistent with our CPNI Policy set out below, that we believe you may find of interest. We may contact you by telephone, postal mail, e-mail, or other methods. You may opt-out of receiving marketing communications from us at any time by contacting email@example.com.
Disclosure of Personal Information
We do not rent, sell, or otherwise provide your personal information to unaffiliated third-parties to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows: We can disclose personal information about you to third-parties with your consent. We can obtain your consent in several ways, such as in writing, orally, online, through “click-through” agreements, including through interactive voice response, or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.
Transaction Processing: We may disclose personal information to third-parties who complete transactions or perform services on our behalf (for example, customer service, billing, shipping, and marketing), and transactions on your behalf (such as, verification of your account information at your request to some third-party business), or transfers related to your service (for example, number portability). We typically restrict by contract the manner in which these third-parties may use and disclose personal information about you without your consent.
Primary Account Holder: We may disclose personal information of an account user to the primary account holder (which is the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you or your use of the service to them or others at their direction. When you are the primary account holder, but you receive special terms or discounted pricing, or other benefits through another party’s agreement with us (such as an employee discount), we may provide enough personal information to that party to verify your initial and continuing eligibility for benefits under their agreement with us and to calculate any associated discounts.
Legal Process and Protection of GWI and others: We may disclose personal communications or information where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (such as a lawful subpoena, E-9-1-1 information, court order), to initiate, bill, render, and collect for products and services, to enforce or apply agreements, to protect our rights and or property in connection with disputes, claims, or litigation; to protect users of our services and other carriers or providers from abusive, fraudulent, or unlawful use of, or subscription to, such services, to facilitate or verify the appropriate calculation of any fees, taxes, or other obligations due to a local, state, or federal government, or if we so determine disclosure is necessary in an emergency situation.
Third-party Services: When the use of our services allows you to take advantage of products and services offered by other companies your personal information may be disclosed.
Business Transfers: We may disclose personal information as part of a corporate business transaction, such as a acquisition or merger, corporate reorganization, or sale of company assets, joint venture, financing, or in the unlikely event of insolvency, receivership or bankruptcy, in which personal information could be transferred to third-parties as a business asset in the transaction.
Retention of Personal Information and Security
We use a variety of electronic, physical, and procedural safeguards to protect personal information from unauthorized use, access, or disclosure while it is under our control. For example when you provide sensitive information (like credit card numbers) to our web site, we use transmission encryption technologies like Secure Socket Layer (SSL). Although we cannot guarantee that misuse, loss, or alteration of your personal information will not occur, we strive to prevent such occurrences.
Our practices and procedures are designed to limit personal information access to those GWI employees and agents with a legitimate need to access such information. GWI employees are bound by confidentiality obligations, which obligate them to protect the confidentiality of our customers’ personal information. Violations of such would subject employees to disciplinary action, up to and including termination.
We retain personal information for as long as we have a business need or as applicable regulations and laws, or government orders require. When we dispose of personal information, we use reasonable procedures to erase or render it unreadable such as shredding documents and wiping electronic media. We will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred and creates a risk of service disruption, identity theft, or as otherwise required by law.
Access to Your Information
You may modify your contact information by contacting Customer Service. We will make good faith efforts to resolve requests to correct inaccurate information except where the request requires disproportionate technical effort or expense, is unreasonable, jeopardizes the privacy of others, or would be impractical.
Use of Your Information
Regarding our marketing communications you may choose to limit or opt-out of certain communications from GWI at any time. While you may elect not to receive marketing information from us, if you subscribe to our services, you will continue to receive customer-service and transactional notices, invoices, and similar communications. If you are a GWI customer you can change your marketing preferences by completing our customer opt-out form. If you are not a GWI customer and would like to opt-out of marketing communications from GWI, you can do so by completing our non-customer opt out form. You can also manage your marketing preferences by contacting Customer Service, or, with respect to marketing e-mails, by following the “unsubscribe” instructions on any marketing e-mail we send you.
We do not solicit children to purchase our products or services. If however, you authorize a child to use our products or services through your GWI account, any personal information associated with such use will be treated as your information in accordance with this policy. We encourage parents to be involved in all the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission. We may offer security features designed to allow the customer to implement restrictions to adult orientated content, but such features are not guaranteed nor are they foolproof.
Caller ID Blocking
When you use GWI’s communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill unless you block that information, which you can generally do by dialing *67 prior to dialing the called party’s phone number. For more details refer to the specific instructions for your communication device regarding Caller ID Blocking. Caller ID Blocking does not prevent the display of your information when you dial certain business numbers, including 911, toll-free numbers or 900 numbers.
Web Beacons, Cookies and Similar Technologies
Customer Service Monitoring
We may record and monitor e-mails, phone calls, or other communications between you and our Customer Service representatives or other employees for quality assurance purposes and training and to review specific transaction requests.
Forums and Chat Rooms
If you use or link to a public bulletin board, forum, chat room, or any type of social network on or from a GWI web site, please understand and be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of any personal information you choose to submit or share with others.
We do not publish directories of our customer’s numbers. Neither will we provide or make such numbers available to any third-parties for listing in their public directories, without the customer’s prior consent.
Other Governing Terms
This policy does not alter or modify any applicable agreement you have with GWI. Also, if you subscribe to our services, our GWI Terms and Conditions and certain other terms may apply to your purchase, use, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency as permitted by law.
Protecting Your Own Personal Information
You play a key role in ensuring the security of your personal information, including protecting against unauthorized access to your device. We encourage you to use passwords to prevent unauthorized access to your information and your voicemail. We recommend that you periodically change your passwords, use unique, non-obvious passwords, and that you not share your passwords with others. Notify us immediately if you believe your personal information has been accessed without your consent.
Customer Proprietary Network Information (CPNI)
Customer Proprietary Network Information, or “CPNI”, is a form of personal information that is generated in connection with the phone services we provide to you. CPNI includes information such as call details, and certain information about your rate plans and features. CPNI however does not include your name, phone number and address. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted procedures and policies designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under applicable law, FCC rules, or explained in this policy. However you may designate other “authorized users” (such as a spouse) to access and manage your account information, including CPNI.
USE OF CPNI
We may use CPNI in the course of providing repair services to you. We may also use CPNI to market GWI services to you that may enhance services that you already receive from GWI. Finally, we may use, disclose or permit access to CPNI to protect the rights or property of GWI or to protect users of GWI’s services from fraudulent, abusive or unlawful use of, or subscription to, such services.
USE OF CPNI UPON AUTHORIZATION FROM THE CUSTOMER
We may use CPNI or disclose CPNI to GWI’s agents and any affiliates that provide communications-related services for the purpose of marketing communication related services to you that are outside the category of service to which you already subscribe. As an example, we may utilize CPNI generated in our furnishing phone service to you to market to you, data services. However, you have the right to restrict our use of your CPNI for this purpose. If you would like to opt out of this type of marketing, you may notify us in writing by mailing such writing to: Marketing, GWI 8 Pomerleau St. Biddeford, ME 04005 or you may call customer service and a customer service representative will note your desire to opt out in your billing record. If you do not notify us within 30 days of this notification that you wish to restrict our use of your CPNI, we will conclude that you consent to our use of CPNI for this limited purpose. The approval shall be valid until you affirmatively revoke or limit such approval. Your decision to opt out of such marketing will not affect the provision of any services to which you subscribe. Your decision to permit such marketing may enhance our ability to offer products and services tailored to your needs.
Changes to This Policy
How to Contact Us
If you have any questions or comments about this policy or about GWI’s privacy practices, please contact Customer Service by sending an e-mail message to firstname.lastname@example.org, by accessing Customer Service through our web site or by calling Customer Service at 866-494-2020.
You may also direct your privacy-related comments or questions to the address below:
43 Landry Street
Biddeford, ME 04005