What Kinds of Information Does Telefonetica Collect and Use?
Visiting Our Web site. Except as otherwise provided in this policy or in other written documentation or policies that may be provided to you regarding the services or Web site, the only personally identifiable information we collect about visitors to our Web site is provided to us voluntarily by you. “Personally identifiable information” is information that tells us specifically who you are, like your name, street address, email address, billing address, social security number, credit card number, other service account information, and certain other financial information. In general, you can visit our Web site without telling us who you are or revealing any personally identifiable information about yourself. Our Web servers may use “cookies” (described below) to collect information about visitors such as your domain name, host from which you access the Internet, the IP address of your computer, and your browser software and operating system. This information may be aggregated to measure such things as the number of visits, average time spent on the site, number of pages viewed, and methods by which our site was found. Telefonetica may use such information to evaluate the use of our site and to continuously improve the content and services being provided.
Feedback. At times we may ask you for contact information or conduct on-line surveys in order to better understand your needs so that we can provide you with a customized experience. If we wish to use this information other than as set forth in this policy, we will let you know at the time of collection. We will take commercially reasonable steps to safeguard this information from unauthorized access. However, any aggregate anonymized data that you send to us such as your questions, suggestions, ideas or other creative material (“Feedback”) belongs to us and will not be treated as confidential. We may use, reproduce, adapt, distribute, display, disclose or create derivative works from Feedback without acknowledgement or compensation to you.
Customer Proprietary Network Information (“CPNI”). We also want you to be aware that certain information related to your telecommunications services account with us such as to whom, where and when you make calls is CPNI. CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our Web site and in all other respects. Without your consent, we will only share or disclose your CPNI (i) to market to you services or products among the categories of services or products you currently subscribe, (ii) to initiate, render, bill and collect our telecommunications services, (ii) to protect you or other carriers from illegal or fraudulent use of, or subscription to, our services or to protect our rights or property, (iii) to provide your call location information in certain specified emergency situations, and (iv) for other legally permissible purposes.
Who Has Access to This Information?
Except as set forth in this policy or unless we specifically disclose it to you at the time of collection or subsequently obtain your approval, we will not make any personally identifiable information that is gathered on our site available to unaffiliated organizations for commercial purposes unrelated to the business of Telefonetica.
Certain federal, state and local laws or government regulations may require us to disclose personally identifiable information about you. In these circumstances, we will use reasonable efforts to disclose only the information required by law, subpoena or court order to be disclosed.
Telefonetica maintains physical, electronic and procedural safeguards designed to protect the confidentiality of personally identifiable information provided by you on and through our Web site. For example, unique passwords or user identifications are required to access a number of our Web site services. In addition to requiring the use of a unique password or user identification, all payments processed through our Web site require certain personally identifiable information provided by you to be sent in a “Secure Session” using Secure Socket Layer encryption technology. This technology is designed to encrypt – or scramble – your financial or credit card account information to help prevent unauthorized parties from reading it. We seek to regularly test and update our technology to help protect your personally identifiable information. However, such precautions do not guarantee that our Web site is invulnerable to all security breaches. Telefonetica makes no warranty, guarantee, or representation that use of our Web site is protected from all viruses, security threats or other vulnerabilities and that your information will always be secure. When doing business with others, such as advertisers to whom you can link from our site, you should consider the separate security and privacy policies of those other sites.
Your Use of Passwords Or User Identifications
This site may provide discussion areas so that customers and visitors can communicate freely and share ideas. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when disclosing such information. These discussion areas may be monitored by us or law enforcement officials as appropriate occasionally in order to enhance the safety and respect for all of our customers and visitors, and off-topic, unlawful or otherwise inappropriate content of materials of which we become aware may or may not be removed from the site during the course of such monitoring. However, Telefonetica is not responsible for any information posted or remaining on these discussion areas.
Links to Other Sites
For the convenience of our visitors and customers, this Web site may contain links to other sites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies before disclosing information to third parties on these independent sites.
Updates or Revisions to Personally Identifiable Information
Your use of certain of our online services may permit you to update personally identifiable information from our database by accessing our web site. If you remove certain information from your account, we will only retain copies of such information as are necessary for us to comply with governmental orders, resolve disputes, troubleshoot problems, enforce any agreement you have entered into with us and as otherwise reasonably necessary.
If You Do Not Wish to Disclose Your Information
We do not intend for this site to be used by children under the age of 13, nor do we seek to collect information about children under the age of 13. If you are under the age of 13, please do not provide us with information and promptly exit this site. We encourage parents or legal guardians to talk with their children about the potential risks of providing information over the Internet.
THE PRIVACY PRINCIPLES
Telefonetica provides Cloud Services only to businesses and not to individuals and therefore seldom—if ever—collects Personal Information. To the extent that Telefonetica Cloud Services collects or will collect Personal Information, its operations and processing of Personal Information conform to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.
Notice and Choice
To the extent permitted by the Safe Harbor Agreement, Telefonetica Cloud Services reserves the right to process Personal Information in the course of providing professional services to Telefonetica Cloud Services’s clients and customers without the knowledge of individuals involved. If and when Telefonetica Cloud Services collects Personal Information directly from individuals in the EU, Telefonetica Cloud Services will inform them about the types of Personal Information it collects from them, the purposes for which Telefonetica Cloud Services collects and uses it, and the types of non-agent third parties to which Telefonetica Cloud Services discloses that information. Telefonetica Cloud Services will also inform those individuals about the choices and means, if any, that Telefonetica Cloud Services offers to limit the use or disclosure of their information.
Disclosures and Transfers
Telefonetica Cloud Services will not disclose an individual’s Personal Information to third parties, except when one or more of the following conditions is true:
- Telefonetica Cloud Services has the individual’s permission to make the disclosure;
- The disclosure is required by law or professional standards;
- The disclosure is reasonably related to the sale or disposition of all or part of Telefonetica Cloud Services’ business;
- The information in question is publicly available;
- The disclosure is reasonably necessary for the establishment or defense of legal claims; or
- The disclosure is to another Telefonetica Cloud Services entity or to persons or entities providing services on Telefonetica Cloud Services’s or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
- is subject to law providing an adequate level of privacy protection;
- has agreed in writing to provide an adequate level of privacy protection; or
- Subscribes to the Safe Harbor Principles.
Permitted transfers of information, whether to third parties or within Telefonetica Cloud Services, include the transfer of data from one jurisdiction to another, including transfers to and from the U.S. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.
To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of its clients, customers and business partners, Telefonetica Cloud Services has put in place and rigorously enforces appropriate physical, electronic, and managerial procedures to safeguard and secure the information that Telefonetica Cloud Services processes. However, Telefonetica Cloud Services cannot guarantee the security of information on or transmitted via the Internet.
To the extent that it has possession of Personal Information at all, Telefonetica Cloud Services processes such information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, Telefonetica Cloud Services takes reasonable steps to make sure that Personal Information is accurate, complete, current, and otherwise reliable for its intended use.
Access and Correction
If an individual becomes aware that information Telefonetica Cloud Services maintains about that individual is inaccurate, or if an individual would like to update or review that individual’s information, the individual may contact Telefonetica Cloud Services using the contact information below. In every case, Telefonetica Cloud Services will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual seeking to amend such information will need to provide sufficient identifying information, such as name, address, birth date, and social security number. Telefonetica Cloud Services may request additional identifying information as a security precaution. In addition, Telefonetica Cloud Services may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, Telefonetica Cloud Services may charge a reasonable fee, where warranted, for access to Personal Information.
Enforcement and Dispute Resolution
Any claim arising out of or relating to Telefonetica Cloud Services’ adherence to the EU Data Directive, or the breach thereof, that cannot be resolved through Telefonetica Cloud Services’ internal processes, will be settled by arbitration administered by the American Arbitration Association (“AAA”) in accordance with its applicable commercial rules. Any arbitrator will be either an attorney or retired judge having significant and recognized experience with and knowledge of privacy issues and information technology. The arbitration panel shall apply the law of the State of Georgia, without regard to its conflict of laws principles, as well as the Safe Harbor Enforcement Principles issued by the U.S. Department of Commerce. In addition, the exclusive location for such arbitration will be Miami FL. All decisions of the arbitration panel will be final and binding on the parties, which waive any right to appeal the arbitration award further, to the extent an appeal may be lawfully waived. Telefonetica Cloud Services are also subject to the jurisdiction of the U.S. Federal Trade Commission.
INFORMATION SUBJECT TO OTHER POLICIES OR STANDARDS