Effective: July 2014
Sweetwater Cable Television (“Sweetwater”) takes the protection of our subscribers’ (“you,” “your” or “customer”) privacy seriously.
This Policy only covers information about you that is collected by Sweetwater in connection with the provision of our services. This Policy does not cover information that may be collected through any other products, services, or websites, even if accessed through our services and even if co-branded with our services. You should read the privacy policies for these other products, services, websites and providers to learn how they handle your personal information. Depending upon the service to which you subscribe, parts of this Policy may not be applicable to you. Please review this Policy in conjunction with your service agreement. We may modify this Policy at any time. The most current version of this Policy can be found on http://www2.sweetwaterhsa.com/.
If you find the changes unacceptable and if those changes materially and adversely impact your use of the service, you may have the right to cancel your service. If you continue to use the service following the posting of a revised Policy, we will consider that to be your acceptance of and consent to the Policy as revised. What type of information does Sweetwater collect? Sweetwater collects both personally identifiable information and non-personal information about you when you subscribe to our service.
Sweetwater uses its system to collect personally identifiable information about you:
(a) when it is necessary to provide our services to you;
(b) to prevent unauthorized reception of our services; and
(c) as otherwise provided in this Policy.
Sweetwater will not use its cable system to collect your personally identifiable information for other purposes without your prior written or electronic consent. Sweetwater also collects personally identifiable and non-personal information about you when you voluntarily provide information to Sweetwater, as may be required under applicable law, and from third parties, as described in this Policy. Personally identifiable information is any information that identifies or can potentially be used to identify, contact, or locate you. This includes information that is used in a way that is personally identifiable, including linking it with identifiable information from other sources, or from which other personally identifiable information can easily be derived, including, but not limited to, name, address, phone or fax number, email address, spouses or other relatives’ names, driver’s license or state identification number, financial profiles, social security number, bank account information, and credit card information. Personally identifiable information does not include information that is collected anonymously (i.e., without identification of the individual or household) or demographic information not connected to an identified individual or household.
Non-personal information, which may or may not be aggregated information about our customers and may include information from third parties, does not identify individual customers. Examples of non-personal information include IP addresses, MAC addresses or other equipment identifiers, and other data. Our systems may automatically collect certain non-personal information when you use an interactive or transactional service. This information is generally required to provide the service and is used to carry out requests that a customer makes through a remote control or set-top box. We may also collect and maintain information about your account, such as billing, payment and deposit history; maintenance and complaint information; correspondence with or from you; information about the service options that you have chosen; information the equipment you have, including specific equipment identifiers; and information about your use of our services, including the type, technical arrangement, quantity, destination and amount of use of certain of those services, and related billing for those services.
Why does Sweetwater collect personally identifiable information?
Sweetwater collects and uses personally identifiable information to: properly deliver our services to you; provide you with accurate and high-quality customer service; perform billing, invoicing and collections; provide updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services; protect the security of the system, prevent fraud, detect unauthorized reception, use, and abuse of Sweetwater ‘s services or violations of our policies or terms of service; keep you informed of new or available products and services; better understand how the service is being used and to improve the service; manage and configure our devices, systems and network(s); maintain our accounting, tax and other records; and comply with applicable federal and state laws and regulations, as well as for the general administration of our business. If you use an interactive or transactional service, for example, responding to a survey or ordering a pay-per-view event, the system will collect certain additional personally identifiable information, such as account and billing information or customer-provided locale and service preferences, to properly bill you for the services purchased and to provide you with a more personalized experience. In addition, certain information, such as your connections to our system (e.g., information related to your equipment and program selections), is automatically collected to, for example, make it possible for your digital boxes to receive and process the signals for the services you order. Our system may also collect anonymous and/or aggregate information using set-top boxes and other equipment. Such information may be used subject to the terms of this Policy. Sweetwater may also maintain research records containing information obtained through voluntary subscriber interviews or surveys.
Who sees the information collected by Sweetwater? Sweetwater will only disclose personally identifiable information to others if:
(a) a customer provides written or electronic consent in advance, or
(b) it is permitted or required under federal or applicable state law.
Specifically, federal law allows Sweetwater to disclose personally identifiable information to third parties: when it is necessary to provide Sweetwater’s services or to carry out Sweetwater’s business activities; for mailing list or other purposes, subject to your ability to limit this last type of disclosure as described below; or as required by law or legal process. To provide services and carry out our business activities, certain authorized people have access to your information, including our employees, entities affiliated through common ownership or control with Sweetwater and third parties that provide and/or support our provision of the services. The frequency of disclosures varies according to business needs, and may involve access on a regular basis.
Federal law allows Sweetwater to disclose through “mailing lists” certain personally identifiable information to non-affiliated entities for non-service related purposes, unless a customer objects in advance. Sweetwater has, however, elected to not disclose customer information through mailing lists at this time. As part of its business activities, if Sweetwater enters into a merger, acquisition, or sale of all or a portion of our assets, Sweetwater may transfer its customers’ personally identifiable and non-personal information as part of the transaction. If allowed by and after complying with any federal law requirements, Sweetwater may disclose personally identifiable information about you to representatives of government or to comply with valid legal process. In these situations, Sweetwater may be required to disclose personally identifiable information about a customer without the customer’s consent and without notice to the customer. Law enforcement agencies may, by federal or state court order, and without notice to you, obtain the right to install a device that monitors your Internet and e-mail use, including addresses of email sent and received and in some cases the content of those communications; and/or your use of our telephone service, including listings of incoming and outgoing calls and in some cases the content of those calls. In some instances where there are valid legal requests for or orders for disclosure of your information, we may notify you of the requests or orders and then it may be up to you to object or take specific action to prevent any disclosures pursuant to those requests or orders. We may also use or disclose personally identifiable information about you without your consent (a) to protect our customers, employees, or property, (b) in emergency situations, (c) to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions or policies and/or (d) as otherwise required by law, for example, as part of a regulatory proceeding.
We may collect information on our websites using cookies, web beacons or similar technologies. These methods permit us to collect various types of information, including which pages you visit, how you use the services, which of our email messages you read, and other information. Sweetwater may use this information to understand usage patterns and perform analyses, to provide you with more personalized service and to improve your online experience. Most web browsers permit users to disable or reject cookies, though doing so may limit the personalization available to you and your access to sections of our website.
How long does Sweetwater maintain personally identifiable information?
Sweetwater will maintain personally identifiable information about you as long as you are a subscriber to Sweetwater’s service and as long as necessary for the purpose for which it was collected. If you are no longer a subscriber to any Sweetwater service and the information is no longer necessary for the purpose for which it was collected, Sweetwater will only keep personally identifiable information as long as necessary to comply with applicable legal requirements. How does Sweetwater protect customer information? Sweetwater takes the security of our customers’ personally identifiable information seriously. Sweetwater takes such actions as are reasonably necessary to prevent unauthorized access by entities other than Sweetwater to personally identifiable information.
However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information. You need to help protect the privacy of your own information. You must take precautions to protect the security of any personally identifiable information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices by using passwords, encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personally identifiable information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks in your home. What are my rights with respect to the information that Sweetwater collects about me? The Cable Act permits customers to limit or prohibit the use of their information for certain marketing practices and disclosures. Sweetwater has elected to not engage in those practices and disclosures at this time. You may not opt-out of service-related communications from Sweetwater or the collection of non-personally identifiable data for the purpose of audience measurement or website analytics. You have a right under the Cable Act to see your personally identifiable information that Sweetwater collects and maintains. The information Sweetwater has about its customers is maintained at its offices and systems. In most cases, the personally identifiable information contained in these records consists solely of billing and account information. If you would like to see your information, please send a written request to Sweetwater at the address found on your monthly bill or by visiting our website at http://www2.sweetwaterhsa.com/. Sweetwater will be glad to make an appointment for you to come in to our office during regular business hours. If your review reveals an error in our records, Sweetwater will correct it.
Additional Provisions for Telephone Customers In providing telephone services, we collect subscriber list information, which is limited to your name, address and telephone number. We also collect information about the quantity, technical configuration, type, destination, location, and amount of your use of the telephone services and information contained on your telephone bill concerning the type of phone services and features you receive. That information, when matched to your name, address, and telephone number, is known as customer proprietary network information or “CPNI” and is subject to additional privacy protections. CPNI does not include subscriber list information, by itself. Examples of CPNI include information typically available from details on a customer’s monthly telephone bill — the type of line, technical characteristics, class of service, current telephone charges, long distance and local service billing records, directory assistance charges, usage data, and calling patterns. For your protection, we will not disclose your call detail records over the phone to an inbound caller, and we require the use of a password to log into accounts where you can view your CPNI online. We will use, disclose, or permit access to CPNI to provide you with the services to which you subscribe, including for use in directories; to bill and collect for communications services; to protect our rights or property, or to protect users or other carriers or service providers from fraudulent, abusive or unlawful use of, or subscription to, such services; to provide inside wiring installation, maintenance, or repair services; as required by law; or as expressly authorized by the customer. Although federal law permits us to use CPNI for certain marketing, we have elected not to use such information for marketing. We also do not provide or sell your CPNI to any third party for marketing activities.