Effective as of April 28th, 2022
Your California Privacy Rights
For all requests, include Customer’s full name, street address, city, state and zip code.
In an email request, Customer must state “Re: Your California Privacy Rights” in the subject line and send Customer email to email@example.com .
In a postal request, Customer must send a letter or post card to: 360 Communications, Inc. PO BOX 1663 Durant, OK 74702 Attention: Your California Privacy Rights
360 Communications’s Site and Services are designed and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. If Customer is not a U.S. citizen or do not reside in the U.S., Customer voluntarily consents to the collection, transfer, use, disclosure and retention of Customer Personal Information (as defined below) in the U.S. Customer also agrees to waive any claims that may arise under Customer’s own national laws.
When Customer uses the Service, the Personal Information Customer sends and receives is transmitted over a wireless network, and may be subject to interception by unauthorized third parties who seek to do you harm. While it is 360 Communications’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Customer sends and receives through the Service, 360 Communications cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.
360 Communications recommends that Customers use caution when sending any Personal Information over the Internet and use encryption technology whenever possible, such as websites that have the “https” designation in the website’s address bar and show a padlock icon in the browser’s window.
360 Communications does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Customer is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to 360 Communications. If 360 Communications learns that 360 Communications has collected Personal Information from a child under age 13, 360 Communications will delete that information as quickly as possible to the extent technically feasible. If Customer believes that its child under age 13 may have provided 360 Communications Personal Information, please contact 360 Communications at firstname.lastname@example.org .
360 Communications collects various types of information about Customers and Customers’ use of the Service via the 360 Communications website, Help Desk and call centers, postal mail, remote kiosks, the 360 Communications Facebook Page or other social network platforms or by other means, generally classified as Personal Information and Non-Personal Information. Generally, 360 Communications gathers and uses Personal Information internally in connection with providing the Service to Customer, including to personalize, evaluate and improve the Service and 360 Communications’s ability to provide the Service to Customer, to contact Customer, to respond to and fulfill Customer requests regarding the Service, and to analyze how Customer uses the Service. 360 Communications may share Customer’s Personal Information with its Affiliates and with other third parties as described below:
What Information does 360 Communications collect and how does 360 Communications use this Information?
Personal Information is the information Customer provides to 360 Communications voluntarily or passively through Customer use of the Service and/or website, and which is directly associated with or reasonably linked to a specific person, computer or device. For example, through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Customer’s premises, when Customer contacts 360 Communications regarding the Service, and through Customer account settings, 360 Communications collects Personal Information such as Customer name, email address, phone number, billing address and billing information (such as credit card account number or other financial account information), service address, and the nature of any of Customer devices or other property making use of the Service. Personal Information also includes Customer proprietary network information (“CPNI”) which is collected and used to provide VoIP services. CPNI includes any information that relates to the quantity, technical configuration, type, destination, location, and amount of use of our VoIP service, such as call detail, logs, and specifics regarding your VoIP account.
Customer may be required to provide certain Personal Information to 360 Communications in order to register with 360 Communications, to assist 360 Communications in improving Customer’s Service or troubleshooting problems Customer is experiencing with the Service, Customer computer or device, or otherwise to improve the quality of the Service. 360 Communications will communicate with Customer if Customer has provided 360 Communications the means to do so. For example, if Customer has given 360 Communications Customer’s email address or phone number, 360 Communications will email or call Customer about Customer use of the Service or product improvements or upgrades, and other transactional information about Customer Service. 360 Communications may also combine Customer Personal Information with additional Personal Information obtained from 360 Communications Facebook Pages or other social network platforms, its Affiliates, its Operational Service Providers (third party owned companies that provide or perform services on 360 Communications’s behalf, to help serve Customer better and to perform functions in order to support 360 Communications businesses and operations), or other companies, such as credit bureaus, background check firms, and marketing research companies. Some forms of Non-Personal Information as described below will be classified as Personal Information if required by applicable law or when such information is directly associated with or reasonably linked to a specific person, computer or device, or is combined with other forms of Personal Information.
Technology is improving every day and to improve 360 Communications’s Services’ operations and functions, 360 Communications may introduce new technologies and monitoring techniques without advance notice or consent from Customer, unless required by law. 360 Communications may also use third party providers to conduct such internal analyses.
Network Information Used for Standard Business Operations
360 Communications also collects Network Information, information about Customer access to, and use of, the 360 Communications Network, which may or may not be directly associated with or reasonably linked to a specific person, computer or device. For example, 360 Communications may collect information about the performance of the Provider Equipment installed on Customer property or at Customer premises, when Customer is using the Service, the various devices Customer is using to access the Service, the amount of data Customer is transmitting and receiving, the content of the data Customer are transmitting and receiving, the websites Customer is visiting, and any other information that is transmitted over the 360 Communications Network. 360 Communications may also aggregate Network Information from multiple customers and 360 Communications will share such aggregated Non-Personal information about the overall performance of the 360 Communications Service and the 360 Communications Network with our Affiliates and other third parties. Aggregated information does not identify a specific individual, computer or device. We use Network Information to monitor and enhance the performance of the 360 Communications Network. 360 Communications will not monitor the content of the websites viewed or email communications as part of 360 Communications’s standard network management.
Generally, 360 Communications will only monitor and preserve the following Network Information:
When Customer is using the Service;
- How Customer is using the Service, such as monitoring traffic patterns regarding websites visited, amount of data being sent or received, or other activity;
- The amount of data Customer is transmitting and receiving through the Service; and
- General information regarding the performance of the Provider Equipment installed on Customer’s property or at Customer’s premises, and its interaction with the rest of 360 Communications’s Network.
However, 360 Communications reserves the right to, and may, monitor, access, review and preserve any Network Information and/or content in the following situations:
In response to an inquiry from Customer or another Authorized User on Customer’s account regarding Customer or their use of the Service or problems Customer or they are experiencing using the Service;
- If 360 Communications has reason to believe Customer is using the Service in violation of Customer’s TSA or PSA or any applicable statutes, rules, ordinances or regulations;
- If 360 Communications has reason to believe Customer use of the Service is negatively affecting other Customers; or
- When 360 Communications is required by law or legal process to do so, or when 360 Communications a good faith belief that 360 Communications is required by law or legal process to do so.
How is Personal Information used for marketing and advertising purposes?
360 Communications will use Personal Information to send Customer marketing and advertising messages related to 360 Communications’s Service and website using Customer’s email address, postal address, or telephone number (for voice, texts, and pre-recorded calls). 360 Communications may deliver a marketing or advertising message based on Customer visits to 360 Communications website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter. 360 Communications may also send Customer “First Party Advertising,” which is advertising that is customized or personalized based on a history of Customer’s use of our Services (possibly combined with information from our Facebook fan page or other social network platforms). First Party Advertising is based solely on a combination of information 360 Communications collects from Customer – not from Customer’s visits to other websites across the Internet. Customer may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage Customer is viewing. And Customer may continue to receive general advertising if Customer opts-out of First Party Advertising, it will not be customized or personalized for Customer. 360 Communications does not provide third party “Network Advertising,” which is advertising based on Customer’s overall Internet usage across different third party websites or online services. Multiple third party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Because 360 Communications does not provide network ads, 360 Communications does not recognize the “Do Not Track” settings on various Internet browsers. 360 Communications does not engage or allow third parties to track you across the Internet and across time for advertising purposes.
360 Communications will share Customer Personal Information with its Affiliates and with other third parties as described in this section for standard business operations :
- To Our Affiliates. 360 Communications may rely on various Affiliates in order to provide the Service to Customers. These are companies that are related to 360 Communications by common ownership or control. 360 Communications may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, and 360 Communications’s own (First Party) promotional and/or marketing and advertising purposes.
- To Operational Service Providers: 360 Communications and its Affiliates contract with other companies and people to perform tasks or services on 360 Communications’s behalf and need to share Customer Personal Information to provide products or services to Customers. For example, 360 Communications may use a payment processing company to receive and process Customer’s ACH or credit card transactions for 360 Communications, or 360 Communications may contract with third parties to assist 360 Communications in optimizing the 360 Communications Network. Unless 360 Communications tells Customer differently, 360 Communications does not grant its Operational Service Providers any right to use the Personal Information 360 Communications shares with them beyond what is necessary to assist 360 Communications.
- For Business Transfers/Restructuring: 360 Communications may choose to buy or sell assets, or 360 Communications may sell assets or be sold. In these types of transactions, Customer Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if 360 Communications (or 360 Communications’s assets) are acquired, or 360 Communications goes out of business, enter bankruptcy, or go through some other change of control, including restructuring, re-organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.
- When Required by Law or in Response to Legal Process: 360 Communications reserves the right to access, read, preserve, and disclose any Personal Information to which 360 Communications has access if 360 Communications is required by law or legal process to do so, or if 360 Communications has a good faith belief that 360 Communications is required by law or legal process to do so.
Is Customer Personal Information secure?
360 Communications endeavors to protect the privacy of Customer’s account and other Personal Information 360 Communications by using reasonable administrative, technical and physical security measures. However, 360 Communications cannot and do not guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Information at any time. Customer’s account is protected by a password for Customer privacy and security. It is Customer’s responsibility to prevent unauthorized access to Customer’s account and Personal Information by selecting and protecting Customer password and/or other sign-on mechanism appropriately and limiting access to Customer computer, tablet or device and browser by signing off after Customer has finished accessing Customer’s account. Customer is required to notify us immediately if Customer’s password or account has been disclosed to a person whose name does not appear on Customer’s account, even if you have allowed such disclosure. Customer understands, acknowledges and agrees that Customer is solely responsible for any use of 360 Communications Services via Customer’s username and password.
Additionally, if Customer contacts 360 Communications, 360 Communications will ask Customer for verification of Customer’s identification and account. 360 Communications will not send an email or text, nor should Customer respond to any email or text communications asking for any sensitive or confidential Personal Information, such as social security number, bank account or credit card account number, or a driver’s license number. If Customer receives an email or text requesting any such information from 360 Communications or someone that claims they are with 360 Communications or Our Affiliates please contact our Privacy Administrator immediately: email@example.com For 360 Communications’s IT Support Services as detailed in our TSA or PSA, the code that allows 360 Communications to access Customer’s computer desktop to help your resolve technical problems is limited only for that specific session. 360 Communications is not able to access Customer’s Computer without Customer’s knowledge, affirmative consent and involvement.
What Personal Information can Customers access, modify and/or delete?
Generally, Customer may access the following Personal Information in Customer’s account:
- Full name
- Username and password
- Email address
- Telephone number; and
- Billing and Service address
- Account and billing information
By contacting 360 Communications at firstname.lastname@example.org , or through any online access portal and/or via telephone, 360 Communications may enable Customers to view, access and modify Customer account settings, and in some cases, edit or delete the Personal Information listed above. For example, 360 Communications may retain historic email, billing and/or Service addresses for security and verification purposes and Customers may not delete such information even after the subscription expires or terminates. Current Customers may not delete any Personal Information because such information is necessary to provide and bill for the Service; Customers may only update or modify Personal Information. When Customer updates Personal Information, however, 360 Communications may maintain a copy of the unrevised information in 360 Communications’s records for internal security reasons and recordkeeping. Some information may remain in 360 Communications’s records after it is modified, amended or deleted by Customer or 360 Communications. 360 Communications may use any aggregated data derived from or incorporating Customer’s Personal Information after Customer updates or deletes it, but not in a manner that would identify Customer personally. 360 Communications may also maintain Personal Information regarding Customer and Customer’s use of the Service after Customer is no longer a 360 Communications Customer as required by 360 Communications’s business practices, by law, and/or tax reporting purposes. The information Customer can view, update, and delete may also change. If Customer has any questions about viewing or updating information 360 Communications has on file about Customer, please contact 360 Communications at email@example.com .
What third party disclosure choices do Customers have?
If you have any questions or concerns regarding 360 Communications’s privacy practices and policies, please contact 360 Communications at firstname.lastname@example.org
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