Customer Privacy Notice
SEPTEMBER 2020
As an MCTV customer, you have a right to know what we do with your personal information that we have. We consider our treatment of such information to be a part of the trust you place in us by using our Internet, TV and Phone Services (“Services”). This Customer Privacy Notice (“Notice”) applies to customers of our Services. Use of the words “customer,” “you” or “your” refers to any subscriber of a Service. We have updated this Notice, and will continue to update it, to better answer questions you may have, but our basic privacy policy will remain the same. We collect and keep only the personal information of our customers that is needed to provide our services, treat it as private, use it only for what we offer you, do not sell it to others, work to keep it secure and destroy it when no longer needed.
In accordance with Section 631 of the Cable Act, we provide you with this separate, written Notice when you first become a customer and at least annually thereafter. This Notice includes information required by the Cable Act, including: (1) the kind of information MCTV collects; (2) how MCTV uses personally identifiable information; (3) to whom MCTV may disclose personally identifiable information; (4) how long MCTV keeps personally identifiable information; (5) how you can inspect records pertaining to your personally identifiable information; and (6) your legal rights. We also regularly update our privacy policy and post the most up-to-date policy on our websites. You can find additional and updated information at any time by visiting our website at www.MCTVOhio.com. We encourage you to review our policies by visiting our website periodically for the latest information and updates. You can learn more about your privacy rights by visiting the websites of the Federal Trade Commission, www.ftc.gov, and the Federal Communications Commission, www.fcc.gov.
In providing services to you, we obtain certain “personally identifiable information”; that is information that identifies you or your business individually or can be reasonably used to identify you individually. Personally identifiable information may include one or more of the following: name, service address, billing address, telephone numbers, social security number, employer identification number (EIN), driver’s license number, user IDs, email addresses and credit card information. Personally identifiable information does not include de-identified, anonymous, or aggregate data that does not identify you individually. For example, information regarding your age would only be considered personally identifiable if it was combined with your name or other information that could identify you individually.
It is important to understand the difference between personally identifiable information and information that is not personally identifiable in order to understand protections granted to Cable, Internet and Phone subscribers under the Communications Act of 1934. The Communications Act allows us to collect personally identifiable information only:
- If you consent, in advance, in writing or electronically;
- In order to provide cable or other services to you; or
- To detect unauthorized reception.
Subject to certain exceptions, we may not disclose personally identifiable information about you, except as necessary to render the Services to you or other services we provide to you in related business activities or with your consent. Prior to complying with a demand by a third party for information about you, we may notify you and you may have the right to oppose the disclosure in court. There are exceptions to this, such as disclosures to law enforcement agencies required by law. We explain below how we respond to requests from law enforcement agencies for disclosure of personally identifiable information.
INFORMATION WE COLLECT
When you subscribe to our Services and interact with us as a customer, we collect both personally identifiable information and information that is not personally identifiable. We collect this information as part of our provision of the Services and keep business records that may include personally identifiable information. The collected information includes information that you may give us when you sign up for a Service or which is provided to us during the course of your relationship with us as a customer. This information includes, but is not limited to: name, service address, billing address, telephone numbers, social security number, employer identification number (EIN), driver’s license number, user IDs, email addresses, names of spouses or relatives, birth dates, credit card, debit card or bank account information. Additionally, we also maintain customer information concerning credit, billing and payments, security deposits, purchases made over the cable system, maintenance and repair, equipment and services provided, and other service-related functions. In providing our Services, we may also collect information about your video equipment, the number and location of television sets in your home or business that are connected to our cable system, computer hardware and software, modems, routers, associated electronic addresses, settings, and other preferences to aid in billing, maintenance and customer support.
Internet Services. Like most Internet service providers, we automatically collect certain general information concerning your use, such as the Internet Protocol (IP) addresses assigned (an identifier assigned to your computer while online), MAC addresses (individual equipment identifiers) of equipment that is used, bandwidth used, system and connection performance, browsers used, dates and times of access and Internet resource requests, including requests to access web pages. Some of this information may identify those subscribers who have downloaded certain materials or accessed certain websites. This type of information is generally retained for about six months. We do not store online messages sent or received unless left in your MCTV Internet account file. Since we cannot control Web sites or Internet services operated by third parties, we recommend that you review the terms of service and privacy policies of those Web sites and services. You can find more detailed information concerning our Online Privacy Policy on our website at www.MCTVOhio.com.
TV Services. We collect certain information in providing you with our cable television and other services. The law prohibits us from using the cable system to collect personal information for unrelated purposes without your consent.
Unless you are notified and agree, we will not collect user information concerning most video program viewing, except as needed to bill you. In providing some specific cable TV services, such as pay-per-view, Video On Demand and interactive cable services, we do maintain limited usage information for billing, programming and related purposes. Aggregate information that does not identify you may be collected and used for programming, advertising and similar purposes. In some cases, non-personal aggregate information may be collected by the cable system in order to determine which programs are most popular, how many people are watching the show, and which cable features are used most often. This aggregate information may be provided to third party audience measurement firms who may combine it with other demographic information to conduct more comprehensive audience analysis. MCTV may also use such information to distribute relevant programming and advertising to customers, without disclosing personally identifiable information about customers, to programmers or advertisers. When we provide digital video recorder services, we may also receive detailed information concerning your use and operation of the recorder for the uses described below in “Use and Sharing.”
Phone Services. In some areas we provide telephone services by “Voice over Internet Protocol” (VOIP). We do not listen to or record your calls. We do, however, monitor certain calls to our staff for quality purposes. In providing telephone services, we do receive usage information, including numbers called and received and duration of calls. We retain this information for up to two years, as required by some authorities, and we treat all such information as private.
Generally, we collect only the personal information needed to provide the Services we offer with the quality you desire and deserve. It is also our policy to keep that information secure and to retain it only as long as needed for our business purposes or as the law may require. We take reasonable precautions to identify you or your authorized representative when we receive an inquiry on your account as permitted by law. We also take reasonable steps to protect personally identifiable information from unauthorized access.
We sometimes collect personal information for special reasons, such as in surveys or registering at our Web Sites. In these instances, you will be notified before it is collected, told how it will be used and may elect not to participate.
USE AND SHARING
Use Policy. We consider personally identifiable information confidential and use it only for the business purpose of providing our Internet, TV and Phone services for such things as sales, installation, operations, administration, advertising, marketing, support, network management, maintenance, customer care, communications with you, billing and collection and for accounting and tax purposes. We may also use such information to monitor for, detect, and protect against both fraud and unauthorized use of our services.
We use aggregate information about our customers and their usage for a variety of purposes. Such aggregate information does not identify individual customers. We may share aggregate information with third parties, such as audience measurement firms who may combine it with other demographic information to conduct audience analyses for our own internal business purposes. MCTV may associate personally identifiable information with aggregate information or with information from others to better offer product and service preferences to you.
Sharing Policy. It is our policy not to disclose any personally identifiable information about you to others outside MCTV and our affiliates, agents, vendors, business partners and others who assist us with providing services to you, and other related business functions, without your prior consent. We do not sell or provide your personal information to parties unrelated to the services we provide without your permission. As a further measure, if in the future we sell mailing lists, you can affirmatively opt out of such sharing by writing to the return address on your billing statement, or you may contact us online at www.MCTVOhio.com. You can also notify us in either way if you prefer not to receive certain types of marketing contacts from us. MCTV sometimes uses affiliates, vendors, or partners in providing our services and may provide personally identifiable information for such purposes. We require that outside parties maintain at least the same level of confidentiality that we maintain. In addition, any use by the vendor may not exceed that needed to provide its service. We do not share personally identifiable information with other third parties without your consent. If you become a customer of a third party provider of any services directly, you should review its privacy policy, as it may differ from ours.
Special Exceptions. We reserve the right to disclose personally identifiable information if we have a good faith belief that it is necessary to: (1) comply with the law or legal process served on us; (2) protect and defend our rights or property or those of others; (3) respond to fraud, abuse, or unauthorized reception; (4) enforce our Website Visitors’ Agreement and Terms of Use, our Acceptable Use Policy, or related standards; or (5) act in an emergency to protect your safety or that of another. We may also share or transfer personally identifiable information along with your account as a part of any sale or transfer all or a portion of our business operations, merger or combination with another organization. In such a case, you will be notified of any changes in policy.
Retention Policy. MCTV may retain personal customer information in its regular business records as long as you are a customer or until no longer needed for business, tax, or legal purposes. Once these purposes no longer apply, we destroy, de-identify or anonymize the information according to our internal polices and protections. Our security measures for this information are discussed below.
Phone and Internet Services. Federal and some state regulations limit our use and sharing of certain information concerning a customer’s telephone and Internet services relating to the quantity, technical configuration, type, destination, location, nature of telecommunications or Internet, or telephone toll service you receive and the amount of your use of telephone or Internet service. This information is known as “Customer Proprietary Network Information” or “CPNI” and includes information on how you use our telephone and Internet services, such as your call patterns, service features, price plans, spending profiles, destinations and related information. In offering our spectrum of local and long distance telephone and Internet services, we do use your telephone or Internet service information to offer you new telephone or Internet services and pricing plans. If you do not want us to use your CPNI for this purpose, you may contact us at the number or address listed on this notice or on your regular bill. On the other hand, if you would like us to offer you information on video services or would like to learn about our bundled offers, please contact us in any of the same ways. Consenting to allow us to use your CPNI will help us offer you the best and most up-to-date services. Your consent will remain in effect until you notify us that you want to revoke or change your permission. Your choice will not affect the services you now receive. We do not disclose this information to unrelated parties, except as required by law.
Directory Listings. 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. These and certain other telephone services are offered subject to tariff or contractual terms that limit our liability in the event of such errors.
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 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.
TV Services. We provide aggregate information concerning pay-per-view, entertainment on demand and interactive services to programmers, advertisers and certain other third parties. Digital video recorder service information is not shared with programmers or third parties, except on an aggregate basis. If you use an interactive service to participate in or to order a product or service, you will be asked for your permission to provide contact information to the appropriate party. When we offer new services to you, like DVR and interactive features, we will also inform you about information we may need and how it may be used.
Enforcement of Your Rights. Federal law (including 47 U.S.C. §§ 222 and 551) limits the information a cable, phone and broadband provider may collect, maintain, use and share. You may enforce your rights concerning our collection, maintenance, use and sharing of your CPNI or PII. Among your remedies is the right to seek damages and reasonable costs and attorneys’ fees.
